NCD981927502_19920316_Geigy Chemical Corporation_FRBCERCLA FS _Final Feasibility Study Report-OCR

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Geigy Chemical Corporation Site
Aberdeen, North Carolina
Final Report
Feasibility Study Report
March 1992
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FEASIBILITY STUDY REPORT
GEIGY CHEMICAL CORPORATION SITE
ABERDEEN, NORTH CAROLINA
MARCH 1992
SIRRINE PROJECT NO. G-1024.20
SIRRINE ENVIRONMENTAL CONSULTANTS
GREENVILLE, SOUTH CAROLINA
I
Feasibility Study Report
Geigy Chemical Corporation Site
Aberdeen, North Carolina
Page
1.0 INTRODUCTION 1-1
I 1.1 Objectives 1-1
1.2 Report Format 1-2
I 2.0 SUMMARY OF REMEDIAL INVESTIGATION 2-1
2.1 Area Features 2-1
I 2.1.1 Site Setting and Topography 2-1
2.1.2 Land Use and Economy 2-1
I 2.1.3 Regional Geology 2-2
2.1.4 Site Hydrogeology 2-2
I 2.1.4.1 Uppermost Aquifer 2-2
2.1.4.2 Second Uppermost Aquifer 2-3
2.1.4.3 Third Uppermost Aquifer 2-3
I 2.1.5 Surface Water 2-3
2.1.6 Demographics 2-4
2.1.7 Climate/Air Quality 2-4 -2.1.8 Ecological Habitats 2-4
2.1.9 Access and Utilities 2-4
I 2.2 Site Background 2-5
2.2.1 Site History 2-5
I 2.2.2 Previous Investigations 2-6
2.3 Remedial Investigation Activities 2-6
I 2.3.1 Task 11: Subsurface Soil Investigation 2-6
2.3.2 Task 12: Groundwater Investigation 2-7
I 2.3.2.1 Phase 2, Step 1 2-7
2.3.2.2 Phase 4, Step 2 2-7
I 2.3.3 Task 13: Ditch Sediment Investigation 2-8
2.4 Previous Removal Actions 2-8 I 2.4.1 1989 Removal 2-8
2.4.2 1991 Removal 2-9
I 2.4.3 Removal Summary 2-10 , Geigy FS March 16, 1992
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2.5 Summary of Current Site Conditions
3.0 SUMMARY OF RISK ASSESSMENT
4.0 REMEDIAL RESPONSE OBJECTIVES
4.1 Applicable or Relevant and Appropriate Requirements (ARARs)
4.1.1
4.1.2
4.1.3
Action-Specific ARARs
Location-Specific ARARs
Chemical-Specific ARARs
4.1.3.1
4.1.3.2
Groundwater
Soils
4.2 Remedial Design Basis
4.2.1 Surficial Soil
4.2.2 Groundwater
4.2.3 Chemical and Physical Properties of Selected Pesticides
4.3 Summary of Remedial Response Objectives
5.0 IDENTIFICATION OF POTENTIAL TECHNOLOGIES
5.1 Screening Criteria
5.1.1 Effectiveness
5.1.2 Implementability
5.1.3 Cost
5.2 Listing of Potential Technologies
5.3 Groundwater Control Screening
5.3.1 Groundwater Recovery
5.3.2 Groundwater Treatment
5.3.3 Groundwater Discharge
5.3.4 Groundwater Containment
5.4 Exposure Control Screening
5.4.1 Direct Treatment
5.4.2 In-Situ Treatment
5.4.3 Off-Site Treatment or Disposal
5.4.4 Containment
5.4.5 No Further Action
Geigy FS ii
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March 16, 1992
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5.5 Technology Screening Summary
5.5.1 Groundwater Recovery
5.5.2 Groundwater Treatment
5.5.3 Groundwater Discharge
5.5.4 Groundwater Containment
5.5.5 Exposure Control
6.0 DEVELOPMENT OF ALTERNATIVES
6.1 Areas of Potential Remediation
6.2 General Screening Criteria
6.2.1 Effectiveness
6.2.2 Implementability
6.2.3 Cost
6.3 Formulation of Potential Alternatives
6.3.1 Ground Water Control
6.3.1.1
6.3.1.2
6.3.1.3
6.3.1.4
6.3.1.5
Groundwater Recovery
Groundwater Treatment
Groundwater Discharge
Groundwater Containment
Concerted Groundwater Activities
6.3.2 Exposure Control/Foundation Disposal
6.3.3 Preliminary Costs for Alternatives
6.4 · Screening Evaluation
6.4.1 Groundwater Control
6.4.2 Exposure Control
6.5 Summary of Retained Alternatives
7.0 DETAILED ANALYSIS OF ALTERNATIVES
7.1 Evaluation Criteria
7.2 Groundwater Control
7.2.1 Alternative GWC-1: No Action
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Alternative GWC-1A: No Action 7-5
Alternative GWC-1 B: Long-term Monitoring of
Site Groundwater 7-7
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7.3
7.2.2 Alternative GWC-2: Slurry Wall and Cap
7.2.3 Alternative GWC-3: Groundwater Recovery to Attain MCLs
Exposure Control Alternatives
7.3.1 Alternative EC-1: No Further Action
7.3.2 Alternative EC-2: Off-Site Disposal
7.3.2.1
7.3.2.2
Alternative EC-2A: Off-site Disposal Attaining
a 1E-05 LECR
Alternative EC-28: Off-site Disposal Attaining
a 1E-06 LECR
7.3.3 Alternative EC-3: Capping
7.3.3.1
7.3.3.2
Alternative EC-3A: Capping to Attain an LECR of 1 E-05
Alternative EC-38: Capping to Attain an LECR of 1 E-06
8.0 COMPARATIVE SUMMARY OF ALTERNATIVES
8.1 Groundwater Control
8.2 Exposure Control
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LIST OF APPENDICES
A Selected Soil Data and Calculation for Pesticides
B Risk-Based Remediation Goals for Pesticides in Groundwater
C Description of the Vadose Zone Interactive Processes (VIP) Model
D Estimate of Groundwater Flow Rate and Aquifer Restoration nme
E Preliminary Cost Estimates
F Detailed Cost Estimates
G References
Geigy FS V March 16, 1992
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LIST OF FIGURES
1.1 Approximate Location of Geigy Chemical Corporation Site
2.1 Monitoring Well Locations
2.2 Surficial Aquifer Contour Map
2.3 Second Uppermost Aquifer Contour Map
2.4 Railroad and Highway Right of Ways
2.5 Soil/Sediment Sampling Locations
2.6 Area of Former Active Use
2.7 Soil Areas Remediated in 1989
2.8 Soil Areas Remediated in 1991
4.1 Proposed Locations of Surficial Soil Remediation: 1 0E-6 LECR
4.2 Proposed Locations of Surficial Soil Remediation: 1 0E-5 LECR
5.1 Proposed Groundwater Extraction Well Locations
5.2 Proposed Interceptor Trench Location
5.3 Proposed Containment Cap and Slurry Wall
5.4 Proposed Containment Caps for Surficial Soil and Foundation Debris
7.1 Groundwater Treatment Flow Diagram -Alternative GWC-3
D.1 Assumed Capture Zone for Estimating Groundwater Flow Rate
D.2 Estimated Capture Zone for the Second Uppermost Aquifer
LIST OF TABLES
2.1 Effect of Previous Removal Actions on Site-Wide Concentrations
2.2 Summary of Maximum Concentrations for Pesticides of Potential Concern
3.1 Summary of Potential Health Risks Associated with the Geigy Chemical Corporation Site:
Current Land Use
3.2 Summary of Potential Health Risks Associated with the Geigy Chemical Corporation Site:
Future Land Use
4.1 Potential Location-Specific ARARs
4.2 Potential Remediation Goals for Groundwater
4.3 Chemical and Physical Properties of Selected Site Pesticides
5.1 Potential Groundwater Remediation Technologies
5.2 Moore County Sanitary Sewer Authority Sewer Use Ordinance
Limitations
5.3 Groundwater Control Technology Summary
6.1 Potential Remedial Alternatives
6.2 Preliminary Costs for Alternatives
6.3 Retained Alternatives for Detailed Analysis
7.1 Projected Influent Concentrations to Treatment
8.1 Comparative Summary of Alternatives
Geigy FS vi March 1 6, 1992
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A.1 Calculation of Pre-1989 Average Site-Wide Soil Concentrations for BHC Isomers
A.2 Calculation of Current Average Site-Wide Soil Concentrations for BHC Isomers
A.3 Calculation of Pre-1989 Average Site-Wide Soil Concentrations for Toxaphene
A.4 Calculation of Current Average Site-Wide Soil Concentrations for Toxaphene
A.5 Current Toxaphene Concentrations in Site Surficial Soils
A.6 Toxaphene Concentrations in the Site Surficial Soils After Remediating to a LECR of 1 0E-6
A.7 Toxaphene Concentrations in the Site Surficial Soils After Remediating to a LECR of 1 0E-5
A.8 Foundation Volume Calculations (Concrete and Fill Soil)
C.1 Significant Input Parameters Used in the VIP Model
C.2 Parameters Used to Calculate Volumetric Flow Rate of Groundwater and Leachate
Dilution Factor
E.1 Screening Level Cost Estimates
E.2 Interception Trench -Preliminary Cost Estimate
F.1 Cost Summary Table
F.2 Alternative GWC-1A
F .3 Alternative GWC-1 B
F .4 Alternative GWC-2
F.5 Alternative GWC-3
F.6 Alternative EC-1
F.7 Alternative EC-2A
F.8 Alternative EC-28
F.9 Alternative EC-3A
F.1 0 Alternative EC-38
F.11 Capping
F .12 Slurry Wall
F.13 Groundwater Extraction System
F.14 Carbon Adsorption Treatment System
F.15 Discharge to Moore County POTW
F.16 Landfill Surficial Soils at the USPCI Facility In Clyde, Utah to Achieve a LECR of 10E-5
F.17 Incinerate Surficial Soils at a RCRA Approved Incinerator to Achieve a LECR of 1 0E-5
F.18 Landfill Surficial Soils at the USPCI facility in Clyde, Utah to Achieve a LECR of 1 0E-6
F.19 Landfill Foundation Debris at the USPCI Facility in Clyde, Utah
F.20 Landfill Foundation Debris at a Municipal Landfill
F.21 Incinerate Surficial Soils at a RCRA Approved Incinerator to Achieve a LECR of 1 0E-6
CORA Modules 102 Through 504
Geigy FS vii March 16, 1992
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1.0 INTRODUCTION
Following is a Feasibility Study (FS) for the Geigy Chemical Corporation Site (hereafter referred
to as the Geigy Site or Site). The Site is located In a rural section of Moore County, North
Carolina, approximately 1 mile southeast of Aberdeen, North Carolina where Highway 211 and
the Aberdeen & Rockfish railroad tracks intersect (Figure 1.1 ). A more detailed discussion of the
Site is presented In Section 2 of this FS.
1.1 OBJECTIVES
The overall objectives of the Remedial Investigation/Feasibility Study (RI/FS) process as
established by the EPA under the Superfund program are to characterize the nature and extent
of contamination at the site, to evaluate potential risks to human health and the environment, and
to evaluate potential remedial alternatives.
The FS evaluates the feasibility of potential remedial alternatives that will essentially eliminate or
minimize the uncontrolled release of any hazardous substances from the Site. This FS also
addresses any areas of potential off-site chemical migration.
This FS is in accordance with the Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA or Superfund) as promulgated under the National Oil and Hazardous
Substances Contingency Plan (NCP) of November 20, 1985 (50 Federal Register 47973), the
Superfund Amendments and Reauthorization Act (SARA) of October 17, 1986, and the amended
NCP of March 8, 1990 (55 Federal Register 8666). The general framework of this document is
based on the interim final EPA document Guidance for Conducting Remedial Investigations and
Feasibility Studies Under CERCLA (EPA, October 1988).
The primary objectives of the FS are to:
• develop appropriate remedial action levels based on Federal and State chemical-and
location-specific Applicable or Relevant and Appropriate Requirements (ARARs) and non-
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promulgated advisories or guidance issued by Federal or State government, where
available.
• identify remedial alternatives and technologies available to reduce the concentrations
based on known Site characteristics and levels of chemical residuals
• perform screening of the identified remedial alternatives and technologies and conduct a
detailed evaluation of the retained alternatives
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identify action-specific ARARs for the Implementation of the retained alternatives
identify technologically feasible remedial alternatives that attain institutional and regulatory
requirements and are cost-effective.
This FS report gives a conceptual review of alternatives but is not intended to present design
level detail. The intent of the report is to develop a representative framework for evaluating the
potential remedial alternatives applicable to conditions at the Site. Upon selection of a Site
remedy, a detailed design will be conducted during the Remedial Design phase.
1.2 REPORT FORMAT
The remainder of this report is organized into the following sections:
2.0 SUMMARY OF REMEDIAL INVESTIGATION
3.0 SUMMARY OF RISK ASSESSMENT
4.0 REMEDIAL RESPONSE OBJECTIVES
5.0 IDENTIFICATION OF POTENTIAL TECHNOLOGIES
6.0 DEVELOPMENT OF ALTERNATIVES
7.0 DETAILED ANALYSIS OF ALTERNATIVES
8.0 COMPARATIVE SUMMARY OF ALTERNATIVES
APPENDICES
Geigy FS 1-2 March 16, 1992
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Brief descriptions of the remaining sections are provided on the following pages.
Section 2 (Summary of Remedial Investigation) summarizes the findings of the Site RI (ERM-
Southeast, 1992) relevant to the evaluation of remedial alternatives.
Section 3 (Summary of Risk Assessment) summarizes the Baseline Risk Assessment (Clement
International Corporation (Clement, 1992). Data collected and interpreted in the RI were used
to perform the risk assessment. This evaluation serves as the basis for assessing the potential
human health and environmental impacts from the Site under current or Mure land-use
conditions. The baseline risk assessment includes an analysis of potential pathways of exposure
and potential impacts to receptors (if any)_ of a no further action remedial alternative. Exposure
pathways identified in the baseline risk assessment that exceed EPA's criterion of 1 o-4 for
cumulative risk will be further evaluated as part of the FS process.
Section 4 (Remedial Response Objectives) presents the potential applicable or relevant and
appropriate requirements (ARARs) for the Site and identifies potential areas/media of remediation.
Site-specific and chemical-specific parameters relevant to conceptual design are also specified.
Section 5 (Identification of Potential Technologies) identifies and screens potential treatment and
disposal technologies on the basis of Site conditions, waste characteristics, and technical
requirements. The screening process results in the elimination or modification of those
technologies that are not applicable, feasible, effective, sufficiently developed, or otherwise not
appropriate to be combined into remedial alternatives for the Site. The development of
preliminary cost information allows the elimination of more costly technologies which do not
provide additional remedial effectiveness over remedies of equivalent effectiveness.
Section 6 (Development of Alternatives) assembles a series of remedial alternatives for each
different media identified in Section 4. Alternatives thus identified are compared with respect to
short-and-long term aspects of technical effectiveness, implementability, and present worth costs.
The result is a reduced list of alternatives for detailed analysis (Section 7). Only the most
promising alternatives based on these evaluation factors are retained for final screening.
Geigy FS 1-3 March 16, 1 992
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Section 7 (Detailed Analysis of Alternatives) presents a detailed analysis of the retained remedial
alternatives based on the following NCP criteria: (1) overall protection of human health and the
environment, (2) compliance with ARARs, (3) long-term effectiveness and permanence, (4)
reduction of toxicity, mobility, or volume, (5) short-term effectiveness, (6) implementability, (7)
cost, (8) state acceptance, and (9) community acceptance. The action-specific ARARs are
finalized in this section according to the refined potential remedial alternatives.
A comparative analysis of remedial alternatives Is presented In Section 8.
References for the FS are provided in the last appendix.
Figures and Tables are provided at the end of their referenced section or appendix.
Geigy FS 1-4 March 16, 1992
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2.0 SUMMARY OF REMEDIAL INVESTIGATION
This section summarizes the RI report (ERM-Southeast, 1992). The purpose of the RI was to
describe the (1) nature and extent of contamination at the Geigy Site and (2) methods used to
collect and evaluate data. That information is used as the data base to support the selection and
evaluation of remedial alternatives. More detailed information is contained in the RI report.
2.1 AREA FEATURES
Following is a description of area features, including topography, land use,
geology/hydrogeology, demographics, climate, ecological habitats, and utilities.
2.1.1 Site Setting and Topography
The Geigy Chemical Corporation site (Site) is one-half mile east of Aberdeen on Highway 211 in
Moore County, North Carolina (Figure 1.1). The vacant Site is bounded by Highway 211 and the
Aberdeen and Rockfish Railroad. The former area of active use at the Site comprised
approximately one acre. The Site consists of partial concrete foundations from two former
warehouses, a small office building, a concrete tank pad, and a small parking area (Figure 2.1 ).
The Site is in the Sandhills physiographic province, characterized by rolling hills underlain by
well-drained, unconsolidated sands. Site elevations range from about 460 to 480 feet above
mean sea level (MSL). The Site is essentially flat.
2.1.2 Land Use and Economy
Historically, agriculture was the primary economy of Moore County. Manufacturing, lumbering,
retail trade, and tourism (i.e., Southern Pines) are currently the primary industries. The population
of Moore County is approximately 59,000 (1990 census).
Geigy FS 2-1 March 16, 1992
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2.1.3 Regional Geology
Generally, the geology under the Site consists of unconsolidated sedimentary rocks (200-250 feet
thick) on top of crystalline basement rocks. Site soils are of the Candor series and are deep,
excessively drained sandy soils (e.g., sand, silty sand, loamy sand, sandy loam).
2.1.4 Site Hydrogeology
Three aquifers underlie the Site: the shallow (uppermost), Black Creek (second uppermost), and
Upper Cape Fear (third uppermost) aquifers.
2.1.4.1 Uppermost Aquifer
The uppermost aquifer (shallow aquifer) receives rainfall infiltration. Approximate depth to
groundwater in the uppermost aquifer at the Site is 35 to 45 feet. Saturated thickness at and
near the Site ranges from one to 18 feet with an average saturated thickness and hydraulic
conductivity beneath the Site of 12 feet and 2.8 feet/day, respectively. Groundwater flow in the
uppermost aquifer appears to be controlled by recharge areas located at the eastern and western
ends of the Site and by moderate topographic slopes on the northern and southern sides of the
Site (Figure 2.2).
The shallow saturated thickness of the surficial aquifer, coupled with its low hydraulic conductivity
(2.8 feet/day) and porosity (0.38), indicate that water yields would be low. Estimated yield is on
the order of 0.5 gpm per well. In addition, residential drinking water wells in the area are typically
100 to 200 feet deep and hence below the surficial aquifer (Mr. Benford Graham, Graham and
Currie Well Drilling Company, October 8, 1991 ). Therefore, the uppermost aquifer in the
immediate area of the Geigy Site is not typically an adequate source of drinking water.
Potentiometric data from the shallow monitoring wells indicate groundwater flow from the eastern
and western portions of the Site meet in an elongated zone of convergence. East of the
convergence zone, groundwater flows west and northwest with a hydraulic gradient of 0.026 ft/ft.
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West of the convergence zone, groundwater flow is predominantly to the east-southeast with a
hydraulic gradient of 0.017 fl/fl (Figure 2.2).
2.1.4.2 Second Uppermost Aquifer
The Black Creek confining unit (thickness from 1 Oto 13 feet at the Site) is between the surficial
aquifer and the Black Creek aquifer (second uppermost aquifer). Based on two samples
collected at the Site during the RI, the confining unit has a hydraulic conductivity less than 1 o-8
cm/s (ERM Southeast, 1992). Soils below the Black Creek confining unit are unsaturated from
three to 15 feet below the confining unit, indicating that the uppermost and second uppermost
aquifers are not hydraulically connected at the Site.
Average thickness and hydraulic conductivity of the second uppermost aquifer are 40 feet and
28 feet/day, respectively. This aquifer serves as the primary source of potable groundwater in
the Aberdeen area. General, area-wide information indicate that groundwater is low in dissolved
solids and hardness and is slightly acidic (ERM-Southeast, 1992). Groundwater flow in the
second uppermost aquifer is generally northwesterly (Figure 2.3) with an average hydraulic
gradient of 0.004 ft/ft (ERM-Southeast, 1992). The second uppermost aquifer and the third
uppermost aquifer are the primary source of drinking water in the Aberdeen area.
2.1.4.3 Third Uppermost Aquifer
The Upper Cape Fear confining unit (approximately 60 feet thick) is over the Upper Cape Fear
aquifer. In the Aberdeen area, the Upper Cape Fear aquifer (third uppermost aquifer) ranges
from 1 Oto 20 feet thick and directly overlies the crystalline bedrock. Average estimated hydraulic
conductivity is 30 feet/day. Groundwater flow in this aquifer is generally to the northwest.
2.1.5 Surface Water
There is no surface water at the Site. Drainage ditches at the Site are dry except during storm
events. Surface water runoff during storms is rapidly absorbed into the well-drained soils in the
vicinity of the Site.
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2.1.6 Demographics
Approximately 2700 people live in Aberdeen and 59,000 in Moore County. Approximately 1200
people (median age 33) live within a one mile radius of the Site (ERIM-Southeast, 1992). Major
employment is in manufacturing, lumbering, retail trade, and tourism (e.g., Southern Pines).
2.1.7 Climate/Air Quality
Average daily maximum temperature is 90 degrees F. in July and average daily minimum is 30
F. In January. Average annual precipitation is 48 inches. Precipitation is fairly uniform year-
round, ranging from three to five inches per month.
Air quality measurements conducted in 1989 at Fayetteville, 30 miles east of Aberdeen, for total
suspended particulates (TSP), particulate matter-10 micrometer (PM-10), carbon monoxide CO),
and ozone indicated that air quality based on these parameters was within national and state
standards. One slight exceedance for CO was reported in 1989.
2.1.8 Ecological Habitats
There are no endangered species or habitats on the Site. The Site is primarily covered with a
small office building, foundations, dirt roads, a railroad, parking lot, previously remediated areas,
and grass. The Site is located between a state highway and an active rail line with the
intervening width ranging from 80 to 150 feet. As such, the Site is not an attractive or large area
for wildlife (Figure 2.1).
2.1.9 Access and Utilities
The Site is bounded by State Highway 211 and the Aberdeen and Rockfish Railroad (Figure 2.4).
As discussed below, the rights of way for the highway and railroad includes a significant portion
of the Site. Electricity, telephone, natural gas, and city water are available at the Site. Moore
County sewerage connection is not available at the Site but is available within a half of a mile.
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The railway at the Geigy Site is the major line for the Aberdeen & Rockfish Railroad (A&RR). The
A&RR conducts at least two round-trip deliveries every day, five days a week, between Aberdeen
and Fayetteville, North Carolina. Individual trains haul a maximum of 80,000 tons per load. A
wide range of manufactured goods, raw materials, and agricultural products are transported
along the line. The railway is considered a secondary line within the regional railroad system.
The right-of-way for the railway is 80 feet from the centerline and for the highway is 50 feet from
the centerline. The resulting right-of-ways are presented in Figure 2.4. The A&RR owns the land
within the railway right-of-way and claims the piece of land between the railway, the highway, and
the Allred property to the east through adverse possession and currently pays the property tax
on both pieces of land.
In addition, a power line runs north-south across the eastern side of the Site near the gravel road
(Figure 2.4). The power line easement is approximately 15 feet from the centerline.
2.2 SITE BACKGROUND
Following is a brief discussion of the Site's history and of previous investigations.
2.2.1 Site History
The Site was operated as a pesticide blending and formulation facility by various operators from
approximately 1947 to 1967 and by retail distributors of agricultural chemicals from 1968 to 1989.
The pesticides DDT, toxaphene, and BHC were received in bulk at the Site, blended with clay and
other inert materials, repackaged, and sold. Pesticides were not manufactured at the Site but
were formulated by dry mixing into a product suitable for local consumer use. During normal
formulation activities, there were occasional incidental losses to the Site soils. All on-site facilities
(except for the office building) were demolished in early 1991. A portion of the concrete pad
under the former warehouse A and a concrete pad under the former warehouse B remain at the
Site (Figure 2.1 ). Removal actions are further discussed in Section 2.4. Currently the Site is
unoccupied and partially fenced.
Geigy FS 2-5 March 1 6, 1992
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2.2.2 Previous Investigations
An EPA site investigation was conducted in March 1988, prior to the RI. The objectives were to
collect soil and groundwater samples from on-site and off-site locations and other necessary
information to generate a Hazard Ranking System (HRS) score. Using these initial data, the Site
was ranked 843 out of 1073 sites on the National Priority List (NPL or Superfund; 56 Federal
Register 5598, February 11, 1991 ).
2.3 REMEDIAL INVESTIGATION ACTIVITIES
The following tasks were performed according to the EPA-approved work plans during the RI:
Task 1: RI/FS Work Plan Preparation
Task 2: Site Reconnaissance
Task 3: Site-Specific Health and Safety Plan
Tasks 4 and 5: Quality Assurance Requirements
Tasks 6 through 9: Site Security, Subcontractors, Community
Relations, and Access Agreements
Task 1 O: Initial Soil Removal
Task 11: Subsurface Soils Investigation
Task 12: Groundwater Investigation
Task 13: Ditch Sediment Investigation
Task 14: Preparation of a Remedial Investigation Report
Task 1 O (previous removal actions) is discussed in Section 2.4. Details about Tasks 11, 12, and
13 are discussed below.
2.3.1 Task 11: Subsurface Soils Investigation
0 An investigation of surface and subsurface soils was conducted in four sampling phases to
delineate the vertical and horizontal extent of contamination. Phase 1 provided a definition of I potential Site-specific parameters for soils (target compound list (TCL) pesticides, copper, lead,
zinc); Phase 2 defined the horizontal extent of contamination; Phase 3 delineated the vertical I extent of contamination; and, Phase 4 provided additional information to complete the data set.
Analytical results are discussed in Section 2.5.
Geigy FS 2-6 March 16, 1992
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2.3.2 Task 12: Groundwater Investigation
Two phases of groundwater monitoring well construction and sampling were conducted: (1)
Phase 2, Step 1 and (2) Phase 4, Step 2. Each is described below. In addition, several private
and municipal supply wells were sampled by EPA In March 1987 and again in October 1989.
Analytical results are discussed in Section 2.5.
2.3.2.1 Phase 2, Step 1
Ten groundwater monitoring wells were installed in the initial groundwater investigation (Phase
2, Step 1): six (MW-1S through MW-6S) in the surficial aquifer, three (MW-1D, MW-4D, MW-6D)
in the intermediate aquifer (Black Creek aquifer), and one (PZ-1) in the deep aquifer (Upper Cape
Fear aquifer).
Phase 2, Step 1 sampling was conducted in November 1990. The ten monitoring wells and one
on-site water supply well were sampled. Analytical parameters included field parameters (pH,
temperature, specific conductance), TCL volatiles, TCL semivolatiles, target analyte list (TAL)
metals, and TCL pesticides.
2.3.2.2 Phase 4, Step 2
Based on the Phase 2, Step 1 results, the groundwater investigation expanded laterally (Phase
4, Step 2). Six monitoring wells were installed in off-site areas downgradient of the existing
monitoring well system in the shallow aquifer (MW-7S through MW-10S, MW-12S and MW-13S;
Figure 2.1 ). In addition, three monitoring wells were installed in the intermediate aquifer (MW-
11 D, MW-14D, and MW-15D; Figure 2.1).
Phase 4, Step 2 groundwater samples were collected in July 1991 from the off-site deep
monitoring well (MW-11 D), on-site deep monitoring wells (MW-14D, MW-15D), off-site shallow
monitoring wells (MW-7S through MW-10S, MW-12S and MW-13S), two off-site private wells
(Allred and Powder Metals Products), and one off-site USGS well (USGS-02-3). Samples were
analyzed for field parameters, TCL volatiles and/or TCL pesticides.
Geigy FS 2-7 March 16, 1992
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2.3.3 Task 13: Ditch Sediment Investigation
Ditch sediments at the Site contain water only during storm events and hence are not considered
to be traditional sediments (e.g., sediment in lakes). The ditch sediment, therefore, is more
accurately called ditch soil. The ditch soil Investigation consisted of three phases (Phases 2, 3,
and 4) to delineate the horizontal and vertical extent of contamination. Ditch soil samples were
analyzed for pesticides, copper, lead, and zinc. Soil sampling locations are shown on Figure 2.5.
Analytical results for ditch soil sampling are discussed in Section 2.5.
During the Phase 2 investigation, 12 on-site and nine off-site ditch soil samples were collected,
generally from ground surface to a one foot depth. One sample was collected at 1.5 feet and
one was collected from 1.5 to 3 feet below the surface.
Thirty-three Phase 3 ditch soil samples were collected where concentrations of total BHC, total
DDT, and toxaphene exceeded 1 O mg/kg during Phase 2 and were collected at one and two feet
below the surface. Samples were also collected 50 feet downgradient of areas where pesticides
were detected.
Phase 4 ditch soil samples were collected at four locations where surface pesticide
concentrations were greater than 500 mg/kg prior to removal in 1991. Samples were collected
at two, five, and ten foot depths.
2.4 PREVIOUS REMOVAL ACTIONS
Removal actions were conducted during the RI. These removal actions were in 1989 and 1991,
as described below.
2.4.1 1989 Removal
A two-phase soil removal action, approved by the EPA, was conducted at the Site to remove
areas of visually contaminated soils and debris. The areas for removal were generally located
at former areas of active use such as near the access doors to the warehouses (Figure 2.6).
Geigy FS 2-8 March 16, 1992
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Initial removal was conducted in February 1989 by GSX Services, Inc. Visual areas of pesticide
contamination were removed (Figure 2.7) and the wastes placed at the GSX Landfill in Pinewood,
South Carolina. A total of 462 tons of material were removed and disposed.
The removal of visually contaminated soils was completed in October 1989. Remediation areas
are shown on Figure 2.7. Concentrated surface materials were visually identified in each area,
excavated, and packed in six, 30 gallon fiberpack containers (approximately one ton of soil total).
This material was incinerated at the ThermalKem facility in Rock Hill, South Carolina. Other
excavated soils (approximately 227 tons) were transported as hazardous waste to the Laidlaw
Environmental Services Landfill (formerly GSX Services) In Pinewood, South Carolina.
2.4.2 1991 Removal
A removal action was approved by the EPA in which interim removal levels were set at less than
100 mg/kg for gamma-BHC and less than 500 mg/kg for toxaphene. As approved by the EPA,
the warehouse superstructures, a portion of the eastern end of the warehouse A foundation,
pump house, and contaminated soils were removed from the Site during March through April of
1991 (Figure 2.8). The remaining concrete foundations beneath the former warehouses A and
B (Figure 2.1) appeared to be structurally sound (e.g., no significant cracking). Therefore, the
concrete was steam cleaned. Approximately 2841 tons of soil and debris were removed, Of this,
505 tons of soil were transported to the Rollins Facility in Deer Park, Texas for incineration. The
remainder was disposed at the Chemical Waste Management landfill in Carlyss, Louisiana.
Confirmation sampling was conducted to determine if the interim removal goals had been met.
These data are presented in Table 1-3 of the RI. The highest remaining concentration for
gamma-BHC in a remediated area was 3.2 mg/kg (SS 91) and for toxaphene was 11 O mg/kg
(area F). Therefore, the interim remediation goals were achieved.
Geigy FS 2-9 March 16, 1992
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2.4.3 Removal Summary
Approximately 3071 tons of contaminated soil and 460 tons of debris have been removed from
the Site and properly disposed. Average Site-wide concentrations of BHC Isomers and
toxaphene have been reduced 91 and 99 percent, respectively (Table 2.1 ).
2.5 SUMMARY OF CURRENT SITE CONDITIONS
Analytical parameters for soil and groundwater samples included volatile and semivolatile organic
compounds, metals, polychlorinated biphenyls (PCBs), and pesticides. Copper, lead, and zinc
were not above background concentrations. Pesticides were the only compounds found at
significant concentrations. Trichloroethane (TCE) was detected in the second uppermost aquifer
as discussed below. Within the pesticide group of analytes, the BHC isomers and toxaphene
were the most prevalent. Air was not found to be impacted by the Site. Table 2.2 summarizes
the maximum concentrations of pesticides in soil and groundwater at the Site.
With the exception of toxaphene, pesticides in soil currently range from undetected to the low
mg/kg range ( <55 mg/kg). Toxaphene concentrations are generally less than 1 o ppm with a
maximum of 450 mg/kg. Generally, the highest levels of pesticides were found southeast of
former warehouse A (Figure 2.5).
Two removal actions (1989 and 1991) removed approximately 2000 tons of soil from the Site.
Average Site-wide pesticide concentrations were significantly reduced (Table 2.1 ).
Maximum groundwater concentrations for pesticides were found in shallow monitoring wells. The
BHC isomers (alpha, beta, gamma, and delta) were the most prevalent pesticides, with maximum
concentrations around 30 ug/1. Pesticide contamination in the uppermost aquifer is migrating
toward the center of the Site, due to the convergence of groundwater flow from the east and
west. The recharge area to the west (Figure 2.2) prevents groundwater in the uppermost aquifer
from migrating towards the municipal wells (e.g., City Well #4). For the area within the facility
property, there is no hydraulic communication between the uppermost and second uppermost
aquifers due to the uppermost confining unit. For the area south of the facility property, however,
Geigy FS 2-10 March 16, 1992
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the presence of the uppermost confining unit, and therefore the hydraulic communication
between the uppermost and second uppermost aquifers Is uncertain. No pesticides were
detected in the USGS shallow well (USGS-02-3). No pesticides were detected in the second or
third uppermost aquifers beneath the Site.
Pesticides were detected in the second uppermost aquifer at MW-11 D, located about 375 feet
south of the facility property (Figure 2.3). The groundwater gradient at MW-11 D is from the
southeast, indicating a potential off-site source of contamination. However, pesticides detected
in MW-11 D will be assumed to be site-related in the absence of additional data.
The uppermost confining layer is present across the Site but thins off-site to the south. The
hydraulic conductivity of the confining layer sampled (1 a.a cm/sec) is sufficient to prevent
hydraulic and contaminant transport, as evidenced by the unsaturated soils beneath the confining
layer and the absence of pesticides in the second uppermost aquifer beneath the Site.
Continuity of the confining layer, in the vicinity of monitoring wells MW-10S and MW-11 D, is
uncertain .
Based on EPA data, BHC isomers were also detected at lower concentrations in off-site wells
including the Booth well (1200 feet south), Davis well (3200 feet southeast), and municipal wells
MUW-01 (3200 feet west), MUW-04 (900 feet west), and MUW-09 (4200 feet southwest). The
highest concentration was gamma-BHC at 16 ug/I in MUW-01, sampled in March 1987. Gamma-
BHC in the subsequent sampling of MUW-01 in October 1989 was 0.011 J ug/I (J indicates that
the result was below the quantitation limit and was an estimated value).
Trichloroethane (TCE) was detected in the second uppermost aquifer in two on-site monitoring
wells (MW-6D at 160 ug/I and MW-4D at 47 ug/I). Monitoring well PZ-1 was sampled twice during
the RI. TCE was not detected the first time and was below the quantitation limit (BJ) in the
second sampling event. TCE was also detected upgradient (southeast) of the Site in two off-site
private domestic wells (Allred at 72 ug/I and PMP at 360 ug/1). TCE was not detected in the soils
or the uppermost aquifer.
Geigy FS 2-11 March 16, 1992
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Air sampling for pesticides adsorbed to particulate matter was conducted in February 1989, prior
to the initial soil removal. Airborne pesticide concentrations were found to be below action levels.
Two removal actions (1989 and 1991) have since occurred. Therefore, current airborne pesticide
concentrations would be even less than prior to removal.
Geigy FS 2-12 March 16, 1992
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:::::::.--
CITY WELL #4
..
~GS-O2-2
~MW-7S
~PZ-1
.. "'"
GS-O2-2
GS-O2-1
WOODS
LEGEND
GEOLOGICAL SURVEY WELL
MONITORING WELL
PRODUCTION ZONE WELL
180 rt.
GS-O2-3
GS-O2-5
~MW-13S
WOODS
MW-7S ~
PZ-1
MW-8
~MW-12S MW-5S
WOODS
MW-9S
0
WOODS
111~IRRINE l!I ill:NIRONMENTAL 11 COI\ISULTANTS '
MW-15
WOODS W-HD\
N
ALLRED
PROPERTY
FIGURE 2.1
MONITORING WELL LOCATIONS
GEIGY CHEMICAi. CORPORATION SITE
ABERDEEN. NORTH CAROLINA
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c:::::::--.
Cl1Y WELL #4
WOODS
,,. __ _
""'""
~W-75 WONITORNG WEU.
~Pl-1 PRODUCTION 20ft'. WEIL
S\JRFOM. ~FER COftT~ (0,\Sl£0 WHERE N"EfftO)
"'
\
\
iDs
\
\
\
!
~ MW-12S
)
MW 2S
W-4S
liii7
~W-10
-
WOODS
N
l
i
LLRED -140\
. ROPERlY
FIGURE 2.2
SURFICIAL AQUIFER CONTOUR MAP
GEIGY CHEMICAL CORPORATION SITE
AE£ROEEN. NORTH CAROLINA
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GS-02-2
D
CITY WELL #4
WOODS
LEGEND
_.GS-02-2 GEOLOGICAL SURVEY WELL
♦MW-7S MONITORING WELL
_.pz -1 PRODUCTION ZONE WELL
GS-02-1
GS-02-3
SECOND UPPERMOST AQUIFER CONTOUR
WOODS
MW-7S ♦
♦ MW-12S
WOODS
MW-8S
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N
!si;;]
~W-1D
FIGURE 2.J
SECOND UPPERMOST
AQUIFER CONTOUR MAP
GEIGY CHEMICAL CORPORATION SITE Al£R0£EN. NORTH CAAOLINA
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------·-------
WOODS
WOODS
LEGEND
~ HIGHWAY 211 RIGHT OF WAY (50 FEET FROM CENTERLINE)
®™ RAILROAD RIGHT OF WAY (80 FEET FROM CENTERLINE)
POWERLINE RIGHT OF WAY (20 FEET FROM CENTERLINE)
b-'. • '.,.-'. -'.1 PROPERTY NOT ENCUMBERED BY RIGHT OF WAYS (APPROXIMATELY 0.2 ACRES)
------HIGHWAY CENTER LINE
60 0 60 120 100 n.
L_J
WOODS
WOODS
OEMOL£T AUTOMOTIVE
CLfANING SERVICE
ALLRED
PROPERTY
FIGURE 2.4
RAILROAD AND HIGHWAY
RIGHT OF WAYS
GEIGY CHEMICAL CORPORATION SITE
ABERDEEN. NORTH CAROLINA
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WOODS
LEGEND
SEDIMENT SAMPLE LOCATION
SOIL SAMPLE LOCATION
60 0 60 120 180 FT.
D
WOODS
WOODS
=1~~~ El CONSULTANTS
WOODS
~ ~
N
OEMOLET ALITOMOTI\1£
CL[ANfNC SERVICE
Q. f ALLRED
PROPERTY
FIGURE 2.5
SOIL/SEDIMENT SAMPLING LOCATIONS
GEIGY CHEMICAL CORPORATION SITE
ABERDEEN. NORTH CAROLINA
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WOODS
LEGEND
SEDIMENT SAMPLE LOCATION
SOIL SAMPLE LOCATION
0 60 120 100 "'n.
~ ss~.,.0 l -J,t '.!;-,.
S~39 -,
WOODS
0
r-::::::::"'::'~LL,! '!RT
GR4\,ft
WOODS /
lilll~IRRIN~ Bl ~MENl",-11 CONSULTANTS
WOODS
w <
N
OEMOLCT AUTOMOTIIIE
CLEANING SERVICE
ALLRED
PROPERTY
FIGURE 2.6
AREA OF FORMER ACTIVE USE
GY CHEMICAL CORPORATION SITE GEi ABERDEEN. NORTH CAROUNA
-------- - - --- - - -- -
SS-9
®
•
I OFFICE I
0
TANK PAD WAREHOUSE B
LEGEND
~ SOIL AREAS REMOVED
® SOIL SAMPLING LOCATIONS
(Approximate}
60 120
•
DOOR3 DOOR2
WAREHOUSE A
MAIN RAILROAD TRACK
180 Feet SIRRINE
ENVIRONMENTAL CONSULTANTS
•
\
N
\
DOOR 1
SPUR TRACK
Figure 2_7
Soll Areas Remedlated In 1989
Geigy Chemical Corporation Site
Aberdeen, North Carolina
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SS-48 m 0 Decontamination Pad
~ Truck Scales □
Office Former Cone.
0
STATE HIGHWAY 211
Warehouse A
Aberdeen and Rockf"JSh Railroad B-s0-1•
SD-12 •
Woods
LEGEND
SURFACE SOIL/BORING LOCATIONS
SEDIMENT SAMPLING LOCATIONS
EXCAVATION AREAS (MARCH-APRIL, 1991)
60 120
SS-64
Estimated Property Line
180 Feet
SS-91 SS-113 &
SIRRINE
ENVIRONMENTAL CONSUL1ANTS
---SS-69
Figure 2.8
Soil Areas Remediated In 1991
Geigy Chemical Corporation Site
Aberdeen, North Carolina
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Table 2.1
Effects of Previous Removal Actions on Site-Wide Concentrations
The Geigy Chemical Corporation Site, Aberdeen, Nonh Carolina
Effects of Previous Removal Actions on Site-Wide Concentrations
Average
Initial Site-Wide
Average Concentration
Site-Wide After Percent
Concentration (1) Removals (2) Concentration
Pesticide (mg/kg) (mg/kg)
BHC Isomers 5.2 0.31
Toxaphene 1,119 7.57
1 =See Appendix A for derivation of average Site-wide concentrations
2=Removal actions of 1989 and 1991 (see Section 2.4)
Reduction
94
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Table2.2
Summary of Maximum Concentrations for Pesticides of Potential Concern
Geigy Chemical Corporation Site, Aberdeen, North Carolina
Maximum Depth Maximum
Soil Below Groundwater
Conc.(2) Sample Surface Concentration
Pesticide (1) (mo/kal Number /feetl luo/1)
Aldrin 14 SS-06 (3) 0-1 0.1
alpha-BHC 21 SS-91 1 36
beta-BHC 4. 1 SS-91 1 25
gamma-BHC 3.2 SS-91 1 30
delta-BHC 1.9 SS-73-5 5 29
DDD 28 SS-06 (3) 0-1 ND
DDE 11 SS-58-20S 0-1 ND
DDT 54 SS-06 (3) 0-1 ND
Dieldrin 9.7 SS-06 (3) 0-1 2
Endrin Ketone 0.28 SS-71-2 2 4
Toxaphene 450 SS-06 (3) 2 10
Monitoring
Well
Number
MW-4S
MW-6S
MW-10S
MW-6S
MW-6S
--
--
--
MW-10S
MW-10S
MW-2S
1 = Chemicals selected were either detected In groundwater at the Site or found
at an elevated concentration in the vadose soil (i.e., toxaphene).
2 = Maximum is for soil remaining on Site
3 = Blind field split of SS-12; reported value is average of duplicates SS-06 and SS-12
ND= Not Detected
DATSUM.OLN 1/20/92
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3.0 SUMMARY OF RISK ASSESSMENT
The human health and ecological risks associated with the Site were evaluated in a Baseline Risk
Assessment (RA; Clement, 1992). Results from the RA will be used to determine remedial
response objectives for the Site (Section 4). Following Is a summary of the RA.
The primary data used in the risk assessment were collected during the RI (ERM-Sou1heast 1991 ;
Section 2). Extensive remedial activities have already occurred at the Site, as discussed in
Section 2.4. Thus, the Baseline RA addresses a no-further action alternative In accordance with
the NCP and USEPA for risk assessments at Superfund sites.
Based upon USEPA guidance, all of the organic chemicals measured in the environmental media
selected for evaluation were considered to be chemicals of potential concern. The chemicals
associated with the past site activities, however, are organochlorine pesticides. Inorganic
chemicals in groundwater were selected as chemicals of potential concern because of the limited
background data. The predominant chemicals in on-site soil are toxaphene, and DDT and its
metabolities DOE, and ODD while in groundwater, toxaphene and the BHC isomers are
predominant.
For each chemical of potential concern, toxicity information was then compiled. This included
brief descriptions of the potential toxicity of each chemical to human health and quantitative
toxicity criteria used to calculate risks. The toxicity criteria were primarily obtained from USEPA's
Integrated Risk Information System (IRIS) and Health Effects Assessment Summary Tables
(HEASTs).
Potential exposure pathways were reviewed and selected for quantitative evaluation in the risk
assessment. The following exposure pathways were selected for detailed evaluation under
current and surrounding land-use conditions:
• Incidental ingestion of chemicals in on-site surface soil/sediment by an older child
trespasser (8-13 years),
Geigy FS 3-1 March 16, 1992
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• Dermal absorption of chemicals in on-site surface soil/sediment by an older child (8-
13 years),
• Incidental ingestion of chemicals in off-site surface soil/sediment by an older child
(8-13 years),
•
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Dermal absorption of chemicals In off-site surface soil/sediment by an older child (8-
13 years),
Inhalation of volatilized surface soil/sediment chemicals by an older child trespasser
(8-13 years),
Inhalation of volatilized surface soil/sediment chemicals by a merchant north of the
Site,
• Inhalation of volatilized surface soil/sediment chemicals by a nearby adult and young
child resident (1-6 years) northeast of the Site,
• Inhalation of wind blown dust particulates by a merchant north of the Site, and
• Inhalation of wind blown dust particulates by a nearby adult and young child resident
(1-6 years) northeast of the Site.
Under future land-use conditions, the following exposure pathways were selected for evaluation:
•
•
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Geigy FS
Incidental ingestion of chemicals in on-site surface soil/sediment by a hypothetical
future adult and child (1-6 years) resident,
Incidental ingestion of chemicals in on-site surface soil/sediment by a hypothetical
future merchant,
Dermal absorption of chemicals in on-site surface soil/sediment by a hypothetical
future adult and child (1-6 years) resident,
Dermal absorption of chemicals in on-site surface soil/sediment by a hypothetical
future merchant,
Ingestion of groundwater from the surficial aquifer by hypothetical future on-site adult
and child (1-6 years) residents,
Ingestion of groundwater from the surficial aquifer by hypothetical future on-site
merchant,
Ingestion of groundwater from the second uppermost aquifer within property
boundaries by hypothetical future on-site adult and child residents,
Inhalation of volatile organic chemicals while showering with groundwater from the
surficial aquifer by hypothetical future on-site adult and child (1-6 years) residents,
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• Inhalation of volatile organic chemicals while showering with groundwater from the
second uppermost aquifer within property boundaries by hypothetical Mure on-site
adult and child residents,
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Dermal absorption of chemicals while showering with groundwater from the surficial
aquifer by hypothetical Mure on-site adult and child (1-6 years) residents,
Ingestion of groundwater from the off-site second uppermost aquifer (MW-11 D) by
hypothetical future adult and child (1-6 years) residents,
Inhalation of volatilized surface soil/sediment chemicals by hypothetical future adult
and child (1-6 years) residents, and
Inhalation of volatilized surface soil/sediment chemicals by a hypothetical future
merchant.
Human exposure and risk were thus considered under both current and future land-use
conditions for the chemicals of potential concern at the Site. Cumulative risks across pathways
and for all chemicals were also presented.
Under current land-use conditions, the cumulative risk for an on-site older child trespasser in
contact with surface soil and air on the site (Table 3.1) was equal to the NCP point of departure
risk of 1 x1 o-6 (55 Federal Register 8666, March 8, 1990). The cumulative risk for an older child
contacting off-site sediment was 9x1 o-6. None of these risk exceed USEPA's remedial risk range
of 1 x1 o-4 to 1 x10-6, and they are far below USEPA's criterion of 1 x10-4 for cumulative risk. In
addition, noncancer risks were well below the level of concern.
Off-site exposures to merchants north of the site and to young child and adult residents northeast
of the Site were also evaluated under current land-use conditions for the inhalation of on-site dust
and volatilized chemicals (Table 3.1 ). The cumulative inhalation risks to these receptors were well
below USEPA's remedial risk range of 1x10-4 to 1x10-6. Noncancer risks were also well below
the level of concern.
Under future land-use conditions, the cumulative risk for a residential young child (1-6 years)
exposed to the chemicals of potential concern in soil, air and surficial groundwater was 2x1 o-3,
while for an adult the cumulative risk was 4x1 o-3 (Table 3.2). These risks were dominated by the
Geigy FS 3-3 March 16, 1992
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consumption of pesticides in groundwater from the surficial aquifer over a period of 6 years
(child) and 30 years (adult). Inhalation and dermal exposures while showering accounted for far
less risk than exposure through ingestion. If exposure to surficial groundwater was not to occur
in the future, the cumulative risks for a young child and an adult resident exposed to chemicals
in surface soil and air would be reduced to 4x1 o-5 and 2x1 o-5,respectively (Table 3.2). These
risks are well within USEPA's risk range of 1x104 to 1x10~ used for the selection of remedial
alternatives. The incidental ingestion of surface soil containing toxaphene was most responsible
for these risks.
Noncancer risks to hypothetical young child (1-6 years) and adult residents are similarly
dominated by the ingestion of groundwater from the surficial aquifer. The presence of pesticides
in surficial groundwater resulted in a hazard index greater than 1.0 for liver and kidney effects for
both a young child and adult resident (Table 3.2).
The cumulative risks for a merchant contacting soil, air and surficial groundwater under future
land-use conditions was estimated to be 1 x1 o-3 (Table 3.2). These risks were also dominated
by the ingestion of groundwater from the surficial aquifer over a period of 25 years. The
cumulative risk associated with the contact of on-site surface soil and air was 1x10-5. This risk
is within USEPA's risk range of 1x104 to 1x10~ used for the selection of remedial alternatives.
Of the air and soil pathways, risks are highest for the incidental ingestion of chemicals in surface
soil, and are primarily attributed to toxaphene. In addition, the hazard index was greater than 1.0
for liver effects due to the hypothetical consumption of surficial groundwater. Again, pesticides
were responsible for potential noncarcinogenic effects.
Risk was also ,estimated for a future resident who might consume groundwater from the second
uppermost aquifer in the vicinity of off-site monitoring well MW-11 D. Pesticides were not detected
in the second uppermost aquifer directly beneath the Site. The risk associated with this
hypothetical future exposure was estimated to be 7x104 for a young child (1-6 years) resident,
and 2x1 o-3 for an adult resident (Table 3.2). Risks associated with inhalation and dermal
exposure while showering were either less than USEPA's point of departure risk of 1x10~
(inhalation) or were within USEPA's remedial risk range of 1x104 to 1x10~ (dermal). The hazard
index for liver effects was greater than 1.0 for a future adult resident ingesting groundwater in the
Geigy FS 3-4 March 16, 1992
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vicinity of MW-11 D, while for a young child, the hazard index was greater than 1.0 for liver and
kidney effects (Table 3.2).
Adverse ecological impacts associated with the site are not expected to occur. No aquatic life
impacts are expected, as the two drainage ditches that occur at the Site only contain water
during storm events and thus do not sustain aquatic life. No impacts on the vegetative
community are expected given the probable low phytotoxicity of the insecticides of concern in
soil. Adverse terrestrial wildlife impacts also are not expected. The Site does not support
extensive wildlife populations, given its small size, the limited diversity of the vegetative
community (which limits food and cover resources), and the availability of higher quality habitat
in adjacent areas. Some impacts are possible for soil invertebrates living in limited areas of the
Site, although these impacts could not be evaluated with any degree of certainty given the
available toxicological and exposure database. Even if toxic effects in soil invertebrates are
possible in localized areas, extensive impacts are considered unlikely because the sand and low-
organic content soil present naturally at the Site is unlikely to support an abundant and diverse
soil invertebrate community.
A soil remediation goal for the risk-limiting chemical, toxaphene, was derived in accordance with
EPA guidance for the direct contact pathway of greatest concern, i.e. the incidental ingestion of
soil under future residential conditions (Appendix E of the Baseline Risk Assessment; Clement,
1992). Not-to-exceed surface soil concentrations of 5 mg/kg toxaphene, 50 mg/kg toxaphene,
and 500 mg/kg toxaphene were found to represent 1 x1 o-6, 1 x1 o-s, and 1 x1 o-4 excess
upperbound lifetime residual cancer risks respectively, for site-wide exposure to all of the
pesticides combined. A site-wide residual risk of 1 x1 o-5 could be considered for this Site,
because it is unlikely that residential development would occur there in the future. This is
because the Site is currently bisected by railroad tracks, is bordered by a highway, and most of
the property consists of either railroad or highway right-of-ways (Figure 2.4).
Risks to a child (1-6 years) and adult resident ingesting groundwater from the on-site second
uppermost aquifer are 1 x10·5 and 2x1 o·5, respectively. The hazard index exceeded one for a
child resident due to TCE, however was less than one for an adult resident.
Geigy FS 3-5 March 16, 1992
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The risks due to inhalation of TCE in groundwater while showering are 3E-6 and 4E-6, for a child
and adult resident, respectively.
Geigy FS 3-6 March 16, 1992
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TABLE 3.1
SUMMARY OF POTENTIAL HEALTH RISKS ASSOCIATED WITH THE
GEIGY CHEMICAL CORPORATION SITE: Current Land Use
Exposure Pathway
CURRENT LAND USE:
Soil Ingestion:
On-Site Child/teenage trespasser (8-13 years)
Off-Site Child/teenager (8-13 years)
Dermal Absorption from Soil Matrix:
On-Site Child/teenage trespasser (8-13 years)
Off-Site Child/teenager (8-13 years)
Inhalation of Volatilized Chemicals
On-Site Child/teenage trespasser (8-13 years)
Merchant North of Site
Child (1-6 years) Resident Northeast of Site
Adult Resident Northeast of Site
Inhalation of Dust Particulates
Merchant North of Site
Child (1-6 years) Resident Northeast of Site
Adult Resident Northeast of Site
Upper Bound Hazard Index for
Excess Lifetime Noncarcino~enic
Cancer Risk8 Effects
7E-07 <1
7E-06 <1
4E-07 <1
2E-06 <1
2E-08
6E-07
1E-07
9E-08
6E-10
8E-11
1 E-10
---= This exposure pathway could not be evaluated due to the absence of EPA toxicity criteria.
a The upperbound individual excess lifetime cancer risk represents the additional probability
that an individual may develop cancer over a 70-year lifetime as a result of exposure
conditions evaluated.
b The hazard index indicates whether or not exposure to mixtures of noncarcinogenic chemicals
may result in adverse health effects. A hazard index less than one indicates that adverse
human health effects are unlikely to occur.
Geigy FS 3-7 March 16, 1992
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TABLE 3.2
SUMMARY OF POTENTIAL HEALTH RISKS ASSOCIATED WITH THE
GEIGY CHEMICAL CORPORATION SITE: Future Land Use
Exposure Pathway
FUTURE LAND USE:
Soil Ingestion:
Merchant
Child (1-6 years) Resident
Adult Resident
Dermal Absorption from Soil Matrix:
Merchant
Child (1-6 years) Resident
Adult Resident
Ingestion of Surficial Aquifer Groundwater:
Merchant
Child (1-6 years) Resident
Adult Resident
Ingestion of On-site Second Uppermost Aquifer
Groundwater
Child
Adult
Ingestion of Off-Site MW-11 D Groundwater:
Child (1-6 years) Resident
Adult Resident
Inhalation of Volatiles While Showering with
Surficial Groundwater:
Child (1-6 years) Resident
Adult Resident
Inhalation of Volatiles While Showering
with On-site Second Uppermost Aquifer
Child
Adult
Dermal Absorption While Bathing with Surficial
Groundwater:
Child (1-6 years) Resident
Adult Resident
Geigy FS 3-8
Upper Bound Hazard Index for
Excess Lifetime Noncarcino~enic
Cancer Risk8 Effects
4E-06
3E-05
1E-05
6E-07
4E-06
1E-06
1E-03
2E-03
4E-03
1E-5
2E-5
7E-04
2E-03
3E-08
4E-08
3E-6
4E-6
2E-06
SE-06
<1
<1
<1
<1
<1
<1
> 1 (liver: 1.2)
> 1 (liver: 8.9,
kidney: 6.5)
> 1 (liver: 4.1,
kidney: 3.2)
> 1 (liver: 1.6)
<1
> 1 (liver: 2.4,
kidney: 2.0)
> 1 (liver: 1.2)
<1
<1
<1
<1
March 16, 1992
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Inhalation of Volatilized Chemicals
Merchant
Child (1-6 years) Resident
Adult Resident
TABLE 3.2 (Continued)
6E-07
1E-06
9E-07
---= This exposure pathway could not be evaluated due to the absence of EPA toxicity criteria.
8 The upperbound individual excess lifetime cancer risk represents the additional probability
that an individual may develop cancer over a 70-year lifetime as a result of exposure
conditions evaluated.
b The hazard index indicates whether or not exposure to mixtures of noncarcinogenic chemicals
may result in adverse health effects. A hazard index less than one indicates that adverse
human health effects are unlikely to occur.
Geigy FS 3-9 March 16, 1992
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4.0 REMEDIAL RESPONSE OBJECTIVES
Site-specific remedial response objectives are based on the baseline risk assessment and on the
evaluation of applicable or relevant and appropriate requirements (ARARs). A summary of the
risk assessment was presented in Section 3. Results of the risk assessments and the evaluations
of ARARs will be used to define potential areas of remediation at the Site.
4.1 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)
Section 121 (d) of the Comprehensive Environmental Response, Compensation and Liability Act
(CERCLA) of 1980, as amended by the Superfund Amendments and Reauthorization Act of 1986
(SARA), requires that remedial actions comply with requirements or standards set forth under
Federal and State environmental laws. The requirements that must be complied with are those
that are applicable or relevant and appropriate (ARAR) to the (1) potential remedial actions, (2)
location, and (3) media-specific chemicals at the Site.
As mandated by CERCLA 121 (d)(2)(A), remedies must consider "any promulgated standard,
requirements, criteria, or limitation under a State environmental or facility siting law that is more
stringent than any Federal standard, requirement, criteria, or limitation" if the former is applicable
or relevant and appropriate to the site and associated remedial activities. SARA requires that the
remedial action for a site meet all ARARs unless one of the following conditions is satisfied:
Geigy FS
the remedial action is an .interim measure where the final remedy will attain the ARAR
upon completion;
compliance will result in greater risk to human health and the environment than other
options;
compliance is technically impracticable;
an alternative remedial action will attain the equivalent of the ARAR;
for State requirements, the State has not consistently applied the requirement in
similar circumstances.
4-1 March 16, 1992
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In addition to ARARs, many Federal and State environmental and public health programs also
develop criteria, guidance, and proposed standards that are not legally binding, but that may
provide useful information or recommended procedures (EPA, August 1988). These "to-be-
considered" factors (TBCs) are not potential ARARs but are evaluated along with ARARs to set
remediation objectives (e.g., cleanup goals).
ARARs may be classified as either action-specific, location-specific or chemical-specific. Review
of ARARs and TBCs with respect to the Site is given in the following subsections.
4.1.1 Action-Specific ARARs
Action-specific requirements set controls or restrictions on the design, performance and other
aspects of implementation of specific remedial activities. Examples include RCRA regulations for
off-site disposal of hazardous residuals, Clean Water Act standards for discharge of treated
groundwater, and North Carolina sediment and erosion control standards (North Carolina Division
of Land Resources) for excavation of soils. Because action-specific ARARs apply to discrete
remedial activities, their evaluation is presented in Section 7, Detailed Analysis of Alternatives, for
each retained alternative. A retained alternative must conform to all ARARs unless one of the five
statutory waivers stated above is involved.
SARA Section 121 (e) exempts any on-site response action from having to obtain a Federal, State
and/or local permit. The on-site actions must, however, still comply with the substantive aspects
of these requirements.
4.1.2 Location-Specific ARARs
Location-specific ARARs must consider Federal, State, and local requirements that reflect the
physiographical and environmental characteristics of the Site or the immediate area. Remedial
actions may be restricted or precluded depending on the location or characteristics of the site
and the resulting requirements. A listing of potential location-specific ARARs and their
consideration towards the Site is given in Table 4.1.
Geigy FS 4-2 March 16, 1992
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Since Federal and State groundwater classification guidelines are not promulgated regulations,
they are not potential ARARs at Superfund sites (EPA, August 1988). Groundwater classification,
however, will be treated as a "to be considered" (TBC) factor.
I Federal classification guidelines are as follows (EPA, December 1988):
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Class I: Groundwater that Is Irreplaceable with no alternative source or Is
ecologically vital;
Class II: A -Groundwater currently used for drinking water;
B -Groundwater potentially available for drinking water;
Class Ill: Groundwater not considered a potential source of drinking water due to
natural contamination or insufficient yield.
The uppermost aquifer at the Site is considered Class 11B (potential source of drinking water).
The second uppermost aquifer at the Site is considered Class IIA (current source of drinking
water).
State classification guidelines are based on best usage (NCAC 2L.0201 ). The uppermost and
second uppermost aquifers are therefore considered Class GA groundwater under the State
system.
4.1.3 Chemical-Specific ARARs
Chemical-specific ARARs are concentration limits in the environment promulgated by government
agencies. Per the NCP, an attempt must be made to develop health-based site-specific levels
for chemicals or media where such limits do not exist and there is a concern with their potential
health or environmental impacts. Potential chemical-specific ARARs are discussed by media
below.
4.1.3.1 Groundwater
Groundwater ARARs will be evaluated with respect to the uppermost and second uppermost
aquifers at the Site. Potential ARARs for groundwater include Maximum Contaminant Levels
Geigy FS 4-3 March 16, 1992
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(MCLs), North Carolina Drinking Water Standards, and North Carolina Groundwater Standards.
Some chemicals found in groundwater at the Site lacked established groundwater quality criteria
for consideration in developing remedial alternatives. Consequently, an attempt was made to
calculate remediation goals for these chemicals using a risk-based calculation (discussed below).
Maximum Contaminant Levels (MCLs)
The NCP states that Maximum Contaminant Levels (MCLs), established under the Safe Drinking
Water Act (SOWA), are potentially relevant and appropriate groundwater standards for
groundwater that is a current or potential source of drinking water (300.430(e)(2)(i)(A)). Although
the groundwater in the uppermost aquifer Is not known to be a source of drinking water in the
immediate vicinity of the Site, MCLs will be considered the remediation goal for the uppermost
aquifer. Per the NCP, MCLs will also be considered the primary remediation goal for pesticides
in the second uppermost aquifer. MCLs and proposed MCLs for Geigy Site groundwater
chemicals are provided in Table 4.2. In addition, the table presents the maximum groundwater
concentration for a particular chemical and its associated sampling location as determined by
the RI.
North Carolina Drinking Water and Groundwater Standards
North Carolina drinking water standards (1 O NCAC 1 OD) are essentially identical to the SOWA
MCLs established by the EPA (Table 4.2). North Carolina Groundwater Standards (North
Carolina Administrative Code (NCAC) Title 15A, Chapter 2, Subchapter 2L) are for Class GA
groundwater, best usage as a source of drinking water.
As seen in Table 4.2, the North Carolina Groundwater Standards for gamma-BHC and toxaphene
are below the CERCLA Contract Required Quantitation Limit. In such cases, the North Carolina
Groundwater Standard defers to the quantitation limit as the maximum allowable concentration
(15 NCAC 2L Section .0202(b)). Since potential best usage of Site groundwater is as drinking
water, the North Carolina groundwater standards are below CERCLA Contract Required
Quantitation Limits, and the attainment of MCLs will satisfy North Carolina drinking water
standards, MCLs are the remediation goal for Site groundwater.
Geigy FS 4-4 March 16, 1992
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Establishment of Risk-Based Goals for Selected Pesticides
AJ. seen on Table 4.2, six pesticides in the groundwater lack established water quality criteria for
consideration in developing remedial alternatives. These are aldrin, alpha-BHC, beta-BHC, delta-
BHC, dieldrin, and endrin ketone.
Groundwater quality goals for these remaining compounds would traditionally be based on
health-based risk levels, where available. Site groundwater does not currently represent a
pathway for human exposure and such a derivation is not strictly appropriate. However, to
develop potential remediation goals that would have an equivalence to available MCLs, the
health-based approach will be used to develop preliminary remediation goals. Oral reference
doses (R!Ds) are used for non-carcinogens while oral cancer potency factors (slope factors) are
used for carcinogens. Calculation of groundwater quality goals is based on the following EPA
factors:
70 kg body weight
2 liters per day ingestion
1 o-4 risk level (carcinogens).
Risk-based goals were calculated for four of the pesticides where MCLs did not exist. It was not
possible to calculate values for delta-BHC and endrin ketone due to the absence of toxicity
factors. Derivation of risk-based goals is presented in Appendix B. The resulting risk-based
goals are listed in Table 4.2.
Groundwater Remediation Goals
Groundwater remediation goals for chemicals of concern at the Geigy Site are listed in Table 4.2.
The North Carolina groundwater standard for gamma-BHC is less than CERCLA contract required
quantitation limit; therefore, the quantifiable MCL value will be the remediation goal. Currently,
the MCL for gamma-BHC is 4 ug/I; however, the MCL will become 0.2 ug/1 effective July 30, 1992.
Current research, including full-scale groundwater remediation projects, has shown that there are
practical limitations in remediating the groundwater concentrations of selected compounds to
MCLs (Borden and Kao, 1992, Travis and Doty, 1990; EPA, 1989b; EPA, 1989c; EPA, 1989d;
Geigy FS 4-5 March 16, 1992
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EPA, 1990b; EPA, 1990C; Hall, 1991; Haley et al., 1990). Limitations include sorption of contaminants to soils, specific aquifer properties such as subsurface heterogeneity and fractures, low remediation levels (e.g., MCLs), and the presence of stagnation zones within the extraction system. Groundwater recovery and treatment, however, would contain and reduce contaminant levels while attempting to restore the aquifer to MCLs using current groundwater recovery technologies.
4.1.3.2 Soils
As discussed in Section 2, interim remedial actions in 1989 and 1991 removed most of the pesticides in the soils at the Site. These removal actions significantly reduced the concentration of chemicals in source areas (i.e., vadose zone soils), greatly reducing the potential for effects on human health and the environment. Following is a discussion of remediation goals for the surficial soils (0' to 1' depth) and vadose zone soils (> 1' depth).
Surficial Soils
The NCP specifies that for known or suspected carcinogens, acceptable exposure levels are generally concentration levels that represent an excess upper bound lifetime cancer risk between 10-4 and 10-6 (55 Federal Register 8666, March 8, 1990). The NCP does not address non-carcinogenic risks. For non-carcinogens, a hazard index (HI) less than one is considered acceptable and thus remediation is generally not warranted (EPA, 1991 ). As summarized in Section 3, the risk assessment estimated that under current Site conditions, the LECR from on-site exposure to surface soil was 1 xl o-6 and the HI was well below one. Therefore, under current conditions, the Site surface soil does not require remediation.
A future residential scenario was examined in the Baseline Risk Assessment (Clement, 1992).
As discussed in the risk assessment and summarized in Section 3 of this FS, the LECR for an adult under the future residential scenario is estimated to be 2.2 x 1 o-s for exposure to Site surface soil and sediment. Per the limiting chemical concept in Part B of Risk Assessment Guidance for Superfund (RAGS), the chemical primarily responsible for the risk was toxaphene. The HI is below one for exposure to surface soil and sediment.
Geigy FS 4-6 March 16, 1992
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The estimated risks from future residential exposure to surficial soils and sediment are within the
acceptable range of risk values specified In the NCP (i.e., LECR less than 1 o-4) and by EPA
guidance (i.e., HI less than one). However, for use by the EPA risk manager, soil remediation
levels were developed in the Risk Assessment (Clement, 1992) to achieve 1 o-6 and 1 o-5 LECR
values.
As mentioned, the primary chemical responsible for potential surficial soil risks is toxaphene.
Therefore, surficial soil remediation levels were calculated for toxaphene based on the limiting
chemical concept discussed above. LECR values of 10-5 and 10-6 would be achieved by
attaining levels of 50 and 5 mg toxaphene/kg soil, respectively, at the Site (Appendix E of the
Baseline Risk Assessment; Clement, 1992). Removal of surface soil locations with toxaphene
concentrations greater than these levels would meet the respective LECR values of 1 o·5 and 1 o-6.
Calculations of soil volumes to achieve these LECR values are presented in Appendix A. To
reduce the average site-wide risks to a LECR of 1 o-6, approximately 670 cubic yards of soil would
have to be removed (Table A.6) as shown on Figure 4.1. In addition, the concrete slab
foundations of former warehouses A and B and the associated fill soil would have to be removed
to gain access to the underlying soil (Figure 2.1 ). Volumes of non-contaminated concrete and
fill soil are approximately 400 and 1200 cubic yards, respectively (Table A.8).
Removal volume to achieve a LECR of 1 o-5 LECR would be approximately 140 cubic yards (Table
A.7) as shown on Figure 4.2. No surface soil remediation would be necessary to achieve a LECR
of 1 o-4 since the estimated future residential risk maximum is already below this value.
Vadose Zone Soils
There are no ARARs for pesticides in vadose zone soils. Potential remediation requirements are
therefore based on a compound's capacity to generate leachate levels that could exceed
groundwater remediation goals. Concentrations of chemicals in vadose zone soils that are
protective of groundwater can be calculated through vadose zone modeling. Such modeling was
conducted using the Vadose Zone Interactive Processes (VIP) model (Stevens et al., 1991 ).
Geigy FS 4-7 March 16, 1992
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The VIP model was developed by the Civil and Environmental Engineering Department of Utah
State University (Logan, Utah). The VIP model was developed to predict the fate and transport
of compounds in the vadose zone. Variable input parameters, such as those associated with a
specific soil type and recharge rate (e.g., precipitation), allow the model to be tailored to a
specific situation. The model therefore can be used to calculate site-specific remediation goals.
To conduct a model run, site-specific and chemical-specific parameters are input. The model
runs are continued until the maximum concentration of vadose zone leachate reaches the
groundwater. The concentration in this maximum slug of contamination is attenuated by the
groundwater beneath the modeled vadose zone. Details about the modeling for the Site,
including input parameters, are provided in Appendix C.
Gamma-BHC and toxaphene were selected for VIP modeling since the BHC isomers and
toxaphene are the predominant site-related pesticides in groundwater. In addition, the highest
average concentrations for pesticides in the vadose zone soil (Table 4.3) were for toxaphene.
Gamma-BHC was selected to represent the total BHC isomers since it has the most stringent
MCL (0.2 ug/1), the longest half-life, and lowest Kd value. Gamma-BHC therefore has the lowest
potential remediation level, greatest persistence and greatest mobility of the BHC isomers. Other
BHC isomers would not have the potential to impact Site groundwater if gamma-BHC cannot
exceed its MCL. The VIP modeling was conducted to determine soil conditions that could not
exceed MCLs in Site groundwater.
The VIP model operates by creating a homogeneous source volume representing existing Site
conditions (baseline evaluation). Leachate levels are then generated based on Site-specific input
parameters and compared with the groundwater remediation goals. If groundwater remediation
goals are not exceeded by the maximum leacha~e levels, no soil remediation is indicated. The
methodology is analogous to the evaluation of surficial soil risks, where no remediation is I necessary if the cumulative risks are within acceptable EPA levels.
I Results of the baseline VIP modeling are presented in Appendix C. Vadose zone soil
concentrations which remain at the Site do not have the potential to impact groundwater above
I MCLs and therefore do not require further remediation. , Geigy FS 4-8 March 16, 1992
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4.2 REMEDIAL DESIGN BASIS
Site media that pose significant risks to human health and the environment and/or exceed ARARs
represent areas of potential remediation. Potential human health and environmental risks were
evaluated in the risk assessment (Section 3). Following is a discussion of surficial soil and
groundwater that potentially require remediation.
4.2.1 Surficial Soil
Estimated risk from surficial soil currently are within or below EPA's acceptable risk values.
However, as discussed in Section 4.1.3.2, selected remediation would have to be done to
achieve a LECR of 1 o-5 or 1 o-6.
4.2.2 Groundwater
As discussed, Site groundwater is currently not used as a source of drinking water nor is it
expected to in the future. However, pesticides in both the uppermost and second uppermost
aquifers will be considered for remediation. Potential remediation technologies will be developed
based on the remediation goal of attaining MCLs at the Site. The groundwater recovery system
would control off-site migration during implementation of any remedial alternative.
The assessment of potential groundwater recovery technologies is based on RI data (ERM-
Southeast, 1992) and chemical/physical properties of the site pesticides. Groundwater extraction
modeling and potential technologies are presented in Section 5.
4.2.3 Chemical and Physical Properties of Selected Pesticides
Table 4.3 presents chemical and physical properties of selected Site-related pesticides.
Published values may vary; therefore, best professional judgement was used to select the values
that appear in Table 4.3.
Geigy FS 4-9 March 16, 1992
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4.3 SUMMARY OF REMEDIAL RESPONSE OBJECTIVES
Three types of ARARs were examined: action-specific, location-specific, and chemical-specific.
Detailed evaluation of action-specific ARARs Is dependent on the specific remedial response
alternatives that will be considered. These will be evaluated in Section 7, Detailed Analysis of
Alternatives.
Two location-specific ARARs are potentially applicable at the Site during a remedial action:
construction within a right of way of a State highway and construction within a right of way for
the railroad (Table 4.1).
Chemical-specific ARARs were examined for groundwater. Retained chemical-specific ARARs for
Site groundwater are presented in Table 4.2. Remediation alternatives will be developed to
recover and treat Site groundwaters exceeding MCLs. Technologies for groundwater remediation
will consider Site-specific conditions and the chemical/physical properties of the pesticides of
concern .
Significant amounts of pesticide contaminated soils were removed from the Site in 1989 and
1991. Therefore, current Site conditions were modeled to determine if the remaining pesticides
would adversely impact the surficial aquifer.
Vadose zone modeling was conducted using the VIP model to determine if average Site-wide
concentrations for gamma-BHC and toxaphene would exceed their MCLs in the surficial aquifer;
Modeling results indicate that under current Site conditions, the pesticides that remain in the
vadose zone soils cannot exceed MCLs in the surficial aquifer. Therefore, vadose zone soil
remediation is not necessary and will not be considered further in this FS.
The NCP specifies an acceptable risk range of 1 o-4 to 1 o-6 for carcinogenic risks. Selection of
the appropriate risk level for remediation is determined by EPA's risk manager based on a
number of factors, including:
Geigy FS 4-10 March 16, 1992
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• uncertainty of the risk levels
• site access
• surrounding land use
• natural or man-made impediments to development
• likelihood of future development
Site soils pose potential cumulative risks within the NCP's acceptable range (2.2 x 10-si.
Volumes of soil to be remediated to achieve 1 o-5 and 1 o-6 risk levels are approximately 140 and
670 cubic yards, respectively. Remedial alternatives will be developed that address those
surficial soils exceeding a LECR of 1 o-5 and of 1 o-6.
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SS-61 ®
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WOODS
OSD-28 & OSD-29
EXCAVATION VOL.= 15 CY
LEGEND
SEDIMENT SAMPLE LOCATION
SOIL SAMPLE LOCATION
0
LIMIT OF SOIL EXCAVATION
SURFICIAL SOILS WITH TOXA-
PHENE CONCENTRATIONS 2 5
120 240
mg/kg
360
VOL.=35 CY
EXCAVATION VOL.=29 CY
WOODS
EXCAVATION VOL.= 139 CY
SS-46
SS-49
SS-103
SD-21
SS-104
SS-105
1---,r.....:.:..:,_ss-110
SS-71
SS-56
SD-6
OSD-22
D
SLAB 23
-62
-62-20S
ss-61 [+t so~:~-43
EXCAVATION VOL.=177 CY ""''</
EXCAVATION VOL.-15 CT
EXCAVATION VOL.=38 CY
WOODS
N
w z 5 ,,_
w ~
DEMOLET AUTOMOTI\/E
CLEANING SERVICE
ss-1ee
···-® WOODS ~,....,,,.
, ,
I IP~
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LLRED
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FIGURE 4.1
PROPOSED LOCATIONS OF
c;uRFICAL SOiL REMEDIATION: 1 OE-6
' GEIGY CHEMICAL CORPORATION SITE
ABERDEEN, NORTH CAROLINA
LECR
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SS-61
(1)
□
EXCAVATION VOL.=23 CY
SS-110
EXCAVATION VOL.=21 CY
SS-58-20S
LEGEND
SOIL SAMPLE LOCATION
LIMIT OF SOIL EXCAVATION
SURFICIAL SOILS WITH TOXA-
PHENE CONCENTRATIONS 2. 5 mg/kg
0 60 120
EXCAVATION VOL.=53 CY
180 FEET
SS-61
SS-62
Booy
SHQp
\
\
I I / __ ,,,.
SS-63
-WELL
SS-63-20S
SS-93
EXCAVATION VOL.= 15 CY
' ' \ \
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FIGURE 4.2
w z ::i
(L
w
~ (,/)
PROPOSED LOCATIONS OF
SURFICIAL SOIL REMEDIATION: 1 OE-5 LECR
GEIGY CHEMICAL CORPORATION SITE
ABERDEEN. NORTH CAROLINA
--.--
SITE FEATURE/LOCATION
Wtthin 61 meters (200 feet) of a
fault displaced in Holocene time
Wtthin 100-year floodplain
Wtthin floodplain
Wtthin area where action may
cause irreparable harm, loss, or
· destruction of significant artifacts
-- - -
CITATION
40 CFR 264.18 (a)
40 CFR 264.18 (b)
Protection of floodplains
(40 CFR 6, Appendix A);
Fish and Wildlife
Coordination Act (16 USC
661 et seq.); 40 CFR
6.302; Floodplains
Executive Order (EO
11988)
National Historical
Preservation Act (16 USC
Section 469); 36 CFR Part
65
-" -.. ..
TABLE 4.1
POTENTIAL LOCATION· SPECIFIC ARARs
GEIGY CHEMICAL CORPORATION SITE
I!!!!!!
REQUIREMENT SYNOPSIS CONSIDERATION IN nus FS
New treatment, storage, or disposal of Not an ARAR because Site is not wtthin 200
hazardous waste prohibtted; applies to RCRA feet of a fault displaced in Holocone time.
hazardous waste; treatment, storage, or
disposal.
Faciltty must be designed, constructed,
operated, and maintained to avoid washout; .
applies to RCRA hazardous waste; treatment,
storage, or disposal.
Not an ARAR because Site is not in a
100-year flood plain.
Action to avoid adverse effects, minimize Not an ARAR because Site is not in a flood
potential harm, restore and preserve natural plain.
and beneficial values; applies to action that will
occur in a floodplain, i.e., lowlands, and
relatively flat areas adjoining inland and coastal
waters and other flood prone areas.
Requires that action be taken to recover and Not an ARAR because Site is not a
preserve artifacts when alteration of terrain designated archaeological area.
threatens significant scientific, prehistorical,
historical, or archaeological data.
--.---- -- --l!!!!!I
SITE FEATURE/LOCATION
Critical habttat upon which
endangered species or
threatened species depends
Wetlands
Wilderness Area
TABLE 4.1 (Continued)
POTENTIAL LOCATION· SPECIFIC ARARs
GEIGY CHEMICAL CORPORATION SITE
CITATION REQUIREMENT SYNOPSIS
Endangered Species Act II endangered or threatened species are
of 1973 (16 USC 1531 present, action must be taken to conserve
et seq.); 50 CFR Part 200, endangered or threatened species, including
50 CFR Part 402; Fish and consuhation wtth the Department of Interior.
Wildlife Coordination Act
(16 USC 661 et seq.); 33
CFR Parts 320-330
Clean Water Act Section
404; 40 CFR Part 230, 33
CFR Parts 320-330
For wetlands as defined by U.S. Army Corps
of Engineers regulations, must take action to
prohibtt discharge of dredged or fill material
into wetlands wtthout permit.
CONSIDERATION IN nus FS
Not an ARAR because Site does not have
endangered or threatened species.
Not an ARAR since Site is not a wetlands
area.
40 CFR Part 6, Appendix A For action involving construction of facilities or Not an ARAR since Site is not a wetlands
management of property in wetlands (as area.
defined by 40 CFR Part 6, Appendix A,
Section 4 (j)), action must be taken to avoid
adverse effects, minimize potential harm, and
preserve and enhance wetlands to the ex1ent
possible.
Wilderness Act (16 USC For Federally-owned area designated as
1131 et seq.); 50 CFR 35.1 wilderness area, the area must be
administered in such manner as will leave tt
unimpaired as wilderness and to preserve tts
wilderness.
Not an ARAR since Site is not a wilderness
area.
--
SITE FEATURE/LOCATION
Wtthin area affecting national wild,
scenic, or recreational rivers
Classification and potential use of
an aquifer
Construction wtthin State highway
system right-of-way.
Construction wtthin a railroad
right-of-way.
- - --" I!!!!!!!! ~ ==r
CITATION
Wild and Scenic Rivers Act
(16 use 1211 et seq.);
section 7 (a); 40 CFR 6.302
(e)
Guidelines for Ground
Water Classification, EPA
Ground Water Protection
Strategy. (EPA, 1984;
EPA, 1986) and North
Carolina Administrative
Code, ntle 15A, Chapter 2,
Subchapter 21.
North Carolina
Administrative Code,
Subchapter 2E, Section
. 0420 Construction Wtthin
Right-of-Way.
Federal Railroad
Administrative, Telephone
Conversation, Sept. 4, 1991
TABLE 4.1 (Continued)
POTENTIAL LOCATION-SPECIFIC ARARs
GEIGY SITE
REQUIREMENT SYNOPSIS CONSIDERATION IN THIS ES
For activtties that affect or may affect any of the Not an ARAR since Site Is not on scenic river
rivers specified in section 1271 (a), must avoid
taking or assisting in action that will have direct
adverse effect on scenic river.
Consider Federal and State aquifer
classifications in the assessment of remedial
response objectives.
Written permission from the North Carolina
DOT is required for construction on state
highway right-of-ways .
Permission from the Aberdeen and Rockfish
Railroad prior to construction wtthin their
right-of-way.
Not an ARAR, evaluated as a TBC.
Potential ARAR
Potential ARAR
G-1024 Geigy Tables 10/15191
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Table 4.2
Potential Remedation Goals for Groundwater
Geigy Chemical Corporation Site, Aberdeen, North Carolina
North North
Carolina Carolina
Risk-Drinking Groundwtr.
Maximum Monitoring SOWA Based Water Quality
Groundwater Well MCL Goal (1) Standard Standard
Chemical Cone. lua/ll Number /ua/ll /ua/ll lua/ll /ua/ll
Aldrin 0.1 MW-4S NA 0.5 NA NA
alpha-BHC 36 MW-6S NA 1.4 NA NA
beta-BHC 25 MW-lOS NA 4.7 NA NA
gamma-BHC 30 MW-6S 0.2 (2) NC 0.2 0.0265
delta-BHC 29 MW-6S NA NTD NA NA
Dieldrin 2 MW-lOS NA 0.5 NA NA
Endrin Ketone 4 MW-10S NA NTD NA NA
Toxaphene 10 MW-2S 3 NC 3 0.031
Trichloroethene 200 MW-4D 5 NC 5 2.6
(TCE; 3\
SOWA= Sale Drinking Water Act Maxium Contaminant Level (40 CFR Part 141.61)
North Carolina Drinking Water Standards from NCAC TiHe 10, Ch. 10, Subsection 10D
North Carolina Groundwater Standards for groundwater class GA from NCAC Title 1 SA,
Ch. 2, October 1990
1 = Risk-based goals calculated in Appendix B
2 = Effective July 30, 1992; current MCL is 4 ug/1
3 = Not detected in Site soils or in the uppermost aquifer
4 = Value is the quantitation lim~ for water, not the absolute detection limit
NA = Not Available
NC = Not Calculated since a MCL value was available
NTD = No Toxicological Data were available to calculate a PPLV
GW-REM.OLN, 3/11/92
CERCLA
Contract
Required Groundwater
Ouantitation Remediation
Limit Goal
(ua/ll /ua/ll
0.05 0.5
0.05 1.4
0.05 4.7
0.05 0.2
0.05 NID
,. 0.10 0.5
0.10 NID
1.0 3
10 (4) 5
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Table4.3
Chemical and Physical Properties of Selected Sne Chemicals
Geigy Chemical Corporation Sne, Aberdeen, North Carolina
Vapor
Pressure(2)
Boiling Water (mm Hg,
Henry's
Law
Constant (3) Log
Point(1) Solubilny(2) 20 to 30 (Pa cum) Koc(2) Log Specific
Chemical Idea. C.l lma/ll deg. C.) lmole\14} lml/o\ Kow(2l Densnv/1,51
Aldrin 145 0.18 6E-6 91.23 4.98
lat 2 mm Ho\
alpha-BHC 288 1.63 2.50E-5 0.87 3.58
beta-BHC 60 0.24 2.80E-7 0.12 3.58
gamma-BHC 323 7.80 1.60E-4 0.13 3.03
delta-BHC 60 31.4 1.70E-5 0.073 3.82
DDD 193 0.1 1.89E-6 0.64 5.89
DDE NA 0.04 6.50E-6 2.54 (o,p'-DDE) 6.64
7.951n,c'-DDEi
DDT 260 0.005 5.50E-6 2.36 5.39
Dieldrin Decomposes 0.195 1.78E-7 1.12 3.23
Endrin Ketone (6) 245 0.23 7E-7 0.033 3.92
/Decomposes}
Heptachlor Epoxide NA 0.35 3.00E-4 44.5 (2) 2.34
Toxaphene Decomposes 0.5 0.4 0.42 2.98
at >120 0.2-0.4 (1l
Trichloroethene (TCE) 87 1100 57.9 922 (2) 2.10
Notes:
NA = Not Available
1 = Montgomery and Welkom, Groundwater Chemicals Desk Reference,
Lewis Publishers, 1990
2 = Superfund Public Health Evaluation Manual, EPA, October 1986 (EPN540/1-86/060)
3 = Suntio et al., 1988
4 = To convert to atm-cu m/mole, divide by 1.013E+05
5 = Relative to distilled water
5.30
3.90
3.90
3.90
4.10
6.20
7.00
6.19
3.50
4.56
2.70
3.3
2.38
6 = No data could be found for endrin ketone. Endrin ketone is a biodegradation product of endrin;
therefore, values for endrin were used. Data are from Montgomery and Welkom, 1990.
CHEMPHYS.OLN, 3/11/92
1.70
1.87
1.89
1.89
1.87 .
1.48
NA
1.56
1.75
1.65
NA
1.55
1.46
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5.0 IDENTIFICATION OF POTENTIAL TECHNOLOGIES
The purpose of this initial screening effort Is to identify a list of generally applicable remediation
technologies that can be grouped into remedial alternatives for the Site. Remedial action
technologies evaluated include treatment alternatives, physical controls, and institutional
measures that can be used individually or in combination with other technologies to eliminate or
control any significant risks to public health or any environmental concerns associated with the
Site. The potential remedial measures must be technically feasible considering the Site
conditions and the identified chemicals. The specific technologies have been individually
screened on the basis of the Site conditions, waste characteristics, and technical requirements.
Preliminary cost information has been used to screen out the more costly technologies which do
not provide additional remedial effectiveness over those retained. A series of general remedial
alternatives has been developed for Site media using retained technologies.
Certain technologies have been retained that may only apply to a discrete portion of a medium
but may be useful in forming an overall alternative or disposing of a minor amount of material.
Specific technical and institutional requirements regarding implementation of retained
technologies are described more completely in the Detailed Analysis of Alternatives (Section 7).
5.1 SCREENING CRITERIA
The National Contingency Plan (NCP) and Superfund Amendments and Reauthorization Act
(SARA) provide basic criteria for screening of technologies. The criteria are:
• effectiveness
• implementability
• cost.
5.1.1 Effectiveness
Technologies must be compatible with the waste and Site conditions and must protect public
health and the environment. To accomplish this they must be effective in reducing or eliminating
Geigy FS 5-1 March 16, 1 992
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any short-term and long-term risks to human health or environment directly associated with the
Site to appropriate levels. The technology itself must not have adverse impacts on the
environment, public health, or public welfare. Technologies for which Site waste characteristics
or Site conditions clearly limit their effectiveness or which do not provide adequate protection of
the environment, public health, and public welfare have been eliminated. Technologies which
have not demonstrated effectiveness at similar sites have also been eliminated from further
consideration.
5.1.2 Implementability
Implementability addresses both the technical and institutional feasibility of applying a
technology. Technologies have been evaluated based on the technical feasibility and availability
of resources and equipment, and the administrative feasibility of implementing them. The nature
of the technology should be such that, in the physical setting associated with the Site, it can be
implemented in a cost effective and timely manner. In addition, the implementation of the
technology should not elicit substantial public concerns in the community. Site accessibility,
available area, and potential future use of the property may also affect the implementation of
certain technologies. Technologies that are unworkable based on site conditions, including
material volumes and concentrations, have been eliminated. Mobilization and permitting
requirements, where applicable, must be workable and previously demonstrated at equivalent
projects. Preliminary consideration has also been given to regulatory constraints such as
handling, disposal, and treatment requirements that will effect the implementation of certain
remedial technologies. These considerations will be evaluated further for the retained
technologies when action-specific ARARs are developed. Technologies that are not technically
or administratively feasible have been removed from further consideration.
5.1.3 Cost
Any technology which delivers similar levels of effectiveness and implementability as other
technologies but has a significantly greater cost has been eliminated. Technologies that are
equivalent in cost but are clearly less effective than other retained technologies also are rejected.
Otherwise, cost is not used as a criterion to screen technologies at this point in the process.
Geigy FS 5-2 March 16, 1992
n
5.2 LISTING OF POTENTIAL TECHNOLOGIES
The purpose of this section is to establish a preliminary list of treatment technologies that are
potentially applicable based on the considerations outlined in Section 5.1. As directed by the I NCP, appropriate technologies for the range of general response actions have been considered.
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The initial list of technologies is based on past experience at other sites, demonstrated
technologies at similar hazardous waste sites, a literature review of technical publications, EPA
guidance publications, a literature search of the EPA Alternative Treatment Technology
Information Center database (ATTIC), and Appendix D of the NCP.
Based on the areas of potential remediation identified in Section 4.2 and on the remedial design
basis presented in Section 4.3, potentially applicable technologies were identified for the following
areas of application:
•
•
•
• •
groundwater recovery
groundwater treatment
groundwater disposal
soil/sediment remediation .
The evaluation of technologies is divided between those addressing groundwater and
soils/sediments, due to the dissimilar processes involved. Sediments at the site described in
Section 4.2.2 and for the purposes of evaluating technologies are equivalent to soils. Hereafter,
soils and sediments will be referred to simply as soils.
5.3 GROUNDWATER CONTROL SCREENING
Pesticides in the uppermost and second uppermost aquifer at the Site exceed MCLs.
Groundwater at the Site is currently not used for potable or other human activities. The Baseline
Risk Assessment (Clement International, 1992), evaluated potential risks associated with the
ingestion of groundwater in the uppermost aquifer by a hypothetical resident in the future.
Potential future risks from groundwater ingestion exceeded the acceptable range of 1 o-4 to 1 o-6
Geigy FS 5-3 March 16, 1992
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as specified by the NCP (40 CFR 300.430 (e)(2)(i)(A)(Z))). Groundwater control technologies will
be evaluated based on the exceedance of ARARs and potential risks to human health in the
future .
Groundwater control refers to all elements of potential groundwater remediation, Including
recovery, treatment, discharge and containment. Comprehensive groundwater control
alternatives will include retained technologies for each element. Groundwater recovery,
treatment, discharge, and containment technologies are presented in Table 5.1.
5.3.1 Groundwater Recovery
The following technologies have been evaluated as a means of recovering contaminated
groundwater for the purpose of treatment. These technologies will be coupled with the treatment
technologies in Section 5.3.2, discharge technologies in Section 5.3.3 and containment
technologies in Section 5.3.4 in developing overall remedial alternatives.
1) Extraction Wells
Extraction wells (or recovery wells) withdraw groundwater from distinct points. Multiple extraction
wells are placed such that the zone of influence from each individual well overlaps that from
adjacent wells, thereby providing a concerted withdrawal of groundwater containing site-related
chemicals.
The uppermost and second uppermost aquifers contain pesticides that could be attributed to Site
activities (ERM-Southeast, 1992). The uppermost groundwater contour map (Figure 2.2), shows
that a flow divide exists near monitoring wells MW-3S and MW-6S. Groundwater from the eastern
and the western part of the Site flows together and are divided into two components; one
component flowing north and the other flowing south/southwest. Analyses of the surficial aquifer
contour map reveals that the bulk of Site groundwater water is flowing north from the flow divide.
A lesser portion of the Site groundwater, in the vicinity of monitoring well MW-1 OS, has the
potential to flow south at the divide. Such a flow regime would allow effective use of extraction
Geigy FS 5-4 March 16, 1992
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wells as a method of controlling the migration of Site groundwater and withdrawing pesticides
for treatment.
Pesticides In the second uppermost aquifer exceed MCL.s at monitoring well MW-11 D. The flow
regime in this aquifer is characterized by a slight gradient to the west-northwest (Figure 2.3). This
type of groundwater flow can also be controlled by extraction wells. A number of monitoring
wells have been installed at the Site and the installation of extraction wells in the uppermost and
second uppermost aquifers would pose no technical difficulties.
Extraction wells serve two purposes, to control groundwater flow and to remove site-related
constituents from the aquifer. Based on the known hydraulic properties, extraction wells should
be capable of controlling groundwater flow in the two uppermost aquifers at the Site. The
removal of constituents is site-specific and depends on the geology, soil type, and aquifer
properties of the site and the physical properties of the constituents. Recent EPA studies have
indicated potential difficulties in achieving part per billion (ppb) remediation levels (Travis and
Doty, 1990; Haley, et al, 1991 ). At the Geigy site, the future MCL of 0.2 ug/1 (ppb) for gamma-
BHC would likely be the rate limiting compound for any aquifer restoration. Because of the Site-
specific nature of groundwater remediation, the potential to achieve MCL.s would have to be
determined through the on going evaluation of actual system performance.
For conceptual purposes in the FS, six extraction wells would be installed in the uppermost
aquifer along the northern Site boundary and a seventh extraction well installed west of MW-4S.
The estimated combined flow rates for the wells would be approximately 5 gallons per minute
(gpm). Two extraction wells would also be placed downgradient of MW-11 D in the second
uppermost aquifer. The combined maximum flow rate of these two wells would be approximately
15 gpm, making the total extraction rate for the Site approximately 20 gpm. Actual groundwater
extraction well locations and flow rates would be determined through testing during Remedial
Design. Extraction wells for groundwater recovery is an effective technology used at many
CERCLA sites. Groundwater extraction wells will be retained for further evaluation.
Geigy FS 5-5 March 16, 1992
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2) Interceptor Trenches and Subsurface Drains
Trenches and drains can be used to collect groundwater containing site-related chemicals along
a line located hydraulically downgradient from the source. In terms of hydraulics, trenches and
drains behave similarly to a series of extraction wells Installed along a straight line, but extend
over a more continuous zone than extraction wells. Drains are generally passive systems,
designed to allow groundwater to flow into a drain under the natural hydraulic gradient.
Interceptor trenches, on the other hand, can be actively pumped to induce flow into the trench.
Subsurface drains and interceptor trenches can be more cost-effective than extraction wells at
shallow depths, but increasing excavation and construction costs reduce their cost-effectiveness
at depths greater than about 40 feet (EPA, January 1987). Only interception trenches will be
considered at this Site, as active pumping would provide greater ability to control hydraulic
gradients across the Site.
An alternative method of trench construction involves the use of a biodegradable bio-polymer
(B-P) slurry to support and stabilize the trench during construction. Using the B-P technique, all
excavation is conducted under slurry. Since trench support is provided by the B-P slurry, the
need for sheeting, shoring, bracing and dewatering is eliminated. Safety using the B-P method
is improved as the trench is always under slurry and there is no worker access. Using a custom-
built hydraulic excavator with extended reach, trench depths up to 70 feet are possible.
Depending on the purpose and design of the trench, different materials including backfill, well
casings, pipe and geomembranes can be placed through the slurry into the trench. After
excavation and backfilling are complete, additives within the B-P slurry naturally biodegrade to
water and carbohydrates. The B-P slurry trenching technique was successfully employed at a
site in central California for the construction of two extraction trenches. The deepest extraction
trench was 65 feet deep, 170 feet long and was constructed in soils composed of silty sands and
cemented sands (Day, 1991 ).
The depth to the uppermost aquitard beneath the Site ranges between 40 to 70 feet from the
surface, placing application of interceptor trenches at the limits of technical feasibility. The
proposed location of the interceptor trench is shown in Figure 5.2. The interceptor trench
however, would not be able to capture contaminated water from areas near monitoring well MW-
Geigy FS 5-6 March 16, 1992
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1 OS in the uppermost aquifer or anywhere in the second uppermost aquifer, so one extraction
well would be installed downgradient of monitoring well MW-10S and two would be installed
downgradient of MW-11 D. The use of an interceptor trench in conjunction with select extraction
wells to collect groundwater at this Site will be retained for further consideration.
3) No Action
The NCP requires that the no action alternative be retained throughout the Feasibility Study as
a basis of comparison during the detailed analysis of alternatives. The no action alternative
would leave chemical residuals in groundwater and rely on natural attenuation mechanisms to
bring concentrations within remediation levels. Groundwater monitoring nor measures to control
or influence the migration of chemical residuals in groundwater would be attempted under a true
no-action alternative. A limited no action alternative could include groundwater monitoring and
legal restrictions on future uses of the Site. The no action alternative would not reduce the
potential for off-site migration of chemical residuals in groundwater nor would it reduce the
potential for human or environmental exposure to the compounds, although there is no current
human exposure pathway to Site groundwater .
5.3.2 Groundwater Treatment
Compounds exceeding potential groundwater remediation levels at the Site are limited to
pesticides, and the assessment of treatment technologies can be limited accordingly. The
required level of treatment of extracted groundwater will be a function of the selected discharge
option.
1) Air Stripping
Air stripping is a mass transfer process in which volatile organics in water are transferred to an
air stream, typically within a packed tower equipped with a blower. The water flows down
through the packing while the air flows upward (countercurrent packed tower). The volatile
components in solution have an affinity for the gas phase and are transferred or stripped from
Geigy FS 5-7 March 16, 1992
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the water to the gas phase and exhausted through the top of the tower. Air stripping is often
employed as a pretreatment step to reduce the organic loading of water being treated by carbon
adsorption.
In general, compounds with dimensionless Henry's Law Constants (He) greater than 0.01 are
readily stripped. With the exception of toxaphene, all pesticides detected in site groundwater
have dimensionless He values less than 9.6 x 104 (Montgomery and Welkom, 1990). Such low
He values for Site pesticides limit the effectiveness of air stripping for treating Site groundwater.
For this reason, air stripping is not retained for further consideration.
2) Activated Carbon Adsorption
Activated carbon is the adsorbent most widely used for the removal of organic contaminants from
liquid (or gas) waste streams. Carbon, which is generally nonpolar, is particularly effective for
the removal of hydrophobic, high molecular weight organic compounds from aqueous streams.
Interaction of the contaminant surface molecules with the carbon surface atoms result in weakly
attractive forces. Adsorption of the contaminant to the carbon is a reversible process which
allows the carbon surface to be regenerated either thermally or chemically. High temperature
thermal regeneration, which destroys the adsorbed organics, is the most effective method for
removal of adsorbed contaminants.
The physical/chemical characteristics of a compound can be used to evaluate its affinity for
carbon. As a general rule, molecules of higher molecular weight and lower solubility are attracted
more strongly to activated carbon than are molecules of lower molecular weights or higher
solubilities. Compounds with molecular weights between 100 to 1,000 grams per mole and
solubilities of less than 100 mg/I in water are considered highly adsorbable. Pesticides detected
in Site groundwater have molecular weights ranging from 291 for the BHC isomers to 414 for
toxaphene and aqueous solubilities ranging from 0.18 mg/I for aldrin to 21.3 mg/I for delta-BHC.
Furthermore, removal efficiencies for dieldrin and toxaphene using activated carbon are I reportedly 99.91 % and 97.2%, respectively (EPA, December 1987). A more important parameter
in the assessment of carbon adsorption is the organic carbon partitioning coefficient (Koc).
I Compounds with a Koc greater than 500 ml/gm are considered highly amenable (Hazardous , Geigy FS 5-8 March 16, 1992
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Waste Consultant, 1986). The primary constituents in Site groundwater, BHC isomers and
toxaphene, all have Koc values greater than 500 ml/gm (EPA, October 1986). Based on their
adsorption characteristics, EPA considers certain adsorption to be the best available technology
(BAT) for the removal of toxaphene and gamma-BHC (56 FR 3526). Activated carbon adsorption
is considered a potentially viable technology for the removal of pesticides detected in Site
groundwater and is retained for further consideration.
3) Sorptive Resins
Resin adsorption is a process which may be used to extract and, if desired, recover organic
solutes from aqueous wastes. The nature of the resin adsorption process is similar to that of
carbon adsorption and the two processes may be competitive in several applications. The most
significant difference between carbon and resin adsorption is that resins are chemically
regenerated with caustic or organic solvents while carbon is usually thermally regenerated.
Resins generally have less adsorptive capacity than carbon and are more expensive. Resins are
better suited for adsorbing ionic or highly polar chemicals rather than nonpolar compounds such
as the pesticides detected in Site groundwater (Hydrosource, Inc; Ecolochem, Inc., September
1991 ). Also, relatively little information is available on the few systems that are currently in
operation, leaving uncertainties regarding process effectiveness and reliability. Based on
comparative effectiveness with carbon adsorption, this technology is not retained for further
consideration.
4) Chemical Oxidation (UV-Ozone/Hydrogen Peroxide)
In chemical oxidation, the oxidation state of the treated compound is raised through addition of
chemicals. Oxidants such as ozone or hydrogen peroxide are mixed with a waste stream and
exposed to ultraviolet (UV) light from numerous ultraviolet lamps as the waste stream passes
through a reaction vessel. The UV radiation enhances oxidation by direct dissociation of the
contaminant molecule or through excitation of the oxidizing species (e.g., ozone and/or hydrogen
peroxide) in the waste stream. Flow patterns and configurations in the reaction chamber are
designed to maximize exposure of the total volume of oxidant bearing wastewater to the W light.
Organic compounds can ultimately be oxidized to carbon dioxide and water, although this level
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of treatment is generally not warranted to meet discharge levels. Chemical oxidation has been
applied successfully for the treatment of pesticides including BHC isomers, aldrin and dieldrin
(EPA, December 1987) and will be retained for further evaluation.
5) Biological Treatment
Biological treatment involves the degradation of organic compounds by microorganisms using
treatment processes such as activated sludge, aerated lagoons, trickling filters, rotating biological
contractors, aerobic and anaerobic digestion. The microorganisms, which are either suspended
in a liquid medium (e.g., activated sludge) or attached to a solid surface (e.g., trickling filter),
metabolize organic waste constituents to carbon dioxide and water if the process is aerobic, or
to carbon dioxide and methane if the process is anaerobic.
Chlorinated pesticides, like many other chlorinated hydrocarbons, are resistant to microbial
degradation and require requisite conditions before biodegradation will occur. BHC isomers and
DDT generally must undergo anaerobic reductive dechlorination before subsequent aerobic
biodegradation of the by products can occur (EPA, September 1986). Sequential
anaerobic/aerobic conditions required to promote biodegradation of site related pesticides are
difficult to achieve, monitor and maintain. Improper or inadequate biological treatment of
groundwater containing site related pesticides can result in pass through or partial degradation
of the target compound.
In a study to determine the fate of pesticides undergoing biological treatment, a municipal
wastewater treatment system, which included a primary clarifier, an aeration basin, and a
secondary clarifier, was spiked with a number of priority pollutants including toxaphene and
lindane. The primary sludge, return activated sludge, and final effluent were sampled to
determine whether the compound was biodegraded, air stripped or adsorbed as it passed
through the treatment system. Adsorption accounted for 58 and 20 percent of removal for
toxaphene and gamma-BHC, respectively. Two percent of the toxaphene and 55 percent of the
gamma-BHC was detected in the final effluent leaving only 40 percent of the toxaphene and 25
percent of the gamma-BHC subject to removal by means of volatilization or biodegradation.
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In another study, the concentration of aldrin (and other pesticides) in the influent and effluent of
a municipal wastewater treatment system was measured. These measurements indicated that
aldrin was transformed into dieldrin, a byproduct which is as toxic as the parent compound.
Although Site related pesticides can be biodegraded, requisite conditions under which they can
be metabolized make implementation and control of available biological treatment technologies
(e.g., bioreactors, publicly owned treatment works) difficult to control, potentially limiting their
effectiveness. For this reason, biological treatment of groundwater for the removal of pesticides
will not be retained for further consideration.
6) Land Treatment
Land treatment, a form of biological treatment, involves applying groundwater to the soil and
enhancing degradation of organic compounds through the addition of nutrients and oxygen. As
discussed under biological treatment, Site related pesticides are not readily amenable to
biological treatment. Biodegradation kinetics typically involve half-lives on the order of years
(Appendix C). Furthermore, chlorinated pesticides, including BHC isomers, undergo reductive
dechlorination under anaerobic conditions before aerobic degradation of the intermediate by
products can occur (EPA, September 1986; Borrow and Kinsella, 1989). Land treatment involves
aerobic biodegradation of organic compounds only. For reasons of effectiveness, land t.reatment
is not technically feasible and will not be retained.
5.3.3 Groundwater Discharge
Groundwater must be discharged after recovery and treatment. The level of groundwater
treatment required is a function of the selected discharge option. Potential methods for the
discharge of treated groundwater are listed below.
1) Horizontal Infiltration Gallery
With horizontal infiltration, the treated groundwater is pumped into trenches lined with gravel and
allowed to percolate into the soil. A positive hydraulic head is the driving force behind the
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system, as opposed to an active pumping system injecting the water into the subsurface. The
success of this method is dependent on vadose zone acceptance of the treated water. Area
soils are Candor series soils which are described as excessively drained sandy soils (ERM-
Southeast, 1992). Regional percolation rates are site specific but range from 0.1 to 1.2 I gallons/day/fl2 and average 0.4 to 0.6 gallons/day/fl2 (Moore County Health Department,
September 1991). An approved method of percolation testing would be required to determine
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permissible application rates of treated water. The infiltration gallery must be located so that
recharge to the aquifer does not interfere with the performance of the extraction system. A non-
discharge permit issued by the NC Department of Environment, Health and Natural Resources
(NCDEHNR) would be required for this discharge option.
The feasibility of this technology is dependent on the extraction rate and the allowable application
rate for Site soils and suitable application areas. Based on a combined extraction rate of 20 gpm
and an average percolation rate of 0.5 gallons/dayttt2, approximately two acres of land would be
required for the discharge of treated groundwater (including buffer zone and a steady discharge
field). This much area outside the influence of an extraction system is generally not available at
the Site. Less area could be required based on higher percolation rates and the design of a high
recharge system (e.g., Infiltrator™ type system). Actual area requirements can only be
determined through site-specific percolation testing. Infiltration galleries will be retained
provisionally pending a final determination of the allowable application rates.
2) Injection Wells
Treated groundwater could be discharged to the subsurface environment by injection wells.
Although underground injection is a proven technology for treated groundwater discharge, the
State of North Carolina prohibits its use (G.S. 143-214.2(b)). This technology will not be retained
for further evaluation.
3) Surface Water Discharge
Surface water discharge may include the discharge of treated groundwater into a stream, river,
or surface water body. Surface water discharge would require a National Pollutant Discharge
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Elimination System (NPDES) permit. No storm sewer, nor any sizable stream, river or surface
water body capable of receiving treated groundwater Is known to exist within 1-1 /2 miles of the
Site. Discharging treated groundwater to Pages Lake, the nearest surface water to the Site,
would require the construction of a force main and lift stations that would create utility, traffic and
aesthetic concerns within residential neighborhoods and the Aberdeen business district during
construction. This option would require considerably more time to implement and would be
considerably more costly than other discharge options. Surface water discharge will not be
retained for further evaluation.
4) Publicly Owned Treatment Works (POTW)
The Moore County Sanitary Sewer Authority (MCSSA) is responsible for processing municipal
waste for local townships, including Aberdeen. The wastewater treatment facility or POTW that
would receive Site effluent is located in Pine Bluff, NC. Processes at the Moore County POTW
include dual stage activated sludge treatment, anaerobic sludge digestion and chlorination.
Discharges to the POTW must achieve the sewer use ordinance limitations presented in Table
5.2. Discharge of treated groundwater to the Moore County POTW would offer no advantage for
treatment as discharge limits for effluent pesticide concentrations are SW-846 method 8080
quantitation limits. Initially, effluent pesticide concentrations would be monitored monthly and
all other parameters monitored quarterly. A quarterly monitoring frequency for effluent pesticide
concentration may be negotiated after demonstrating successful treatment of the groundwater.
Additionally, bench scale toxicity testing of the treated groundwater may be required which could
affect concentration based discharge limitations. The type of bench scale toxicity testing would
be at the discretion of the systems superintendent. The MCSSA facility permit will be renewed
in April, 1992 and discharge limitations could be revised at this time.
Preliminary discussions with the MCSSA systems superintendent indicate that the MCSSA
treatment facility has sufficient available capacity to accommodate projected Site groundwater
extraction rates. The systems superintendent is responsible for classifying the discharge as a
significant industrial discharge (SID). If the treated groundwater is considered a SID, it must be
permitted as such by the systems superintendent.
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The closest manhole servicing the Aberdeen municipal sewer is located approximately 1 /2 mile
west of the Site at Central Drive and Highway 211. Discharge to this manhole would require
construction of a force main with lift station across Highway 211 and the Aberdeen & Rockfish
railroad tracks. New discharge lines would require non-discharge permitting by the NC
Department of Environment, Health and Natural Resources. Discharging treated groundwater to
the MCSSA treatment facility is a technically feasible discharge option. Capital costs for
construction of the discharge line would be substantially less costly and less disruptive of public
services than for the surface water discharge option. Groundwater discharge to the Moore
County POlW will be retained for further consideration.
5.3.4 Groundwater Containment
Subsurface barriers are used to minimize off-site migration of contaminants in groundwater by
installing low-permeability cut-off walls or diversions below ground to contain, capture, or redirect
groundwater flow in the vicinity of the Site. These methods can be used in conjunction with
groundwater recovery technologies to influence hydraulic gradients to minimize off-site
contaminant migration .
Slurry Walls
Slurry walls are the most common subsurface barriers at hazardous waste sites because they
can vastly reduce groundwater flow in unconsolidated earth and are readily constructed.
Additionally, they provide a means ofestablishing hydraulic gradient control when combined with
groundwater or leachate extraction systems to reduce contaminant mobility. Slurry walls are
almost always used in conjunction with other means of containment or treatment. Generally, they
are constructed in vertical trenches that are excavated under a slurry. For a typical soil-bentonite
installation, the slurry hydraulically shores the trench walls to prevent collapse while forming a
filter cake on the trench walls to minimize fluid losses into the surrounding soils. An appropriate
backfill is added to complete the installation. Alternate installation methods including the B-P
trench construction method discussed in Section 5.3.1-2, Interceptor Trenches and Subsurface
Drains, are also available that will be considered with this technology. Depth to the uppermost
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confining layer or aquitard across the Site is approximately 40 to 70 feet. Excavation to these
depths is achievable using the B-P trenching technique.
Design parameters for slurry walls include vertical depth and horizontal placement. Walls that
extend into a low permeability zone are called keyed and those that extend partially into the
water table are called hanging. Hanging walls are used to control contaminants which float on
top of the groundwater. Since the contaminants at this Site can disperse throughout the water
table, keyed slurry walls are the only type requiring further consideration. For application at this
Site, the slurry wall would be keyed into the uppermost aquitard layer.
Considerations for the various slurry wall configurations are generally Site specific. Slurry walls
can be isolated upgradient or downgradient of the groundwater contaminant plume or can
completely surround the plume. Upgradient walls are used with drains to divert uncontaminated
groundwater away from the waste area and down to a receiving body. Groundwater gradients
must be properly managed to prevent groundwater from flowing over or behind the wall.
Downgradient walls are used as a barrier of flow of contaminated groundwater, allowing recovery
or treatment via extraction wells. Circumferential walls are used to isolate an area of
contamination, usually with an impermeable surface barrier. A groundwater collection system can
be used to selectively direct groundwater flow. This extraction of groundwater may create
differential hydraulic pressure across the wall, which must be allowed for in design.
Circumferential walls are the most expensive but offer the most extensive control of contaminant
migration. A circumferential slurry wall used in conjunction with a low permeability cap and a
groundwater collection system would be considered to contain contaminated groundwater in the
uppermost aquifer by maintaining an inward hydraulic gradient across the slurry wall. Site-
specific limitations of these technologies are discussed below.
Slurry walls can be constructed of soil-bentonite (SB), cement bentonite (CB), or reinforced
concrete sections (diaphragms). In general, SB walls have the lowest permeability and the widest
range of waste compatibilities. SB admixtures may include proprietary formulations to enhance
chemical compatibility. Preliminary testing of the backfill material with actual Site groundwater
should be performed to determine suitability for use.
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Diaphragm walls are reinforced concrete panels which are emplaced by slurry trenching
techniques. Diaphragms may be cast-in-place or pre-<:ast, and are capable of supporting great
loads. Because diaphragm walls are constructed in slurry-filled trenches, it is possible to include
them in CB or SB walls for short sections, such as road or rail crossings that require their greater
strength. H joints between diaphragms are made correctly, diaphragm walls can have
permeabilities comparable to CB walls (EPA, October 1985).
Capping offers proven protection against infiltration to the groundwater. For this application, a
low permeability cap constructed over the entire area within the circumferential slurry wall would
be required to minimize recharge of the contained groundwater (Figure 5.3). Operational
considerations include the need for long-term maintenance and uncertain design life. Synthetic
liners supported by a low permeability base may last over 1 00 years.
A groundwater collection system would be required to maintain an inward hydraulic gradient
across the slurry wall to prevent off-site migration of Site groundwater in the uppermost aquifer.
Well point extraction using extraction wells is commonly used for this purpose at other sites and
is discussed in Section 5.3.1. Extracted groundwater would require treatment prior to disposal .
Treatment and disposal technologies are presented in Sections 5.3.2 and 5.3.3 respectively.
The integrated cap and slurry wall system would not control groundwater in the uppermost
aquifer in the vicinity of MW-1 OS or in the second uppermost aquifer in the vicinity of MW-11 D.
Implementation of the cap/slurry wall system would also require dedicated extraction wells at
MW-1 OS and MW-11 D for complete groundwater control.
The use of slurry walls in conjunction with capping and groundwater recovery is a technically
feasible alternative for containment of contaminated groundwater in the surficial aquifer. The use
of slurry walls, capping and well point extraction will be retained for further consideration.
5.4 EXPOSURE CONTROL SCREENING
Exposure control measures address Site surficial soils containing residual chemical
concentrations that are above calculated remediation levels based on the acceptable exposure
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levels range of 1 o-4 to 1 o-6 lifetime excess cancer risk (LECR). These soils were identified in
Section 4.2.2 and are summarized below:
• Site soils represent a current risk of 1.0 x 1 o-6 and a potential Mure risk of 2.2 x 1 o-5. No
further remediation is required to achieve an LECR of 1 o-4.
• Soils requiring remediation to achieve a LECR of 1 o-5 are surficial soils (surface to 1 foot)
shown in Figure 4.2 comprising approximately 140 cubic yards
• Soils requiring remediation to achieve a LECR of 1 o-6 are surficial soils shown in Figure
4.1 comprising approximately 670 cubic yards.
Since there are no concentration based ARAR's for site surficial soils, remedial efforts will be
directed toward elimination of routes for direct exposure. Efforts to control exposure to surficial
soils involve two general strategies: either remediate the soils to achieve health-based standards
or isolate the soils, thereby eliminating direct routes of exposure and reducing the potential risk
posed by the soils to acceptable levels. Exposure control technologies involving treatment to
achieve health-based concentrations in soils prior to on-site placement must be capable of
reducing soil toxaphene concentrations to 5 mg/kg and 50 mg/kg to achieve a LECR of 1 o-6 and
10-5, respectively.
Site subsurface soils were found to pose no significant risks to human health or groundwater
(Section 4.1.3.2). Consequently, remedial measures were not deemed necessary for subsurface
soils.
The foundation of the former on-site warehouse will be removed if natural soils beneath the slab
require remediation. The foundation is composed of a concrete slab, 6 to 8 inches thick, that
is supported by cinder blocks and off-site fill dirt. Foundation removal would occur if soil
remediation to achieve a LECR of 1 o-6 is required as two soil samples from beneath the
foundation contained toxaphene concentrations in excess of 5 mg/kg (Figure 4.1 ). Up to 400
cubic yards of concrete debris could be generated if the foundation had to be removed.
Removal of the foundation is not required to meet ARARs or to protect human health and the
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environment. Disposal of foundation debris will be discussed in conjunction with soil remediation
technologies, where appropriate.
Technologies retained after this screening will be used to develop remedial action alternatives.
5.4.1 Direct Treatment
Direct treatment refers to excavating contaminated soils and performing any necessary
pretreatment steps, such as sizing and/or shredding, followed by on-site treatment to achieve
health-based concentrations and subsequent on-site placement. Excavation will be required prior
to application of all direct treatment technologies. Control of dust and vapors during excavation
would be necessary to adequately protect human health and the environment. Excavated soils
would be staged in a secure holding area prior to on-site treatment. Evacuation requirements
for Site soils immediately adjacent to Highway 211 and the Aberdeen & Rockfish railroad could
pose potential limitations on the implementability of direct treatment technologies due to right-of-
way considerations, but these would be limited due to the shallow excavations required.
Construction within State Highway 211 or the Aberdeen & Rockfish railroad right of ways requires
preapproval by the NC State Highway System and the Aberdeen & Rockfish railroad, respectively.
A major limitation to the development of direct treatment alternatives for the Geigy Site is the
limited volume of soils potentially requiring remediation. The maximum volume of soils for
remediation is approximately 670 cubic yards, based on a risk level of 1 E-06 (Section 4.1.3.2).
Typical volume requirements necessary to amortize the front end costs associated with the
permitting, mobilization, utility connections, equipment, site work, materials, labor, temporary
facilities, and demobilization of an on-site remediation process are in the range of 5,000 to 10,000
cubic yards. Without a sufficient "critical mass", vendors are generally unwilling to obligate their
equipment for such a short processing period and the unit costs become unfavorable as
compared to fixed (i.e. off-site) facilities.
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1) Biological Treatment
Biological treatment uses indigenous or introduced aerobic bacteria to biodegrade organic
compounds in soils or groundwater. Biodegradation has been used for only limited full-scale
applications to date. Two different methods of utilizing biodegradation to reduce chemical
concentrations In soils to acceptable levels are considered: land treatment and use of a
bioreactor.
Land Treatment
Land treatment involves excavation and placement of contaminated soils into a lined waste pile
where the soils are irrigated and nutrients are applied. Contaminants can potentially be
biodegraded by indigenous and introduced bacteria. Key parameters for this type of treatment
include adequate aeration, optimum temperature, pH, moisture and nutrient contents, and the
presence of the appropriate microbial population. Land treatment would require regular
maintenance for tilling moisture control, fertilization, etc. Contaminated leakage may require
treatment and therefore must be collected when utilizing this treatment method. An evaluation
of off-gasses is warranted.
Land treatment would not be a suitable alternative to remediate Site soils as many chlorinated
pesticides including BHC isomers and DDT require anaerobic conditions before reductive
dechlorination can occur. Reductive dechlorination of these compounds must occur first before
aerobic metabolism of the intermediate compound can occur (EPA, September 1986). Land
farming fosters aerobic biodegradation of organic compounds only. Land farming will not be
retained for further consideration.
Bioreactor
Biodegradation can be performed on excavated soils and sediments in the form of a slurry fed
to a bioreactor. Microbes in the reactor are supplied with required growth factors, and nutrients.
A typical soil slurry is approximately 20% to 30% suspended solids by weight. Bioreactor
' residence time varies depending on the physical/chemical nature of the contaminant. A by-
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product of the slurry-phase treatment process is residual water from the slurry dewatering
process, which may require treatment prior to disposal. An evaluation of off-gas generation
would be required to determine whether treatment of off-gasses is required.
Successful biodegradation of chlorinated pesticides, including BHC isomers and DDT, would
require sequential anaerobic/aerobic bioreactor systems. The anaerobic system would be
required to support reductive dechlorination of the pesticides before aerobic metabolism of the
intermediate by-products could proceed. Although both anaerobic and aerobic bioreactor
systems are available, monitoring and managing sequential anaerobic and aerobic processes
could not be effectively controlled. Bioreactor technologies will be removed from further
consideration based on effectiveness and implementability.
2) Chemical Extraction
Chemical extraction is a physical transfer process from which contaminants are disassociated
from the soil, becoming dissolved or suspended in a liquid solvent. Chemical extraction
processes generally separate contaminated soils into the following phase fractions: organics,
water, and particulate solids. The resulting liquid waste stream then undergo subsequent
treatment to remove the contaminants and then the solvent is recycled, if possible. Three
representative chemical extraction technologies are liquid carbon dioxide (CO2) extraction, critical
fluid solvent extraction and the BEST process. These technologies _will be considered for
remediation of Site soils.
Supercritical CO2 Extraction
Certain gases may become solvents for removing organic from solids and aqueous solutions
when they are kept at supercritical conditions. Liquid carbon dioxide is the most commonly used
solvent. The organic contaminants are extracted from the soil by the liquid carbon dioxide and
recovered when the carbon dioxide is volatilized. The carbon dioxide can then be recycled
following recompression. In order to use this technology for soils or soils treatment, the material
must be slurried so it can be pumped into the unit. Preparation of soil materials into a suitable
slurry could be a potential problem associated with this process.
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An EPA study found supercritical CO2 extraction to give poor recoveries of adsorbed organics
from activated carbon and synthetic resins (EPA June, 1986), which may reflect the efficacy of
the process of other solid residuals. Another EPA study found this process to have removal
levels greater than 40 percent for only 4 of 23 organic compounds tested (Ehntholt, D.J., 1985).
The authors theorized that low removal efficiencies may have been due In part to an ineffective
trap system (volatiles) and adsorption on the extraction system (hydrophobic solutes). Although
pilot tests have been conducted with this type of technology, no full-scale operations have been
applied. Therefore, supercritical CO2 extraction is not considered further.
Critical Fluid Solvent Extraction
Critical fluid (CF) solvent extraction used liquified propane and/or butane to extract organic
contaminants from soils. Propane and butane, which are gasses at standard temperature and
pressure (STP), are liquified at supercritical conditions. The CF solvent (liquified propane and/or
butane) is passed through contaminated soils in a counter current extractor, making non-reactive
contact with the soil. The organic contaminants are extracted from the soil by the CF solvent
which passes from the extractor into a separator via a pressure reducing valve. In the separator,
the CF solvent is vaporized and recycled, while the organic contaminants are drawn off as a
concentrate for further treatment or disposal (USEPA -The Superfund Innovative Technology
Evaluation Program Progress and Accomplishments Fiscal Year 1989).
Critical fluid solvent extraction has been successfully demonstrated under EPA's Superfund
Innovative Technology Evaluation (SITE) Program at the New Bedford Harbor Site in
Massachusetts where PCB's were extracted from sediments. Critical fluid solvent extraction
technology, however, has not yet been demonstrated for the removal of pesticides from soils.
Additionally, no full-scale application of critical fluid extraction has been conducted at a
Superfund site (C.F. Systems Corp., 1992). Although critical fluid solvent extraction is a
promising technology for the removal of pesticides from soils, it lacks sufficient development and
will not be retained for further consideration.
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BEST Process
Another extraction technique which has been developed is called the "BEST" (Basic Extraction
Sludge Technology) Process. It uses aliphatic amines, usually triethylamine (TEA), to break down
suspensions and emulsions in sludges and contaminated soils. The BEST process consists of
two stages, a cold stage followed by a hot stage. In the cold stage, soils are mixed with the
refrigerated extractant to form a mixture at about 40"F. Under these conditions, TEA is
simultaneously miscible with many organics and water. After an appropriate residence time is
completed, the solids in the mixture are removed by centrifugation and then dried to remove
residual TEA. Precipitated metal oxides formed due to the alkaline nature of the extractant are
removed with the solids. The liquid is then heated in the hot stage which reduces the TEA
solubility in water. The resulting TENorganic phase is decanted from the water phase and the
TENorganic phase is sent to a stripping column where the TEA is recovered and the organics
are discharged. The TEA is then recycled back into the treatment process. Disposal of the
waste phase produced would be required.
The BEST process has reportedly been effective at remediating soils for pesticides at a site in
California. Bench scale testing using soils from the site indicated that soils containing pesticide
concentrations in excess of 1000 ppm could be remediated to levels of less than 1 ppm
(Resource Conservation Company, 1991 ). However, no full-scale application of the BEST
process has been conducted at a site impacted by pesticides. Due to its limited development,
the BEST process will not be retained for further consideration.
3) Supercritical Water Oxidation
Supercritical water oxidation is a technology that oxidizes organic contaminants in a water
medium at temperatures and pressures that were supercritical for water (i.e. >374°C [705°F) and
218 atmospheres). In the supercritical region, oxygen and organic compounds become totally
miscible with the supercritical water and inorganic compounds, such as salts, become less
soluble. When subjected to the supercritical water oxidation process, organics are oxidized and
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any inorganic salts are precipitated from the supercritical water. The oxidation reaction proceed
rapidly (<1 minu1e) and completely, transforming organic compounds into carbon dioxide and
water.
The process is being developed by MODAR, Inc. of Natick, Massachusetts. Application of the
MODAR process has been limited to pilot level testing (500 gpd) on aqueous wastes and
sludges. A full-scale MODAR system has not yet been built and the current design is being
revised. The effectiveness of supercritical oxidation processes toward soils is not sufficiently
demonstrated for application at the Site. This technology is rejected from further consideration.
4) Soil Washing
Soil washing is a method of extracting contaminants from excavated sludge or soil using a liquid
such as water as the washing solution. Soil washing is similar to the in-situ process of soil
flushing, which is essentially the same process except soil washing is performed on excavated
soils which are fed into a processing unit.
Washing liquids can be water, organic solvents, water/heating agents, water/surfactants, acids,
or bases. Selection of the washing solution is based on characteristics of the contaminants and
of the soil. Bench-scale testing would be necessary to select the appropriate surfactants and
dosages for specific applications. The washing solution is then treated to remove contaminants
via a subsequent wastewater treatment system, although the presence of the extraction solu1ion
may complicate treatment of the contaminants. Some soils may require multiple washing cycles
for effective contaminant removal.
Review of the literature indicates that the majority of full-scale research on soil washing is being
performed in Europe (The Hazardous Waste Consultant, May/June 1989) and the availability of
U.S. vendors is limited. Soils treated in the European studies have been used in asphalt mixtures
or sent to landfills. Soil washing, however, is one of the remedial technologies selected in a June
1991 record of decision (ROD) involving a California pesticide formulation facility where as many
as 50 pesticides including DDT, and toxaphene impacted the site. The washed soils are to be
returned to the site (Inside EPA's Environmental Document Service, July-September 1991 ).
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Soil washing was also conducted using a demonstration unit at a non-CERCLA site in Arizona
that was contaminated with pesticides including DDE, DDT and toxaphene. ECOVA Corporation
reports that DDE and DDT concentrations were reduced from 165 ppm to 4 ppm (98% reduction)
during field applications of their soil washing technique. Toxaphene concentrations at the site
were also reduced from 113 ppm to 4 ppm, a 96 percent reduction (ECOVA Corporation, 1991 ).
Based on the referenced case studies, soil washing appears to be a promising technology for
the remediation of soils containing pesticides. The application towards a given site would
depend on soil type and the constituents requiring remediation. Chemical partitioning dictates
that the majority of contaminants partition to the smallest particles (those with the greatest
surface area per volume). Conversely, soil washing is least effective for fines (e.g., silts, clays)
and these materials are typically segregated for separate treatment. Treatability testing would
be required to determine the fraction of soils amenable to soil washing and the removal
efficiencies for the remaining soils prior to design and full-scale implementation.
Soil washing, like other direct treatment technologies, requires a sufficient volume of materials
("critical mass") to warrant mobilization and operation of a commercially available unit. Soil
washing systems operate at a nominal throughput of 20 to 50 tons per hour (Biotrol, 1991 ). the
maximum volume of soils potentially requiring remediation at the Site is approximately 670 cubic
yards, which is equivalent to 870 tons. Based on an average service factor of 70 percent, the
Site soils would be remediated within approximately two days. This duration of treatment is
insufficient for a potential vendor to mobilize, install utilities, establish treatment processes, permit
and demobilize their system. Soil washing is therefore rejected from further consideration on the
basis of implementation.
5) Stabilization
Stabilization is a treatment process designed to improve the handling and physical characteristics
of the waste, decrease the surface area of the waste material across which transfer or loss of
contaminants can occur, and/or limit the solubility of any hazardous constituents of the waste.
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Stabilization involves the addition of materials which limit the solubility or mobility of waste
constituents with or without change or improvement in the physical characteristics of the waste.
Stabilization processes can be performed In-situ or on excavated materials depending on Site
conditions. There are various types of stabilization agents which can be used based on the
contaminants of concern. The most common agents used are cement and silicate-based.
Cement-based stabilization involves mixing the waste directly with Portland cement. Silicate-
based stabilization use siliceous materials such as fly-ash, blast furnace slag or other pozzolanic
materials together with lime, cement, gypsum or other setting agents. Cement-based and
silicate-based stabilization increase the weight and volume of the original material thereby,
increasing the space requirements for waste disposal. Both technologies are frequently used to
treat soils contaminated with inorganic compounds, as organic compounds can physically
interfere with matrix bonding and are subject to leaching from the stabilized material (EPA, May
1989).
In general, stabilization technologies are not considered an appropriate form of treatment for soils
representing risks due to indirect contact. Treatment by means of stabilization would not
significantly reduce the concentration of pesticides in Site soils. Consequently, the stabilized
product would be unsuitable for placement on-site as health-based concentrations required for
site surficial soils would not be achieved. For effectiveness reasons, stabilization of Site surficial
soils will not be retained for further consideration.
6) Transportable Incineration
Incineration is a demonstrated treatment technology for the removal of organic compounds from
soils. Quantitative reduction of organic chemicals in soils has been consistently achieved by
incineration. Some of the Site soils recovered during the Phase 2 removal action (October 1989)
were incinerated at an off-site facility (Rollins, Deer Park, TX). Incineration technologies are
capable of achieving required remediation levels by permanently destroying residual pesticides
in surficial soils and is the best demonstrated available technology (BOAT) for treating toxaphene
and gamma-BHC solid wastes.
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The assessment of appropriate and available technologies among the many kinds of incinerators
must be conducted. Transportable incineration technologies primarily used for remedial
application include rotary kiln incineration, infrared thermal treatment, and fluidized bed
incineration. The assessment of each technology must be based upon individual considerations
as they pertain to specific applications.
A primary consideration common to all transportable technologies is the trial burn demonstration
requirements. Elements of the trial burn process include (EPA, January, 1987}:
• Prepare trial burn plan and submit to Federal and State agencies (required 6 months
after notification).
• Prepare responses to any questions or deficiencies in the trial burn plan (1 month).
• Make any additions or modifications to the incinerator that may be necessary (1 to
3 months).
• Prepare for trial burn.
Prepare for all sampling and analysis (S&A) (2 to 3 months).
Select date for trial burn, in concert with S&A staff or contractor (completed
1 month prior to test).
Notify all appropriate regulatory agencies (1 month).
Obtain required quantities of waste having specified characteristics (est. 2
months).
Calibrate all critical incinerator instrumentation (2 weeks).
• Conduct trial burn sampling (1 week).
• Conduct sample analysis (1 to 1-1/2 months).
• Calculate trial burn results (1/2 month).
• Prepare results for submittal to EPA (1 /2 to 1 month). Include requested permit
operating conditions.
• Obtain permit to accept candidate waste (3 months).
The total process requires approximately 20-24 months.
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Transportable incinerators are currently in use and planned for use at a number of CERCLA sites.
The mobilization, trial burn and demobilization requirements are such that a significant portion
of the time and costs associated with on-site incineration are outside of actual treatment. The
demand for incineration and logistics regarding on-site applications have combined to create a
severe shortage of incineration capacity. The demand is further exacerbated because there are
but a handful of firms with incineration experience at CERCLA sites. Land disposal restrictions
based on incineration were given a two year extension because of this capacity shortage. The
net result is that it is not technically or economically feasible to mobilize an on-site incinerator to
a site unless there are at least 10,000 cubic yards of material (Chemical Waste Management;
July, 1991), with exceptions for especially toxic residuals. Site soils requiring remediation
comprise only approximately 670 cubic yards or 870 tons (1 o-6 LECR), significantly less than that
necessary to access a transportable incinerator. Transportable incinerators typically have a
nominal throughput of 5-1 0 tons/hour. The 690 tons of soils requiring remediation would
therefore be processed in less than ten days. This short period is out of proportion to the time
required for a trial burn and represents a utilization rate of less than two percent. Major
incineration vendors will not obligate their equipment for such a short period of actual
remediation. The economics are also unfavorable, since the mobilization, start up and trial burn
costs must be spread over such a limited volume of materials. Additionally, the available area
at the site to locate a mobile incinerator and peripheral equipment would be restrictive. This
technology is therefore rejected from further consideration on the basis of implementation.
7) Thermal Desorption
Thermal Desorption removes organic compounds from soils by mixing the soils in the presence
of a stream of heated air or indirectly contacted with a heated fluid to volatize and remove
organic contaminants from the soils. Treated soils would be returned to the site. Three
proprietary thermal technologies include Low Temperature Thermal Aeration (LTTA) by Canonie
Environmental, the X*TRAX system by Chemical Waste Management, Incorporated and Low
Temperature Thermal Treatment (LT3) by Weston Services, Incorporated.
Soils suitable for thermal desorption must be appropriately sized and preferably of low moisture
content. Soil sizing requirements range from 1-inch to 3-inches in diameter for the X*TRAX and
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L TT A technologies, respectively. X*TRAX uses grinders to reduce the size of soil particles to
meet sizing requirements. Soils with relatively high moisture content require longer residence
times to drive off any water which would inhibit the desorption and volatization of organic
compounds from soils.
Thermal desorption technologies are only effective for the removal of organic compounds with
boiling points less than the treatment operating temperatures. Operating temperatures of the
thermal desorption technologies vary, but range from 350°F (177°C) for LTTA, 450°F to 750°F
(232°C to 399°C) for X*TRAX and 650°F (343°C) for the LT3 technologies. The boiling points of
pesticides detected in Site soils range from 60°C for beta-BHC to 323°C for gamma-BHC. Based
on system operating temperatures and the boiling points of pesticides in Site soils, the X*TRAX
and L T3 thermal desorption technologies may be an effective alternative for the removal of a
number of the chemical residuals from Site soils.
Mobilization, demobilization and permitting requirements for thermal desorption technologies are
extensive, requiring a significant portion of time outside of actual treatment time. The estimated
time for permitting (or permit equivalency), mobilization, soil treatment (based on a nominal
throughput of 5 tons/hours) and demobilization are presented below:
• Permitting 5 to 8 months
• Mobilization and setup 2 to 7 weeks
• Soil processing 1 to 2 weeks
• Demobilization 3 to 7 weeks .
Thermal desorption technologies, like transportable incinerators, are currently in use and planned
for use at a number of CERCLA sites. The demand for thermal desorption technologies and
logistics regarding on-site applications have combined to create a severe shortage of thermal
desorption capacity. It is therefore not technically or economically feasible to mobilize a thermal
desorption unit to a Site unless there is at least 10,000 cubic yards of material (Chemical Waste
Management, June 1991). Site soils requiring remediation comprise a maximum of only
approximately 670 cubic yards. Based on a lower end throughput of 5 tons per hour and a
nominal service factor of 70 percent, the maximum volume of site soils (10-6 LECR) would require
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less than ten days of treatment. Vendors will not obligate their equipment for such a limited
performance period. Therefore, application of thermal desorption technology at this Site is
insufficient, for reasons similar to those given for transportable incineration (low utilization rate,
poor economy of scale).
Although thermal desorption is potentially effective toward remediating soils containing pesticides,
the volume of Site soils requiring remediation cannot justify its application at this Site. Thermal
desorption technologies are therefore removed from further consideration based on
implementation considerations.
8) Classification
Classification refers to the segregation of soils based on particle size. Classification can be used
as a pretreatment step to differentiate heterogeneous soils when there exists a chemical
partitioning based on soil size and/or type. Organic chemicals will preferentially partition to the
finer particle sizes, such as silts and clays, because of their greater adsorption capacity (Olsen
and Davis, 1990). Along with organic matter, clay is the most important soil component with
respect to the adsorption of pesticides (Dragun, 1988).
Soils at the Geigy Site contain approximately 25-30 percent silts and clays (ERM-Southeast,
1992). The remaining soils are primarily sands, which can be readily segregated from the soil
matrix. Based on physical/chemical partitioning, the majority of pesticide mass should be
concentrated on the finer particles. This partitioning can be evaluated by performing a gradation
of site soils by discrete sieve sizes and conducting a pesticide analysis on the resulting soil
fraction. Those soil fractions that exceed the Site cleanup levels (1 o·5 and 1 O~ LECR would be
remediated while those already satisfying the cleanup levels could be returned to the Site.
Treatability testing would be required during Remedial Design to establish the efficacy of
classification for Site soils. Classification would be conducted using standard construction
equipment, such as vibratory screen. Dust control would be conducted to control any fugitive
emissions. Classification is provisionally retained as a pretreatment technology pending
successful treatability testing.
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5.4.2 In-Situ Treatment
In-situ treatment for soil remediation is performed without excavation, using the soil matrix as the
treatment zone. A limitation of in-situ technologies is the minimal zone for treatment (one foot).
In-situ remedial technologies, however, generally require longer periods of time to attain desired
clean up levels than intrusive remedial options. Potential in-situ treatment options Include soil
vapor extraction, enhanced biodegradation, soil flushing, and soil vitrification.
(1) Soil Vapor Extraction
Soil vapor extraction (SVE) involves the removal of volatile organics from the soil matrix by
mechanically drawing or venting air through the unsaturated soil layer. As air is pulled through
the soil, the equilibrium that exists between the organic compounds distributed on soil particles,
in soil moisture, and in soil gas is disturbed. Soil gas containing volatized organic compounds
is replaced by fresh air, causing a redistribution of volatile organics from soil particles and soil
moisture into the soil gas. Air emissions may require further treatment before they are vented
to the atmosphere. Soil moisture will be entrained in the extracted soil gas, initially in high
volumes, until content in the affected soils is reduced by the SVE process. The moisture would
typically be collected for further treatment.
SVE is more suited towards remediating subsurface soils where a vacuum can easily be
generated and maintained. Generating and maintaining a vacuum in the surficial foot of soils
would not be a technically effective use of SVE. Furthermore, pesticide residuals in Site soils are
not amenable towards SVE due to their low Henry's law values (Terra Vac, 1991 ). For these
reasons, SVE will not be retained for further consideration based on effectiveness considerations.
2) Enhanced Biodegradation
In-situ biodegradation involves enhancing the naturally occurring microbial activities found in
subsurface soils. Breakdown and removal of contaminants can be accelerated by the addition
of oxygen, inorganic nutrients, and prepared microbial populations. This technology has been
developing rapidly and is one of the most promising in-situ treatment techniques.
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Enhanced biodegradation does not allow for positive control of intermediate by-products formed
resulting from microbial decomposition of contaminants. By-products of some organic
compounds are more toxic and/or mobile than the parent compound, thereby compounding the
threat posed by contaminant residuals in soils.
Biodegradation of chlorinated pesticides, including BHC isomers and DDT, require anaerobic
conditions for reductive dechlorination to occur. Reductive dechlorination of these compounds
must occur before aerobic biodegradation of reductive dechlorination by-products can occur.
Although anaerobic/aerobic degradation of pesticides and their metabolized by-products may
occur naturally, control of sequential anaerobic/aerobic conditions within the upper foot of soil
would prove impractical. Enhanced biode.gradation is removed from further consideration based
on technical considerations.
3) Soil Flushing
Soil flushing is a method of extracting contaminants from unexcavated soils using an
injection/recirculation system. Flushing of contaminated soils occurs upgradient of the
groundwater extraction system that intercepts and recirculates the flushing fluid. The extracted
groundwater is treated and the clean water is passed back through the contaminated soil.
Potential flushing fluids include water, acids, bases, water/chelating agents, water/surfactants,
and organic solvents. Selection of the optimal washing fluid is based on characteristics of the
contaminants and of the soil. If surfactants or chelating agents that pose environmental risks are
added, they also must be removed for complete remediation.
General difficulties facing effective implementation of surfactant-assisted soil flushing include the
need for intensive soil contact followed by thorough collection of leachate. For effective soil
flushing, soils should be consistent, permeable, and contain only a few specific contaminants.
Site soils are relatively homogeneous from the ground surface to the uppermost aquitard,
consisting of loosely compacted silty/clayey and gravelly sand. Sandy soils such as those at
the Site have characteristically high permeabilities ranging from 4.2 x 1 o-5 to 1.4 x 10·2 cm/sec
(ERM-Southeast, 1992). Soil conditions appear to be amenable to soil flushing. Conversely, site
pesticides have high organic carbon portioning coefficients (Koc) that result in a strong affinity
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to soils. Soil flushing would be expected to have limited effectives towards the high Koc
pesticides at the Site.
The greatest concern regarding soil flushing is that mobilized contaminants would not be
completely recovered by the extraction system and therefore degrade groundwater conditions.
Furthermore, site related pesticides have relatively high Koc values, making them difficult to
remove from soils. For effectiveness reasons, soil flushing is removed from further consideration.
4) Vitrification
In-situ vitrification is a process of melting contaminated soils in place to bind the waste in a
glassy, solid matrix resistant to leaching and more durable than graphite or marble. It was
originally developed for treatment of radioactive wastes, although it has potential for use with
soils contaminated with heavy metals, inorganics, and organic wastes.
The process consists of placing electrodes in the soil and constructing trenches filled with a
flaked graphite and glass frit mixture to connect the electrodes in an "X" pattern. Voltage is then
applied to the electrodes and the graphite/glass frit mixture is quickly heated to 3600°F, which
is well above the melting point of soil (2000 to 2500°F). A molten zone expands horizontally and
vertically to encompass the volume between the electrodes. As the soil melts, organic wastes
are pyrolized and combust when they come in contact with air. The high temperatures at the
surface cause virtually complete combustion of the organics in the gases. Hazardous
compounds that do not volatilize remain in the molten soil and become part of the glass and
crystalline product after cooling. Non-combusted volatiles are collected in an off-gas hood for
treatment. When the desired vitrification depth is reached, the electrodes are turned off and the
soils are allowed to cool.
In-situ vitrification tests have been completed on an engineering scale (0.05 -1.0 tons of soil),
a pilot-scale (1 0 tons of soil) and a large-scale (400 to 800 tons of soil). Test results have shown
that 99.99% of volatile heavy metals are trapped in the vitrified mass or removed by the off-gas
system. Bench-scale results for PCB-contaminated soils showed overall destruction and removal
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efficiencies (DRE's) of >99.99% and tests on soils contaminated with 2, 3, 7, 8 -TCDD give
similar results.
Although soil vitrification appears to be a promising technology, a fire occurred in a soil
vitrification system during a recent large-scale test at a Superfund site. The sole marketer of the
in-situ vitrification technology has since announced that all large-scale commercial use of the
technology will be suspended indefinitely due to technical problems. Additionally, EPA Region
VI has withdrawn its order to use in-situ vitrification at a Texas Superfund site (Inside EPA's
Superfund Report, 1991 ). Since soil vitrification technology requires further development, It will
not be retained for consideration at this Site.
5.4.3 Off-Site Treatment or Disposal
Remediation of contaminated soils and residual materials can potentially be handled at an off-site
facility.
Off-site treatment and disposal options are typically most effective when an immediate response
is required, the blend of site contaminants presents special treatment concerns, or there is a
limited volume of materials to be remediated. Off-site options are least effective for large volumes
of materials, because of capacity limitations and cost. Current site conditions do not warrant an
immediate response and the only constituents to be remediated are chemically similar
(pesticides). However, the limited volume of soils requiring remediation limits the availability of
on-site technologies. The limited volume of Site soils would not impinge on capacity limits and
could be handled in a cost-effective manner. The transportation, disposal and/or treatment of
materials from a CERCLA Site to an off-site facility must comply with EPA's "off-site policy"
(OWSWER Dir. 9834.11 ). Off-site disposal may require additional efforts to comply with RCRA
regulations, if determined to be an ARAR. Another consideration for selection of off-site treatment
or disposal alternatives is the accessibility of the Site. Two off-site removal actions have been
conducted previously at the Site (Section 2.4).
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1) Commercial Landfilling
Site soil and debris have been disposed safely at the Laidlaw facility In Pinewood, SC and the
CWM facility in Carlyss, LA during previous removal actions (Section 2.4). Per EPA's off-site
policy, the receiving facility for CERCLA waste materials must meet the following criteria:
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no relevant violations at the receiving unit
no releases and previous releases must have been addressed
releases at other units must have been addressed .
Potential off-site RCRA-approved landfills include:
• Laidlaw -Pinewood, SC
• CWM -Emelle, AL and Carlyss, LA
• USPCI -Clyde, UT
Compliance with the off-site policy is an ongoing requirement. Potential receiving facilities would
be reviewed to ensure compliance prior to any removal actions .
Disposal of Site materials would also have to comply with any Land Disposal Restrictions (LDR;
40 CFR 268). LDR govern listed and characteristic waste materials. To be considered a listed
waste under RCRA, the following requirements must be met:
• exact identification of the original waste stream
• whether the material was off-specification or past expiration
• material must contain a chemical given in 40 CFR 261.33 as the sole active
ingredient.
EPA guidance requires there to be affirmative evidence that is "reasonably ascertainable" within
the scope of an RI/FS for a material to be considered a listed waste (OSWER Dir. 9347.3-05).
Such a finding cannot be supported by the historical site information or the RI data. The low
level of pesticides in Site soils are the result of incidental losses during various manufacturing
processes. Site soils therefore cannot be classified as a listed waste under RCRA.
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While not a listed waste, Site soils may be a characteristic waste if they fail the Toxicity
Characteristic Leaching Procedure (TCLP) analysis. TCLP standards exist for the following Site
constituents (EPA code in parentheses):
• gamma-BHC (D013)
• toxaphene (D015)
Site soils failing TCLP would have to satisfy LOR before they could be placed in a landfill.
Commercial landfilling of Site soils would be based on disposal at a RCRA Subtitle C facility. Soil
removal to achieve a 1 o-6 LECR would require demolition of a portion of the remaining building
formation. Pesticides below the foundation are attributed to formulation that occurred during
early operation on the eastern end of the Site as the facility expanded with the construction of
Warehouses A and B, the existing foundation was placed over the soils containing pesticides.
The concrete foundation is therefore not believed to contain significant pesticide residuals and
could be disposed at the Moore County municipal (Subtitle D) landfill. Confirmation testing (e.g.,
TCLP) would be conducted prior to actual disposal. Materials failing TCLP would be sent to a
Subtitle C landfill.
Disposal of Site soils at the Subtitle C landfill has been conducted successfully in the past and
will be retained for further consideration. Disposal at a municipal landfill will be retained for the
removal of any concrete foundation, pending confirmation testing.
2) Commercial Incineration
Commercial off-site incinerators capable of accepting soils are generally of the rotary kiln type.
The rotary kiln is a cylindrical refractory-lined shell that is mounted on a slight incline. Rotation
promotes movement of waste through the kiln as well as enhancement of waste mixing. Rotary
kilns can incinerate solids, semi-solids, and liquids independently or in combination.
Pretreatment requirements are generally less than those for other types of hazardous waste
incinerators. Incineration efficiencies are very high when the kilns are coupled with a secondary
combustion chamber, with combustion temperatures ranging from 1500 to 3000"F and residence
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times from a few minutes to hours. For these reasons, rotary kilns are the preferred method for
treating mixed hazardous solid residues.
Off-site incineration is cost-effective when applied to high concentration materials in relatively low
volumes. The maximum toxaphene in soils to be remediated is 220 mg/kg, a low value that
could minimize the need for incineration. The highest concentration materials were remediated
during the previous two removal actions. Soils potentially requiring incineration would be those
that exceed LOR based on failing the TCLP, a volume of up to 670 cubic yards (1 o-o LECR). This
volume is within the range that could typically be accepted at an off-site incinerator. Potential
off-site facilities include:
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CWM -Port Arthur, TX and Sauget, IL
Rollins -Deer Park, TX
ThermalKem -Rock Hill, SC
A facility would have to be in compliance with EPA's off-site policy (OSWER Dir. 9834.11) to
receive Site soils.
Current constraints regarding the application of off-site rotary kilns include available capacity and
the type of wastes that are acceptable. Soils are generally disfavored because of their high ash
content and low BTU value. Site soils were incinerated at an off-site commercial incineration I facility (Thermal Kem) during the Phase 2 removal action conducted in October 1989.
Incineration would achieve remediation goals by permanently destroying residual pesticides in I surficial soils. Incinerated soils would be replaced on-site with clean fiU-from an off-site source,
thereby minimizing any potential for exposure to unearthed soils. Off-site commercial incineration I of soils will be retained for further consideration.
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5.4.4 Containment
Containment alternatives prevent direct exposure to wastes by isolating them using an
engineered barrier. Properly constructed and maintained containment options function by
preventing access to the waste in perpetirity. Deed restrictions would typically be applied in
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conjunction with engineered measures to help control Mure activities at the Site. Containment
strategies have been applied successfully at numerous hazardous waste sites.
1) Capping
Capping is a process used to cover waste materials to prevent their contact with the land surface
and groundwater. For application at this Site, capping would be used solely for the purpose of
controlling exposure to surficial soils containing pesticide residuals in excess of potential
remediation goals. A cap constructed over soils targeted for remediation (Figures 4.1 and 4.2)
would provide an engineered barrier that would effectively isolate the soils, thereby denying any
route of direct exposure to the soils.
Two general types of caps could be used to contain the soils; a multilayered soil cap or a hard
cap. Both types of caps have been used at RCRA facilities in EPA Region IV as both provide an
effective means of waste containment. A soil cap would be composed of at least one foot of
clean soil covered by a vegetative layer. A flexible membrane liner between the compacted soil
base and the soil cap would provide an engineered barrier between the waste and the overlying
cap. The top layer of the cap would be vegetated native grasses to prevent erosion. Other
means of erosion control such as drainage swales would also be used to direct precipitation
away from the cap,
A hard cap would typically consist of a gravel layer, asphalt binder course and a Petromat-type
fabric used to improve cap durability. An advantage of a hard cap is that it requires less long-
term maintenance and is usually less expensive than a multilayer soil cap.
Capping is a proven and effective technology applied at numerous CERCLA sites. Capping will
be retained for further consideration. For cost estimating purposes, a hard cap will be
considered for application at this Site. Actual cap selection and design will be determined during
Remedial Design.
Capping may be an effective alternative for foundation debris disposal, if required. Foundation
rubble would have to be crushed and sized to allow compaction beneath the cap. Capping of
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foundation debris on-site will be retained as a disposal option, if necessary. Removal of the
foundation would only be required to achieve a 10~ LECR. No removal would be required to
achieve a 1 o-5 LECR.
2) On-Site Landfill
Remediation alternatives that involve off-site processing must satisfy certain criteria under the
NCP, as outlined in Section 5.4.3. Equivalent on-site alternatives should be evaluated when off-
site alternatives are considered. An on-site landfill Is considered here as the counterpart of
commercial landfilling. Site soils cannot be determined to be RCRA hazardous without TCLP
testing. To be conservative and for purposes of the FS, on-site landfill would have to meet RCRA
Subtitle C requirements and corresponding North Carolina Siting criteria.
Creation of an on-site landfill would involve the excavation of a landfill cell and the installation of
an appropriate liner system. The excavation and staging of contaminated soils would be required
if the landfill cell is sited at a location where soils are presently impacted. Contaminated soils
would then be placed into the lined excavation and covered with an impermeable liner.
Construction would most likely occur as a single landfill cell. To construct a landfill in strict
accordance with RCRA standards requires the following:
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a double liner system
two leachate detection systems
groundwater monitoring, and
any applicable siting criteria .
RCRA requirements are given in 40 CFR 264 Subpart N. These regulations specify that new
landfills should contain ''two or more liners and a leachate collection system above and between
the liners." An alternative design can be implemented if it is demonstrated that the alternative
would be as effective as the RCRA design for the prevention of contaminant migration.
Evaluation of the Site's geological and hydrological conditions is also critical to developing a well
designed hazardous waste landfill. Factors to be considered include seismic activity, settlement
or subsidence, high groundwater table, storm water run-on, and flood plains.
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The area available on Site to construct an on-site landfill renders this remedial alternative
impractical to implement. Siting requirements for non-hazardous waste disposal sites require a
minimum SO-foot buffer between all property lines and disposal areas (NCAC Title 15A.0503).
The resulting area available for on-site landfill construction would be irregularly shaped
(triangular) and limited to less than 1 acre. Extensive construction requiring excavation up to the
Highway 211 and/or the Aberdeen & Rockfish railroad track boundaries would be required. The
level of effort required to construct a landfill of such limited size would be difficult to justify.
Furthermore, on-site landfilling would yield no net reduction of residual chemicals on-site, would
result in increased monitoring requirements and the limited volume of waste would not justify the
cost of an on-site landfill. On-site landfilling is not retained for further consideration based on
implementability.
5.4.5 No Further Action
The National Oil and Hazardous Substances Contingency Plan (NCP) directs that the no-action
alternative be retained during the Feasibility Study (40 CFR 300.430(e)(6)). The NCP defines the
no-action alternative as no further actions if there have been previous removal actions at the Site
(Section 2.4). The no action alternative references the Site risk assessments and presents a
baseline of performance with which to evaluate other alternatives. Site soils would be left in
place under this alternative. While this alternative involves no active remediation, Site related
pesticides would be degraded to some extent through natural mechanisms (e.g., biodegradation,
Appendix C). Limited Site control may be exercised to deter unauthorized access. Typical
options include maintenance of the perimeter security fence, regular surveillance and deed
restrictions. The no further action alternative will be applied to disposal of foundation debris as
well as Site soils.
5.5 TECHNOLOGY SCREENING SUMMARY
Potential technologies were screened according to the technical criteria in Section 5.1. The
screening of site remediation technologies is presented separately below for groundwater
recovery, groundwater treatment, groundwater discharge, groundwater containment and
Geigy FS 5-39 March 16, 1992
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exposure control. A summary of the technical evaluations for groundwater and exposure control
are presented in Tables 5.4 and 5.5, respectively.
5.5.1 Groundwater Recovery
Two technologies were evaluated for the extraction of Site groundwater. Extraction wells and
interception trenches/subsurface drains were retained because of their proven effectiveness. The
no action alternative was retained as required by the NCP.
5.5.2 Groundwater Treatment
The compounds in groundwater exceeding ARARs are pesticides and the evaluation of potential
treatment technologies was limited accordingly. A total of six technologies were evaluated and
two were retained. Carbon adsorption and chemical oxidation were retained because of their
demonstrated effectiveness towards pesticides. Air stripping was rejected because of its limited
effectiveness towards pesticides .
Biological treatment and land treatment were rejected because chlorinated pesticides are
resistant to biodegradation. Sorptive resins was rejected because of the uncertainties regarding
its effectiveness and reliability.
5.5.3 Groundwater Discharge
Four options were evaluated for the discharge of treated groundwater. Discharge to a POlW
was retained as being technically effective. Horizontal infiltration galleries were provisionally
retained pending determination of allowable application rates. The injection well option was
rejected because under State law it is not permissible. Surface water discharge was rejected
because it would not be cost effective due to the lack of available surface water bodies within
reasonable proximity of the Site.
Geigy FS 5-40 March 16, 1 992
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5.5.4 Groundwater Containment
One option using a circumferential slurry wall in conjunction with a low permeability cap and
using well point extraction was considered for groundwater containment. This option was
considered technically feasible and was retained.
5.5.5 Exposure Control
Ten direct treatment technologies were evaluated for possible implementation at the Site of which
none were retained for further evaluation. Soil washing and three thermal desorption
technologies were evaluated and rejected from further consideration due to the disaportionate
volumes of soils requiring remediation and the extensive mobilization/demobilization requirements
of thermal desorption. Soil washing was also rejected from further consideration since it has not
been demonstrated under similar site conditions. Bioreactor technologies and land treatment
were rejected due to limited effectiveness toward chlorinated pesticides. Stabilization was
rejected based on effectiveness concerns. Supercritical CO2 extraction, critical fluid solvent
extraction, supercritical water oxidation, and the BEST process were rejected because they are
developing technologies that have not been demonstrated under Site conditions. Transportable
incineration technologies were rejected from further consideration on the basis of implementation.
One pretreatment technology, classification, was retained pending treatability testing.
Four in-situ technologies were evaluated. Soil flushing was rejected based on effectiveness
concerns. Soil vapor extraction and enhanced biodegradation were rejected because they are
not effective toward pesticides. Vitrification is not sufficiently developed for use at this Site.
Two off-site treatment technologies, commercial landfilling and commercial incineration were
considered and retained for further consideration. Commercial and municipal landfilling will also
be retained for disposal of foundation debris.
Capping was the only retained containment technology for Site soils. Capping of foundation
debris was also retained for further consideration. On-site landfilling was rejected on the basis
of implementability and restrictive State siting criteria.
A summary of the exposure control technology screening is presented in Table 5.5.
Geigy FS 5-41 March 16, 1992
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I N,\.GJ0,24\FlGSl
0
GS-O2-1
GS-O2-3
CITY WELL #4
WOODS
LEGEND
~GS-O2-2 GEOLOGICAL SURVEY WELL
~MW-7S
~PZ-1
■EW-8
60 0
MONITORING WELL
PRODUCTION ZONE WELL
PROPOSED GROUNDWATER
EXTRACTION WELL IN THE
UPPERMOST AQUIFER
PROPOSED GROUNDWATER
EXTRACTION WELL IN THE
SECOND UPPERMOST AQUIFER
60 1eo 1ao n.
WOODS
MW-7S ~
MW-12S~
~ MW-5S
WOODS EW-71.l
EW-9 ■
[
MW-11D
EW-8 ■
0
W-9S
0
rMW-10S
~ MW-4S
WOODS
fllSIRRINE
Ill ~~'r1°.Jk
N
WOODS
FIGURE 5. 1
PROPOSED GROUNDWATER
EXTRACTION WELL LOCATIONS
GEIGY CHEMICAL CORPORATION SITE ABERDEEN, NORTH CAROLINA
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GS-02-134 \
GS-02_-1
/CS-02-3
~
CITY WELL #4
434
432----
WOODS
430----\--
428
426
LEGEND
4> GS-02-2 GEOLOGICAL SURVEY WELL
4> MW-7S MONITORING WELL
4> PZ-1 PRODUCTION ZONE WELL
'"EW-7 PROPOSED GROUNDWATER
EXTRACTION WELL
60 • .. teo U10 n .
\
\
\
426
\
\
\
MW 7S 4>
)
?
W-8S
-WOODS -..--....__ / .., 4> _/'-EW-7 •
EW-9 ■ ~ 428 / . r·Mw 11D / EW-8 ■ '--. 430 "---.
432 /
434
/
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432
/ 434
/
_,,,,--
wo7
438
N
WOODS
LLRED
ROPERTY
FIGURE 5.2
PROPOSED INTERCEPTOR
TRENCH LOCATION
GEIGY CHEMICAL CORPORATION SITE
ABERDEEN, NORTH CAROLINA
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0
CITY WELL #4
0
WOODS
LEGEND
PROPOSED AREA TO
BE CAPPED
PROPOSED SLURRY WALL LOCATION
.. , .. 180 rt .
WOODS
SLURRY WALL ~
WOODS
CAP AREA ~
PROPOSED REROUTED
RAILROAD TRACKS
0
WOODS
IISIRRINE
l'il ~~~
N
WOODS
PROPERTY
FIGURE 5.3
PROPOSED CONTAINMENT
CAP AND SLURRY WALL
GEIGY CHEMICAL CORPORATION SITE ABERDEEN. NORTH CAROLINA
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I 60 O 60 120
WOODS
WOODS
180 FT.
CAP A:
CAP 8:
SURFICIAL SOILS (LECR of 10E-5)
SURFICIAL SOILS (LECR OF 10E-6 AND
FOUNDATION DEBRIS
0
WOODS
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WOODS
PROPERTY
I UR .
PROPOSED CONTAJN~ENT CAPS FOR
SURFICIAL SOIL AND FOUNDATION DEBRIS
GEIGY OiEMICAL CORPORATION SITE
ABERDEEN NORTH CAROLI
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TABLE 5.1
POTENTIAL GROUNDWATER REMEDIATION TECHNOLOGIES
RECOVERY
Extraction Wells
Interception Trenches and Subsurface Drains
No Action
TREATMENT
Air Stripping
Activated Carbon Adsorption
Sorptive Resins
Chemical Oxidation (UV-Ozone/Hydrogen Peroxide)
Biological Treatment
Land Treatment
DISCHARGE
Horizontal Infiltration Gallery
Injection Wells
Surface Water Discharge
Publicly Owned Treatment Works (POTW)
CONTAINMENT
Slurry Wall with Capping and Well Point Extraction
Geigy FS 5-46 March 16, 1992
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TABLE 5.2
MOORE COUNTY SANrrARY SEWER AUTHORrrv
SEWER USE ORDINANCE LIMrrATIONS
Parameter Limit (ug/L) Parameter Limit (mg/L) I alpha -BHC 0.05 Chemical Oxygen Demand 500
beta -BHC 0.05 Biochemical Oxygen Demand 250
I delta -BHC 0.05 Total Suspended Solids 250
gamma-BHC 0.05 Total Kjeldahl Nitrogen 40
Heptachlor 0.05 Total Arsenic 0.003
I Aldrin 0.05 Total Cadmium 0.003
Heptachlor Epoxide 0.05 Total Copper · 0.061
Endosulfan I 0.05 Total Cyanide 0.041
I Dieldrin 0.10 Total Lead 0.049
4,4' -ODE 0.10 Total Mercury 0.0003
Endrin 0.10 Total Nickel 0.021
I Endrin Aldehyde 0.10 Total Silver 0.005
Endrin Ketone 0.10 Total Chromium 0.05
Endosulfan II 0.10 Total Zinc 0.175
I 4,4' -DOD 0.10 Total Aluminum NS
Endosulfan Sulfate 0.10 Total Iron NS
4,4' -DDT 0.10 Total Magnesium NS
Chlordane 0.50 Total Manganese NS II Methoxychlor 0.50 Selenium NS
Toxaphene 1.0 Boron NS
MBAS NS I pH NS
Total Phenols NS
Sulfates NS
I Sulfides NS
Ammonia Nitrogen NS
Phosphate (as Total
I Phosphorous NS
Oils and Greases NS
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TABLE 5.3
POTElifllAL SURFICIAL SOIL REMEDIATION TECHNOLOGIES
Direct Treatment
I Biological Treatment
Land Treatment
I Bioreactor
Chemical Extraction
I Supercritical CO2 Solvent Extraction
Critical Fluid Solvent Extraction
BEST Process
I Supercritical Water Oxidation
I
Soil Washing
Stabilization/Solidification
I Transportable Incineration
Thermal Desorption
It Classification (pretreatment)
I In-Situ Treatment
Soil Vapor Extraction
I Enhanced Biodegradation
Soil Flushing
Vitrification
I Off-Site Treatment or Diseosal
I Commercial Landfilling
Commercial Incineration
I Containment
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Capping
On-Site Landfill
No Action
I , Geigy FS 5-48 March 16, 1992
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TABLE 5.3 (CONTINUED)
POTENTIAL SOIL REMEDIATION TECHNOLOGIES
I Potential Disposal Options for Foundation Debris
I Commercial Landfilling
Capping
No Action
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TEa-tNOLOGY
GROUNDWATER RECOVERY
EXTRACTION WELL
INTERCEPTION TRENCHES AND
SUBSURFACE DRAINS
NO ACTION
GROUNDWATER TREATMENT
AIR STRIPPING
ACTIVATED CARBON ADSORPTION
SORPTIVE RESINS
CHEMICAL OXIDATION (UV-OZONE)
BIOLOGICAL TREATIMENT
LAND TREATMENT
GROUNDWATER DISCHARGE
HORIZONTAL INFILTRATION GALLERY
INJECTION WELLS
- -
SURFACE WATER DISCHARGE
PUBLICLY OWNED TREATMENT WORKS
(POlW)
GROUNDWATER CONTAINMENT
SLURRY WALL, CAPPING AND
WELL POINT EXTRACTION
Geigy FS
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TABLE5.4
GROUNDWATER CONTROL
TEa-tNOLOGY SUMMARY
STATUS
RETAINED
RETAINED
RETAINED
REJECTED
RETAINED
REJECTED
RETAINED
REJECTED
REJECTED
RETAINED
REJECTED
REJECTED
RETAINED
RETAINED
5.50
-- --
REASON
EFFECTIVENESS
EFFECTIVENESS AND RELIABILITY
EFFECTIVENESS
EFFECTIVENESS
----
PROVISIONALLY DEPENDING ON APPLICATION RATES
NOT PERMITTABLE
NOT COST EFFECTIVE
March 16, 1992
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DIRECT TREATMENT
IN-SITU TREATMENT
OFF-SITE TREATMENT
CONTAINMENT
NO-ACTION
Geigy FS
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TABLE5.5
EXPOSURE CONTROL TECHNOLOGY SUMMARY
TECHNOLOGY
LAND TREATMENT
BIO REACTOR
SUPERCRITICAL CO2 EXTRACTION
CRITICAL FLUID SOLVENT EXTRACTION
BEST PROCESS
SUPERCRITICAL WATER OXIDATION
SOIL WASHING
STABILIZATION/SOLIDIFICATION
TRANSPORTABLE INCINERATION
THERMAL DESORPTION
CLASSIFICATION
SOIL VAPOR EXTRACTION
ENHANCED BIODEGRADATION
SOIL FLUSHING
VITRIFICATION
COMMERCIAL LANDFILLING
COMMERCIAL INCINERATION
CAPPING
ON-SITE LANDFILL
5-51
STATUS
REJECTED
REJECTED
REJECTED
REJECTED
REJECTED
REJECTED
REJECTED
REJECTED
REJECTED
REJECTED
RETAINED
REJECTED
REJECTED
REJECTED
REJECTED
RETAINED
RETAINED
RETAINED
REJECTED
RETAINED
- -
REASON/NOTES
EFFECTIVENESS
-.. .. ,,.
EFFECTIVENESS AND IMPLEMENTABILITY
NOT A DEMONSTRATED TECHNOLOGY
NOT A DEMONSTRATED TECHNOLOGY
NOT A DEMONSTRATED TECHNOLOGY
NOT DEMONSTRATED TECHNOLOGY
NOT DEMONSTRATED UNDER SIMILAR SITE
CONDITIONS/IMPLEMENTATION
EFFECTIVENESS
IMPLEMENTATION
IMPLEMENTATION
TREATABILITY TESTING REQUIRED
EFFECTIVENESS
EFFECTIVENESS
EFFECTIVENESS
NOT FULLY DEVELOPED
SOIL AND FOUNDATION DEBRIS
SOIL ONLY
SOIL AND FOUNDATION DEBRIS
IMPLEMENTATION
SOIL AND FOUNDATION DEBRIS
March 16, 1992
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6.0 DEVELOPMENT OF ALTERNATIVES
Remedial action alternatives represent a directed application of feasible technologies towards
areas of potential risk or site control. The technology screening in Section 5 evaluated options
on an individual basis without reference to their part in a comprehensive remedial action. The
purpose of this section is to assemble the retained technologies into functional alternatives
considering site-specific factors and then to evaluate the alternatives collectively. This initial
screening of alternatives has been conducted to select the best remedial schemes based on the
overall nature of the Site. Potential technologies for groundwater control have been formulated
into concerted alternatives. The alternatives retained from this evaluation are subjected to a
detailed analysis in Section 7.
Potential alternatives have been developed for groundwater and exposure control. The NCP
requires that a range of alternatives including treatment be evaluated to reduce toxicity, mobility,
or volume of contaminants be developed. The range includes alternatives which remove or
destroy the residual chemicals, and to the maximum extent feasible eliminate or minimize the
need for long-term management. Alternatives have also been developed which involve little or
no treatment but which provide protection to human health and the environment by preventing
or controlling exposure to the contaminants through engineering or institutional controls. The
no action alternative has also been retained for each media to provide a baseline for comparison,
as required by the NCP.
6.1 AREAS OF POTENTIAL REMEDIATION
Determination of areas potentially meriting remediation was performed through the baseline risk
assessments (Section 3), through the assessment of chemical-specific ARARs, and the
development of site-specific remediation levels (Section 4). Existing significant risks and the
capability to generate future impacts on other media are both criteria for targeting areas for
potential remediation.
Site groundwater poses no current risks to human health and the environment. Potential future
risks could occur if Site groundwater were to be used for human consumption. Groundwater in
Geigy FS 6-1 March 16, 1992
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both the uppermost and second uppermost aquifers exceeds ARARs (MCL.s). Groundwater
alternatives will be developed with the goals of controlling off-site migration (containment) and/or
attaining MCL.s (restoration).
Site surficial soils were determined to pose potentially unacceptable risks to a hypothetical future
resident through incidental exposure to residual pesticides. Since there are no ARARs for
surficial soils, remedial efforts are directed toward limiting potential risks by controlling exposure
to surficial soils that exceed potential remediation goals. Considered exposure control
alternatives were those that would eliminate potentially unacceptable risks through remediation
or by controlling direct exposure pathways to the soils.
No source control measures were considered for Site subsurface soils as they pose no current
or potential risks to human health or groundwater and there are no ARARs for subsurface soils.
Although the foundation of the former warehouse at the Site is not known to pose any significant
risks to human health or the environment and no ARARs dictate its removal, the foundation will
be removed if natural soils from beneath the foundation must be remediated. Consequently,
removal of the foundation will be required only if Site surficial soils must be remediated to achieve
a LECR of 1 o-6, as it is only under this scenario that soils beneath the foundation will require
removal (Figures 4.1 and 4.2).
6.2 GENERAL SCREENING CRITERIA
The purpose of this section is to screen defined alternatives through a comparative evaluation
and generate a refined list for detailed analysis. Screening is conducted under the broad criteria
of effectiveness, implementability and cost. Descriptions of these criteria are presented below.
Within these criteria, consideration is given to construction and implementation activities (short-
term effectiveness) and any residual risk remaining after the completion of remedial activities
(long-term effectiveness). While the screening at this stage is general, pending the more
thorough and extensive analysis in Section 7, the evaluation is sufficiently developed to allow
differentiation among alternatives.
Geigy FS 6-2 March 16, 1992
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6.2.1 Effectiveness
The primary consideration for an alternative is its protectiveness of human health and the
environment. Associated considerations include the reduction in toxicity, mobility or volume of
Site residuals that will be achieved. Short-term factors include protection of the community and
on-site workers during construction and implementation. Long-term factors include potential risks
from remaining residuals and the potential need to replace the remedy in the Mure.
6.2.2 Implementability
The implementability criterion evaluates the technical and administrative feasibility of constructing,
operating, and maintaining an alternative. Technical feasibility refers to the ability to construct,
reliably operate, and satisfy action-specific regulations. Administrative considerations include the
ability to obtain regulatory approvals (where necessary), public acceptance, available
treatmenVdisposal capacity, and the availability of necessary equipment and personnel.
6.2.3 Cost
Cost is a secondary criteria used to evaluate equivalent alternatives. Those alternatives that are
equivalent in cost but clearly would not achieve as effective a remediation as other alternatives
are rejected from further consideration. Alternatives that achieve the same level of treatment but
at considerably higher cost also are rejected. Otherwise, cost is not used as an elimination
criteria at this juncture.
General capital, mobilization, start-up, and operational costs are considered during the evaluation
of technologies. Because of the limited detailed technical information available and the accuracy
required for this phase of the evaluation, only a preliminary cost analysis is necessary. Present
worth costs are used to allow common comparison of alternatives.
Geigy FS 6-3 March 16, 1992
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6.3 FORMULATION OF POTENTIAL ALTERNATIVES
Potential remedial alternatives are presented below for the following areas of application:
• groundwater control
• exposure control/foundation disposal
6.3.1 Groundwater Control
Groundwater control alternatives involving direct remediation would include elements of
groundwater recovery, treatment, and discharge. Containment alternatives would involve the use
of physical barriers in conjunction with direct remediation options. These elements are evaluated
individually below. The no action alternative is developed under the groundwater recovery
alternatives, since without recovery there can be no additional activities.
6.3.1.1 Groundwater Recovery
Retained technologies for groundwater recovery are extraction wells and interception trenches.
Groundwater remediation alternatives will be based on the use of extraction wells and
interception trenches. Groundwater recovery options would achieve MCLs at the property lines
immediately and attain MCLs across the Site during operation. The no action alternative will also
be developed for groundwater control, as required by the NCP.
6.3.1.2 Groundwater Treatment
Groundwater treatment is directed at the removal of pesticides as required for discharge.
Retained technologies are carbon adsorption and chemical oxidation. Both technologies can be
designed to handle the anticipated flow rates and mass loadings. The required level of treatment
is dependent on the selected discharge option, although both treatment options can meet the
range of anticipated effluent concentrations.
Geigy FS 6-4 March 16, 1992
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6.3.1.3 Groundwater Discharge
Discharge options for treated groundwater are to the Moore County POlW or provisionally to an
infiltration gallery. Discharge to the infiltration gallery was provisionally retained because its
feasibility cannot be determined until field testing is conducted to establish that the required flow
rates can be discharged at the Site. For purposes of the FS, groundwater discharge would be
evaluated for both the Moore County POlW and an infiltration gallery. The actual discharge
point would be determined during Remedial Design.
6.3.1.4 Groundwater Containment
The main focus of a Site groundwater containment strategy would be to prevent the off-site
migration of groundwater from the surficial aquifer. The retained groundwater containment
alternative is a slurry wall keyed into the uppermost aquitard in conjunction with a cap.
Groundwater extraction would be required to maintain a negative hydraulic gradient across the
slurry wall. A groundwater containment strategy for Site groundwater in the surficial aquifer
would be combined with a recovery, treatment and discharge strategy for remediating
groundwater in the second uppermost aquifer.
6.3.1.5 Concerted Groundwater Alternatives
Potential technologies for each element of groundwater remediation have been combined in an
efficient, technically sound fashion to create overall alternatives for groundwater control. Each
of the comprehensive alternatives for groundwater are described below and summarized
in Table 6.1.
The source and extent of TCE in the second uppermost aquifer is indeterminate at this juncture.
Additional monitoring wells will be required to more adequately characterize the nature of TCE
in this aquifer. All of the groundwater control alternatives except for no action include further
characterization of the second uppermost aquifer.
Geigy FS 6-5 March 16, 1992
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ALTERNATIVE GWC-1: No Action
The no action alternative is required by the NCP. The no action alternative Is the baseline
alternative against which the effectiveness of other remedial alternatives are judged. No remedial
efforts would be conducted under this alternative. In accordance with the no action strategy,
there would be no groundwater extraction and hence no treatment or discharge. Pesticide
concentrations in groundwater would be reduced only through natural attenuation processes
such as biodegradation, adsorption and dispersion. No active efforts would be taken to control
any off-site migration of groundwater.
ALTERNATIVE GWC-1A: No Action
Alternative GWC-1 A would be a true no action alternative and involve no further activities to
assess groundwater migration potential. This alternative is supported by the projected absence
of any receptors for Site groundwater and by modeling that indicates average groundwater
concentrations would be below MCLs within a 1 O year period (Appendix D.2).
ALTERNATIVE GWC-1B: Long-term Monitoring of Site Groundwater
Alternative GWC-1 B would include long-term monitoring of Site groundwater to assess the
migration and degradation of pesticides. Deed restrictions would be placed on the Site to control
any future uses of groundwater.
ALTERNATIVE GWC-2: Containment of Site Groundwater from the Surficial Aquifer
Under this alternative, a slurry wall keyed into the uppermost aquitard would be constructed to
contain groundwater from the surficial aquifer underlying the Site. A low permeability cap would
be constructed within the confines of the slurry wall to restrict infiltration into the surficial aquifer
and to divert surface runoff away from the Site (Figure 5.3). Well point extraction at select
locations would be required to maintain an inward hydraulic gradient across the slurry wall to
prevent off-site migration of the contained groundwater. The collected groundwater would
Geigy FS 6-6 March 16, 1992
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require treatment prior to disposal. One extraction well in the uppermost aquifer and two In the
second uppermost aquifer would be installed to control groundwater outside of the slurry wall.
Slurry wall construction would involve excavating a trench under slurry to depths ranging from
45 to 70 feet. Excavations to these depths approaches the limits of technical feasibility and
would require special excavation equipment with extended reach capability (Section 5.3.4). The
northern slurry wall would be constructed entirely within the Highway 211 right-of-way. Approval
from the North Carolina Department of Transportation (NCDOT) would be required before
construction within their respective right-of-ways could begin. The Aberdeen & Rocldish rail line
would have to be rerouted to allow placement of the cap and slurry wall. Extensive rerouting of
utilities would be required where present. A low permeability cap would be constructed within
the confines of the slurry wall to minimize infiltration within the slurry wall. Capping is a proven
and effective technology that can be readily implemented at the Site using standard construction
techniques following rerouting of the Aberdeen & Rockfish railroad tracks. Engineered drainage
swales would be constructed to divert surface runoff away from the tracks. The cap would be
constructed solely for the purpose of restricting infiltration within the slurry wall to minimize the
amount of groundwater collected.
Groundwater recovery would be accomplished using well point extraction for the purpose of
hydraulic control. Restoration of the aquifer would proceed more slowly than for alternatives
emphasizing direct recovery. Treatment and disposal of the collected groundwater would
depend upon actual recovery rates. For the purpose of this FS, treatment by carbon adsorption
and disposal to the Moore County PO1W will be assumed. Actual treatment and disposal
alternatives would be determined during detailed design should this remedial alternative be
selected for the Site.
This alternative would deny future use of the uppermost aquifer below the Site. Deed restrictions
would be required to control any future uses.
Geigy FS 6-7 March 16, 1992
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ALTERNATIVE GWC-3: Recovery and Treatment of Site Groundwater
Alternatives developed under this strategy would Involve extraction, treatment and disposal of Site
groundwater in the uppermost and second uppermost aquifers. The performance objective of
this set of alternatives is to control the migration of Site groundwater and to ultimately attain
MCLs at the Site.
ALTERNATIVE GWC-3A: Extraction Wells, Carbon Adsorption and Discharge
Under this alternative, Site groundwater would be recovered using extraction wells, treated using
carbon adsorption and discharged to the Moore County POTW or to an on-site infiltration gallery.
Preliminary groundwater modeling of the surficial aquifer indicates that seven groundwater
extraction wells with an estimated combined pumping rate of approximately five gpm would be
required to control the migration of Site groundwater (Appendix D.1). The same modeling
indicates that two extraction wells with a maximum combined extraction rate of 15 gpm would
be required in the second uppermost aquifer. Actual well placement and extraction rates would
be determined during Remedial Design. Proposed placement of the groundwater extraction wells
is shown in Figure 5.1. Five of the proposed extraction wells would be constructed within the
right-of-way of Highway 211 and would require submittal of a right-of-way encroachment
agreement. Construction of the extraction wells including well head equipment installation is
estimated to take 1 to 1-1 /2 months with minimal disruption of Highway 211 traffic. Groundwater
recovery using extraction wells is a proven and demonstrated technology used at a number of
CERCLA sites.
Groundwater treatment is directed at the removal of pesticides to the level required for discharge.
Limitations for discharge to the Moore County POTW are discussed in Section 5.3.3. Carbon
adsorption is considered the best available technology (BAT) for the removal of gamma-BHC and
toxaphene from groundwater (56 FR 3526). Carbon adsorption treatment systems can be
designed to handle anticipated mass loadings and flow rates to achieve the required discharge
limitations. Treatment using carbon adsorption to remove organics from groundwater is a proven
and demonstrated technology selected for use at a number of CERCLA sites.
Geigy FS 6-8 March 16, 1992 ·
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Discharge options for treated groundwater are to the Moore County POTW or to an on-site
infiltration gallery. The Moore County POTW is currently capable of accepting the anticipated
flow rates (Moore County Sanitary Sewer Authority, 1991). Discharge to the infiltration gallery is
provisionally retained until field testing is conducted to determine whether loading rates for Site
soils can accommodate the required discharge flow rate from the Site. Based on the
groundwater extraction rate (approximately 20 gpm) and the average infiltration rates for area
soils (0.5 gpd/tt2), construction of an on-site infiltration gallery is questionable. For the purpose
of the FS, groundwater discharge will be addressed for both the POTW and an infiltration gallery.
The actual groundwater discharge option will be determined during Remedial Design.
ALTERNATNE GWC-3B: Extraction Wells, Chemical Oxidation and Discharge
Under this alternative, Site groundwater would be recovered using groundwater extraction wells,
treated using chemical oxidation (UV -ozone/hydrogen peroxide), and discharged to the Moore
County POTW or an infiltration gallery. Groundwater recovery using extraction wells and
discharge of treated groundwater are discussed under Alternative GWC-3A.
Groundwater treatment using chemical oxidation would be conducted to reduce pesticide
concentrations to the level required for discharge. Chemical oxidation treatment systems can
be designed to handle the anticipated flow rates and mass loadings. Treatability testing would
be required to determine system design parameters and potential removal efficiencies.
ALTERNATIVE GWC-3C: Interception Trench, Carbon Adsorption and Discharge
Under this alternative, an interception trench, a single extraction well (EW-7) in the uppermost
aquifer, and two extraction wells in the second uppermost aquifer would be used to control the
migration of Site groundwater. Carbon adsorption would be used to treat the groundwater.
Treated groundwater would be discharged to the Moore County POTW or an on-site infiltration
gallery. Groundwater treatment using carbon adsorption and discharge of treated groundwater
are discussed under Alternative GWC-3A.
Geigy FS 6-9 March 16, 1992
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Under Site conditions, groundwater recovery using an interception trench is feasible. The
groundwater divide at the west end of the Site enables a single interception trench to capture
most of the groundwater requiring treatment. A single extraction well (EW-7), however, would be
required to capture groundwater in the vicinity of MW-1 OS (Figure 5.2), as groundwater in this
area could be beyond the influence of the interception trench and flow south of the groundwater
divide. Two extraction wells would be placed in the second uppermost aquifer to control
pesticides in the vicinity of MW-11 D. Total extracted flow rate for the system would be
approximately 20 gpm.
Although an interception trench would be an effective means for controlling the migration of Site
groundwater, it would not offer the flexibility of groundwater extraction wells. While the trench
extract rate can be adjusted to influence area hydraulic gradients, extraction well pumping rates
can be adjusted individually to influence local hydraulic gradients. Furthermore, individual
extraction wells can be removed from service if groundwater recovery at one portion of the Site
is no longer required.
Construction of an interception trench would involve significant access considerations. The
proposed trench would be located within the Highway 211 right-of-way (Figure 5.2), thereby
complicating construction efforts. All construction within the Highway 211 right-of-way would
require submittal of a right-of-way encroachment agreement to the NCDOT. Approval by the
NCDOT would be required prior to trench construction or rerouting of any underground utilities.
Local traffic would be disrupted during trench construction.
ALTERNATIVE GWC-3D: Interception Trench, Chemical Oxidation and Discharge
Site groundwater would be recovered using an interception trench and extraction wells and
treated by chemical oxidation under this alternative. Collected groundwater would be discharged
to the Moore County POTW or an on-site infiltration gallery after treatment. Groundwater
recovery using an interception trench is discussed under Alternative GWC-3C. Groundwater
treatment using chemical oxidation and discharge of treated groundwater are presented in
Alternative GWC-3B.
Geigy FS 6-10 March 16, 1992
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6.3.2 Exposure Control/Foundation Disposal
Exposure control alternatives involve remedial alternatives that would prevent exposure to soil
borne pesticides, thereby reducing the potential Mure risks to human health to acceptable levels.
Retained exposure control technologies are commercial landfilling, commercial incineration and
capping. The no further action alternative will also be developed for exposure control, as
required by the NCP.
Foundation disposal involves disposal of debris (concrete and fill dirt) generated during
foundation removal, if required. Foundation disposal will occur as a consequence of required
remediation of underlying natural soils to achieve a 1 o-6 LECR. Foundation removal would not
be required to achieve a 1 o·5 LECR. Therefore, foundation disposal is considered using
exposure control technologies where appropriate.
The foundation is not known to pose any significant risks to human health or the environment
and ARARs do not dictate it's removal. Foundation excavation and disposal would be conducted
to facilitate access to contaminated soils beneath the concrete that exceed remediation levels.
ALTERNATIVE EC-1: NO FURTHER ACTION
The no action alternative is considered as required by NCP. The no action alternative is the
baseline alternative against which the effectiveness of other remedial alternatives are judged. No
action will be termed no further action since extensive removal actions were conducted at the site
in 1989 and 1991 (Section 2.4). No further remedial efforts would be conducted under this
alternative. In accordance with the no further action strategy, there would be no excavation of
surficial soils, hence no treatment or disposal of the soils. Likewise, no effort to isolate the soils
to prevent incidental exposure to humans or the environment would occur. Pesticide
concentrations in surficial soils would be reduced through natural attenuation processes such
as biodegradation, volatization and natural flushing.
Alternative EC-1 would be a true no action alternative and involve no further activities to assess
the potential for exposure to site soils nor any means to prevent it. This alternative is supported
Geigy FS 6-11 March 16, 1992
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by the limited potential for future site utilization and the absence of significant risks to human
health under current conditions.
Under the no further action alternative the former warehouse foundation would remain as is and
there would be no effort to demolish or dispose of it.
ALlERNATIVE EC-2: Off-Site Disposal
Under this alternative, the concentration of pesticides In site surficial soils would be permanently
reduced by means of off-site disposal. The estimated volume of soils to be disposed off-site is
670 cubic yards {140 cubic yards) to achieve a LECR of 10~ (LECR of 1 o.si. Surficial soils
targeted for remediation (Figure 4.1 or 4.2) would be excavated and disposed off-site in a secure
landfill or a RCRA-approved incinerator. Prior to off-site disposal, the soils would be staged on-I site and tested using TCLP to determine whether the soils are hazardous by characteristic. If it
is determined that the soils hazardous based on TCLP analyses, the soils would be treated by
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means of incineration before landfilling in accordance with land disposal restrictions (LDRs) for
listed wastes (40 CFR 268.43(a)). Incineration would occur at a RCRA-approved incinerator.
Tentative disposal facilities have been identified for costing purposes in the FS. If determined
to be non-hazardous, soils would be transported by railcar, to the Grassy Mountain secure landfill
in Clyde, Utah. If determined to be hazardous, the soils would be placed in lined and covered
roll-off containers for transportation to the Chemical Waste Management incinerator in Port Arthur,
Texas. Actual off-site disposal facilities would be determined during Remedial Design. Off-site
landfilling and incineration were used to dispose of soils from previous removal actions at the
Site.
ALlERNATIVE EC-2A: Off-Site Disposal of Surficial Soils
Alternative EC-2A would involve off-site landfilling and/or off-site incineration of Site surficial soils
based on an LECR of 1 o-s (Figure 4.2). The volume of soils to be removed would be
approximately 140 cubic yards. Clean fill from an off-site source would be used to backfill
surficial soil excavations.
Geigy FS 6-12 March 16, 1992
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ALTERNATIVE EC-28: Off-Site Disposal of Surlicial Soils and Foundation Debris
Alternative EC-2B would re mediate all those Site soils exceeding and LECR of 10-{;. This
alternative would involve demolition of the former warehouse foundation, disposal of the
foundation debris in an off-site landfill and off-site disposal of surficial soils as presented in
Alternative EC-2A.
The former warehouse foundation would be removed to allow access to the underlying soils. The
foundation would be landfilled in a local municipal landfill as common rubble pending the results
of appropriate testing and acceptance by the municipal landfill. Should landfilling at a municipal
landfill be denied, the foundation debris would be landfilled at a secure landfill as a hazardous
or non-hazardous waste, pending the results of TCLP testing. Actual landfilling options for the
foundation debris would be determined during Remedial Design.
For cost estimating purposes, a range of landfill disposal costs will be provided to reflect the
range associated with soil disposal at a landfill or an incinerator.
ALTERNATIVE EC-3: Capping
Alternative EC-3 would involve capping as a means to isolate Site soils for the purpose of
eliminating the potential for incidental exposure. Capping alternatives are presented to achieve
an LECR of 1 o·5 and of 10-{;. Conceptual dimensions and locations of the caps are presented
in Figure 5.4. Soils (and debris, as necessary) would be consolidated on-site and covered with I a hard (Petromat-type) cap. Actual dimensions, location and materials would be determined
during Remedial Design, should a capping alternative be selected. Capping would not be
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required to deny or reduce infiltration of precipitation into Site subsurface soils.
ALTERNATIVE EC-3A: Capping Surlicial Soils
Alternative EC-3A would involve capping of Site surficial soils exceeding an LECR of 1 o-5 under
future use scenarios (Figure 5.4). The volume of soils to be capped would be approximately 140
cubic yards.
Geigy FS 6-13 March 16, 1992
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ALTERNATIVE EC-3B: Capping Surficial Soil and Foundation Debris
Alternative EC-38 would involve demolition of the former warehouse foundation to allow access
to the underlying soils and capping of the foundation debris along with surficial soils as
described in Alternative EC-3A. Debris resulting from excavation of the foundation would be
sized to facilitate capping.
6.3.3 Preliminary Costs for Alternatives
Preliminary costs for the potential source control and ground water control alternatives are
presented in Table 6.2. Alternatives are referenced by the number in Table 6.1. Construction
and operational costs for the groundwater and source control alternatives were developed using
the Cost of Remedial Action (CORA) model (EPA, 1990a). The approximate level of accuracy for
these cost estimates is -50 to + 100 percent, as suggested by the EPA document Guidance on
Feasibility Studies Under CERCLA (April, 1985). Costs were developed on a present worth basis
using an interest rate of 5 percent. Costs for groundwater control alternatives are based on a
30 year lifetime, the longest allowed under EPA guidance. Projected present worth costs for
these alternatives should therefore be conservative. Documentation of the CORA cost estimates
is provided in Appendix E. Detailed cost estimates will be prepared in Section for retained
alternatives.
6.4 SCREENING EVALUATION
The assembled alternatives are screened below according to the criteria listed in Section 6.2.
Alternatives remaining after this screening will be subjected to detailed analysis in Section 7.
Geigy FS 6-14 March 16, 1992
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6.4.1 Groundwater Control
ALTERNATIVE GWC-1: No Action
The no action alternative will be retained as required by the NCP. Should the no action
alternative be selected, groundwater remediation would occur solely through natural processes.
Any migration of Site groundwater would not be actively controlled.
Based on different levels of Site monitoring, both no action alternatives will be retained.
Alternative GWC-1 A would involve no remedial or assessment activities. Alternative GWC-1 B
would involve no remedial activities but would include long-term monitoring of Site groundwater.
ALTERNATIVE GWC-2: Slurry Wall and Cap
Alternative GWC-2 would involve containment of all Site groundwater by means of capping and
a circumferential slurry wall. Well point extraction would be used to recover contained
groundwater to maintain an inward hydraulic gradient toward the circumferential slurry wall.
Extraction wells would also be required to control a portion of the uppermost aquifer and to
control pesticides in the second uppermost aquifer. The collected groundwater would be treated
prior to discharge. Under this alternative, migration of Site groundwater in the uppermost aquifer
would be controlled by the slurry wall. The cost for this alternative is over 800 percent higher
than other alternatives that are capable of controlling groundwater migration. However, this
alternative offers a different control strategy than direct groundwater extraction. Alternative GWC-
2, Slurry Wall and Cap, is therefore retained for detailed analysis.
ALTERNATIVE GWC-3A: Extraction Wells, Carbon Adsorption, Discharge
Alternative 3A would use extraction wells to control migration of Site groundwater. Treatment
using carbon adsorption would reduce the concentration of pesticide residuals in Site
groundwater and is a permanent remedy. Activated carbon is considered BAT for pesticide
removal. Alternative GWC-3A is capable of controlling the migration of Site groundwater and is
retained for detailed analysis.
Geigy FS 6-15 March 16, 1992
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ALTERNATIVE GWC-3B: Extraction Wells, Chemical Oxidation, Discharge
Alternative GWC-3B would recover Site groundwater to prevent its migration off-site. Chemical
oxidation would be used to treat recovered groundwater prior to disposal. Alternative GWC-3B
is capable of controlling Site groundwater and would permanently reduce the concentrations of
pesticide residuals in Site groundwater. Chemical oxidation would likely be able to meet the
required discharge levels but this would be confirmed during treatability testing. Chemical
oxidation therefore represents an equivalent level of performance to activated carbon. However,
the cost of a chemical oxidation system would be approximately 500 percent more costly than
an activated carbon system. Alternative GWC-3B is rejected from further consideration since it
is significantly more expensive than equivalent alternatives (GWC-3A).
ALTERNATIVE GWC-3C: Interception Trench, Carbon Adsorption, Discharge
Alternative GWC-3C would use an interception trench and select extraction wells to recover Site
groundwater. Carbon adsorption would be used to treat the groundwater prior to discharge.
Alternative GWC-3C would effectively control Site groundwater migration and would permanently
reduce the concentration of pesticide residuals in Site groundwater. The cost of Alternative
GWC-3C, however, is more than 100 percent higher than the cost of Alternative GWC-3A and is
no more effective at containing Site groundwater. Alternative GWC-3C is rejected from further
consideration based upon the cost criterion.
ALTERNATIVE GWC-3D: Interception Trench, Chemical Oxidation, Discharge
Alternative GWC-3D would recover Site groundwater using an interception trench and one
groundwater extraction well. The recovered groundwater would be treated using chemical
oxidation prior to discharge. Alternative GWC-3D would permanently reduce concentration of
pesticide residuals in Site groundwater and would minimize the risk of off-site migration of
contaminated groundwater. The cost of Alternative GWC-3D, however, is more than 600 percent
higher than the cost of Alternative GWC-3A. For extraction alone, the interception trench would
cost nearly 1000 percent more than the recovery well system (Appendix E). Since Alternative
Geigy FS 6-16 March 16, 1992
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GWC-3D is no more effective than Alternative GWC-3A, Alternative GWC-3D will not be retained
for further consideration.
6.4.2 Exposure Control
ALTERNATIVE EC-1: No Further Action
The no further action alternative will be retained as required by the NCP. Should the no further
action alternative be selected, surficial soil remediation would occur solely through natural
processes and no further remedial or assessment activities would be conducted. Incidental
exposure to surficial soils would not be actively controlled. The former warehouse foundation
would remain intact.
ALTERNATIVE EC-2: Off-Site Disposal
This alternative would involve off-site disposal of Site surficial/soils requiring remediation. This
alternative would be conducted in accordance with the EPA's off-site policy and would be readily
implemented. Classification is a potential pretreatment option, based on treatability testing.
Alternative EC-2A would involve off-site disposal of Site surficial soils by means of incineration
or land filling to achieve an LECR of 1 o·5 while Alternative EC-2B would achieve an LECR of 10-6.
Both alternatives would be with the acceptable risk range of the NCP and be a permanent
remedy for the Site. While considerably more costly than the Alternative EC-3 options, off-site I disposal offers a different response strategy and cannot be directly compared. On the basis of
effectiveness, implementability and cost, both off-site disposal alternatives will be retained.
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ALTERNATIVE EC-3: Capping
This alternative would involve on-site cap construction to isolate Site surficial soils to eliminate
any means of incidental exposure and to reduce associated risks. This alternative would be
readily implemented if selected.
Geigy FS 6-17 March 16, 1992
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The primary response requirement for exposure control is to deny incidental human contact with
Site surficial soils. Alternative EC-3A would provide this control and achieve a residual LECR of
1 o-5 while Alternative EC-38 would achieve an LECR of 1 o-o. Both alternatives are effective and
implementable and therefore will be retained.
6.5 SUMMARY OF RETAINED ALTERNATIVES
Alternatives retained after this screening are listed in Table 6.3. These alternatives will be
subjected to a more rigorous screening in the detailed analysis (Section 7).
Geigy FS 6-18 March 16, 1992
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Alternative
GWC-1
A
B
GWC-2
GWC-3
A
EC-1
EC-2
EC-3
B
C
D
A
B
A
B
Geigy FS
TABLE 6.1
POTENTIAL REMEDIAL ALTERNATIVES
GEIGY CHEMICAL CORPORATION SITE
Description
No action
No action
Long term monitoring
GROUNDWATER CONTROL
Groundwater containment -slurry wall and cap
Recovery, treatment and discharge of groundwater exceeding MCLs
Extraction wells, carbon adsorption, POTW
Extraction wells, chemical oxidation, POTW
Interception trench, carbon adsorption, POTW
Interception trench, chemical oxidation, POTW
EXPOSURE CONTROL AND DISPOSAL OF FOUNDATION DEBRIS
No further action
Off-site disposal
Off-site disposal of surficial soils (1 o-5 LECR)
Off-site disposal of surficial soils (1 o-6 LECR)
Capping
Capping surficial soils (1 o-5 LECR)
Capping surficial soils (1 o-6 LECR)
6-19 March 16, 1992
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Alternative
GWC-1A
GWC-1B
GWC-2
GWC-3A
GWC-3B
GWC-3C
GWC-3D
EC-1
EC-2A
EC-2B
EC-3A
EC-3B
Basis:
Geigy FS
TABLE 6.2
PRELIMINARY COSTS FOR ALTERNATIVES
GEIGY CHEMICAL CORPORATION SITE
Description
GROUNDWATER CONTROL
No further action
Long term monitoring
Slurry wall and cap
Extraction wells, carbon adsorption, POTW
Extraction wells, chemical oxidation, POTW
Interception trench, carbon adsorption, POTW
Interception trench, chemical oxidation, POTW
Present Worth Costs
$140,000
$200,000
$5,500,000
$600,000
$3,500,000
$1,300,000
$4,500,000
EXPOSURE CONTROL (AND FOUNDATION DEBRIS DISPOSAL)
No further action
Off-site disposal of surficial soils (1 o-5 LECR)
Off-site disposal of surficial soils (1 o-6 LECR)
Capping surficial soils (1 o·5 LECR)
Capping surficial soils (1 o-6 LECR)
$140,000
$127,000 to $330,000
$510,000 to $1,500,000
$180,000
$350,000
CORA Software (EPA, 1990a) and relevant studies. Documentation provided in
Appendix E.
6-20 March 16, 1992
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TABLE 6.3
RETAINED ALTERNATIVES FOR DETAILED ANALYSIS
GEIGY CHEMICAL CORPORATION SITE
I Alternative Description
GROUNDWATER CONTROL
I GWC-1A No further action
GWC-1B Long-term monitoring of groundwater
I GWC-2 Slurry wall and cap
GWC-3A Extraction wells, carbon adsorption, discharge
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EXPOSURE CONTROL AND DISPOSAL OF FOUNDATION DEBRIS
I EC-1 No further action
I EC-2A Off-site disposal of surface soils (1 o-5 LECR)
EC-2B Off-site disposal of surficial soils (1 o-6 LECR)
-EC-3A Capping surficial soils (1 o·5 LECR)
EC-3B Capping surficial soils (1 o-6 LECR)
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7.0 DETAILED ANALYSIS OF ALTERNATIVES
Detailed analysis of alternatives is required by the NCP (40 CFR 300.430(e)(9)). Alternatives
retained from Section 6 (Table 6.3) will be examined in this section. Detailed analysis is provided
for groundwater control alternatives addressing the uppermost and second uppermost aquifers
at the Site and for exposure control alternatives addressing surficial soils exceeding an LECR of
1 E-5 and 1 E-6. Following is a discussion of the evaluation criteria used to perform the detailed
analysis of alternatives.
7.1 EVALUATION CRITERIA
The NCP requirements are reflected in the interim final document Guidance for Conducting
Remedial Investigations and Feasibility Studies Under CERCLA (OSWER Dir. 9335.3-01, October
1988). Nine evaluation criteria are presented that "have proven to be important for selecting
among remedial alternatives". These criteria provide the basis for evaluating alternatives and
subsequent selection of a remedy. The criteria are:
Overall protection of human health and the environment
Compliance with ARARs
Long-term effectiveness and permanence
Reduction of toxicity, mobility or volume of waste
Short-term effectiveness
Implementability
Present worth capital and operating costs
State acceptance
Community acceptance
All potential remedial alternatives will be evaluated according to the above criteria, except for
State acceptance and community acceptance. State and community acceptance will be
determined based on comments received after their review of this FS. Short descriptions of these
criteria are given below.
Geigy FS 7-1 March 16, 1 992
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1) Overall protection of human health and the environment: A remedial alternative must
eliminate, adequately reduce or control all current or potential risks through identified
pathways. Short-term risks during implementation of an alternative must be within
acceptable levels.
2) Compliance with ARARs: Considers action-specific, location-specific and chemical-specific
ARARs and to-be-considered factors. CERCLA § 121 (d)(4) provides five waivers for ARARs
for remedial actions not financed by the Fund. Potential location-specific and chemical-
specific ARARs for the Site are presented in Section 4.
3) Long-term effectiveness and permanence: Considers the residual risk following
implementation of the alternative, adequacy of process controls, need for replacement of
materials during design life.
4) Reduction of toxicity, mobility and volume: Considers type of process, volume of waste
involved, degree of reduction, degree of irreversibility, type/volume of residuals remaining .
5) Short-term effectiveness: Considers factors relevant to implementation of the remedial
action, including protection of the community, protection of on-site workers, potential
environmental impacts (e.g., air emissions), and time required to achieve the remedy.
6) Implementability: Considers ability to construct, reliability of technology, ease of installing
additional remedial actions (if required), monitoring considerations, and any regulatory
requirements.
7) Present worth costs (capital and operational): Capital costs include the following:
• Mobilization
• Site development
• Equipment purchase and rental
• Engineering and construction management
• Material cost
• Excavation
Geigy FS 7-2 March 16, 1 992
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• Health and safety
• Legal fees and insurance
• Contingency
Operational and maintenance costs reflect the following.
•
•
•
•
•
•
•
•
•
Equipment repair and replacement
Labor
Purchased service cost
Utilities
Cost of monitoring and analysis
Disposal cost
Administrative functions
Contingency
Review of remedy every 5 years, as required by SARA .
8) State acceptance: Assesses State concerns. As part of a cooperative agreement with the
USEPA, State acceptance will be incorporated into the FS as part of the document review
process.
9) Community acceptance: Assesses community concerns. Public comments will be made
on the Final Feasibility Study and incorporated into the responsiveness summary of the
Record of Decision. Where appropriate, anticipated public concerns based on activities
at similar remedial actions elsewhere are included in the Feasibility Study.
Accuracy of the present worth costs is +50/-30 percent, per EPA guidance. The feasibility level
cost estimates given with each alternative have been prepared from the information available at
the time of the estimate. The final costs of the project will depend on actual labor and material
costs, actual site conditions, productivity, competitive market conditions, final project scope, final
project schedule, and other variable factors. As a result, the final project costs may vary from
the estimates presented herein.
Geigy FS 7-3 March 16, 1992
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In estimating the present worth costs, a discount rate of 5 percent is used and inflation is taken
to be O percent. A sensitivity analysis will be used when sufficient uncertainty exists regarding
the design, implementation, operation or effective life of an alternative.
Present worth costs for long-term groundwater monitoring and review of Site remedy every five
years are given for each alternative where residuals would remain at the Site. Present worth
costs for these items are based on 30 years of operation, the maximum time allowed by EPA
guidance.
Schedule estimates are based on projected availability of materials and labor and may have to
be updated at the time of remediation. Construction schedules are based on good weather, the
ability to create and receive adequate and authorized access, and the availability of required
utilities. All cost and time estimates assume that the selected Remedial Design, including
construction drawings, have been approved and all negotiations with contractors have been
concluded.
7.2 GROUNDWATER CONTROL
Groundwater control addresses the migration of Site groundwater and the attainment of ARARs.
Site groundwater currently poses no risks to human health but could present potential future
risks based on the presence of a hypothetical residential receptor. Potential remedial
requirements for Site groundwater were presented in Section 4.1.3. Groundwater at the Site in
the uppermost aquifer and at one location in the second uppermost aquifer exceed MCLs for
pesticides. In addition, the presence of TCE in the second uppermost aquifer requires additional
characterization. The alternatives developed in Section 6 address these considerations. Detailed
analysis of the groundwater control alternatives is given below.
7.2.1 ALTERNATIVE GWC-1: No Action
Groundwater in the uppermost and second uppermost aquifers would not be directly remediated
under this alternative. Reduction of pesticide concentrations would occur only through natural
mechanisms, such as biodegradation (Appendix D). Groundwater would migrate as modeled in
Section 4.2.1 under this alternative.
Geigy FS 7-4 March 16, 1992
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The NCP requires that the no action alternative be retained through detailed screening of
alternatives as a baseline for comparison. For the Site, there are two options under the no action
alternative. Alternative 1 A would involve no activities at the Site other than a review of remedy
every five years. Alternative 1 B would add long-term monitoring of groundwater and deed
restrictions. Detailed analysis of the alternatives is presented below.
7.2.1.1 ALTERNATIVE GWC-1A: No Action
No activities would be conducted regarding Site groundwater under this alternative. Existing
monitoring wells would be retained as is for potential use, although no groundwater monitoring
is included under this alternative. This alternative does not include deed restrictions on future
uses of the property. Future uses of the property are considered unlikely given the highway and
railroad right-of-way restrictions. This alternative represents a true no action alternative. A review
of remedy would be conducted every five years.
Overall Protection of Human Health and the Environment
The no action alternative would be protective of human health and the environment under current
conditions. The baseline risk assessment (Section 3) determined that:
• Site groundwater poses no risks under current conditions since there are no
receptors
• Site groundwater in the uppermost aquifer represents a potential upper bound
lifetime excess cancer risk (LECR) of 4E-03 in the future for a hypothetical adult
resident
• Site groundwater in the second uppermost aquifer represents a potential upper
bound lifetime excess cancer risk (LECR) of 2E-03 in the future for a hypothetical
adult resident
The potential risk levels for groundwater in the future exceed the acceptable range of 1 E-04 to
1 E-06 specified by the NCP. The no action alternative is protective of human health under
current conditions but would not be protective of human health under potential future conditions.
Geigy FS 7-5 March 16, 1992
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Compliance with ARARs
Potential chemical-specific and location-specific ARARs are presented in Section 4.1. MCLs are
relevant and appropriate requirements for Site groundwater (Section 4.1.3.1 ). Pesticides in both
the uppermost and second uppermost aquifers at the Site exceed MCLs. The no action
alternative would therefore not comply with ARARs.
No endangered species or areas of significant historical importance were identified at the Site.
The no action alternative therefore does not violate any location-specific ARARs. There are no
action-specific ARARs for this alternative.
Long-term Effectiveness and Permanence
The magnitude of residual risks at the Site would remain unchanged under the no action
alternative. Since waste residuals would remain at the Site, review of the effectiveness and
protectiveness of the no-action alternative every five years would be required by SARA. Pesticide
concentrations in Site groundwater are anticipated to decrease by approximately 90 percent over
a five year period (Appendix D; based on gamma-BHC). Soil environmental half-lives were used
to estimate pesticide degradation rates in groundwater, since there is more data for soils in the
literature. Groundwater degradation rates may therefore be overestimated.
Reduction of Toxicity. Mobility of Volume
Remediation of groundwater would occur through natural processes such as biodegradation.
adsorption, and attenuation by upgradient flow. Reductions in pesticide concentrations can be
estimated and evaluated with respect to, groundwater migration rates using the environmental
half-lives (Appendix D). Based on the projected reductions in concentrations to achieve the
remediation goals and half-lives, gamma-BHC is the rate limiting compound at the Site. Through
natural degradation mechanisms, gamma-BHC concentrations would be reduced to MCL levels
at the Site in approximately 1 0 years. The retarded velocity of gamma-BHC in Site is
approximately six feet per year (Appendix D). Migration of gamma-BHC in this period would be
approximately 60 feet, which is less than the distance to the off-site monitoring wells. Site
groundwater would therefore be estimated to achieve remediation goals in approximately 10
years through natural mechanisms.
Geigy FS 7-6 March 16, 1 992
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Short-term Effectiveness
This alternative presents no risks to the community, on-site workers or the environment for its
implementation. The no action alternative can be implemented immediately. Since no remedial
actions are included, there is no schedule of completion. Remediation of Site groundwater
through natural mechanisms is anticipated to occur within approximately 1 O years based on
degradation rates presented in the literature.
Implementability
The no action alternative can be readily implemented and would not hinder the implementation
of any remedial actions in the future.
Cost
This alternative involves no capital costs. Operating costs are based on the review of Site
conditions every five years. There would be no maintenance costs.
The detailed cost estimate for Alternative GWC-1 A is presented in Appendix F. A summary of the
estimated costs is given below:
7.2.1.2
Total Construction Costs -
Present Worth O&M Costs
Total Present Worth Costs -
ALTERNATIVE GWC-1B:
$ 0
$140,000
$140,000
Long-term Monitoring of Site Groundwater
This alternative is an extension of Alternative GWC-1 A in that long-term monitoring of Site
groundwater would be added. For purposes of the FS, four additional monitoring wells would
be constructed in the second uppermost aquifer. Sampling here is assumed to be a twice per
year event with analyses for pesticides in the uppermost aquifer and pesticides and TCE in the
second uppermost aquifer. The adequacy of the existing well portfolio and actual sampling
frequency would be established during Remedial Design. This alternative represents a limited
action alternative.
Geigy FS 7-7 March 16, 1992
I \ .,,, ' I This alternative would include deed restrictions on future uses of the property, although long-term · monitoring would by itself restrict site development. Future uses of the property are considered unlikely given the highway and railroad right-of-way restrictions and lending restrictions on CERCLA sites. Evaluation of the no action portion of this alternative would be as described for Alternative 1 A (Section 7.2.1.1 ). The evaluation here will focus on the additional requirements and considerations associated with long-term monitoring of Site groundwater. Overall Protection of Human Health and the Environment This alternative is protective of human health and the environment under current conditions. This alternative would not be protective of human health for potential future conditions involving residential use. Compliance With ARARs Monitoring of Site groundwater wells would allow assessing the effectiveness of natural remediation mechanisms towards achieving remediation goals. Monitoring wells would be installed per EPA Region IV SOPQAM requirements. The remainder of the evaluation under this criterion would be the same as for Alternative GWC-1 A (Section 7.2.1.1 ). ~ Long-term Effectiveness and Permanence Pesticide levels at the Site would decrease through natural mechanisms (e.g., degradation and attenuation of Site chemicals) under this alternative. Periodic monitoring of Site groundwater would be conducted to evaluate the rate of pesticide reductions. The existing groundwater divide forms a preferential flow path for contaminant migration that, along with the limited aquifer depth, would allow effective monitoring of Site groundwater in the uppermost aquifer. Additional monitoring wells would be installed in the second uppermost aquifer to allow better characterization. Since waste residuals would remain at the Site, review of the effectiveness and protectiveness of the no action alternative every five years would be required by SARA. Pesticide concentrations in Site groundwater are anticipated to 9ecrease by approximately 90 percent over a five year Geigy FS 7-8 March 16, 1992
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period (Appendix D). Projected degradation rates are based on published soil data and may
overestimate the rates in groundwater. Actual degradation rates would be determined through
sampling and analysis of Site groundwater monitoring wells.
Reduction of Toxicity, Mobility or Volume
Natural mechanisms would effect a gradual reduction in contaminant concentrations that could
be evaluated through the system of monitoring wells.
Short-term Effectiveness
This alternative presents no risks to the community, on-site workers or the environment through
its implementation. This alternative can be implemented immediately following the installation of
any additional monitoring wells. Installation of the proposed additional monitoring wells would
take approximately one month.
Implementability
Numerous monitoring wells have been installed at the Site. Construction of additional wells, if
necessary, would pose no significant technical concerns. Groundwater flow is the sole migration
pathway and this can be readily monitored using the monitoring well network in conjunction with
select additional wells. The no action alternative would not hinder the implementation of any
remedial action in the future.
The no action alternative would include institutional controls to govern future use of the Site. The
adequacy of these controls to protect human health,would be evaluated periodically (e.g., during
the five-year review of remedy under SARA) to establish their effectiveness.
Cost
Capital costs include the construction of four additional monitoring wells. Operating costs
include periodic sampling of selected monitoring wells, chemical analyses, reporting and review
of the Site conditions every five years. Monitoring costs are conservatively based on a period
of 30 years, the maximum allowed under EPA guidance. Monitoring requirements would be
lessened if natural degradation mechanisms achieve the remediation goals in a shorter period.
Pesticide concentrations are projected to decrease to remediation goals in 1 O years through
Geigy FS 7-9 March 1 6, 1992
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natural mechanisms (Appendix D). As a sensitivity analysis, present worth costs are estimated
for a remediation period of 1 O and 30 years. Maintenance costs would include inspection of the
monitoring wells.
The detailed cost estimate for this alternative is presented in Appendix F. A summary of the
estimated costs is given below:
Total Construction Costs -
Present Worth O&M Costs -
Total Present Worth Costs -
REMEDIATION PERIOD
10 years
$130,000
$740,000
$870,000
30 years
$ 130,000
$1,500,000
$1,600,000
7.2.2 ALTERNATIVE GWC-2: Slurry Wall and Cap
This alternative would involve construction of an interconnected slurry wall and cap system to
contain Site groundwater. The slurry wall would be keyed into the uppermost aquitard. The cap
would prevent infiltration from entering the slurry wall enclosure and creating an outward
hydraulic gradient. Extraction wells would be located outside of the slurry wall in the uppermost
aquifer and in the second uppermost aquifer.
Slurry wall construction would involve excavating a trench under slurry to depths ranging from
45 to 70 feet. Excavations to these depths approaches the limits of technical feasibility and
would require special excavation equipment with extended reach capability (Section 5.3.4). The
northern and southern slurry walls would be constructed entirely within the Highway 211 and the
Aberdeen & Rockfish railroad right-of-ways, respectively. Approval from the North Carolina
Department of Transportation (NCDOT) and the Aberdeen & Rockfish railroad would be required
before construction within their respective right-of-ways could begin. Extensive rerouting of
utilities would be required where utilities are present. Major disruptions of highway and railroad
traffic would occur during construction of the northern and southern slurry walls, respectively.
Geigy FS 7-10 March 16, 1992
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The rail line crossing the southern portion of the Site would have to be rerouted approximately
120 feet to the south, allowing a buffer zone from the drainage swales of the cap (Figure 5.3).
Actual placement would be determined during Remedial Design, should this alternative be
selected. Compacted fill would be required to form the subgrade since relocation would place
the track in a depression. The rail line is a major local railway and rerouting would involve the
following activities:
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purchase of the new right-of-way
transfer of train traffic to other lines during construction
dismantling of the existing line
placement of compacted fill to form the subgrade
construction of the new line
testing the new line prior to full service .
Rerouting of the rail line is a lead item that would precede construction of the cap and slurry wall.
Any delays in obtaining the right-of-way or other institutional requirements (e.g., Department Of
Transportation approval, rezoning of property) would delay the overall remedial schedule.
Construction of the new rail line would require approximately one month following receipt of all
necessary approvals.
Once constructed, the slurry wall would effectively reduce the limited mobility of pesticides in the
uppermost aquifer. A low permeability cap would be constructed above the perimeter of the
slurry wall to minimize infiltration within the slurry wall. Capping is a proven and effective
technology that can be readily implemented at the Site using standard construction techniques
following rerouting of the Aberdeen & Rockfish railroad tracks. Engineered drainage swales
would be constructed to divert surface runoff away from the tracks. The cap would be
constructed solely for the purpose of restricting infiltration within the slurry wall to minimize the
amount of groundwater collected.
Construction of a cap involves the use of heavy earth moving and grading equipment. Existing
access may have to be improved for optimal use of this equipment. Clearing of brush
contiguous .to the capping areas may be required. Vegetation and any stumps would be
Geigy FS 7-11 March 1 6, 1992
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grubbed below the surface to prevent regrowth and ground water observation wells not needed
for long-term monitoring would be abandoned. The cap would be constructed of a single layer
synthetic liner over the compacted sub-base.
A multi-layer cap including compacted clay, as specified under RCRA, is not felt to be appropriate
for the Site. EPA's Hydrological Evaluation of Landfill Performance (HELP) model has been
applied at similar sites to evaluate caps based on the following low permeability barriers (Sirrine,
March 1991):
• 40-mil high density polyethylene (HOPE) liner and one foot of compacted clay
• 60-mil HOPE liner.
The model determined that there was no significant differences in performance of the two
capping systems. Shipping the required qtJantities of clay to the Site would increase costs
without increasing the effectiveness of the remedy. The long-term reliability of synthetic liners
is well established (Gundle, 1990) and a redundant barrier should not be necessary. Single
synthetic liners have been approved to cap areas at other CERCLA sites in Region IV (Sirrine,
June 1990). A 60-mil HOPE liner would therefore be the most appropriate low permeability barrier
to achieve Site capping requirements. For purposes of the Feasibility Study, the Site caps would
consist of a compacted sub-base of common and select fill, 60-mil HOPE liner, drainage net, filter
fabric, soil cover and vegetation. Permeability of the cap would be approximately 1 x 1 o-13 cm/s
(Gundle, 1990). Actual design and materials of construction would be determined in the
Remedial Design phase, should a capping alternative be selected for implementation.
Area of the cap would be approximately 3 acres. The cap would be tied into the slurry wall to
form an integral unit. Drainage swales would be constructed along the cap perimeter to control
surface run-on and direct cap run-off. A security fence would be constructed along the perimeter
of the cap to deter unauthorized access.
Geigy FS 7-12 March 16, 1992
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Placement of the cap would be as presented in Figure 5.3. Materials beneath the cap would
consist of well-drained silty-sand soils. These soils are adequately consolidated and substantial
settling beneath a cap is not anticipated. Markers would be placed on the cap to define any
settlement. Appreciable gas generation beneath the cap would not be anticipated.
Permeability of the uppermost aquitard that was measured is less than 1 E-07 cm/sec, forming
a competent barrier to any vertical migration of pesticides. Permeability of the slurry wall would
be equivalent. For purposes of the FS, the slurry wall would be constructed using the bio-
polymer (B-P) method described in Section 5.3.4. Actual construction methods would be
determined during Remedial Design, should this alternative be selected.
Length of the circumferential slurry wall would be approximately 40 to 70 feet. An extra five feet
should be allowed in construction of the slurry wall for keying into the confining layer and any
surface preparation. Keying a slurry wall to depths of 70 feet or more is difficult process requiring
specialized equipment. Geotechnical borings would be have to be conducted along the
perimeter of the slurry wall to define design parameters prior to construction. Width of the slurry
wall would be approximately three feet. Layout of the cap and slurry wall system is shown in
Figure 5.3.
Groundwater recovery within the slurry wall would be accomplished using well point extraction.
Groundwater recovery would be necessary to maintain a hydraulic differential across the slurry
wall which would restrict groundwater migration outward from the slurry wall. Recovery would
be required along the north and south sides of the slurry wall, where there exists an outward
gradient. An evaluation of the potential infiltration through the cap and groundwater flow through
the slurry wall was conducted to estimate the recovery rate necessary to maintain a sufficient
gradient (Appendix D). Based on these calculations, a total recovery rate of approximately four
gpm would be necessary to maintain an inward gradient.
The slurry wall would have no effect upon groundwater in the second uppermost aquifer.
Groundwater recovery would be implemented outside of the cap/slurry wall system for
groundwater exceeding MCLs. One recovery well would be placed in the uppermost aquifer in
the vicinity of MW-1 OS and two recovery wells would be placed in the second uppermost aquifer
Geigy FS 7-13 March 1 6, 1992
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in the vicinity of MW-11 D. The combined flow rate for these outside recovery wells would be
approximately 16 gpm (Appendix D), making the total extracted flow rate under this alternative
approximately 20 gpm. Actual well locations and flow rates would be established during
Remedial Design.
Treatment of the recovered groundwater within the slurry wall is a secondary consideration under
this containment strategy and is necessary only because treatment would be required before
discharge of the groundwater. Active groundwater restoration would occur outside of the slurry
wall through the three dedicated extraction wells. Treatment of pesticides in the extracted
groundwater would be by carbon adsorption. Disposal of the collected leachate/groundwater
would depend upon actual recovery rates and permitting requirements. Disposal options are the
POTW and an on-site infiltration gallery. For the purpose of this FS, discharge to the POTW will
be assumed since it is the more costly option. Actual disposal requirements would be
determined during Remedial Design, should this alternative be selected for the Site.
Further characterization will be conducted in the second uppermost aquifer under this alternative
to determine the source and extent of TCE contamination. This characterization will be
conducted during the pre-design activities associated with groundwater containment and
remediation and will not impact the remediation schedule. Site-related TCE contamination found
within the second uppermost aquifer will be remediated through groundwater extraction and
activated carbon treatment, as will be done for remediation of pesticides in Site groundwater.
Design parameters for the Site groundwater remediation system will be determined during
Remedial Design. This alternative includes four additional monitoring wells to further.characterize
the nature of TCE in the second uppermost aquifer. Actual characterization requirements would
be established during Remedial Design.
Protection of Human Health and the Environment
This alternative would either contain or treat groundwater exceeding MCLs and therefore would
be protective of human health. Deed restrictions could be required to prevent future access to
groundwater contained within the cap/slurry wall system.
Geigy FS 7-14 March 16, 1992
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Compliance with ARARs
Compliance with location-specific and chemical-specific ARARs is as described for Alternative 1 A
(Section 7 .2.1 .1).
RCRA treatment and disposal requirements are not ARAR for capping at the Site. However, the
single synthetic liner design would still meet an equivalent performance standard of RCRA (40
CFR 264.310), as follows:
i) provide long-term minimization of migration of liquids
ii) function with minimum maintenance
iii) promote drainage and minimize erosion or abrasion of the cover
iv) accommodate settling and subsidence to maintain cover integrity
v) have a permeability less than that of natural subsoils.
Actual design requirements would be specified during Remedial Design.
All construction activities would take place above the 100-year flood plain. The Health and Safety
Plan governing all remedial activities would conform to 29 CFR 1910.120.
Fencing around the capped area would discourage future uses. Deed restrictions could be
included in the implementation of this alternative as a secondary control measure to prevent uses
of the Site that could reduce the effectiveness of remedial measures.
Rerouting of the rail line would have to comply with all applicable Federal and North Carolina
Department of Transportation requirements. Property access would have to be obtained to
create the new right-of-way and the property would have to be rezoned.
Long-term Effectiveness and Permanence
Implementation of this alternative would reduce the magnitude of risks at the Site by treating
groundwater in the second uppermost aquifer and containing groundwater in the uppermost
aquifer. Containment of Site groundwater is considered only to control any off-site migration in
Geigy FS 7-15 March 16, 1992
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the uppermost aquifer. Groundwater in the second uppermost aquifer would not be controlled
by the slurry wall and would be addressed through separate recovery wells.
Long-term stability of the cap should be excellent with regular inspections and maintenance.
Underlying Site materials are primarily inert and minimal settling is anticipated. Synthetic liners
can accommodate slight settling due to their resiliency. Periodic inspections would be required
to check for erosion, settling and conditions of the drainage system. Deterioration of cap
integrity must be identified and corrected quickly to maintain effectiveness. The integrity of the
security fence must also be maintained to deter unauthorized access. An established inspection
and maintenance schedule would be implemented following construction and continued for as
long as chemical residuals remained at the Site. Regular care of the cap system would preserve
its effectiveness indefinitely.
Caps have been constructed at numerous CERCLA sites with excellent results. Proper
construction and regular maintenance would allow a perpetual operating life. Future
replacement, if required, should be straightforward since the earthwork would have already been
completed. Potential risks are considered minimal should elements of the cap require repair or
replacement.
Construction of slurry walls in soils such as those at the Site is a straightforward operation that
has been conducted successfully at numerous sites. The complicating factor at the Site is the
depth to the uppermost aquitard. Constructing a slurry wall at depths of 70 feet requires special
equipment and increases the difficulty of forming a competent seal with the clay aquitard.
Evaluation of the aquitard connection during construction is difficult since the wall is constructed
under a slurry. Evaluating the effectiveness of this alternative would have to be performed
through periodic groundwater monitoring.
Once constructed, the integral cap and slurry wall system will be a permanent installation. The
system can be maintained indefinitely through regular inspections and maintenance.
Since compound residuals would remain with the slurry wall, review of the effectiveness and
protectiveness of this alterative every five ye,ars would be required by SARA. Inspection and
Geigy FS 7-16 March 16, 1992
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maintenance records for the cap as well as groundwater monitoring results would be reviewed
at this time. The cap and slurry wall will be a permanent installation that would require review
indefinitely. Conditions in the uppermost aquifer are anticipated to improve slightly through
containment, as groundwater recovery will be directed at gradient control rather than contaminant
removal. The potential for off-site migration of groundwater will be reduced through containment.
Deed restrictions would be required to deny future access to groundwater within the slurry wall.
Conditions in the second uppermost aquifer are anticipated to improve as the groundwater is
restored through recovery and treatment.
Reduction of Toxicity, Mobility, or Volume
Treatment of groundwater in the second uppermost aquifer and a portion of the uppermost
aquifer would effect a permanent reduction in Site pesticide concentrations. Containment would
permanently reduce the mobility of pesticides in the uppermost aquifer.
Short-term Effectiveness
Environmental impacts as a result of cap and slurry wall construction would be minimal. Erosion
control measures would be required during cap construction to prevent soil loss through surface
runoff.
Grubbing and grading of the Site would be necessary for construction of the cap. Dust control
would be exercised to minimize the potential release of air-borne particulates. Worker safety
would be controlled through adherence to the remedial health and safety plan.
Rerouting of the rail line, and the associated institutional requirements, would be a significant
schedule concern. The time to obtain property access, DOT approval, and rescheduling of train
traffic is unknown but would likely be substantial. Construction of the cap and slurry wall would
require easements for construction in the highway right-of-way and coordination with local town,
utility and highway personnel. Construction would result in significant impacts on traffic along
Highway 211. The highway is a primary regional transportation route, with substantial truck traffic
observed during the RI.
Geigy FS 7-17 March 16, 1992
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Construction of the cap and slurry wall could not begin until all materials are available and
adequate access (e.g., rerouting of the rail line) had been developed. Implementation time would
depend on the number of crews involved but should be approximately eight months. This
schedule assumes standard production rates and compliance with all inspections of performance
requirements and workmanship. Adverse climatic conditions could hinder construction
performance and delay the schedule. Construction should be scheduled to facilitate revegetation
immediately after final grading.
Containment of the uppermost aquifer would be continued indefinitely to maintain control. The
time to achieve remediation levels in the second uppermost aquifer can only be estimated
approximately due to adsorption and hysteresis effects upon mass transfer chemistry between
soils and groundwater. The estimated time to achieve remediation goals based on a continuous
flushing model (EPA, December 1988) that incorporates degradation (Appendix D) would be
approximately five years. Without degradation, the time to achieve remediation goals would be
approximately 1 O years. Based on groundwater extraction at other CERCLA sites, these time
frames are likely underestimated (EPA, September 1989). Based on studies by EPA and other
researchers, the effectiveness of pump and treat remediation systems is 'falling far short of the
estimates made during feasibility studies" (NRC/NAS, 1991 ). Projections of the remedial time
frame would be updated throughout remediation.
Implementability
Construction of a cap is a straightforward operation that has been accomplished at numerous
waste si\es. Clearing of the Site and establishment of access for heavy machinery should pose
no difficulties. Caps have been successfully implemented at other CERCL.A sites.
The availability of common and select fill material should be adequate but procurement and
transportation could control the construction schedule. A drainage system would have to be
constructed along the perimeter of the cap. Special design techniques would be required along
the northern boundary to prevent run-off onto the highway considering the limited separation.
The culvert crossing under Highway 211 west of the Site would have to be replaced with a larger
size. The drainage system would collect only rainwater, which would be redirected to the land
Geigy FS 7-18 March 16, 1992
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surface. Cover design would have to consider possible freezing in the drainage system during
winter.
Liner installation would have to be scheduled for suitable climatic conditions. Seams may be
welded under freezing conditions but not during periods of precipitation. Final construction
should allow for vegetation during the growing season. Hauling the required quantities of
materials to the Site may impact traffic patterns and cause road wear. A staging area would be
required outside of the area to be capped.
Lead time for the HOPE liner and geotextile materials is approximately one month and
competitive sources should be available. Identification of the common and select fill sources
would be the single greatest lead item. Cap construction is a common remedial measure and
there should be a number of qualified bidders.
Cap maintenance can be readily implemented. Periodic cap maintenance would primarily involve
grass cutting and clearing any accumulation in the drainage swales. Inspections would be
required to determine whether repairs to the cap, drainage system, or fence are required.
The native soils will facilitate construction of a competent slurry wall, although cement might be
added to the admixture for structural support. Construction of a slurry wall to the required depths
approaches the limit of technical feasibility and would require specialized equipment. Achieving
an adequate interconnection with the uppermost aquitard would be difficult to confirm during
construction. The number of firms qualified to construct a slurry wall to this depth is limited.
Effectiveness of the containment system would be evaluated through water level measurements
inside and outside of the slurry wall along with groundwater water analyses in the outlying
monitoring wells.
Cost
Construction costs associated with this alternative include rerouting of the rail line, mobilization,
excavation, grubbing, grading, earth work, slurry wall installation, the groundwater recovery and
treatment system, materials, and labor. Operating costs if)clude operation of the groundwater
Geigy FS 7-19 March 16, 1 992
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recovery and treatment system, maintenance of the cap and review of the Site remedy every five
years. Sampling is assumed to be a biannual event focused on indicator parameters. Active
removal of pesticides from groundwater in the uppermost aquifer is not a primary objective of this
alternative and the containment system would remain in perpetuity. Operating costs are therefore
based on a remedial period of 30 years, the longest allowed under EPA guidance. Maintenance
costs include periodic inspections and grounds keeping.
The detailed cost estimate for this alternative is presented in Appendix F. A summary of the
estimated costs is given below:
Total Construction Costs -
Present Worth O&M Costs -
Total Present Worth Costs -
$8,400,000
$1,800,000
$10,000,000
7.2.3 ALTERNATIVE GWC-3: Groundwater Recovery to Attain MCL.s
This alternative involves the recovery of groundwater such that MCLs would be attained at the
Site. MCL.s are considered ARAR for the uppermost and second uppermost aquifers at the Site.
Pesticide contamination would be removed through extraction wells placed in the uppermost and
second uppermost aquifers and reduced through treatment by activated carbon. Discharge
would be either to the Moore County sewer system or to an on-site infiltration gallery.
The proposed extraction system would involve installation of approximately nine recovery wells,
as shown in Figure 5.1. Seven wells would be installed in the uppermost aquifer and two in the
second uppermost aquifer. The total extracted flow rate is anticipated to be approximately 20
gpm. Actual design of the extraction system would be established during Remedial Design,
potentially through aquifer testing. Capture zone effectiveness would be evaluated through
aquifer response measurements conducted during construction of the overall extraction system.
The average flow rate per well screened in the uppermost aquifer would be approximately 0.5
gallons per minute (Appendix D). Such low flow rates would require use of a pneumatic pump
system or low flow 2-inch electric submersible pumps (Grundfos Redi-Flo2 or equivalent). Either
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system would require a sensitive pump controller to maintain the required low flow rates.
Recovery wells in the second uppermost aquifer would produce at approximately 5 -1 o gpm and
could use standard electric submersible pumps.
Compounds potentially requiring treatment in the extracted groundwater are limited to pesticides.
Estimated maximum concentrations in the extracted groundwater are presented in Table 7.1.
Pesticides would be treated through activated carbon adsorption.
Discharge of treated groundwater would be to the Moore County Publicly Owned Treatment
Works (POTW) or to an on-site infiltration gallery. Discharge to the POTW would require
construction of a force main to the nearest manhole, approximately 1/2 mile away. To be
conservative, construction requirements for an infiltration gallery are based on a nominal
application rate of 0.5 gpd/tt2. The actual method of discharge and operating parameters would
be established during Remedial Design.
For purposes of the FS, groundwater treatment would involve the following elements:
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manifolding of the extraction well piping to the treatment system
concentration equalization
carbon adsorption canisters
transfer pumps
flow measurement and sampling
discharg~ line to the Moore County POTW or to an infiltration gallery .
The conceptual flow diagram for groundwater treatment is presented in Figure 7.1. Actual
treatment requirements would be established during Remedial Design, should this alternative be
selected. This alternative would include monitoring of on-site and off-site groundwater wells to
evaluate capture efficiency and the reduction in pesticide concentrations.
Carbon adsorption is considered to be the best available technology (BAT) for the removal of
pesticides from water (56 FR 3526). The treatment system would involve two carbon adsorption
canisters in series, to maximize carbon usage and provide protection against breaklhrough. For
Geigy FS 7-21 March 16, 1992
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a total flow rate of 20 gpm and a blended total pesticide concentration of approximately 0.1 mg/I,
the total pesticide loading to the treatment system would be approximately ten pounds per year.
A standard canister containing 200 pounds of carbon would be expected to last approximately
two years at this loading. Breakthrough of the carbon would be monitored as part of the annual
operations and maintenance requirements. For purposes of the FS, pesticides in the effluent
would be below CLP quantitation limits. Actual treatment requirements would be determined
during Remedial Design and be dependent on the final discharge limits.
Further characterization will be conducted in the second uppermost aquifer under this alternative
to determine the source and extent of TCE contamination. This characterization will be
conducted during the pre-design activities associated with groundwater remediation and will not
impact the remediation schedule. Site-related TCE contamination found within the second
uppermost aquifer will be remediated through groundwater extraction and activated carbon
treatment, as will be done for remediation of the pesticides in Site groundwater. Design
parameters for the Site groundwater remediation system will be determined during Remedial
Design. To provide further characterization, this alternative includes the installation of four
additional groundwater monitoring wells in the second uppermost aquifer. Actual monitoring
requirements would be established during Remedial Design.
Protection of Human Health and the Environment
This alternative would attain MCLs and therefore be protective of human health. Operation of the
treatment system would be contained and present no opportunity for human exposure outside
of controlled maintenance activities. Effluent to the POlW or infiltration gallery would be within
discharge limits and therefore protective.
Compliance with ARARs
This alternative would attain MCLs and therefore comply with ARARs. Discharge to the POlW
would comply with the MCSSA sewer use ordinance. Discharge to an infiltration gallery would
• have to comply with ,the substantive requirements of a Non-Discharge Permit (15A NCAC
2H.0200), as administered by the State of North Carolina. The permit itself would not be required
since discharge to an infiltration gallery would be conducted entirely on-site. On-site CERCLA
actions are exempt from the administrative requirements of permits (SARA 121 (e)(1 )).
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Transportation and disposal of spent carbon would comply with EPA and State manifesting
requirements and DOT regulations. Spent carbon would only be sent to a RCRA TSO facility in
full compliance with its Part B permit, to be in accordance with EPA's off-site policy (OSWER Dir.
9834.11).
Long-term Effectiveness and Permanence
Extraction wells would achieve removal of groundwater for subsequent treatment. Groundwater
recovery via extraction wells and submersible pumps is a proven technology that has a high
degree of reliability. Maintenance consists of periodic inspection of the wells, pumps and control
units.
Carbon adsorption is an effective and reliable process for achieving high removal levels of
pesticides from groundwater. Based on the Koc values in Table 4.3 and maximum influent
groundwater concentrations in Table 7.1, a dual canister carbon adsorption system would be
capable of achieving the projected discharge levels. The removal of pesticides by activated
carbon is considered Best Available Treatment by EPA and no treatability testing would be
required. Carbon systems have few mechanical parts and are designed to run unattended with
minimal maintenance. Maintenance would consist of periodic inspection of the fittings and
analyses of the individual canister effluents.
Effluent from the groundwater treatment system would satisfy all discharge requirements and
would not adversely impact the receiving system. Periodic effluent sampling would be required
for either discharge option.
Groundwater would be taken to essentially background levels, since pumping would continue
until MCLs would not be exceeded off-site. A five-year review of remedy would therefore not be
required once the remediation levels were achieved.
Aquifer desorption kinetics and the limitations of groundwater recovery indicate that the
achievement of MCLs at any site is problematic. Where remediation goals are below 1 mg/I, such
as for gamma-BHC (0.2 ug/1), groundwater extraction will not be effective in achieving these levels
in a "reasonable time frame" (NRC/NAS, 1991 ). Groundwater concentrations tend to level off
Geigy FS 7-23 March 16, 1992
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asymptotically following initial reductions in concentration for compounds with moderate to high
koc values (such as pesticides). Monitoring well data would be reviewed on a regular basis to
determine when the extraction system had reached the limits of technical capability and further
pumping would be of limited benefit. The effectiveness evaluation would comply with North
Carolina's criteria for discontinuance of a remedial system.
Reduction of Toxicity, Mobility, or Volume
Groundwater extraction would reduce the volume of chemicals at the Site while the subsequent
treatment would reduce the toxicity of groundwater prior to discharge. The mass of pesticides
in groundwater would be reduced by approximately 99 percent should the remediation goals be
attained (based on reducing gamma-BHC levels to 0.2 ug/1). Carbon adsorption of groundwater
would comply with SARA's preference for remedies involving treatment.
Short-term Effectiveness
Installation of extraction wells would pose no health risks to the community. On-site workers can
be protected from potential risks through adherence to the remedial health and safety plan.
Construction of the groundwater treatment facility would pose no risks to the community or on-
site workers. There would be no emissions or releases from the treatment system.
Installation of the extraction wells and subgrade utilities would take approximately three months.
Installation of the groundwater treatment system and construction of a discharge system would
require approximately three months and could occur simultaneously with other remedial activities.
The time to achieve remediation levels can only be estimated approximately due to adsorption
and hysteresis effects upon mass transfer chemistry between soils and groundwater. The
estimated time to achieve remediation goals based on a continuous flushing model (EPA,
December 1988) that incorporates degradation (Appendix D) would be approximately five years.
Without degradation, the time to achieve remediation goals would be approximately 1 O years.
Based on groundwater extraction at other CERCLA sites, these time frames are likely
underestimated (EPA, September 1989). Based on studies by EPA and other researchers, the
effectiveness of pump and treat remediation systems is 'falling far short of the estimates made
Geigy FS 7-24 March 16, 1992
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during feasibility studies" (NRC/NAS, 1991 ). Projections of the remedial time frame would be
updated throughout remediation.
Implementability
Numerous· monitoring wells have been constructed at the Site and no difficulties are anticipated
in construction of the extraction wells. Distribution lines to the groundwater treatment system
would be below grade and heat traced to prevent potential freezing where placed above the frost
line.
Installation of a carbon adsorption system at the anticipated flow rate would have no special
installation requirements and the groundwater treatment system should be readily constructed.
Design of the treatment system could not be completed until discharge requirements were
defined.
Installation of a force main approximately 1 /2 mile to the nearest manhole would require
placement in right-of-ways and through the highway but would involve standard construction
techniques and be readily implemented. The P01W sewer lines have adequate hydraulic
capacity to receive the maximum anticipated discharge rate.
Construction of an infiltration gallery at the Site is questionable based on the anticipated flow
rates, nominal infiltration rates, and available area. Percolation testing would be required during
Remedial Design to assess the potential for land application of treated groundwater at the Site.
Cost
Construction costs associated with this alternative include mobilization; extraction wells and the
groundwater distribution system; the groundwater treatment system; discharge system; and utility
connections. Operating costs include power and maintenance for the extraction wells; labor,
power and sampling for the treatment system; and groundwater monitoring. Present worth costs
are nominally based on a projected groundwater remediation period of ten years. Because of
the uncertainty regarding the limitations of groundwater extraction in achieving remediation goals,
a sensitivity analysis has been prepared for this alternative based on the maximum allowed
remediation period of 30 years. For cost estimating purposes of the FS, sampling is assumed
Geigy FS 7-25 March 16, 1992
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to be a biannual event focused on indicator parameters. Actual monitoring requirements would
be established in Remedial Design. Maintenance costs include facility inspections and
equipment repair.
Costs for this alternative are based on discharge to the POTW, which would have both higher
construction and operating costs than discharge to an infiltration gallery. The detailed cost
estimate for this alternative is presented in Appendix F. A summary of the estimated costs is
given below:
REMEDIATION PERIOD
Total Construction -
Present Worth O&M Costs -
Total Present Worth Costs -
7.3 EXPOSURE CONTROL ALTERNATIVES
10 years
$ 710,000
$ 760,000
$1,500,000
30 years
$ 710,000
$1,500,000
$2,200,000
The purpose of exposure control is to address surficial soils at the Site that exceed the
acceptable range specified by the NCP of 1 E-04 to 1 E-06 for lifetime excess cancer risks (LECR).
The Baseline Risk Assessment (summarized in Section 3) determined that surficial soils represent
the following cumulative risks:
• ECR of 9E-06 based on current conditions
• LECR of 4E-05 based on a hypothetical fyture resident.
The current risk level is equal to the "point of departure" specified in the NCP for determining
remediation goals. Site soils therefore do not require remediation based on current conditions.
Based on the NCP's range of acceptable risks, it is appropriate to develop remedial alternatives
corresponding to 1 E-04, 1 E-05, and 1 E-06 risk levels based on potential future conditions. Site
soils would satisfy the 1 E-04 levels without further remediation. Cleanup levels corresponding
to 1 E-05 and 1 E-06 risk levels were developed in Appendix E of the Baseline Risk Assessment.
The derivation of health-based remediation levels is si,immarized in Section 4.1.3.2. Essentially,
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the rate limiting compound for Site risks was determined to be toxaphene. To calculate potential
remediation requirements, the highest toxaphene sample was removed from the Site and the
cumulative soil risks were recalculated. This process was repeated until Site risks were within
an LECR of 1 E-05 and 1 E-06. Through this process, it was determined that removal of all
toxaphene concentrations greater than 50 mg/kg would result in a residual LECR of 1 E-05. The
removal of all toxaphene concentrations greater than 5 mg/kg would result in a residual LECR
of 1 E-06. These are the surficial soil remediation levels for the Geigy Site. The removal of
toxaphene to 5 mg/kg would also reduce the levels of BHC isomers, DDT and other pesticides
concurrently.
There is no definitive guidance to determine which residual risk level should be used to guide
remedial efforts at a site. Factors to be considered include existing land use, encroachments,
potential future land use, area demographics, site control and natural degradation mechanisms.
Salient factors for the Geigy Site are as follows:
• The Site is bordered by a major State highway (Route 211), an active railway, and
a dirt road. The closest residence is approximately 400 feet to the east. A housing
development is located approximately 1 /4 mile to the northwest.
• Existing right-of-ways include the State highway (50 feet from the centerline), the
Aberdeen & Rockfish railroad (80 feet), and a power line (15 feet). Right-of-ways are
described in more detail in Section 2.1.9.
• Future land use at the Site is considered unlikely because of the unattractive
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Geigy FS
encroachments and the availability of affordable land in the area. The existing fence,
building foundation, and rail line would deter future development of the Site.
The potential for groundwater remediation must be considered in the context of
overall Site remediation. Site groundwater exceeds ARARs and the selection of an
active groundwater remedy is plausible. Groundwater remediation would continue
for approximately five to ten years based on the projections in Appendix D but would
likely be longer based on groundwater recovery at other CERCLA sites. The
presence of an active remediation system would provide active control of the Site
and deny unauthorized use.
7-27 March 1 6, 1992
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• The environmental half-life for toxaphene is reported in the literature to range from
1 to 14 years (Appendix C). The site-specific half-life was estimated to be
approximately 4 years, based on a calibration of pre-removal soil concentrations with
groundwater concentrations. Using this half-life, toxaphene concentrations at the
Site should decrease by more than 80 percent over a ten year period.
In summary, residential development cannot be ruled out but the potential is extremely limited,
especially if any groundwater remediation efforts are implemented. These factors could favor
application of an LECR less conservative than 1 E-06 as the remediation level for Site soils. The
existing LCER of 4E-05 or alternatives representing a 1 E-05 LECR are within the acceptable risk
range specified by the NCP and would be considered protective. Furthermore, EPA guidance
states that remedial action is generally not warranted when the current and future reasonable
maximum exposure cases are less than 1 E-04 (EPA, April 1991 ).
The maximum volume of Site soils requiring remediation is approximately 670 cubic yards based
on attaining an LECR of 1 E-06. As discussed in Section 5, this limited volume of material has
precluded the mobilization of many direct treatment technologies and directed alternative
development towards off-site and containment actions. Remedial alternatives for exposure
control retained from Section 6 include no further action, off-site disposal, and capping. The
detailed analysis of these alternatives is presented below.
7.3.1 Alternative EC-1: No Further Action
Extensive soil removal actions were conducted in 1989 and 1991 (Section 2.4). Approximately
2100 tons of contaminated soil have been disposed of or treated at RCRA TSO facilities. The
effect of these actions has been to reduce average Site toxaphene and total BHC concentrations
by 99 and 91 percent, respectively. Because of the removal actions, Site soils are now within
the range of acceptable risks specified by the NCP. Under this alternative, no additional soils
remediation would occur.
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Overall Protection of Human Health and the Environment
Results of the Baseline Risk Assessment (Clement, 1992) are presented in Section 3 and
summarized in Tables 3.1 and 3.2. The NCP specifies an acceptable exposure level range of
1 E-04 and 1 E-06 for carcinogenic risks (40 CFR 300.430(e)(i)(A)(2)). Risk levels less than 1 E-06
are not considered significant. Under current conditions, Site soils represent a cumulative LECR
of 9E-06, which is within the acceptable range. Noncarcinogenic health risks are insignificant.
The no further action alternative would therefore be protective of human health under current
conditions.
The Baseline Risk Assessment also considered a future use scenario involving potential
residential use of the Site. Under this scenario, Site soils represent a cumulative risk of 4E-05.
This risk level is also with the acceptable range of the NCP. Noncarcinogenic health risks are
insignificant. The no further action alternative would also be protective of human health in the
future.
The ecological risk assessment determined that the potential for exposure of most species was
low based on the small size and limited habitat value of the Site when compared to the
surrounding area. Overall ecological impacts are not predicted to occur. The no action
alternative would therefore be protective of the environment.
Compliance with ARARs
There are no Federal or State ARARs for pesticides in soils. Potential location-specific ARARs
are presented in Section 4.1.2 and summarized in Table 4.1. No endangered species or areas
of significant historical importance were identified at the Site. The no further action alternative
therefore does not violate any location-specific ARARs. There are no action-specific ARARs for
this alternative.
Long-term Effectiveness and Permanence
The magnitude of remaining risks would be essentially unchanged under this alternative except
through natural degradation mechanisms, such as biodegradation and volatilization. Since waste
residuals would remain at the Site, review of the effectiveness and protectiveness of the no
Geigy FS 7-29 March 16, 1992
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further action alternative every five years would be required by SARA. Conditions at the Site
would be expected to improve slightly over a five year period due to natural degradation.
Reduction of Toxicity, Mobility and Volume
This alternative would not significantly reduce the levels of pesticides in Site soils over the short
term. A slight level of remediation might occur through natural mechanisms such as
biodegradation.
Short-term Effectiveness
This alternative can be implemented immediately without environmental impact or increased
community or worker exposure.
Implementability
The no further action alternative could be readily implemented and would not hinder the
implementation of any remedial actions in the future. No Site maintenance would be required.
Cost
There are no construction costs. Operating costs would involve a review of remedy every five
years. The detailed cost estimate for this alternative is presented in Appendix F. A summary of
the estimated costs is given below:
Total Construction Costs -
Present Worth O&M Costs -
Total Present Worth Costs -
$ 0
$140,000
$140,000
7.3.2 Alternative EC-2: Off-Site Disposal
This alternative would involve the excavation and off-site disposal of Site soils exceeding a
specified LECR level. There are two options under this alternative:
• Alternative EC-2A: Off-site Disposal to Attain an LECR of 1 E-05
• Alternative EC-2B: Off-site Disposal to Attain an LECR of 1 E-06
Geigy FS 7-30 March 16, 1992
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Soils would be taken to either a secure landfill or a fixed-base incinerator, depending on their
regulatory disposition. Soils failing the toxicity characteristic leaching procedure (TCLP) test for
gamma-BHC (EPA No. D013) or toxaphene (EPA No. D015) would be considered hazardous by
characteristic and incinerated to satisfy land disposal restrictions (LDR). Soils passing the TCLP
test would be sent to a RCRA-approved landfill. Soil would be excavated to a depth of 12 inches
and placed in controlled stockpiles for analysis. Composite samples would be collected from
each pile and analyzed by the TCLP for gamma-BHC and toxaphene. The entire stockpile would
then be disposed according to its composite TCLP analysis. Results of the analysis would be
forwarded to the receiving facility as part of the approval process prior to transportation.
Confirmation sampling would be conducted to ensure the remediation goals had been attained.
Excavated areas would then be covered with clean fill and vegetated with a perennial grass.
For purposes of the FS, the following facilities would be used to establish cost and
implementation factors:
• Incinerator -Chemical Waste Management; Port Arthur, TX
• Landfill -USPCI; Grassy Mountain Facility, Clyde, UT
Transportation to CWM incinerator would be by truck (covered roll-off boxes) and to the USPCI
landfill would be by rail car. The actual facilities would be determined during Remedial Design
in accordance with EPA's off-site policy.
Dust control measures would be employed during excavation and transportation to limit the
potential for fugitive emissions. Clean fill would be placed at the Site and vegetated following
excavation.
Classification (Section 5.4.1) would be a potential pretreatment step associated with the
remediation of Site soils. Costs for a treatability study and classifying equipment are included
with each of the Alternative EC-2 options.
Geigy FS 7-31 March 16, 1992
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7.3.2.1 Alternative EC-2A: Off-site Disposal Attaining a 1 E-05 LECR
This alternative would involve the excavation of approximately 140 cubic yards of surficial soils
such that an LECR of 1 E-05 was attained at the Site. Excavation would be based on the removal
of all soils containing toxaphene exceeding a concentration of 50 mg/kg. Removal of this volume
of soils would require approximately seven roll-off containers or two rail cars. Implementation of
this alternative would be as described for commercial incineration, commercial landfilling and
classification (if practical) in Section 5 and summarized above. Off-site disposal of Site soils to
a secure landfill and an incinerator has been successfully accomplished during previous removal
actions (Section 2.4).
Overall Protection of Human Health and the Environment
This alternative would attain an LECR of 1 E-05 for Site soils. This risk level is within the
acceptable risk range of the NCP and therefore would be protective of human health.
Transportation of materials off-site would be conducted to minimize the potential for human
exposure through the use of wetting agents and covered containers to control fugitive emissions
down to safe driving practices and vehicle maintenance. Soils have been transported from this
Site without incident in the past.
Compliance with ARARs
The disposal of Site soils would have to comply with EPA's off-site policy (OSWER Dir. 9834.11 ).
Should the soils fail TCLP, disposal would, have to comply with the LOR for soil and debris
characteristic wastes (40 CFR 268.43(a)). There is currently a variance for soil and debris that
expires on May 8, 1992. The variance may be extended and its status should be evaluated
during Remedial Design. Soils would be transported by a licensed waste hauler and
transportation would comply with Federal (49 CFR Parts 171-173) and State requirements.
Chemical and location-specific ARARs for this alternative are as described for the no further
action alternative (Section 7.3.1 ).
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Long-term Effectiveness and Permanence
If implemented, this alternative would effectively and permanently remove all soils exceeding an
LECR of 1 E-05 from the Site. Confirmation sampling of the unearthed soils would be conducted
prior to removal activities to verify that all toxaphene levels greater than 50 mg/kg would be
removed. Potential risks exceeding an LECR of 1 E-05 would be eliminated. Remaining risks
associated with chemical residuals would be minimal. Clean fill would be replaced in the
excavation and vegetated to stabilize the Site.
Following completion of this alternative, the remediation goal of a 1 E-05 LECR would have been
attained. A review of remedy would therefore not be required.
Reduction of Toxicity, Mobility and Volume
Cumulative Site risks due to soils would be permanently reduced by approximately 75 percent
under this alternative. Pesticide levels in surficial soils would be reduced by approximately 67
percent, based on the reduction of toxaphene. Incineration of characteristically hazardous soils
would comply with SARA's preference for remedies involving treatment.
Short-term Effectiveness
Potential risks to trained on-site workers during excavation activities would be minimal and could
be controlled through adherence to the remedial health and safety plan. Personal protective
equipment would be worn by on-site workers to prevent direct exposure by inhalation or dermal
contact. Dust control and air monitoring would be exercised to minimize the potential impact of
airborne particµlates on the community. Following approved procedures, the potential for
excavation to impact the community would be minimal.
Excavation and disposal activities would not begin until all materials and equipment are available
and adequate access had been developed. Implementation time would depend on the number
of crews involved but should be less than one month. This schedule assumes standard
production rates and compliance with all inspections of performance and workmanship. Adverse
climatic conditions could hinder work efforts and delay the schedule.
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Implementability
Excavation, hauling and landfilling of soils is a straightforward operation that has been
accomplished at numerous waste sites. Clearing of the Site and establishment of access for
heavy equipment, if necessary, should pose no difficulties. Similar operations have been
implemented at the Geigy site and other CERCLA sites.
Transportation of Site soils would be coordinated with the handling schedule of the receiving
facility. The limited volume of Site soils should not affect any capacity limitations of a receiving
facility.
The efficacy of classification would be determined through treatability testing conducted during
Remedial Design. Classification at the Site would involve the use of commonly available
construction equipment that has adequate availability. Set up and operation should pose no
significant operating difficulties.
Cost
Construction costs associated with this alternative includes mobilization, excavation, earth work,
disposal (landfill and/or incineration), materials and labor. There would be no operating costs.
A sensitivity analysis was conducted based on whether soils would be considered hazardous by
characteristic or non-hazardous, and therefore disposed at a secure landfill, an incinerator, or a
combination of the two. To provide the greatest allowance for potential remediation costs, it was
assumed that all soils went either to a secure landfill (lowest cost) or to an incinerator (highest
cost). The greatest likelihood is that a portion of the soils would fail TCLP and be sent to an
incinerator while the remainder would be sent to a secure landfill. By presenting the costs of
both extremes, the actual remedial costs would likely fall somewhere in the range.
The detailed cost estimate for this alternative is presented in Appendix F. A summary of the
estimated costs is given below:
Total Construction Costs -
Present Worth O&M Costs -
Total Present Worth Costs -
Geigy FS 7-34
Landfilling
$110,000
$ 0
$110,000
Incineration
$360,000
$ 0
$360,000
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7.3.2.2 Alternative EC-2B: Off-site Disposal Attaining a 1 E-06 LECR
This alternative would involve the excavation of approximately 670 cubic yards of surficial soils
such that an LECR of 1 E-06 was attained at the Site. Excavation would be based on the removal
of all soils containing toxaphene exceeding a concentration of 5 mg/kg. Removal of this volume
of soils would require approximately 30 roll-off containers or eight rail cars. Implementation of
this alternative would be as_ described for commercial incineration, commercial landfilling and
classification (if practical) in Section 5 and summarized above (Section 7.3.2). Off-site disposal
of Site soils to a secure landfill and an incinerator has been successfully accomplished during
previous removal actions (Section 2.4).
The primary differences between this alternative and Alternative EC-2A are:
• risk levels attained
• volume of soils removed
• demolition of the building foundation to allow access to the underlying soils.
Evaluation of this alternative will focus on any significant differences with respect to Alternative
EC-2A and summarize any similarities. The differing risk levels and volume of soils removed are
addressed under the detailed criteria as appropriate. Demolition of the building foundation is the
only significant engineering difference. Removal of the foundation would require use of a
wrecking ball and/or bulldozer. Sizing of the resulting debris would require use of a crusher.
Steel reinforcement of the concrete (e.g., rebar) could represent problems in sizing and
separating the debris. Overall, demolition of the building would require heavy construction
equipment but should pose no significant difficulties.
The building foundation was apparently placed over existing soils as the facility expanded from
east to west and is not considered to be contaminated. As a precautionary measure, the
concrete was steam cleaned following demolition of the building superstructure during the last
removal. Concrete debris should therefore be acceptable for disposal at a municipal landfill such
as the Kernersville, North Carolina facility, a Subtitle D facility. For purposes of the FS, disposal
of building foundation debris would occur at the Kernersville Subtitle D facility. Confirmation
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testing would be conducted prior to disposal. As an alternative, crushed debris could be used
at the site for common fill or erosion control (rip-rap). For purposes of the FS, demolition debris
would be sent to the municipal landfill. Actual disposal requirements would be determined during
Remedial Design following confirmation testing.
Overall Protection of Human Health and the Environment
This alternative would attain an LECR of 1 E-06 for Site soils. This risk level is within the
acceptable risk range of the NCP and therefore would be protective of human health. The
remainder of the analysis under this criterion is as discussed for Alternative EC-2A (Section
7.3.2.1 ).
Compliance with ARARs
Disposal of foundation debris at the Kernersville, North Carolina municipal landfill would comply
with local, State and Federal (Subtitle D) requirements. The remainder of the analysis under this
criterion is as discussed for Alternative EC-2A (Section 7.3.2.1 ).
Long-term Effectiveness and Permanence
If implemented, this alternative would effectively and permanently remove all soils exceeding an
LECR of 1 E-06 from the Site. Confirmation sampling of the unearthed soils would be conducted
prior to removal activities to verify that all toxaphene levels greater than 5 mg/kg would be
removed. Potential risks exceeding an LECR of 1 E-06 would be eliminated. Site risks associated
with remaining chemical residuals would be minimal. Clean fill would be replaced in the
excavation and vegetated to stabilize the Site.
Following completion of this alternative, the remediation goal of a 1 E-06 LECR would have been
attained. A review of remedy would therefore not be required.
Reduction of Toxicity, Mobility and Volume
Cumulative Site risks due to soils would be permanently reduced by approximately 97 percent
under this alternative. Pesticide levels in surficial soils would be reduced by approximately 94
percent, based on the reduction of toxaphene. Incineration of characteristically hazardous soils
would comply with SARA's preference for remedies involving treatment.
Geigy FS 7-36 March 16, 1992
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Short-term Effectiveness
Implementation time would depend on the number of crews involved but should be approximately
two months. The remainder of the analysis under this criterion is as discussed for Alternative EC-
2A (Section 7.3.2.1 ).
Implementability
Demolition, sizing and transportation of the foundation debris would require heavy equipment but
should pose no significant obstacles. The remainder of the analysis under this criterion is as
discussed for Alternative EC-2A (Section 7.3.2.1).
Cost
Construction costs associated with this alternative includes mobilization, excavation, earth work,
disposal (landfill and/or incineration), materials and labor. There would be no operating costs.
A sensitivity analysis was conducted based on whether soils would be considered hazardous by
characteristic or non-hazardous, and therefore disposed at a secure landfill, an incinerator, or a
combination of the two. To provide the greatest allowance for potential remediation costs, it was
assumed that all soils went either to a secure landfill (lowest cost) or to an incinerator (highest
cost). The greatest likelihood is that a portion of the soils would fail TCLP and be sent to an
incinerator while the remainder would be sent to a secure landfill. By presenting the costs of
both extremes, the actual remedial costs would likely fall somewhere in the range. Demolition
of the building foundation and disposal at a municipal landfill is included within both ends of the
estimate.
The detailed cost estimate for this alternative is presented in Appendix F. A summary of the
estimated costs is given below:
Total Construction Costs -
Present Worth O&M Costs -
Total Present Worth Costs -
Geigy FS 7-37
Landfilling
$380,000
$ 0
$380,000
Incineration
$1,500,000
$ 0
$1,500,000
March 16, 1992
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7.3.3 Alternative EC-3: Capping
This alternative involves construction and operation of an engineered cover to deny human
access to those Site soils exceeding a specified LECR. There are two options under this
alternative:
• Alternative EC-3A: Capping of Soils Exceeding an LECR of 1 E-05
• Alternative EC-3B: Capping of Soils Exceeding an LECR of 1 E-06
The cap would serve to deny human access to Site soils and thereby prevent any potential for
incidental contact. Without an exposure pathway there would be no risk and the remediation
goals (i.e., attainment of an LECR) would be achieved.
Construction of a cap involves the use of heavy earth moving and grading equipment. Existing
access may have to be improved for optimal use of this equipment. Clearing of brush
contiguous to the capping areas may be required. Vegetation and any stumps would be
grubbed below the surface to prevent regrowth. Groundwater monitoring wells within the capped
area would be abandoned.
A multi-layer cap including compacted clay is not felt to be appropriate for the Site because of
the limited volume to be covered and because the denial of infiltration is not required. For
purposes of the FS, the cap would be constructed of a non-woven polypropylene geomembrane
impregnated and sealed with an asphalt overlay. Such designs have been approved at RCRA
sites in EPA Region IV. This design would have long-term durability with a minimal amount of
maintenance.
Drainage swales would be constructed along the cap perimeter to control surface run-on and
direct cap run-off. A security fence would be constructed along the perimeter of the cap to deter
unauthorized access.
Geigy FS 7-38 March 1 6, 1992
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Placement of the caps for Alternatives EC-3A and EC-3B would be as presented in Figure 5.4.
Materials beneath the cap would consist of Site soils containing low levels of pesticides. These
soils are well consolidated and substantial settling beneath a cap is not anticipated. Gas
generation would be insignificant and a venting system would not be required.
7.3.3.1 Alternative EC-3A: Capping to Attain an LECR of 1 E-05
This alternative would involve the capping of approximately 140 cubic yards of Site soils, as
shown in Figure 5.4. Capping would be based on the consolidation and covering of all soils
containing toxaphene exceeding a concentration of 50 mg/kg. Demolition of the building
foundation would not be required under this alternative.
Overall Protection of Human Health and the Environment
This alternative would attain an LECR of 1 E-05 for Site soils. This risk level is within the
acceptable risk range of the NCP and therefore would be protective of human health .
Consolidation of materials at the Site would be conducted to minimize the potential for human
exposure through the use of dust control agents and covered containers. Soils have been
excavated at the Site without incident in the past.
Compliance with ARARs
Site soils might be considered hazardous by characteristic through TCLP testing. Such a
determination would not affect excavation at the Site because EPA does not consider
consolidation within an area or capping in place to trigger RCRA requirements at a CERCLA site.
RCRA treatment and disposal requirements are not therefore not ARAR for capping at the Site.
Actual design requirements would be specified during Remedial Design.
All construction activities would take place above the 100-year flood plain. The Health and Safety
Plan governing all remedial activities would conform to 29 CFR 1910.120.
Geigy FS 7.39 March 16, 1992
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Fencing around the capped area would discourage future uses. Deed restrictions could be
included in the implementation of this alternative as a secondary control measure to prevent uses
of the Site that could reduce the effectiveness of remedial measures.
Chemical and location-specific ARARs for this alternative are as described for the no further
action alternative (Section 7.3.1 ).
Long-term Effectiveness and Permanence
If implemented, this alternative would effectively isolate all soils exceeding an LECR of 1 E-05 from
potential human exposure. Confirmation sampling of the unearthed soils would be conducted
prior to excavation and removal activities to verify that all toxaphene levels greater than 50 mg/kg
would be removed. Clean fill would be replaced in the excavation and vegetated to stabilize the
Site.
Long-term stability of the cap should be excellent with regular inspections and maintenance.
Underlying Site materials are primarily inert and minimal settling is anticipated. Periodic
inspections would be required to check for erosion, settling and conditions of the drainage
system. Deterioration of cap integrity must be identified and corrected quickly to maintain
effectiveness. The integrity of the fence must also be maintained to deter unauthorized access.
An established inspection and maintenance schedule would be implemented following
construction and continued for as long as chemical residuals remained at the Site. Regular care
of the cap system would preserve its effectiveness indefinitely.
Caps have been constructed at numerous CERCLA sites with excellent results. Proper
construction and regular maintenance would allow a perpetual operating life. Future
replacement, if required, should be straightforward since the earthwork has already been
completed and residuals isolated during construction. Potential risks are considered minimal
should elements of the cap require repair or replacement.
Geigy FS 7-40 March 16, 1992
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Since compound residuals would remain at the Site, review of the effectiveness and
protectiveness of this alterative every five years would be required by SARA. Inspection and
maintenance records for the cap would be reviewed at this time. Conditions at the Site are
anticipated to improve slightly with placement of the cap.
Reduction of Toxicity, Mobility and Volume
Cumulative Site risks due to soils would be reduced by approximately 75 percent under this
alternative. Pesticide levels in surficial soils would remain unchanged except for natural
degradation mechanisms occurring beneath the cap.
Short-term Effectiveness
Potential risks to trained on-site workers during excavation activities would be minimal and could
be controlled through adherence to the remedial health and safety plan. Personal protective
equipment would be worn by on-site workers to prevent direct exposure by inhalation or dermal
contact. Dust control and air monitoring would be exercised to minimize the potential impact of
airborne particulates on the community. Following approved procedures, the potential for
excavation to impact the community would be minimal.
Excavation and capping activities would not begin until all materials and equipment are available
and adequate access had been developed. Implementation time· would depend on the number
of crews_ involved but should be approximately one month. This schedule assumes standard
production rates and compliance with all inspections of performance and workmanship. Adverse
climatic conditions could hinder work efforts and delay the sct:iedule.
Implementability
Construction of a cap is a straightforward operation that has been accomplished at numerous
waste sites. Clearing of the Site and establishment of access for heavy machinery should pose
no difficulties. Caps have been successfully implemented at other CERCLA sites.
The availability of common fill material should be adequate but procurement and transportation
could control the construction schedule. The use of on-site borrow materials should be
evaluated during Remedial Design. A drainage system would have to be constructed along the
Geigy FS 7-41 March 1 6, 1992
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perimeter of the cap. The drainage system would collect only rainwater, which would be
redirected to the land surface. Cover design would have to consider possible freezing in the
drainage system during winter. Cap construction would have to be scheduled for suitable
climatic conditions.
Lead time for the asphalt and geotextile materials is approximately one month and competitive
sources should be available. Cap construction is a common remedial measure and there should
be a number of qualified bidders.
Cap maintenance can be readily implemented. Periodic cap maintenance would primarily involve
grass cutting and clearing any accumulation in the drainage swales. Inspections would be
required to determine whether repairs to the cap, drainage system, or fence are required.
Cost
Construction costs associated with this alternative include mobilization, excavation, grading, earth
work, materials, and labor. Operating costs include maintenance of the cap and review of the
Site remedy every five years. Maintenance costs include periodic inspections and asphalt
resurfacing .
The detailed cost estimate for this alternative is presented in Appendix F. A summary of the
estimated costs is given below:
Total Construction Costs -
Present Worth O&M Costs -
Total Present Worth Costs -
$60,000
$180,000
$240,000
7.3.3.2 Alternative EC-3B: Capping to Attain an LECR of 1 E-06
This alternative would involve the capping of approximately 670 cubic yards of Site soils. as
shown in Figure 5.4. Capping would be based on the consolidation and covering of all soils
containing toxaphene exceeding a concentration of 5 mg/kg. Demolition of the building
Geigy FS 7-42 March 16, 1992
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foundation would be required under this alternative to gain access to some of the underlying
soils.
The primary difference between this alternative and Alternative EC-3A are:
• risk levels attained
• volume of soils covered
• demolition of the building foundation to allow access to the underlying soils.
Evaluation of this alternative will focus on any significant differences with respect to Alternative
EC-3A and summarize any similarities. The differing risk levels and volume of soils covered are
addressed under the detailed criteria as appropriate. Demolition of the building foundation is the
only significant engineering difference. Removal of the foundation would require use of a
wrecking ball and/or bulldozer. Sizing of the resulting debris would require use of a crusher.
Steel reinforcement of. the concrete (e.g., rebar) could represent problems in sizing and
separating the debris. . Overall, demolition of the building foundation would require heavy
construction equipment but should pose no significant difficulties.
Overall Protection of Human Health and the Environment
This alternative would attain an LECR of 1 E-06 for Site soils. This risk level is within the
acceptable risk range of the NCP and therefore would be protective of human health.
Consolidation of materi_als at the Site would be conducted to minimize the potential for human
exposure through the use of dust control agents and covered containers. Soils have been
excavated at the Site without incident in the past.
Compliance with ARARs
Disposal ofthe foundation debris at the Kernersville, NC municipal landfill would have to comply
with applicable Federal, State and local regulations. Based on the current understanding of the
foundation construction and precautionary steam cleaning, foundation debris should be
acceptable for placement in the municipal landfill. Final assessment of these regulations would
be conducted during Remedial Design following confirmation testing of the concrete.
Geigy FS 7.43 March 16, 1992
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The remainder of action-specific ARARs is as described for Alternative EC-3A (Section 7.3.3.1 ).
Chemical and location-specific ARARs for this alternative are as described for the no further
action alternative (Section 7.3.1).
Long-term Effectiveness and Permanence
If implemented, this alternative would effectively isolate all soils exceeding an LECR of 1 E-06 from
potential human exposure. Since compound residuals would remain at the Site, review of the
effectiveness and protectiveness of this alterative every five years would be required by SARA.
Inspection and maintenance records for the cap would be reviewed at this time. Conditions at
the Site are anticipated to improve slightly with placement of the cap. The remainder of the
analysis under this criterion is as discussed under Alternative EC-3A (Section 7.3.3.1 ).
Reduction of Toxicity. Mobility and Volume
Cumulative Site risks due to soils would be reduced by approximately 97 percent under this
alternative. Pesticide levels in surficial soils would remain unchanged except for natural
degradation mechanisms occurring beneath the cap .
Short-term Effectiveness
Implementation time would depend on the number of crews involved but should be approximately
two months. This schedule assumes standard production rates and compliance with all
inspections of performance and workmanship. Adverse climatic conditions could hinder work
efforts and delay the schedule. The remainder of the analysis under this criterion is as discussed
under Alternative EC-3A (Section 7.3.3.1).
Implementability
Demolition of the building foundation would require heavy construction equipment but should
pose no significant obstacles. The remainder of the analysis under this criterion is as discussed
under Alternative EC-3A (Section 7.3.3.1 ).
Cost
Construction costs associated with this alternative include mobilization, excavation, grading, earth
work, materials, and labor. Additional costs beyond those for Alternative EC-3A are for
Geigy FS 7-44 March 16, 1992
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demolition and disposal of the building foundation. Operating costs include maintenance of the
cap and review of the Site remedy every five years. Maintenance costs include periodic
inspections and grounds keeping.
The detailed cost estimate for this alternative is presented in Appendix F. A summary of the
estimated costs is given below:
Total Construction Costs -
Present Worth O&M Costs -
Total Present Worth Costs -
Geigy FS 7-45
$95,000
$180,000
$280,000
March 16, 1992
-
Extraction
Wells (9)
Q ~20gpm
II!!!!!! l!!!!!!I ;;a liiiiiil liiiiiil -
Pesticides= 10 lb/yr
Equalization
Tank
Carbon
Adsorption
- - - -
-r
Monitoring
I--~ Discharge to 1.---~ Moore
County
POTWor
On-Site
Infiltration
Gallery
Figure 7.1
Groundwater Treatment
Flow Diagram
Alternative GWC-3
Geigy Chemical Corporation Site
Aberdeen, North Carolina
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TABLE 7.1
PROJECTED INFLUENT CONCENTRATIONS TO TREATMENT
Compound
alpha-BHC
beta-BHC
gamma-BHC
delta-BHC
Toxaphene
Dieldrin
Endrin Ketone
Aldrin
Total
Maximum Concentration
(uq/ll
36.0
25.0
29.0
30.0
10.0
2.0
4.0
0.1
Influent Concentration
(uq/1)
27.0
19.0
22.0
22.5
7.5
1.5
3.0
0.08
103
Note: Influent concentrations to the treatment facility were conservatively assumed to be
75 percent of the maximum Site groundwater concentrations. Total combined flow
rate is estimated to be approximately 20 gpm.
Ref: ERM-Southeast, Geigy Chemical Corporation Site Remedial Investigation Report (Draft),
September 1991.
Geigy FS 7-47 March 16, 1992
8.0 COMPARATIVE SUMMARY OF ALTERNATIVES
The Baseline Risk Assessment evaluated the potential risks associated with Site soils under
current conditions and for a hypothetical future resident at the Site. The resulting lifetime excess I cancer risk (LECR) values are:
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• current conditions: LECR of 9E-06
• future residential scenario: LECR of 4E-05.
These risk levels fall with the acceptable range specified by the NCP of 1 E-04 to 1 E-06.
Exposure control (EC) addressing Site soils posing potential risks to human health were
developed for LECR values of 1 E-05 and 1 E-06 to allow a range of response actions. Per the
NCP, the no action alternative was presented as a basis for comparison. Extensive amounts of
Site soil have been removed during two previous removal actions and this alternative is termed
the no further action alternative. Exposure control alternatives developed for the Geigy Site are:
• Alternative EC-1: No Further Action
• Alternative EC-2: Off-Site Disposal
EC-2A: Attain LECR of 1 E-05
EC-2B: Attain LECR of .1 E-06
• Alternative EC-3: Capping
EC-3A: Attain LECR of 1 E-05
EC-3B: Attain LECR of 1 E-06
There are no ARARs for pesticides in soils. Site soils are protective of groundwater.
Site groundwater does not represent a pathway for exposure under current conditions. The
Baseline Risk Assessment evaluated potential exposure to groundwater based on a hypothetical
future resident. The resulting risk levels are:
Geigy FS 8-1 March 16, 1992
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• uppermost aquifer: LECR of 4E-03
• second uppermost aquifer: LECR of 2E-03 .
These potential risk levels exceed the acceptable range specified by the NCP. Pesticide levels
in the uppermost and second uppermost aquifers exceed MCLs. Based on these factors,
remedial alternatives were developed for Site groundwater involving containment and restoration.
Groundwater control (GWC) alternatives developed for the Geigy Site are:
• Alternative GWC-1 : No action
•
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GWC-1 A: No activities
GWC-1 B: Long-term groundwater monitoring
Alternative GWC-2: Containment
Slurry wall and cap for the uppermost aquifer, groundwater recovery for the second
uppermost aquifer
Alternative GWC-3: Groundwater recovery and treatment to attain MCLs
Well point extraction in both aquifers, carbon adsorption, discharge to POTW or
infiltration gallery.
A comparative summary of the Site alternatives with respect to the detailed analysis criteria
(Section 7.1) is presented below. Critical elements of the alternative analysis are presented in
Table 8.1.
8.1 GROUNDWATER CONTROL
Groundwater control alternatives address pesticides in the uppermost and second uppermost
aquifers. All of the Site alternatives except no action (GWC-1 A) include the installation of
additional monitoring wells in the second uppermost aquifer for characterization of the presence
of TCE.
Geigy FS 8-2 March 16, 1992
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Overall Protection of Human Health and the Environment
Groundwater poses no risks to human health and the environment under current conditions and
all the alternatives are currently protective. The· no action alternatives would not directly address
pesticide levels in groundwater and therefore would not be protective of human health under
potential future conditions. Alternative GWC-2 would contain groundwater in the uppermost
aquifer and recover groundwater in the second uppermost aquifer such that MC Ls were attained.
Alternative GWC-3 would recover groundwater in the uppermost and second uppermost such
that MCLs were attained. Alternatives GWC-2 and GWC-3 would therefore be protective of
human health and the environment.
Compliance with ARARs
MCLs are relevant and appropriate requirements for Site groundwater. The no action alternative
(GWC-1) would not comply with ARARS. Alternative GWC-2 would attain MC Ls outside of the
slurry wall (in the second uppermost aquifer) and prevent MCLs from being exceeded off-site in
the uppermost aquifer. Alternative GWC-3 would attain MCLs in both aquifers and comply with
ARARs.
There are no location-specific ARARs for existing Site conditions. Construction in the railroad or
highway right-of-ways would require approval from the Aberdeen and Rockfish Railroad and the
North Carolina Department of Transportation, respectively.
Construction of Site monitoring wells would conform to EPA Region IV SOPQAM. The cap in
Alternative GWC-2 would be designed to conform to RCRA performance standards. Construction
of the groundwater recovery, treatment and discharge systems for Alternatives GWC-2
and GWC-3 would satisfy action-specific ARARs. Discharge to the POTW would comply with the
MCSSA sewer use ordinance. Discharge to an on-site infiltration gallery would comply with the
substantive aspects of a North Carolina Non-Discharge Permit.
Long-term Effectiveness and Permanence
Periodic monitoring of Site groundwater would be required to evaluate the degradation of
pesticides through natural mechanisms under Alternative GWC-1 B. Pesticide levels would
decrease permanently through natural mechanisms within the slurry wall and through recovery
Geigy FS 8-3 March 16, 1992
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outside of the slurry wall for Alternative GWC-2. Pesticide concentrations would be permanently
reduced through groundwater recovery for Alternative GWC-3.
Construction of a slurry wall under Alternative GWC-2 would be complicated by the depths to the
uppermost aquitard (up to 70 feet). The competence of the resulting connection would be
verified through hydraulic and analytical monitoring of groundwater.
Groundwater extraction through recovery wells has excellent mechanical reliability but the ability
to achieve part per billion remediation goals is uncertain. Carbon adsorption is considered Best
Available Treatment for pesticides in groundwater.
A review of remedy would be required every five years until the remediation goals were achieved.
Alternative GWC-2 would be a permanent installation that would require review and maintenance
indefinitely. Alternative GWC-3 would be discontinued once the remediation goals were achieved.
Reduction of Toxicity. Mobility and Volume
Pesticide concentrations would decrease to some extent through natural mechanisms for
Alternative GWC-1A and GWC-1 B. thereby reducing the volume of pesticides at the Site.
Alternative GWC-2 would reduce the mobility of pesticides in the uppermost aquifer through
containment and would reduce the volume of pesticides in the second uppermost aquifer through
recovery. Alternative GWC-3 would reduce the volume of pesticides in both aquifers through
recovery and treatment and comply with the statutory preference for alternatives involving
treatment. Pesticide levels would be reduced by approximately 99 percent (based on a reduction
of gamma-BHC to 0.2 ug/I).
Short-term Effectiveness
All of the alternatives can be implemented without significant risks to the community or on-site
workers and without adverse environmental impacts. Construction schedules would be as
follows:
• Alternative GWC-1 A: None
• Alternative GWC-1 B: 1 month
Geigy FS 8-4 March 16. 1992
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• Alternative GWC-2:
• Alternative GWC-3:
8 months
3 months
Construction of Alternative GWC-2 could not proceed until the rail line was rerouted, a potentially
significant obstacle on an institutional basis.
Based on a continuous flushing model (Appendix D), remediation would be achieved in the
following periods:
• Alternative GWC-1 A:
• Alternative GWC-1 B:
• Alternative GWC-2:
• Alternative GWC-3:
1 o years (based on soil degradation rates)
1 O years (based on soil degradation rates)
Indefinite (containment)
5 years (with degradation)
10 years (with no degradation)
Based on groundwater remediation experience at other CERCLA sites, these periods are likely
underestimated.
Implementability
Alternatives GWC-1 A, GWC-1 B, and GWC-3 would pose no significant concerns regarding
implementation. Construction of the slurry wall for Alternative GWC-2 would approach the limits
of technical feasibility due to the required depths (up to 70 feet). Design of the treatment system
for Alternatives GWC-2 and GWC-3 could not be conducted until discharge requirements were
defined.
Cost
Total present worth costs for the groundwater control alternatives are presented in Table 8.1.
8.2 EXPOSURE CONTROL
Exposure control alternatives address Site soils exceeding LECR values of 1 E-05 and 1 E-06. The
volume of Site soils exceeding these risk levels is 140 and 670 .cubic yards, respectively. The
Geigy FS 8-5 March 1 6, 1 992
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limited volumes are the result of the extensive remediation conducted during the previous two
removal actions (Section 4.2). This limited volume of soil precludes the siting of many on-site
treatment technologies and has narrowed the range of practicable alternatives.
Overall Protection of Human Health and the Environment
Potential risks due to Site soils under current conditions and under potential future conditions
(residential scenario) are within the acceptable range of risks specified by the NCP. All of the
alternatives are therefore protective of human health. Site factors to be considered in selection
of Site remediation levels indicate that risk levels less conservative than 1 E-06 would be
protective of current and potential receptors. All of the alternatives would be protective of the
community and on-site workers during implementation.
Site soils represent no significant risks to the environment under current or future conditions.
Compliance with ARARs
There are no Federal or State ARARs for pesticides in soils. There are no action-specific ARARs
for the no further action alternative. Alternative EC-2 would comply with EPA's off-site policy and
applicable land disposal restrictions (40 CFR 268.43(a)). Consolidation of Site soils and capping
in place would not trigger any RCRA requirements (Alternative EC-3).
Long-term Effectiveness and Permanence
Residual pesticide levels under Alternative EC-1 would be essentially unchanged except through
natural mechanisms. Alternative EC-2 would result in a permanent reduction in Site risks and no
review of remedy would be required. The cap for Alternative EC-3 could function in perpetuity
through regular maintenance but a review of remedy would be required every five years.
Reduction of Toxicity, Mobility and Volume
Pesticide levels would remain unaltered except through natural mechanisms for Alternative EC-1.
Alternative EC-2A would result in a reduction in Site risk levels of 75 percent and in pesticide
levels of 67 percent. Alternative EC-2B would reduce Site risk levels by 97 percent and pesticide
levels by 94 percent. Alternative EC-3A would reduce the effective toxicity of Site soils by 75
Geigy FS 8-6 March 16, 1992
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percent while Alternative EC-3B would reduce the effective toxicity by 97 percent. Pesticide levels
beneath the caps would remain unchanged except through natural mechanisms.
Short-term Effectiveness
All of the alternatives can be implemented without significant risks to on-site workers or the
community and without adverse environmental impacts. Construction schedules would be as
follows:
• Alternative EC-1:
• Alternative EC-2A:
• Alternative EC-2B: .
• Alternative EC-3A:
• Alternative EC-3B:
None
1 month
2 months
1 month
2 months
Off-site disposal (Alternative EC-2) would have to be coordinated with the schedule of the
receiving facility.
Implementability
The no further action alternative can be implemented immediately. Off-site disposal to a RCRA-
approved landfill and incinerator have been conducted successfully in the past at the Geigy Site.
Construction of the limited size hardened caps would pose no significant difficulties.
Cost
Total present worth costs for the exposure control alternatives are presented in Table 8.1.
Geigy FS 8-7 March 16, 1992
------
CRITERION
Overall Protectiveness
Human Health
Environmental
Compliance with ARARs
-Chemical-specific
-Location-specific
-Action-specific
Long-term Effectiveness
-Magnitude of
residual risks
-Adequacy of
controls
Geigy FS
- ---" ----
TABLE 8.1
COMPARATIVE SUMMARY OF ALTERNATIVES
GEIGY CHEMICAL CORPORATION SITE
Alternative GWC-1 B Alternative GWC-2
Alternative GWC-1 A Long-term Slurry wall
No action monitoring and cap
Not protective for Not protective for Protective
future scenario future scenario
Protective since no Protective since no Protective since no
expected impacts expected impacts expected impacts
Does not satisfy MCLs Does not satisfy MCLs MCLs attained
Not relevant Not relevant Rezoning req'd for RR
rerouting
Not relevant, no Monitoring wells per DOT req'ts per RR
actions SOPQAM rerouting
Future risks exceed Future risks exceed Acceptable outside of
NCP range NCP range slurry wall after
completion of remedy
None; limited reliability Long-term monitoring Hydraulic, chemical
of GW; fair reliability analysis of GW; long-
term maintenance; fair
reliability
8-8
--
Alternative GWC-3
GW recovery;
carbon adsorption
Protective
Protective since no
expected impacts
MCLs attained
Not relevant
Discharge req'ts per
POTW or NC
Acceptable after
completion of remedy
Monitoring of GW,
effluent; permanent
remedy; good
reliability
March 1 6, 1992
--.-- -
CRITERION
---- -• --
TABLE 8.1 ( continued)
COMPARATIVE SUMMARY OF ALTERNATIVES
GEIGY CHEMICAL CORPORATION SITE
-
Alternative GWC-1 B Alternative GWC-2
Alternative GWC-1A Long-term Slurry wall
No action monitoring and cap
Reduction of Toxicity, Mobility or Volume
-Treatment type Natural mechanisms Natural mechanisms Limited pump and treat
(containment)
. Reduction in > 90% (potentially) >90% (potentially) Containment strategy
volume
. Statutory Does not satisfy Does not satisfy Does not satisfy
preference for
treatment
Short-term Effectiveness
. Risks to community None None None
or workers
. Construction None 1 month 8 months
schedule
Implementability
. Potential concerns None None Depth to confining
layer; rerouting of rail
line
Geigy FS 8-9
-
Alternative GWC-3
GW recovery;
carbon adsorption
Activated carbon,
regeneration
>99%
Satisfies
None
3 months
Area for infiltration
gallery, if required
March 16, 1992
----- -
CRITERION
Cost
-Basis for O&M
costs
-Construction
-Present worth O&M
-Total present worth
costs
-Basis for O&M
costs
-Present worth O&M
-Total present worth
costs
Geigy FS
- ---" - - -
TABLE 8.1 (continued)
COMPARATIVE SUMMARY OF ALTERNATIVES
GEIGY CHEMICAL CORPORATION SITE
-
Alternative GWC-1 B Alternative GWC-2
Alternative GWC-1 A Long-term Slurry wall
No action monitoring and cap
30 years 30 years 30 years
$0 $130,000 $8,400,000
$140,000 $1,500,000 $1,800,000
$140,000 $1,600,000 $10,000,000
NA 10 years NA
$740,000
$870,000
8-10
-l!!!!I
Alternative GWC-3
GW recovery;
carbon adsorption
30 years
$710,000
$1,500,000
$2,200,000
10 years
$760,000
$1,500,000
March 16, 1992
-,-- - --
CRITERION Alternative EC-1
No Further Action
Overall Protectiveness
" Human Health Protective; would
represent LECR of 4E-
05 (future conditions)
" Environmental Protective
Compliance with ARARs
" Chemical-specmc None
" Location•specific None
" Action-spec~ic None
Long-term Effectiveness
" Magnitude of Within acceptable
residual risks range of NCP
" Adequacy of Adequate; five year
controls review
Geigy FS
--• -
TABLE 8.1 (continued)
COMPARATIVE SUMMARY OF ALTERNATIVES
GEIGY CHEMICAL CORPORATION SITE
Alternative EC-2A Alternative EC-2B
Off.Site Disposal Off-site Disposal
LECR Of 1 E..Q5 LECR of 1 E..Q6
Protective; would attain Protective; would attain
LECR of 1 E..Q5 LECR of 1 E..Q6
Protective Protective
None None
None None
Off-site policy; LDRs Off-site policy; LDRs
Within acceptable Within acceptable
range Of NCP range Of NCP
None required; None required;
permanent remedy permanent remedy
8-11
--..... l!!!!!!I
Alternative EC-3A Alternative EC-3B
Capping Capping
LECR of 1 E..Q5 LECR of 1 E..Q6
Protective; would attain Protective; would
LECR of 1 E..Q5 attain LECR of 1 E..Q6
Protective Protective
None None
None None
RCRA not ARAR RCRA not ARAR
Within acceptable Wrthln acceptable
range Of NCP range Of NCP
Periodic maintenance; Periodic maintenance;
five year review five year review
March 16, 1992
--.--- - -
CRITERION Alternative EC-1
No Further Action
Reduction of Toxicity, Mobility or Volume
. Treatment type None
. Reduction in None except natural
volume mechanisms
. Statutory Not satisfied
preference for
treatment
Short-term Effectiveness
. Risks to None
community or
workers
-Construction None
schedule
Implementability
. Potential concerns None
Geigy FS
----
TABLE 8.1 (continued)
COMPARATIVE SUMMARY OF ALTERNATIVES
GEIGY CHEMICAL CORPORATION SITE
Alternative EC-2A Alternative EC-2B
Off-Site Disposal Off-site Disposal
LECR of 1 E-05 LECR of 1 E-06
Incineration as required Incineration as required
Pesticide levels Pesticide levels
reduced 67% reduced 94%
Satisfied Satisfied
No signtticant risks No signtticant risks
1 month 2 months
Have conducted Have conducted
previously, must previously, must
schedule delivery to schedule delivery to
off-site facility off-site facility
8-12
---..
Alternative EC-3A Alternative EC-3B
Capping Capping
LECR of 1 E-05 LECR of 1 E-06
None None
None except natural None except natural
mechanisms mechanisms
Not satisfied Not satisfied
No signtticant risks No signtticant risks
1 month 2 months
No slgn~icant concerns No slgntticant
concerns
March 16, 1992
-..... --- -
CRITERION Alternative EC-1
No Further Action
Cost
-Basis for O&M 30 years
costs
-Construction $0
-Present worth $140,000
O&M
-Total present $140,000
worth costs
Geigy FS
- - --
TABLE 8.1 (continued)
COMPARATIVE SUMMARY OF ALTERNATIVES
GEIGY CHEMICAL CORPORATION SITE
Alternative EC-2A Alternative EC-2B
Off-Stte Disposal Off-stte Disposal
LECR of 1 E-05 LECR of 1 E-06
Not applicable No1 applicable
$110,000-360,000 $380,000-1,500,000
$0 $0
$110,000-360,000 $380,000-1,500,000
NOTE: Range in costs NOTE: Range in costs
reflects disposal of all reflects disposal of all
soils a1 a secure landfill soils at a secure landfill
vs. all at an incinerator; vs. all at an incinerator;
actual costs actual costs
determined by TCLP determined by TCLP
testing testing
8-13
-- --
Alternative EC-3A Alternative EC-3B
Capping Capping
LECR of 1 E-05 LECR of 1 E-06
30 years 30 years
$60,000 $95,000
$180,000 $180,000
$240,000 $280,000
March 16, 1 992
I
►
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APPENDIX A
SELECTED SOIL DATA AND CALCULATIONS FOR PESTICIDES
I
g
0
I
I ,
I
Calculation of pre-1989 and current site-wide soil concentrations for BHC isomers are presented
in Tables A.1 and A.2, respectively. Calculation of pre-1989 and current site-wide soil
concentrations for toxaphene are presented in Tables A.3 and A.4, respectively.
Current site-wide toxaphene concentrations remaining in site surficial soils are listed in Table A.5.
Surface soil locations with toxaphene concentrations equal to or greater than 5 mg/kg were
conceptually remediated (e.g., concentration set to zero) in Table A.6 to achieve a LECR of 1 o-6.
Similarly, surface soil locations with toxaphene concentrations equal to or greater than 50 mg/kg
were conceptually remediated to achieve a LECR of 1 o·5 as shown in Table A.7.
To reduce the average site-wide risks to a LECR of 1 o-6, approximately 530 cubic yards of soil
would have to be removed (Table A.6) as shown on Figure 4.1. In addition, the concrete slab
foundations of former warehouse A and B (Figure 2.1) and the associated fill soil would have to
be removed to gain access to the underlying soil. Volume of non-contaminated concrete and
fill soil are approximately 400 and 1200 cubic yards, respectively (Table A.8).
Removal volume to achieve a LECR of 1 o·5 LECR would be approximately 140 cubic yards (Table
A.7) as shown on Figure 4.2. No surface soil remediation would be necessary to achieve LECR
of 1 o-4 since the estimated future residential risk maximum is already below this value.
Geigy FS A-1 March 16, 1992
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Soil
Sample
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
Sample
!!?.
SS---01
SS---03
SS---04
SS---05
SS---06
SS---09
SS-20
SS-21
SS-22
SS-23
SS-24
SS-25
SS-26
SS-27
SS-28
SS-29
Ss-30
Ss-31
SS-32
SS-34
Ss-35
Ss-36
Ss-37
Ss-38
Ss-39
Ss-40
Ss-41
Ss-42
Ss-43
Ss-44
Ss-45
Ss-46
Ss-47
Ss-48
Ss-49
SS-50
SS-51
SS-52
SS-53
SS-54
SS-56
SS-57
SS-58
SS-59
Ss-60
Ss-61
Ss-62
Ss-63
S$-64
Ss-65
Ss-66
Ss-67
S5-68
Ss-69
SS-71
SS-72
SS-73
SS-75
SS-76
SS-77
SS-78
SS-79
ss-ao
Removal
Depth Surface
u
4•3• 11.610
u
3' 5.100
4' 4.100
6"
1'6"
3'
1'
8"
5•
2'
u
u
u
u
u
u
u
u
u
u
u
u
u
u
u
0.028
u
u
u
u
u
u
u
u
u
0.0049
0.120
u
u
0.480
u
u
u
0.0059
u
0.043
u
0.369
u
0.060
u
u
u
u
u
u
NS
NS
u
u
0.840
u
u
u
u
u
u
u
Tabto A.1
Calculation of Pre-1989 Average
Sito-Wide Soil Concentrations fOf BHC Isomers (1, 2)
Geigy Chemical Corporation Site
0.5' -1·
NS
11.610
NS
5.100
4.100
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
0.290
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
u
u
u
NS
NS
1.912
NS
NS
u
NS
u
NS
NS
NS
NS
(Concentration: mg/kg)
11h
NS
11.610
NS
5.100
4.100
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
0.130
NS
0.589
NS
NS
NS
NS
NS
NS
NS
1.040
NS
NS
NS
NS
1.5 ft.
NS
11.610
NS
5.100
4.100
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
0.130
NS
NS
NS
NS
NS
NS
NS
NS
NS
1.040
NS
NS
NS
NS
2 ft
NS
11.610
NS
5.100
4.100
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
u
NS
0.012
u
NS
0.510
NS
NS
NS
NS
u
0.488
u
NS
u
u
u
u
NS
u
u
NS
0.080
0.688
0,800
97.0
NS
1.040
0.526
u
0.248
NS
2'-5'
NS
11.610
NS
5.100
4.100
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
u
NS
NS
NS
NS
NS
NS
5 ft
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
u
NS
u
u
NS
u
NS
NS
NS
NS
u
u
u
NS
u
u
u
u
u
u
u
NS
u
0.019
0.059
17.50
NS
u
u
u
u
NS
5'-10'
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
.!.Q..!!
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
u
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
u
u
u
u
NS
NS
u
NS
u
u
NS
u
NS
NS
NS
NS
.!.!.!!
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
g
0
I
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I
•
I
I
I
I
I
I
I
Soil
Sample
64
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79
80
81
82
83
84
85
86
87
88
89
90
91
92
93
94
95
96
97
98
99
100
101
102
103
104
105
106
107
108
109
110
111
112
113
114
115
116
117
118
119
120
121
122
123
124
125
126
Sample Removal
!Q Depth
S!Hl1
S!Hl2
S!Hl3
S!Hl4
S!HIS
S!Hl7
S!Hl8
S!Hl9
SS--90
SS-91 1'
SS-92
SS--93
SS--94
SS-95
SS--96
SS-97
SS-98 1'
SS-99 1 '6•
SS-100
SS-101
SS-103
SS-104
SS-105
SS-106
SS-107
SS-108 3'
SS-109
SS-110
SS-111
SS-112
SS-113 5·
SS-114
SS-115
SS-116
SS-117
SS-118
SS-119
SS-58-20S
SS-61-20S
SS-62-20S
S5-63--20S
-20S
S5--66--20S
SS-91-10N
SS-92-10N
SS-93-10N
SS-93-20E
SLAB 8
SLAB 9
SLAB 10
SLAB 11
SLAB 12
SLAB 13
SLAB 14
SLAB 15
SLAB 16
SLAB 17
SLAB 18
SLAB 19
SLAB 20
SLAB 21
SLAB 22
SLAB 23
Surface
u
u
u
u
NS
u
NS
NS
NS
198.0
NS
1.860
0.053
0.0051
u
0.0055
111.0
1.80
25.490
u
u
u
u
u
u
195.0
u
0.520
u
u
372.0
NS
NS
0.230
NS
0.120
NS
4.960
0.040
u
0.640
0.160
0.495
0,850
NS
0.038
0.016
0.109
0.207
0.013
0.014
0.042
14.30
8.227
0.310
0.190
0.065
u
u
2.830
0.594
u
0.830
Table A. 1 (Continued)
Calculation of Pre-1989 Average
Site-Wide Soil Concentrations for BHC Isomers (1, 2)
Geigy Chemical Corporation Site
o.5' -1·
NS
NS
NS
NS
NS
NS
NS
NS
NS
198.0
NS
NS
NS
NS
NS
NS
111.0
1.80
NS
NS
NS
NS
NS
NS
NS
195.0
NS
NS
NS
NS
372.0
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
{Concentration: mg/kg}
1!h
NS
NS
NS
NS
NS
NS
NS
NS
NS
28.30
NS
NS
NS
NS
NS
NS
1.290
0.610
NS
NS
NS
NS
NS
NS
NS
0.307
NS
NS
NS
NS
2.880
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
1.5 ft.
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
0.610
NS
NS
NS
NS
NS
NS
NS
0.307
NS
NS
NS
NS
2.880
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
2 ft
u
NS
NS
NS
NS
NS
NS
NS
0.376
3.670
0.047
0.027
NS
NS
NS
NS
u
u
1.200
0.070
u
NS
0.012
u
NS
0.307
1.60
u
NS
0.026
2.880
NS
NS
u
u
u
u
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
2·-5·
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
0.307
NS
NS
NS
NS
0.819
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
5 ft
u
NS
NS
NS
NS
NS
NS
NS
0.011
0.049
0.128
u
NS
NS
NS
NS
u
u
0.059
0.050
u
NS
u
u
NS
u
u
u
NS
u
0.819
NS
NS
0.013
u
u
u
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
s·-10·
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
1Q.!
NS
NS
NS
NS
NS
NS
NS
NS
NS
0.018
NS
NS
NS
NS
NS
NS
u
NS
NS
NS
NS
NS
NS
NS
NS
u
NS
u
NS
NS
0.070
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS-
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
ill
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
I Table A.1 (Continued)
Calculation of Pre-1989 Average
Sito-Wide Soil Concentrations for BHC Isomers (1, 2)
Geigy Chemical Corporation Site
(Concentration: mglkg)
Soil Sample Removal
Sample !Q Deplh Surface 0.5' -1' !JL. 1.5 ft. 2 n 2'-5' 5ft ~ .!Q..!! ill 127 A 7' 0.349 0.349 0.349 0.349 0.349 0.349 0.349 0.349 NS NS
128 8 e·e· 0.534 0.534 0.534 0.534 0.534 0.534 0.534 0.534 NS NS g 129 C 11' 0.320 0.320 0.320 0.320 0.320 0.320 0.320 0.320 0.320 0.320
130 D 7'6 .. 0.130 0.130 0.130 0.130 0.130 0.130 0.130 0.130 NS NS
131 E 8' 0.209 0.209 0.209 0.209 0.209 0.209 0.209 0.209 NS NS
132 F 11' 1.630 1.630 1.630 1,630 1.630 1.630 1,630 1.630 1.630 1.630 0 133 G e·e· 0.509 0.509 0.509 0.509 0.509 0.509 0.509 0.509 NS NS
134 H 6' 5.340 5.340 5.340 5.340 5,340 5.340 5.340 5,340 NS NS
135 5' 0.171 0.171 0.171 0.171 0.171 0.171 0.171 NS NS NS
138 J 5' 0.213 0.213 0.213 0.213 0.213 0.213 0.213 NS NS NS D 137 K 5' 0.328 0.328 0.328 0.328 0.328 0.328 0.328 NS NS NS
138 SD-1 0.110 NS NS u NS u NS NS NS NS
139 SD-2 u NS NS u NS u NS NS NS NS
m
140 SD-3 u NS NS 0.015 NS u NS NS NS NS 141 S0--4 u NS NS NS NS NS NS NS NS NS
142 SD-6 0.250 NS NS 1,630 NS NS NS NS NS NS 143 SD-7 0.0044 NS NS NS NS NS NS NS NS NS
I 144 SD-8 0.410 NS NS u NS 0.021 NS NS NS NS
145 SD-9 1 ·e· NS NS u u NS u NS NS NS NS
146 S0-10 1· NS NS u u u u u NS u NS
147 SD-11 NS NS 6.30 1.140 0.041 u u NS NS NS
I 148 S0-12 3' NS NS u u u u 0.043 NS NS NS
149 S0-13 0.094 NS NS u NS u NS NS NS NS
150 S0-14 1 ·e· NS u u u 0.010 NS u NS u NS 151 SD-15 3' NS 2.50 2.50 u 0.092 0.092 NS NS NS NS .. 152 SD-18 u NS NS NS NS NS NS NS NS NS
153 SD-19 0.176 NS NS u NS u NS NS NS NS
154 SD-20 0.043 NS NS NS NS NS NS NS NS NS
155 SD-21 u NS NS u NS u NS NS NS NS
I 156 SD--41 u NS NS NS NS NS NS NS NS NS 157 OSD-21 u NS NS NS NS NS NS NS NS NS
158 0S0-23 u NS NS NS NS NS NS NS NS NS 159 0S0-24 u NS NS u NS u NS NS NS NS
I 160 OSD-25 u NS NS NS NS NS NS NS NS NS
161 OSD-26 u NS NS NS NS NS NS NS NS NS
162 OSD-27 u NS NS u NS u NS NS NS NS
163 0S0-28 u NS NS u NS 0.026 0.038 NS NS NS
I 164 OSD-30 NS NS NS u NS NS u NS NS NS 165 OSD-42 u NS NS NS NS NS NS NS NS NS
166 OSD-43 0,540 NS NS NS NS NS NS NS NS NS
I Total 975.13 913.05 74.49 38.30 142.29 31.81 28.52 9.02 2.04 1.95
Number of Samples 147 29 29 37 61 32 60 8 18 2
Average BHC isomer concentration at site 5.2 mg/kg I 1 -Remedial Investigation Study, Geigy Chemical Corporation Site; ERM-Southeast, Inc., March 16, 1992.
2 -Field Activities Report -Building Demolition And Soil Removal, Geigy Chemical Corporation Site; Olin Corporation; October, 1991.
I U -Not Detected at the detection limit indicated
J -Quantitative estimate
C -Confirmed by GC/MS
I NS -Not Sampled
SS -Soil Sample
SLAB -Soil sample from beneath warehouse foundation , SO -Sediment Sample
OSD -Off-site sediment sample
File: MARCH\A-1
Date: 03113/92
I
I
g
n
D
I
I
I
I
I
I
I
I
I ,
I
Soil
Sample
1
2
3
4
5
' 1
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43 ..
45
46
47
48
49
60
51
52
53
54
55
56
57
58
69
00
61
62
63
Sample
!!,
SS-01
SS-03
SS-04
SS-05
SS-06
SS-09
SS-20
SS-21
SS-22
SS-23
SS-24
SS-25
SS-26
SS-27
SS-28
SS-29
SS-30
SS-31
SS-32
SS-34
SS-35
SS-36
SS-37
SS-36
SS-39
SS-40
SS-41
SS-42
SS-43
SS-44
SS-45
SS-46
SS-47
SS-46
SS-49
SS-50
SS-51
SS-52
SS-53
SS-54
SS-58
SS-57
SS-58
SS-69
SS-00
SS-61
SS-62
SS-63
SS-64
SS-65
SS-66
SS-67
SS-66
SS-69
SS-71
SS-72
SS-73
SS-75
SS-78
SS-n
SS-78
SS-79
SS-80
3'
4'
6"
1'6~
3'
1'
,.
••
2'
Surlace
u
Fill
u
Flll
Fill
u
u
u
u
u
u
u
u
u
u
u
u
u
u
u
0,028 J
u
u
u
u
u
u
u
u
u
0.0049 J
0.120 J
u
Fill
0,480 J
u
u
u
0.0059 J
u
0.043 J
u
0.369 J
u
0.060 J
u
u
u
Fill
Fill
Fill
Fill
Fill
Fill
u
Fill
Fill
Fill
Fill
Fill
Fill
Fill
Fill
Table A.2
Cak:ula1ion ol Curren I Average
Site-Wide Soil Concentration• !Of BHC Isomers (1, 2)
Geigy Chemical Corp,oralion Site
0.5' -1'
NS
RU
NS
Fin
Fill
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
0.290
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
Fill
Fill
Fill
NS
NS
1.912
NS
NS
Fill
NS
Fill
NS
NS
NS
NS
(Concentration: mg/kg)
.!...!!:.
NS
Fill
NS
Fill
Fill
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
Fill
Fill
0.589
NS
NS
NS
NS
NS
Fill
NS
Fill
NS
NS
NS
NS
1.5 tt.
NS
Fill
NS
Fill
Fill
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
0.130
RH
NS
NS
NS
NS
NS
NS
Fill
NS
Fill
·Ns
NS
NS
NS
,.,!!
NS
Fm
NS
Fm
Fill
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
u
NS
0.012
u
NS
0.510 C
NS
NS
NS
NS
u
o.~ J
u
NS
u
u
u
u
Fill
u
u
NS
0.080 J
0.686 C
NS
RU
NS
1.040
NS
NS
NS
NS
2'-5'
NS
11.610 J
NS
5.100 C
4.100 J
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
u
NS
NS
NS
NS
NS
NS
~
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
u
NS
u
u
NS
u
NS
NS
NS
NS
u
u
u
NS
u
u
u
u
u
u
u
NS
u
0.019
0.059
17.50 C
NS
u
u
u
u
NS
5'-10'
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
.!.Q.!!
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
u
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
u
u
u
u
NS
NS
u
NS
u
u
NS
u
NS
NS
NS
NS
.!!..!!
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
I
g
u
I
I
•
I
I
I
I
I
I
I
Soll
Sample
64
65
66
67
66
"' 70
71
72
73
74
75
76
n
78
79
80
81
62
83
64
65
66
67
66
69
90
91
92
93
94
96
96
97
96
Samp~
!Q
SS--01
SS--02
SS--03
SS--04
SS--05
SS--07
SS--06
SS--09
SS-90
SS-91
SS-92
SS-93
SS-94
SS-95
SS-96
SS-97
SS-96
SS-99
SS-100
SS-101
SS-103
SS-104
SS-105
SS-106
SS-107
SS-108
SS-109
SS-110
SS-111
SS-112
SS-113
SS-11 ◄
SS-115
SS-116
SS-117
99 SS-118
100 SS-119
101 SS-58-20S
102 SS-61-20S
103 SS-62-20S
104 SS--&-20S
105 SS-64-20S
106 SS-66-205
107 SS-91-10N
108 SS--92-10N
109 SS-93-ION
11 o SS-93--20E
111 SLAB 8
112 SLAB 9
113 Sl..A8 10
114 SLAB 11
115 SLAB12
116 SLAB13
117 SLAB14
118 SlAB15
119 SLAB 16
120 SLAB 17
121 SLAB 18
122 SlAB 19
123 SLAB20
124 SlAB21
125 St.AB22
126 SLAB23
1'
3'
6'
Surface
Fill
u
u
u
Fill
u
Fill
Fill
Fill
Fill
Fill
1.860 J
0.053 J
0.0051 J
u
0.0055 J
Fill
Fill
Fill
Fill
u
u
u
u
u
Fill
Fill
0.520 J
Fut
Fill
Fill
Fill
Fill
Fill
FUJ
Fill
Fill
4.960 C
0.040
u
0.640 C
0.160
0.495 C
0.850 C
Fill
0.038
0.016
0.109
0.207
0.013
0.014
0.042
14.30
8.227
0.310
0.190
0.065
u
u
2.830
0.594
u
0.830
Table A.2 (Continued)
Calculation ol Current Average
Sile-'Mde Soil Concentratione !or BHC Isomers (1, 2)
Geigy Chemical Corporation Site
0.5' _ ,.
NS
NS
NS
NS
NS
NS
NS
NS
NS
Fill
NS
NS
NS
NS
NS
NS
Fill
Fill
NS
NS
NS
NS
NS
NS
NS
Fill
NS
NS
NS
NS
Fill
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
(Concenlratlon: mg/kg)
.!...!!:.
NS
NS
NS
NS
NS
NS
NS
NS
NS
28.30
NS
NS
NS
NS
NS
NS
1.290
Fill
NS
NS
NS
NS
NS
NS
NS
Fill
NS
NS
NS
NS
Fill
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
1.5ft.
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
0.610
NS
NS
NS
NS
NS
NS
NS
FlH
NS
NS
NS
NS
Flll
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
2h
NS
NS
NS
NS
NS
NS
NS
NS
0.376 J
3.670 C
0.047
0.027
NS
NS
NS
NS
u
u
1.200 C
0.070 J
u
NS
0.012
u
NS
Fill
1.60 C
u
NS
0.026
Fill
NS
NS
u
u
u
u
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
2'-5'
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
0.307
NS
NS
NS
NS
RH
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
'" u
NS
NS
NS
NS
NS
NS
NS
0.011
0.049
0.128
u
NS
NS
NS
NS
u
u
0.059
0.050
u
NS
u
u
NS
u
u
u
NS
u
0.690
NS
NS
0.013 J
u
u
u
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
.€=19.:
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
.!Q.!!
NS
NS
NS
NS
NS
NS
NS
NS
NS
0.018
NS
NS
NS
NS
NS
NS
u
NS
NS
NS
NS
NS
NS
NS
NS
u
NS
u
NS
NS
0.070
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
!!...!!
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
I
Table A.2 (Continued)
Calculation of Current Average
Site-Wide Soil Concentrations tor BliC lsOl'Tlflrs {1, 2)
Geigy Chemical Corpon1.tion Site
(Concentralion: mg/k.g)
So<I s.m,~ Ao=al
I Sample !Q Deplh ~ !.€...:..!.: .!...!!:. 1.5 h. ,..!! ~ §.!! 5'-10' !Q..!! .!.!...!!
127 A 7' Fill Flll Fm All Fill Fill All 0.349 NS NS
128 B 6'6• Fill RU Fill Fill Fill Fill Fill 0.53< NS NS
129 C 11' Fill Fill Fill Fill Fill Fill FIii Fill Fill 0.320
130 D 7'6· Fill Fill Fill Fill Fill Fill Fill 0.130 NS NS
D 131 E •• Fill Fill Fill Fill Fm Fill Fill 0.209 NS NS
132 F 11' Fill Fill Fill Fill Fill Fill FIii Fill Fi11 1.630
133 G e·e· Fill Fill Fill Fill Fill Fill Fill 0,509 NS NS
134 H •• Fill Fill Fill Fill Fill Fill Fill 5.340 NS NS
135 5' Fill Fill Fill Fill RH Fill 0.171 NS NS NS u 136 J 5' Fill Fill Fill Fill Fill Fill 0.213 NS NS NS
137 K 5' Fill Fill Fill Fill Fill Fill 0.328 NS NS NS
138 50-1 0.110 J NS NS u NS u NS NS NS NS
139 50-2 u NS NS u NS u NS NS NS NS
E 1,0 50-3 u NS NS 0.015 NS u NS NS NS NS
"' 50-4 u NS NS NS NS NS NS NS NS NS
1'2 50-8 0.250 J NS NS 1.530 C NS NS NS NS NS NS
143 50-7 0.0044 J NS NS NS NS NS NS NS NS NS
144 50-8 0.410 J NS NS u NS 0.021 NS NS NS NS
I 145 50-9 1'6• Fill Fill RH u NS u NS NS NS NS
140 50-10 1' Fill Fill Fill u u u u NS u NS
147 50-11 NS NS NS 1,140 C 0.0-41 u u NS NS NS
148 50-12 3• FiU Fill Fill Fill Fm u 0.043 NS NS NS
I 149 50-13 0.094 J NS NS u NS u NS NS NS NS
150 SD-14 ,·s· Fill Fill Fill u 0.010 NS u NS u NS
151 50-15 3• Fill Fm Fill Fill Fm 0.092 NS NS NS NS
152 50-18 u NS NS NS NS NS NS NS NS NS
153 50-19 0.176 J NS NS u NS u NS NS NS NS
D 15' 50-20 0.043 J NS NS NS NS NS NS NS NS NS
155 50-21 u NS NS u NS u NS NS NS NS
158 50-41 u NS NS NS NS NS NS NS NS NS
157 OS0-21 u NS NS NS NS NS NS NS NS NS
I 158 050-23 u NS NS NS NS NS NS NS NS NS
159 050-24 u NS NS u NS u NS NS NS NS
160 050-25 u NS NS NS NS NS NS NS NS NS
161 050-26 u NS NS NS NS NS NS NS NS NS
162 OS0-27 u NS NS u NS u NS NS NS NS
I 163 OS0-28 u NS NS u NS 0.026 0,036 NS NS NS
164 0$0-'30 NS NS NS u NS NS u NS NS NS
165 050-42 u NS NS NS NS NS NS NS NS NS
166 OSD---43 0.54-0 J NS NS NS NS NS NS NS NS NS
I Tolal 40.11 2.20 30.18 3.53 9.90 21.26 19.27 7.07 0.09 1.95
Number of Samples 166 31 29 39 57 32 60 • 18 2
j Average BHC isomer concentration at i;:ite 0.31 mglkg
I 1 -Remedial lnve11tigation Study, Geigy Chemical Corporation Sito; ERM-Southea11t, Inc., March 16, 1992.
2-Fleld Activltie'G Report-Building Demolidon And Soil Removal, Geigy Chemical Corporation Site; Olin Corporation; October, 1991.
I U -Not Detected al lhe detection limit indicated
J -O\Jantitative eGUma1e
C -Confirmed by GC/MS
NS -Not Sampled
FlU -Covered with clean till
I SS -Soll Sample
SlAB-Soil 11ample from beneath warehouse foundation
SO -Sediment Sample
OSO-Oll-6ile 11ediment 11amplc
I File: MARCH\A-2
Date: 03/13/92 ,
I
I
u
I
I
I
I
I
I
I
I
I
I
I
Soil
Sampl
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
Sample
!Q
S&--01
S&--03
S&--04
S&--05
S&--06
S&--09
ss-20
SS-21
SS-22
SS-23
SS-24
SS-25
SS-26
SS-27
SS-28
SS-29
SS-30
SS-31
SS-32
SS-34
SS-35
SS-36
SS-37
SS-38
Ss-39
S$-40
ss-41
S&-42
S&-43
S&-44
S&-45
S&-46
S&-47
S&-46
S&-49
SS-50
SS-51
SS-52
SS-53
SS-54
SS-56
SS-57
SS-58
SS-59
SS-60
SS-61
SS-62
SS-63
SS-64
SS-65
SS-66
SS-67
SS-68
SS-69
SS-71
SS-72
SS-73
SS-75
SS-76
SS-77
SS-78
SS-79
SS-80
Removal
Depth
3'
4'
••
8"
2'
Surface
0.340
220
u
120
450
u
1.50
1.80
1.30
u
0.810
5.60
u
3.20
0.850
0.920
0.490
1.30
0.430
u
3.30
u
u
u
u
0.920
0.760
0.740
2.30
4.70
0.860
11.0
8.0
130
15.0
5.80
18.0
0.400
3.60
4.10
5.40
37.0
83.0
14.0
9.30
54,0
59.0
130
3,700
460
840
NS
0.250
1,400
54,0
320
520
4.70
18.0
u
15.0
20.0
8.10
Table A.3
Calculation of Pre-1989 Average
Site-Wide Soil Concentrations for T oxaphene ( 1, 2)
Geigy Chemical Corporation Site
0.5' -1'
NS
220
NS
120
450
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
22.0
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
3,700
460
840
NS
0.250
2.60
NS
NS
520
NS
18.0
NS
NS
NS
NS
(Concentration: mg/kg)
!..!!:.
NS
NS
NS
120
450
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
16.0
NS
0.440
NS
NS
NS
NS
NS
5,500
NS
18.0
NS
NS
NS
NS
1.5 ft.
NS
NS
NS
120
450
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
16.0
NS
NS
NS
NS
NS
NS
NS
5,500
NS
18.0
NS
NS
NS
NS
2 ft
NS
NS
NS
120
450
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
u
NS
1.0
0.810
NS
38.0
NS
NS
NS
NS
u
24.0
u
NS
u
u
u
u
NS
u
0.460
NS
0.260
1.40
26.0
5,500
NS
18.0
2.80
u
u
NS
2'-5'
NS
u
NS
120
450
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
7.60
NS
NS
NS
NS
NS
NS
5ft
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
u
NS
u
u
NS
u
NS
NS
NS
NS
u
u
u
NS
u
u
u
u
u
u
u
NS
u
u
0.200
280
NS
3.40
u
u
u
NS
s·-10·
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
1Q.I!
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
u
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
u
u
u
u
NS
NS
u
NS
u
u
NS
1.90
NS
NS
NS
NS
.!!.!
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
I
u
I
I
I
I
I
I
I
I
I
I
I
I
Soil
Sampl
64
65
Sample
!Q
SS---111
SS---112
66 SS---113
67 S$-84
68 S5--85
69 SS-87
70 SS--88
71 SS-89
72 SS-00
Removal
Depth
73 SS-91 1'
74 SS-02
75 SS-93
76 SS--94
n ss-95
78 SS-96
79 SS-97
80 SS-98 1'
81 SS-99 1'6•
82 SS-100
83 SS-101
84 SS-103
85 SS-104
86 SS-105
87 SS-106
88 SS-107
89 SS-108 3'
90 SS-109
81 SS-110
92 SS-111
93 SS-112
94 SS-113 5'
95 SS-114
96 SS-115
97 SS-116
98 SS-117
99 SS-118
100 SS-119
101 S-58-20S
102 5--61-20S
103 S-62-20S
104 6-63-20S
105 5-64-20S
106 S-66-20S
107 S-91-t0N
108 S-92-l0N
109 S-93-10N
110 S-93-20E
111 SLAB 8
112 SLAB 9
113 SLAB 10
114 SLAB 11
115 SLAB 12
116 SLAB 13
117 SLAB 14
118 SLAB 15
119 SLAB 16
120 SLAB 17
121 SLAB 18
122 SLAB 19
123 SLAB 20
124 SLAB 21
125 SLAB 22
126 SLAB 23
Surface
33.0
3.60
0.510
1.90
2.90
4.30
8.80
8.70
26.0
530
35.0
78.0
3.90
1.50
u
0.850
330,000
19.0
54.0
18.0
21.0
7.10
18.0
18.0
2.10
33,000
59.0
130
3.70
12.0
1,900
4.70
8.50
48.0
18.0
14.0
34.0
220
3.90
5.20
64.0
u
u
15.0
u
4.40
1.90
0.620
1.50
u
u
u
u
u
2.70
5.90
1.40
u
u
3.90
1.80
0.290
6.30
Table A.3 (Continued)
Calculation of Pre-1989 Average
Site-Wide Soil Concentrations for Toxaphene (1, 2)
Geigy Chemical Corporation Site
0.5' -1'
NS
NS
NS
NS
2.90
4.30
8.80
8.70
26.0
530
35.0
NS
NS
NS
NS
NS
2.20
6.90
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
2.60
4.70
8.50
NS
18.0
NS
34.0
NS
NS
NS
NS
NS
NS
NS
u
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
(Concentration: mg/kg)
!.!!,
NS
NS
NS
NS
NS
NS
NS
NS
NS
27.0
NS
NS
NS
NS
NS
NS
2.20
6.90
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
2.60
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
1.5 tt.
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
6.90
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
2.60
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
2 tt
u
NS
NS
NS
NS
NS
NS
NS
0.310
u
u
0.810
NS
NS
NS
NS
u
u
15.0
0.400
0.560
NS
1.40
u
NS
u
u
1.10
NS
u
2.60
NS
NS
u
u
u
u
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
2'-5'
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
6.40
NS
NS
NS
NS
1.50
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
5tt
u
NS
NS
NS
NS
NS
NS
NS
2.20
u
0.440
u
NS
NS
NS
NS
u
u
u
0.220
u
NS
u
u
NS
u
0.260
1.0
NS
u
1.50
NS
NS
u
u
u
u
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
5'-10'
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
!Q.1!
NS
NS
NS
NS
NS
NS
NS
NS
NS
u
NS
NS
NS
NS
NS
NS
u
NS
NS
NS
NS
NS
NS
NS
NS
u
NS
u
NS
NS
u
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
.!..!..!!
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
I Table A.3 (Continued)
Calculation of Pre-1989 Average
Sito-Wide Soil Concentrations for Toxaphene (1, 2)
Geigy Chemical Corporation Site
{Concentration: mg/kg)
Soil Sample Removal
Sampl !Q_ Depth Surface 0.5' -1' !..!!:. 1.5 ft. ~ 2·-s· §JI_ ~ ~ .!!.!!
127 A 7' 1.20 1.20 1.20 1.20 1.20 1.20 1.20 1.20 NS NS
128 B 6'6• 0.490 0.490 0.490 0.490 0.490 0.490 0.490 0.490 NS NS I 129 C 11' 56.0 56.0 56.0 56.0 56.0 56.0 56.0 56.0 56.0 56.0
130 D re· u u u u u u u u NS NS
131 E 8' 6.50 6.50 6.50 6.50 6.50 6.50 6.50 6.50 NS NS
I 132 F 11' 110 110 110 110 110 110 110 110 110 110
133 G 6'6"' 1.80 1.80 1.80 1.80 1.80 1.80 1.80 1.80 NS NS
134 H •• 42.0 42.0 42.0 42.0 42.0 42.0 42.0 42.0 NS NS
135 5· 1.20 1.20 1.20 1.20 1.20 1.20 1.20 NS NS NS
I 136 J 5' 2.60 2.60 2.60 2.60 2.60 2.60 2.60 NS NS NS
137 K 5' 3.60 3.60 3.60 3.60 3.60 3.60 3.60 NS NS NS
138 S0-1 28.0 NS NS 8.0 NS u NS NS NS NS
139 S0-2 11.0 NS NS u NS u NS NS NS NS
I 140 S0-3 14.0 NS NS 0.540 NS 0.920 NS NS NS NS
141 SD-4 u NS NS NS NS NS NS NS NS NS
142 S0-6 43.0 NS NS 58.0 NS NS NS NS NS NS
143 S0-7 0.540 NS NS NS NS NS NS NS NS NS
I 144 SD-8 14.0 NS NS 2.80 NS 1.20 NS NS NS NS
145 S0-9 1'6• 410 410 2.20 2.20 NS 130 NS NS NS NS
146 S0-10 1' 540 540 54.0 54.0 0.600 1.30 0.200 NS u NS
147 SD-11 3,300 NS NS 68.0 1.90 15.0 3.20 NS NS NS
I 148 S0-12 3• 1,100 1,100 15.0 15.0 15.0 15.0 u NS NS NS
149 S0-13 18.0 NS NS 0.180 NS u NS NS NS NS
150 SD-14 1'6'" 45,000 45,000 5.50 5.50 5.20 NS 8.500 NS 7.90 NS
151 S0-15 3' 2100 2100 100 100 150 150 NS NS NS NS -152 S0-18 2.20 NS NS NS NS NS NS NS NS NS
153 SD-19 11.0 NS NS u NS u NS NS NS NS
154 S0-20 9.70 NS NS NS NS NS NS NS NS NS
155 S0-21 13.0 NS NS 26.0 NS 4.0 NS NS NS NS
I 156 S0-41 2.30 NS NS 2.30 NS NS NS NS NS NS
157 0S0-21 u NS NS NS NS NS NS NS NS NS
158 OS0-22 25.0 NS NS 1.10 NS 1.20 NS NS NS NS
159 0S0-23 0.200 NS NS NS NS NS NS NS NS NS
I 160 0S0-24 u NS NS 2.70 NS 0.790 NS NS NS NS
161 OS0-25 u NS NS NS NS NS NS NS NS NS
162 0S0-26 0.280 NS NS NS NS NS NS NS NS NS
163 OS0-27 u NS NS 25.0 NS 6.20 NS NS NS NS
I 164 OS0-28 21.0 NS NS 36.0 NS 2.30 4.20 NS NS NS
185 0S0-30 NS NS NS 1.10 NS 1.20 NS NS NS NS
186 0S0-42 1.30 NS NS NS NS NS NS NS NS NS
167 OSD-43 44.0 NS NS NS NS NS NS NS NS NS
I Total 428171 56421 6545 6747 8603 1140 531 218 176 186
Number of Samples 186 42 26 38 60 34 59 8 18 2
I j Average T oxaphene concentration at site 1119 mg/kg
1 -Remedial Investigation Study. Geigy Chemical Corporation Site; ERM-Southeast, Inc., March 16. 1992.
I 2 -Field Activities Report -Building Demolition And Soil Removal, Geigy Chemical Corporation Site; Olin Corporation: Oclober, 1991.
U -Not Detected al tho detection limit indicated
J -Quantitative estift1ate
C -Confirmed by GCIMS
NS -Nol Sampled
Fill -Covered with clean fill
SS -Soil Sample
SLAB -Soil sample from beneath warehouse foundation
SD -Sediment Sample
OSD -Off-site sediment sample
File: MARCH\A-3
I Date: 03/13/92
I
I
I
I
I
I
I
I
I
I
I ,
I
Soil
Sampl
1
2
3 • • • 7
• •
10
11
12
Samp~
!Q
SS--01
SS--03
SS--04
SS--05
SS--06
SS--09
SS-20
SS-21
SS-22
SS-23
SS-24
SS-25
13 SS-26
1-t SS-27
15 SS-28
16 SS-29
17 SS-30
18 SS--31
19 SS-<12
20 SS-34
21 SS--<>5
22 SS-36
23 SS-37
24 SS-38
25 SS-39
26 SS-40
27 SS--41
26 SS-42
29 SS-43
30 SS-44
31 SS--45
32 SS-46
33 SS-47
34 SS-46
35 SS-49
36 5S-60
37 SS-51
39 SS-52
39 SS-53
.. 55-54
., SS-56
42 SS-57
43 SS-66
.. SS-59
45 SS-60
.. SS--81
47 SS--82
48 SS--83
.. SS--84
50 SS--85
51 SS--86
52 SS--87
53 SS-&
54 SS--89
55 SS-71
56 SS-72
57 SS-73
58 SS-75
59 SS-76
60 SS-TT
61 SS-78
62 SS-79
63 ss..ao
Removal
Depth
3' ..
••
1'6~
3'
1'
,.
2'
Surface
0.340
Fill
u
Fill
Fm
u
1.50
1.80
1.30
u
0.810
5.60
u
3.20
0.650
0,920
0.490
1.30
0.430
u
3.30
u
u
u
u
0.920
0.760 J
0.740 J
2.30
4.70
0.860
11.0 J
8.0 J
Fill
15.0 J
5,60 J
16.0 J
0.400
3,80
4.10 J
5.40 J
37.0 J
83.0 J
14.0 J
9.30 J
54,0 J
59.0 J
130 J
Fin
Fill
Fill
Fill
Fill
Fill
54.0 J
Fill
Fill
Fill
Fill
Fill
Fill
Fill
Fill
Table A.-t
Calculallon of Current Average
Site-Wide Soil Conoentratlone for Toxaphene (1, 2)
Geigy Chemical Cotporatlon Site
0.5' -1'
NS
Fill
NS
Fill
Fill
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
22.0
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
Fill
Fill
Fill
NS
0.250 J
2.80
NS
NS
Fill
NS
Fill
NS
NS
NS
NS
(Coooont,atlon: mg/kg)
!..!.!:.
NS
Fill
NS
Fill
Fill
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
Fill
RII
0.440
NS
NS
NS
NS
NS
Fill
NS
RH
NS
NS
NS
NS
1.5h.
NS
RH
NS
FIii
RU
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
16.0
FIii
NS
NS
NS
NS
NS
NS
FIii
NS
Fill
NS
NS
NS
NS
g_!!
NS
Fill
NS
FUI
RU
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
u
NS
1,0
0.810
NS
38.0 C
NS
NS
NS
NS
u
~.o J
u
NS
u
u
u
u
Fill
u
0.480
NS
0.260 J
1.40
NS
RH
NS
18.0
NS
NS
NS
NS
2'-5'
NS
u
NS
120 C
450 C
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
7.80
NS
NS
NS
NS
NS
NS
§..!!
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
u
NS
u
u
NS
u
NS
NS
NS
NS
u
u
u
NS
u
u
u
u
u
u
u
NS
u
u
0.200
280 C
NS
3.40
u
u
u
NS
£:.![.
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
.!Q..!!
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
u
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
u
u
u
u
NS
NS
u
NS
u
u
NS
1.90
NS
NS
NS
NS
.!l!!
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
'NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS'
NS
NS
I
I
I
I
I
• I
I
I
I
I
I
I ,
I
Soll
Sampl
64
65
66
67
66
69
70
71
72
73
74
75
76
77
78
79
60
61
02
03
64
05
86
" .. ••
00
Samp~
!Q
SS-81
SS-82
SS-83
SS-M
SS-85
SS-87
SS-88
SS-89
SS-00
ss-91
SS-82
SS-93
ss-94
SS-65
SS-66
SS-97
SS--96
SS-99
SS-100
SS--101
SS--103
SS-104
SS--105
SS-106
SS--107
SS-100
SS-109
91 SS--110
92 SS--111
93 SS--112
1'
1'
1'6"
3'
94 SS-113 5'
95 SS-114
96 SS-115
97 SS-116
~ SS-117
99 SS-118
100 SS-119
101 SS-58-20S
102 SS-61-20S
103 SS-62-20S
104 SS-63--20S
105 SS-M--20S
106 SS-66-20S
107 5--91-l0N
108 5-92-l0N
109 5-93-t0N
110 SS-93--20E
111 SLAB 6
112 SLAB 9
113 SLAB 10
114 SLAB11
115 SLAB12
116 SLAB 13
117 SLAB 14
116 SLAB 15
119 SLAB 16
120 SLAB 17
121 SLAB 18
122 SLAB 19
123 SLAB20
124 SLAB21
125 SLAB22
126 SLAB23
Surface
Fill
3.60
0,510
1.00
Fill
Fill
FIii
Fill
RU
Fill
Fill
76.0 J
3.00
1.50 J
u
0.850
Fm
Fifi
Fill
Fill
21.0 J
7.10 J
16.0 J
16.0 J
2.10
Fill
Fill
130 J
FIii
Fill
Fill
Fill
All
Fill
Fill
Fill
Fill
220 C
3.90
5.20 C
64.0 C
u
u
15.0 C
All
4.40
1.90
0.620
1.50
u
u
u
u
u
2.70
5.90
1.40
u
u
3.00
1.60
0.290
8.30
Table A.◄ (Continued)
Cak:u1ation of Current Average
Site-Wde Soll Concenlra!lons for Toxaphone (1, 2)
Geigy Chemical Corporation Sile
0.5' -,.
NS
NS
NS
NS
2.00
◄.30 J
6.80
8.70
26.0 J
Fill
35.0 J
NS
NS
NS
NS
NS
Fill
FiU
NS
NS
NS
NS
NS
NS
NS
Fill
NS
NS
NS
NS
Fill
4.70
8.50 J
NS
18.0 J
NS
34.0 J
NS
NS
NS
NS
NS
NS
NS
u
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
(Concentralion: mglk.g)
!.!!:. NS
NS
NS
NS
NS
NS
NS
NS
NS
27.0
NS
NS
NS
NS
NS
. NS
Z20
Fill
NS
NS
NS
NS
NS
NS
NS
·Fill
NS
NS
NS
NS
Fill
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
'NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
~ NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
6.00
NS
NS
NS
NS
NS
NS
NS
Fill
NS
NS
NS
NS
Flll
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
2h
NS
NS
NS
NS
NS
NS
NS
NS
0.310 J
u
u
0.610
NS
NS
NS
NS
u
u
15.0 C
0.400
0.560 J
NS
1.40
u
NS
Fill
u
1.10
NS
u
Fill
NS
NS
u
u
u
u
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
2'-5'
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
6.40
NS
NS
NS
NS
Fill
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
'" u
NS
NS
NS
NS
NS
NS
NS
2.20
u
0.440
u
NS
NS
NS
NS
u
u
u
0.220
u
NS
u
u
NS
u
0.2"'
1.0
NS
u
u
NS
NS
u
u
u
u
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
~
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
12..!!
NS
NS
NS
NS
NS
NS
NS
NS
NS
u
NS
NS
NS
NS
NS
NS
u
NS
NS
NS
NS
NS
NS
NS
NS
u
NS
u
NS
NS
u
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
.!.!.!!.
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
D
'-
Table A.4 (Continued)
Calculation ol Current Average
Site-Wide Soll Concentrations for Toxaphene (1. 2)
Geigy Chemical Corporation Site
m (Concentration: mg/1::g)
Soll Samp~ Ro=al
Sampl !Q Depth Surface ~ .!..!!:. 1.5 ft. 2h 2'--5' Sh ~ .!!!..!! l.!...!! I 127 A T Fill Fill FIii Fill Fill Fill Fill 1.20 NS NS
128 B s·s· FIii Fill Fill Fill Fill Fill Fill 0.490 NS NS
129 C 11' Fill Fill FIii Fill Fill Fill Fill Fill Fill 56.0
130 D re· Fill Fill Fill Fm Fill Fill Fill u NS NS
I 131 E 8' Fill Fill Fill Fill Fill Fill Fill 6.50 NS NS
132 F 11' FIii Fill Fm Fill FUI Fill Fill Fill Fill 110
133 G e·s· Fill Fill FIii Fill FIii Fill Fill 1.80 NS NS
134 H 8' Fill Fill Fill Fill_ Fill Fill Fill 42.0 NS NS
135 6' Fill Fill FIil Fill Fill Fill 1.20 NS NS NS
I 136 J 6' Fill Fill FIii Fm Fill Fill 2.60 NS NS NS
137 K 6' Fill Fill Fill Fill FIii Fill 3.eo NS NS NS
138 50-1 28.0 NS NS 8.0 C NS u NS NS NS NS
139 50-2 11.0 NS NS u NS u NS NS NS NS
I 140 50-3 14.0 NS NS 0.540 NS 0.920 NS NS NS NS
141 50-4 u NS NS NS NS NS NS NS NS NS
142 SD-< 43.0 J NS NS 58.0 C NS NS NS NS NS NS
143 50-7 0.540 NS NS NS NS NS NS NS NS NS
144 SD-a 14.0 J NS NS 2.60 NS 1.20 NS NS NS NS
I 145 50-9 ,·e· Fill Fill Fill 2.20 J NS 130 C NS NS NS NS
146 50-10 1' Fill Fill Fill 4.60 0.600 1.30 0.200 NS u NS
147 S0-11 NS NS NS 66.0 C 1.90 15.0 C 3.20 J NS NS NS
148 50-12 3' Fill Fill Fill Fill Fm 15.0 C u NS NS NS
149 50-13 18.0 J NS NS 0.180 NS u NS NS NS NS
I 150 50-14 ,·s· Fill Fill Fill 6.50 5.20 C NS 6,500 J NS 7.90 J NS
151 50-15 3' Fill Fill Fill Fill FIii 4.0 NS NS NS NS
152 50-18 2.20 NS NS NS NS NS NS NS NS NS
153 50-19 11.0 NS NS u NS u NS NS NS NS
II 154 50-20 9.70 NS NS NS NS NS NS NS NS NS
155 50-21 13.0 NS NS 26.0 C NS 4.0 NS NS NS NS
158 50-41 2.30 NS NS 2.30 NS NS NS NS NS NS
157 OSD-21 u NS NS NS NS NS NS NS NS NS
158 OSD-22 25.0 NS NS 1.10 NS 1.20 NS NS NS NS
I 159 050-23 0.200 NS NS NS NS NS NS NS NS NS
160 OS0-24 u NS NS 2.70 NS 0.790 NS NS NS NS
161 OSD-25 u NS NS NS NS NS NS NS NS NS
162 050-26 0.260 NS NS NS NS NS NS NS NS NS
I 163 0S0-27 u NS NS 25.0 C NS 6.20 C NS NS NS NS
164 OSD-28 21.0 NS NS 36.0 NS 2.30 4.20 NS NS NS
165 050-30 NS NS NS 1.10 NS 1.20 NS NS NS NS
166 050-42 1.30 NS NS NS NS NS NS NS NS NS
167 050-43 44.0 J NS NS NS NS NS NS NS NS NS
I To<aJ 1427.5 175,6 29.6 266.9 111.2 767.1 311.2 52.0 9.8 166
Number ol Samples 164 40 25 35 59 29 58 8 18 2
I I Average Toxaphene concentration a1 site 7.57 mg/kg
1 -Remedial Investigation Study, Geigy Chemical Corpol'ation Site; ERM-SOUtheast, Inc., March 16, 1992.
2 -Field Activities Report -Building Demolition And Soil RemoYal, Geigy Chemical Corporation Site; Olin Corporation; October, 1991.
I U -Nol Detected al the detection limit indicated
J -Quanlilalive eatima\e
C -Confirmed by GCIMS
NS -Nol Sampled
I RII -Coverod with clean fill
SS -Soil Sample
SLAB -Soil sample lrom beneath warehouse lounda!ion
SO-Sediment Sample
OSO -Off-eite sediment sample
FIie: MARCH\A-4
Date: 03/13/92
I
D
TableA.5
Current Toxaphene Concentrations in Site Surficial Soils
Geigy Chemical Corporation Site (1)
(Concentration: mg/kg)
Sample Sample Sample • ID ToxaQhene ID ToxaQhene ID ToxaQhene
SS-01 0.340 SS-59 14.0 J SD-4 u
SS-04 u SS-60 9.30 J SD-6 43.0 J
SS-09 u SS-61 54.0 J SD-7 0.540
I SS-20 1.50 SS-62 59.0 J SD-8 14.0 J
SS-21 1.80 SS-63 130 J SD-13 18.0 J
SS-22 1.30 SS-68 0.250 J SD-18 2.20
I SS-23 u SS-71 54.0 J SD-19 11.0
SS-24 0.810 SS-82 3.60 SD-20 9.70
SS-25 5.60 SS-83 0.510 SD-21 13.0
SS-26 u SS-84 1.90 SD-41 2.30
I SS-27 3.20 SS-85 2.90 OSD-21-01 u
SS-28 0.850 SS-87 4.30 J OSD-22-01 25.0
SS-29 0.920 SS-88 8.80 OSD-23-01 0.200
I SS-30 0.490 SS-89 8.70 OSD-24-01 u
SS-31 1.30 SS-90 26.0 J OSD-25-01 u
SS-32 0.430 SS-92 35.0 J OSD-26-01 0.280
SS-34 u SS-93 78.0 J OSD-27-01 u
I SS-35 3.30 SS-94 3.90 OSD-28 21.0 (2)
SS-36 u SS-95 1.50 J OSD-29 36.0 (3)
SS-37 u SS-96 u OSD-30-01 25.0 • SS-38 u SS-97 0.850 OSD-42-0.5 1.30
SS-39 u SS-103 21.0 J OSD-43-0.5 44.0 JC
SS-40 0.920 SS-104 7.10 J SLAB-8 0.620
SS-41 0.760 J SS-105 18.0 J SLAB-9 1.50
I SS-42 0.740 J SS-106 18.0 J SLAB-10 u
SS-43 2.30 SS-107 2.10 SLAB-11 u
SS-44 4.70 SS-110 130 J SLAB-12 u
I SS-45 0.860 SS-58-20S 220 C SLAB-13 u
SS-46 11.0 J SS-61-20S 3.90 SLAB-14 u
SS-47 8.0 J SS-62-20S 5.20 C SLAB-15 2.70
I SS-49 15.0 J SS-63-20S 64.0 C SLAB-16 5.90
SS-50 5.80 J SS-64-20S u SLAB-17 1.40
SS-51 18.0 J SS-66-20S u SLAB-18 u
SS-52 0.400 SS-92-l0N 15.0 C SLAB-19 u
I SS-53 3.60 SS-93-10N 4.40 SLAB-20 3.90
SS-54 4.10 J SS-93-20E 1.90 SLAB-21 1.80
SS-56 5.40 J SD-1 28.0 SLAB-22 0.290
I SS-57 37.0 J SD-2 11.0 SLAB-23 6.30
SS-58 83.0 J SD-3 14.0
I U -Not Detected at the detection limit indicated
C -Confirmed by GC/MS
J -Quantitative Estimate
SS -Soil Sample
I SD -Sediment Sample
OS□ -Off-Site Sediment Sample , 1 -Remedial Investigation Study, Geigy Chemical Corporation Site; ERM-Southeast, Inc., 20 January, 1992.
2 -OSD-28 was collected at the 0 to 1.5 tt. sample interval.
3 -Sample OSD-29 was collected at sampling location OSD-28 at the 1.5 to 3 tt. sampling interval.
File: MARCHIA-5-7
Date: 03/13/92
I
D
I
I
I
I
I
I
• I
I
I
I
I
I
I ,
I
Sample
ID Toxa~hene
SS-01 0.340
SS-04 u
SS-09 u
SS-20 1.50
SS-21 1.80
SS-22 1.30
SS-23 u
SS-24 0.810
SS-25 IRemediatel
SS-26 u
SS-27 3.20
SS-28 0.850
SS-29 0.920
SS-30 0.490
SS-31 1.30
SS-32 0.430
SS-34 u
SS-35 3.30
SS-36 u
SS-37 u
SS-38 u
SS-39 u
SS-40 0.920
SS-41 0.760 J
SS-42 0.740 J
SS-43 2.30
SS-44 4.70
SS-45 0.860
SS-46 Remediate
SS-47 ReiriE!<ll~it
SS-49 FlemE!<l1aii
SS-50 R~iri.ici1~fo
SS-51 iieihl,;;iarn
SS-52 0.400
SS-53 3.60
SS-54 4.10 J
SS-56 Remediate
SS-57 Remediate : .. ::,.:::··•:-::· ·,:: SS-58 Reniediate
Table A.6
Toxaphene Concentrations in Site Surficial Soils
Atter Remediating to a LECR of 1 0E-6
Geigy Chemical Corporation Site (1)
(Concentration: mg/kg)
Sample Sample
ID ToxaQhene ID
SS-59 ReITlediat8 SD-4
SS-60 Fl.,;;;;;a;JiJ SD-6
SS-61 Riri1~flt~ SD-7
SS-62 i:iJ;;;;,;Jilte SD-8
SS-63 i:i~ihiiiliil"IJ SD-13
SS-68 0.250 J SD-18
SS-71 IRemediatel SD-19
SS-82 3.60 SD-20
SS-83 0.510 SD-21
SS-84 1.90 SD-41
SS-85 2.90 OSD-21-01
SS-87 4.30 J OSD-22-01
SS-88 Remedia.te OSD-23-01
SS-89 iie;;;iiiliate OSD-24-01
SS-90 Ae~:~&'i~i~ OSD-25-01
SS-92 Fle~t~iltJ OSD-26-01
SS-93 F{J:~-~farn OSD-27-01
SS-94 3.90 OSD-28
SS-95 1.50 J OSD-29
SS-96 u OSD-30-01
SS-97 0.850 OSD-42-0.5
SS-103 Remediate OSD-43-0.5
SS-104 R~'M~"fJt: SLAB-8
SS-105 i:iJiii"8farn SLAB-9
SS-106 iieihl,;;1~it SLAB-10
SS-107 2.10 SLAB-11
SS-110 Remediate SLAB-12
SS-58-20S i:i~ih;,;JiJ1J SLAB-13
SS-61-20S 3.90 SLAB-14
SS-62-20S Remediate SLAB-15
SS-63-20S i:ielri.iciliit SLAB-16
SS-64-20S u SLAB-17
SS-66-20S u SLAB-18
SS-92-10N iRemediatel SLAB-19
SS-93-10N 4.40 SLAB-20
SS-93-20E 1.90 SLAB-21
SD-1 Remediate SLAB-22
SD-2 i:iemE!ilfatJ SLAB-23
SD-3 A-~-rriedGtte
Toxa~hene
u
IRemediatel
0.540
Re"rnOOiate
i:iJihiiilialil
2.20
Remediate ::-::::;:::::;:_,,,,:,:-:-:-:,:,:-:-:-:
Remediate
iiJMl,;;i~iJ
2.30
u
iRemedia.tel
0.200
u
u
0.280
u
Remediate
i:iEiiri.;;l\~iJ
iiii;;;ei.iiafo
1.30
IRemediatel
0.620
1.50
u
u
u
u
u
2.70
I Remediatel
1.40
u
u
3.90
1.80
0.290
I Remediatel
I Proposed number of sampling locations to be remediated: 44 sampling locations (See notes 2 and 3).
Volume of soil remediated: Approximately 670 cubic yards.
U -Not Detected at the detection limit indicated
C -Confirmed by GC/MS
J -Quantitative Estimate
SS -Soil Sample
SD -Sediment Sample
OSD -Off-Site Sediment Sample
(2)
(3)
1 -Remedial Investigation Study. Geigy Chemical Corporation Site; ERM-Southeast, Inc., 20 January, 1992.
2 -OSD-28 was collected at the Oto 1.5 tt. sample interval.
3 -Sample OSD-29 was collected at sampling location OSD-28 at the 1.5 to 3 tt. sampling interval.
File: MARCH\A-5-7
Date: 03/13/92
I
0
► Table A.7
. Toxaphene Concentrations in Site Surficial Soils
Alter Remediating to a LECR of 1 0E-5
Geigy Chemical Corporation Site (1)
(Concentration: mg/kg)
m
Sample Sample Sample
ID ToxaQhene ID ToxaQhene ID ToxaQhene
SS-01 0.340 SS-59 14.0 J SD-4 u
SS-04 u SS-60 9.30 J SD-6 43.0 J
I SS-09 u SS-61 Rerriectfate SD-7 0.540
SS-20 1.50 SS-62 R~'T~¥i~f~ SD-8 14.0 J
SS-21 1.80 SS-63 Remediate SD-13 18.0 J
I SS-22 1.30 SS-68 0.250 J SD-18 2.20
SS-23 u SS-71 !Rerriectiatel SD-19 11 .0
SS-24 0.810 SS-82 3.60 SD-20 9.70
SS-25 5.60 SS-83 0.510 SD-21 13.0
I SS-26 u SS-84 1 .90 SD-41 2.30
SS-27 3.20 SS-85 2.90 OSD-21-01 u
SS-28 0.850 SS-87 4.30 J OSD-22-01 25.0
I SS-29 0.920 SS-88 8.80 OSD-23-01 0.200
SS-30 0.490 SS-89 8.70 OSD-24-01 u
SS-31 1 .30 SS-90 26.0 J OSD-25-01 u
SS-32 0.430 SS-92 35.0 J OSD-26-01 0.280
I SS-34 u SS-93 IRemediatel OSD-27-01 u
SS-35 3.30 SS-94 3.90 OSD-28 21.0 (2)
SS-36 u SS-95 1.50 J OSD-29 36.0 (3)
B SS-37 u SS-96 u OSD-30-01 25.0
SS-38 u SS-97 0.850 OSD-42-0.5 1.30
SS-39 u SS-103 21.0 J OSD-43-0.5 44.0 JC
SS-40 0.920 SS-104 7.10 J SLAB-8 0.620 I SS-41 0.760 J SS-105 18.0 J SLAB-9 1.50
SS-42 0.740 J SS-106 18.0 J SLAB-10 u
SS-43 2.30 SS-107 2.10 SLAB-11 u
I SS-44 4.70 SS-110 Remediate SLAB-12 u
SS-45 0.860 SS-58-20S RJffi;;;Jiiite SLAB-13 u
SS-46 11 .0 J SS-61-20S 3.90 SLAB-14 u
I SS-47 8.0 J SS-62-20S 5.20 C SLAB-15 2.70
SS-49 15.0 J SS-63-20S !Remectiatel SLAB-16 5.90
SS-50 5.80 J SS-64-20S u SLAB-17 1 .40
SS-51 18.0 J SS-66-20S u SLAB-18 u
I SS-52 0.400 SS-92-10N 15.0 C SLAB-19 u
SS-53 3.60 SS-93-10N 4.40 SLAB-20 3.90
SS-54 4.10 J SS-93-20E 1.90 SLAB-21 1.80
I SS-56 5.40 J SD-1 28.0 SLAB-22 0.290
SS-57 37.0 J SD-2 11 .0 SLAB-23 6.30
SS-58 !Remectiatel SD-3 14.0
I Number of sampling locations remediated: 9
Volume of soil remediated: Approximately 140 cubic yards
U -Not Detected at the detection limit indicated
C -Confirmed by GC/MS
J -Quantitative Estimate
SS -Soil Sample
SD -Sediment Sample
OSD -Off-Site Sediment Sample
1 -Remedial Investigation Study, Geigy Chemical Corporation Site: ERM-Southeast, Inc., 20 January, 1992.
2 -OSD-28 was collected at the 0 to 1 .5 ft. sample interval.
I 3 -Sample OSD-29 was collected at sampling location OSD-28 at the 1.5 to 3 It. sampling interval.
File: MARCHIA-5-7
Date: 03/13/92
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Table A.8
Foundation Volume Calculations (Concrete and Fill Soil)
Geigy Chemical Corporation Site
Total Volume Estimate for Concrete and Fill Soil (1)
Len!l!!! Width Height Volume
Warehouse A 200 ft. 60 ft. 3 ft. 1,333 Cubic Yards
Warehouse B 60 ft. 40 ft. 3 ft. 267 Cubic Yards
Total Volume of Concrete and Fill Soil: 1,600 Cubic Yards
Estimated Fill Soil Volume
Assumes a 2.3 foot thick layer of fill soil and a concrete slab thickness of 0. 7 feet
Length Width Height Volume
Warehouse A 198.7 ft. 58.7 ft. 2.3 ft. 1,007 Cubic Yards
Warehouse B 58.7 ft. 38.7 ft. 2.3 ft. 193 Cubic Yards
Total Fill Soil Volume: 1,200 Cubic Yards
Estimated Concrete Slab Volume
Warehouse A (Total Volume)-(Soil Volume) 326 Cubic Yards
Warehouse B (Total Volume)-(Soil Volume) 73 Cubic Yards
Total Concrete Slab Volume: 400 Cubic Yards
1 = This is the estimated volume of concrete and fill soil that would have to be excavated
to gain access to the soil underlying the slab foundations of former warehouses A and B
(Figure 2.1).
File: SLABVOL.OLN
Date: 01 /20/92
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APPENDIX B
RISK-BASED REMEDIATION GOALS FOR PESTICIDES IN GROUNDWATER
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Introduction
Six pesticides in the surficial aquifer at the Site lack established groundwater quality criteria (e.g.,
MCLs) for consideration in the development of remedial alternatives: aldrin, alpha-BHC, beta-
BHC, delta-BHC, dieldrin, and endrin ketone. An attempt was made to develop health-based
groundwater remediation goals for these pesticides that would have a general equivalence to
MCLs. Results are summarized in Table 4.2, EPA methodology was followed to develop these
goals, as discussed below.
Development of Risk-Based Remediation Goals
Remediation goals were calculated using the following standard parameter values for chronic
human exposure via the groundwater ingestion pathway: 70 kg adult body weight and an adult
drinking water consumption rate of 2 liters per day (EPA, March 1990 and EPA, March 1991 ).
Site specific parameter values used here (exposure frequency, exposure duration, and averaging
time) are typical values (EPA, March 1990) .
Remediation goals for the surficial aquifer were developed for a 1 0E4 risk level since exposure
is not likely to occur since shallow groundwater would not be used for potable purposes due to
low aquifer yield. The values are presented as remediation goals since asymptotic levels may
be reached upon potential groundwater treatment, below which further reduction in concentration
may not be technically possible.
The remediation goal for ingestion of groundwater is calculated by:
RG = 1 0E4 x 365 days/yr x 70 yrs x 70 kg x 1000 ug/mg
2 I/day x 350 days/yr x 30 yrs x PF (kg-day/mg)
RG = 8.6/PF (units of ug/I)
where: RG = remediation goal
PF = slope factor (kg-day/mg)
Geigy FS B-1 January 20, 1992
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Aldrin
The EPA Carcinogen Assessment Group has classified aldrin as a group B2 substance, i.e.,
probable human carcinogen based on inadequate evidence from human studies and adequate
evidence on from animal studies (IRIS, 1991 ). The slope factor for aldrin is 17. The resultant
remediation goal is 0.0005 mg/I or 0.5 ug/1.
alpha-BHC
The EPA Carcinogen Assessment Group has classified alpha-BHC as a group B2 substance, i.e.,
probable human carcinogen based on inadequate evidence from human studies and adequate
evidence on from animal studies (IRIS, 1991 ). The slope factor for alpha-BHC is 6.3. The
resultant remediation goal is 0.0014 mg/I or 1.4 ug/1.
beta-BHC
The EPA Carcinogen Assessment Group has classified beta-BHC as a group C substance, i.e.,
possible human carcinogen based on limited evidence from animal studies in the absence of
human studies (IRIS, 1991 ). The slope factor for beta-BHC is 1.8. The resultant remediation goal
is 0.0047 mg/I or 4.7 ug/1.
delta-BHC
The EPA Carcinogen Assessment Group has classified delta-BHC as a group D substance, i.e.,
not classified as to human carcinogenicity. No slope factor or oral reference dose for
noncarcinogenic effects (RID) were found. Consequently, no remediation goal was calculated
for delta-BHC.
Dieldrin
The EPA Carcinogen Assessment Group has classified dieldrin as a group B2 substance, i.e.,
probable human carcinogen based on inadequate evidence from human studies and adequate
evidence on from animal studies (IRIS, 1991 ). The slope factor for dieldrin is 16. The resultant
remediation goal is 0.0005 mg/I or 0.5 ug/1.
Geigy FS B-2 January 20, 1992
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Endrin Ketone
No RID or slope factor were found for endrin ketone. Consequently, it was not possible to
calculate a remediation goal.
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APPENDIX C
DESCRIPTION OF THE VADOSE ZONE INTERACTIVE PROCESSES (VIP) MODEL
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Introduction
Remediation goals for subsurface soils located above the water table (the vadose zone or the
unsaturated zone) are based on the potential of a chemical to impact groundwater. The potential
impact of pesticides in the vadose zone soil on groundwater in the surficial aquifer were
estimated using the Vadose Interactive Processes (VIP) model (Stevens, et al., 1991 ).
The purpose of this appendix is to provide an overview of the VIP model and to provide the
assumptions and detailed information used to perform the VIP modeling. A discussion of the
results and conclusions is provided in Section 4.
The VIP model was developed by the Civil and Environmental Engineering Department of Utah
State University (Logan, Utah) and EPA's Kerr Environmental Laboratory in Ada, Oklahoma.
Chemical-specific fate and transport processes simulated by the VIP model include volatilization,
degradation (e.g., biodegradation, hydrolysis), sorption/desorption, advection, and dispersion.
In addition, site-specific parameters such as soil type, adsorption coefficients (Kd), and
groundwater recharge are variable to allow for more accurate modeling.
Overview of the Vadose Zone Modeling
The VIP model operates by creating a homogeneous source volume corresponding to existing
Site conditions. Site-specific parameters, such as infiltration rate and equilibrium partitioning
coefficients, are input and the model calculates the resulting leachate concentrations.
Toxaphene and total BHC were used as the chemicals of interest as they are the most prevalent
compounds in Site soils and groundwater. Gamma-BHC was modeled to represent the BHC
isomers since it had the longest half-life and lowest Kd value (Table C.1 ), making it the most
conservative choice for the modeling of the BHC isomers (i.e., most persistent and likely to
migrate to groundwater).
Geigy FS C-1 January 20, 1992
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The model predicted the maximum water-phase concentration at the bottom of the vadose zone
and the time at which this maximum occurs. This concentration (ug/I) was then blended in the
groundwater beneath the vadose zone based on the aquifer flow rate and Site-specific mixing
depth. The resulting predicted concentration for gamma-BHC and toxaphene was then
compared to its remediation goal (Table 4.2).
Major Assumptions Used for the VIP Modeling
Following is a discussion of the significant assumptions used in this VIP modeling program.
Major assumptions used in the VIP modeling are summarized in Table C.1 and discussed below.
Distance Between Contamination in Vadose Zone and Water Table For modeling purposes, the
maximum concentration of each pesticide was assumed to be distributed over a zone 12 feet
thick. Depth to groundwater in the surfical aquifer ranges from 35 to 45 feet. For VIP modeling,
depth to groundwater was assumed to be 35 feet. Therefore, depth to groundwater from the
bottom of this conceptual box was assumed to be 23 feet. Twelve feet is conservative, since the
majority of the pesticide contamination is less than 1 O feet below the ground surface, providing
a buffer of at least 23 feet of soil above the groundwater.
Soil Partitioning Coefficients (Kd) One of the most important parameters used in predicting the
fate of organic chemicals in the vadose zone is the affinity of a chemical to bind to organic and
inorganic matter in the soil. For a particular soil, a partitioning coefficient (Kd) can be measured
or calculated.
Measurement of site-specific Kd values is tedious, time-consuming, and expensive.
Consequently, many researchers have observed that Kd values for organics may be predicted
on the basis of a non soil-specific parameters known as the organic and inorganic matter
partitioning coefficients, Koc and Koi respectively (Olsen and Davis, 1990). Kd values may be
calculated from the following equation:
Geigy FS C-2 January 20, 1992
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Kd = (Koc x foe) + (Kai x foi)
where:
Koc = organic carbon partitioning coefficient
foe = fraction of organic carbon in the soil
Kai = inorganic carbon partitioning coefficient
foi = fraction of inorganic material in the soil
These values for the BHC isomers and toxaphene are provided in Table C.1.
Degradation Half-Lives Another fate process that is important for predicting the concentration
at which an organic chemical may reach the water table is the chemical's half-life in the soil. First
order decay constants associated with biodegradation or hydrolysis are the most common rate
constants used in the VIP model. Half-lives used in the VIP modeling are listed in Table C.1.
The environmental half-life for BHC isomers in soil is consistently reported in the literature as one
year or less (Table C.1). The gamma-BHC half-life was therefore set at one year. The
environmental half-life for toxaphene was reported as 1 to 14 years (HSDB, 1991 ). To determine
the Site-specific half-life for toxaphene, the VIP model was calibrated using Site conditions. Pre-
removal soil concentrations were input as the source term for comparison with existing
groundwater concentrations. All Site parameters were held constant and the toxaphene half-life
was adjusted until the VIP model produced groundwater concentrations equal to existing
conditions. Historical pesticide concentrations responsible for existing groundwater
concentrations were likely higher than those measured in 1989, therefore this approach would
tend to estimate a slower degradation rate than the actual degradation rate and be conservative.
The resulting half-life for toxaphene was four years, which is within the range of literature values
and reasonable considering the limited toxaphene concentrations in Site groundwater as
compared to the pre-removal soil concentrations.
Water Bulk Flow Another important input for the model is the bulk flow of precipitation of water
through the vadose zone (vertical flux). The model assumes one dimensional downward flow of I water through the vadose zone.
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Two parameters determine the bulk flow of water through the vadose zone: (1) an empirical
relationship between soil texture and soil water content as developed by Clapp and Hornberger
(1978), and (2) recharge rate. The most appropriate Clapp and Hornberger empirical constant
for Site soils was 4.1 (silty sand; Table C.1 ). A recharge rate of 20 inches per year was used
(Table C.2).
Volatilization Since the chemicals of interest are generally below the ground surface, volatilization
was not considered to be a significant removal process.
Model Output
Model output provides a plot of contaminant concentration (in soil water) versus depth at a
certain time. If the maximum concentration is not yet at the bottom of the vadose zone
(vadose/groundwater interface), then the model is run with a longer simulated time period. The
simulated time is increased until the maximum contaminant concentration is found at the vadose
zone/groundwater interface, or until 50 years. Modeling over 50 years is inaccurate and not
possible with the VIP model. Lack of movement over a 50 year period is an indication of an
immobile contaminant. The resulting leachate concentration (ug/L) is then conceptually mixed
with the groundwater below the vadose zone (next section).
Mixing of Vadose Leachate With Groundwater
There were several important factors considered when estimating the amount of mixing that
occurs between leachate (recharge) and groundwater in the uppermost aquifer. These factors
included the flux of leachate water entering the aquifer, the chemical concentration in this water
when it reaches the water table, and the areal extent of this affected recharge at the Site.
Important aquifer parameters considered were flux of groundwater beneath the sub-site and the
depth to which the two waters will mix.
Geigy FS C-4 January 20, 1992
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A mass balance approach was used to calculate the concentration of a chemical after it is mixed
with groundwater:
C(gw)
where:
= C(I) X Q(I)
Q(I) + Q(gw)
C(gw) = final concentration in groundwater after leachate from
the vadose zone is added
C(I) = concentration in leachate (predicted from VIP model)
Q(I) = volumetric flow rate of leachate; equals the recharge
rate used in the VIP model times the surface area (A) of
the unit being modeled
Q(gw) = volumetric flow rate of groundwater entering the mixing
zone per unit time; calculated from the hydraulic
gradient, hydraulic conductivity, and mixing depth.
The mixing depth is calculated based on the VHS Model (50 Federal Register 229: 48896,
November 27, 1985). The model recommends a vertical dispersivity of 0.2 meters (0.66 feet) to
simulate a reasonable worst-case scenario. A dispersivity of 0.66 feet is typical for a silty sand.
Consequently, a vertical dispersivity of 0.66 feet (az; Table C.2) was used for calculating the
mixing zone. However, the resultant mixing depth was greater than the average surficial aquifer
thickness of 12 feet. Therefore, 12 feet was the assumed mixing depth.
Based on the preceding evaluation, leachate concentrations were diluted by a factor of 1.2 after
mixing with the groundwater in the mixing zone. Site-specific values used to calculate Q(I),
Q(gw), and A are presented in Table C.2. Final concentrations of chemicals calculated in the
groundwater were then compared to potential groundwater remediation goals (Table 4.2).
Results and Discussion
Results from the VIP model based on existing Site conditions are as follows:
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Geigy FS
Maximum gamma-BHC concentration in the leachate: 0.03 ug/I
Maximum additional gamma-BHC concentration in groundwater: 0.02 ug/I (MCL is
0.2 ug/I)
C-5 January 20, 1992
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Maximum toxaphene concentration in the leachate: 1.6 ug/1
Maximum additional toxaphene concentration in groundwater: 1.3 ug/1 (MCL is 3
ug/1)
Therefore, the VIP modeling indicates that under current Site conditions (after soil remediations
of 1989 and 1991 ), the vadose zone pesticide concentrations will not significantly impact the
surficial groundwater beneath the Site.
Geigy FS C-6 January 20, 1992
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Table C.1
Significant Input Parameters Used in the VIP Model
The Geigy Chemical Corporation Site, Aberdeen, North Carolina
Value Used in
lnout Parameter VIP Model Reference
Depth of Contamination 12 feet Based on RI data
Depth to Groundwater from 23 feet Based on RI data
Bottom of Contaminated Zone
Soil Moisture Coefficient (silty sand)
(Clapp and Hornberger Constant)
4.1 (1) Clapp & Hornberger, 1978
Porosity 0.38 (1) RI
Bulk Soil Density 1.6 g/cu cm Based on RI; See note #1
Mean Dailv Recharne Rate 0.139 cu cm/dav/sa cm Geise et al., 1991
Half-Life Values for Dearadation in Aerobic Soil
alpha-BHC 135 days HSDB, 1991
beta-BHC 124 days HSDB, 1991
delta-BHC 100 days HSDB, 1991
gamma-BHC 240 days HSDB, 1991
Tox,,nhene 4vears HSDB, 1991 & calibration
Kd Values (ml/al
alpha-BHC 7 ml/g See note #2
beta-BHC 7 ml/g See note #2
delta-BHC 10 ml/g See note #2
gamma-BHC 5 ml/g See note #2
Tox~nhene Kd 5 ml/a See note #2
HtiBD = Hazardous Suostances Data Base, MEDLARS 1 ( ) D1mens1onIess
·_t:,19t¢•·#.•t:/.Qalc5t.ilajii:ih 9f_$i:iil.J}t.ill(~h$ify\ t•••t >r·•··••·····•···•·.··•
Bulk soil density was calculated by multiplying 2.65 g/cu cm (solids density) by
the solid fraction of the soil (1 -0.38\
•N2!¢I#.?:}Qaj¢ylii!i¢h•••2!.·.1::qyili_priyrjj/\9$i:iipti¢h•••g~f!i9i¢ht•·•(K§J••• \/•t···•·••·•·.·•······
Kd = organic adsorption + inorganic adsorption
Kd = (foe x Koc) + (foi x Koi) (Olsen and Davis, 1990)
Where:
foe = fraction of organic carbon in Site soils (0.001; RI)
Koc = organic carbon distribution coefficient: 3800 ml/g for alpha-BHC
3800 ml/g for beta-BHC
6600 ml/g for delta-BHC
1000 ml/g for gamma-BHC
foi = fraction of inorganic matter in soil (1 -0.001 = 0.999)
1000 ml/g for toxaphene
Koi = inorganic distribution coefficient, approximate! equal to (SA)/((Kow) ~0.16))
Where:
SA = surface area of silty sand = 15 sq m/g soil
Kow = Octanol/water partitioning coefficient:
INPUT.OLN, 1/20/92
(Mitchell, 1976)
8000 for alpha-BHC
8000 for beta-BHC
13,000 for delta-BHC
8000 for gamma-BHC
2000fortoxaohene
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Table C.2
Parameters Used to Calculate Volumetric Flow Rate of Groundwater and Leachate Dilution Factor
The Geinv Chemical Corporation Stte, Aberdeen, North Carolina
0.5
z = (az y')
Where: z = mixing depth (feet)
az = vertical dispersivity
assume: az = 0.1 x transverse dispersivfy
az = transverse dispersivfy = 6.6 feet (from the RI)
az = 0.66 feet
y' = width of source area parallel to ground-water flow (feet) = 600 feet
z = 19.6 feet; however, the average surficial aquffer thickness is 12 feet; therefore, 12 feet was used
Q(gw) = k X i X A
Where: k = hydraulic conductivity (feeVday) = 2.6 feeVday
i = groundwater gradient (unttless slope) = 0.02 feet/feet
A= area perpendicular to groundwater flow (square feet)
= L x z = 2160 square feet
Where: L = length ~f source area (feet) = 180 feet -
z = mixing depth (feet) = 12 feet
Q(gw) = 904 gallons/day
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" O(Q = Ax R
Where: A = area of source R = annual recharge rate = 20 inches/year
= L x W = 108,000 square feet
Where: L = length of source area (feet) = 180 feet
W = width of source area parallel to groundwater flow (feet) = 600 feet
O(Q = 3689 gallons/day
Dilution Factor= O(Q/(Q(I) + Q(gw)) = 0.6 or a 1.25 fold dilution
VIP2.OLN, 1/20/92
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APPENDIX D
ESTIMATE OF GROUNDWATER FLOW RATE
AND
AQUIFER RESTORATION TIME
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0.1 Groundwater Flow Rate
The surficial and the second uppermost aquifers were considered for potential. Pertinent
hydraulic data for the surficial aquifer are given below (ERM-Southeast, 1992):
K = average hydraulic conductivity
= 2.8 ft/day
= average hydraulic gradient
= 0.026 ft/ft (Eastern portion of the Site)
= 0.017 ft/ft (Western portion of the Site).
Average thickness of the aquifer is conservatively estimated to be 12 feet. Considering a 300 feet
wide strip of aquifer that will contribute flow to the extraction wells EW-1 through EW-7, as shown
in Figure 0.1, the approximate groundwater flow is:
[2.8 ft/day][0.026 ft/ft + 0.017 ft/11][300 ft x 12 11][7.48 gallons/tt3][1 day/1440 min]
= 2.25 gpm
"" 3 gpm.
Six proposed extraction wells, EW-1 through EW-6, (Figure 0.1) would may effectively capture
Site groundwater. These extraction wells, however, may not capture groundwater emanating
from areas near monitoring well MW-1 OS. An additional extraction well, EW-7, would be installed
downgradient of monitoring well MW-1 OS to contain groundwater in that area. The estimated
extraction rate for each individual well is 0.5 gpm. The total estimated extraction rate is 3.5 gpm.
Flow rate for the collection trench is estimated to be 3.0 gpm. Total flow rate for the collection
trench and extraction well (EW-7) would therefore be 3.5 gpm.
Chemicals of concern were detected in the second uppermost aquifer at location MW-110.
Therefore, two extraction wells are proposed downgradient of MW-11 0. Locations of these
proposed extraction wells are shown in Figure 0.2.
Geigy FS 0-1 January 20, 1 992
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Steady state capture zone analysis was performed using FLOWPATH developed by Waterloo
Hydrogeologic Software for a flow rate of 5.0 gpm per well. Site specific hydraulic data for this
aquifer were obtained from RI report (ERM-Southeast, 1992) and are given below:
K = 28 fVday
i = 0.004 fVft
It was also assumed that the aquifer is under water table conditions and is recharged at a rate
of 0.004 fVday. Estimated capture zone is shown in Figure D.2. To account for the uncertainties
involved in modeling, a flow rate of 7.5 gpm per well has used for remedial alternative evaluation.
During the remedial design phase, however, it may be necessary to evaluate the effectiveness
of the selected extraction system through numerical modeling.
D.2 Restoration Time
Restoration time was estimated for two different alternatives: (1) No Action and (2) Pump and
Treat. The assumptions involved in the estimation are:
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D.2.1
Equilibrium between the soil and the water phases is instantaneous .
Adsorption -desorption phenomenon is completely reversible .
Degradation of contaminants in both the phases follows first order kinetics .
Impact of flowing water on equilibrium and degradation is negligible .
No Action
For the "No Action" alternative, the restoration time t in days is given by:
t = [(1/0.693)In(Co/C1)]t112
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Where:
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1112
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Initial concentration of the contaminants
Remediation level (usually maximum contaminant level)
Degradation half-life of the contaminant in days
Considering half-lives and relative concentrations of the contaminants, gamma-BHC was found
to be the critical Site-specific chemical for estimating restoration time.
Maximum gamma-BHC concentration in the surficial aquifer is 30 ug/I, the MCL is 0.2 ug/I, and
the longest reported half-life is 413 days (Howard et.al., 1991 ). Restoration time is therefore;
t = [1/0.693 In (30 ug/I 0.2 ug/L)] 413 days
= 2986 days
8.20 yrs.
"" 10 yrs.
Restoration time for the second uppermost aquifer was estimated to 6.5 years. Restoration time
alone may not provide any useful information to evaluate "No Action" alternative. It is essential
to obtain the supplemental data for the migration distance over the restoration period. The
maximum distance travelled by BHC isomers and toxaphene in groundwater can be estimated
using the following equation:
d = [ (ki/nettl • (1/Rd)] t
Where: d = distance travelled (ft),
k = permeability (ft/day),
= hydraulic gradient (ft/ft),
nett = effective porosity,
Rd = retardation factor,
= 1 + Kd rJn
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·where: Kd = soil-water partition coefficient (ml/gm),
rb = bulk density of soil matrix (gm/cm\
n = total porosity, and
I = restoration time (days).
The BHC isomers and toxaphene have the same Kd and consequently the same Rd. The
distance travelled by these chemicals through a isotopic and homogeneous aquifer under the
same hydraulic gradient will be the same. For the surficial aquifer, the estimated distance
travelled under a hydraulic gradient of 0.026 is given by:
d = [(2.8 ft/day)(0.026 ft/ft)/0.2][1/(1 + 5 ml/gm x 1.6 gm/cm3/0.38)][10 x 365 days]
= 60.ft.
The retarded velocity is 6.1 ft/yr.
For the second uppermost aquifer the distance travelled was estimated to be 60 ft. and the
velocity 9.5 ft/yr.
D.2.2 Pump and Treat
A mass balance, considering degradation and effect of pumping and ignoring desorption from
soil, results in the following analY1ical expression for restoration time:
t = In (Co/C)/[Q/nV + k]
Where: t = restoration time (days),
Co = concentration of contaminant at present (ug/L)
C = MCL (ug/L),
Q = extraction rate (ft3 /day),
V = volume of contaminated aquifer (ft3),
n = porosity, and
k = degradation rate constant (daf\
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The volume of the contaminated surficial aquifer was estimated to be 1.3 x 1 06 tt3 and
considering gamma-BHC was considered the rate limiting chemical in determining restoration
time,
t = ln[30 ug/I / 0.2 ug/l]/[674 tt3/day / [(1.3 x 106 tt3)(0.38)] + 1.67 x 10-3 daf1]
= 5.01/(3.04 x 10-3 daf1)
= 1648 days
= 4.5 yrs
"' 5 yrs
It was assumed that the saturated thickness of the second uppermost aquifer was 20 ft. and that
a rectangular area measuring 250 ft. x 250 ft. was contaminated. Restoration time was estimated
to be 1.5 years.
D.2.3 A Note on Restoration Time Estimation
Restoration time has been estimated under simplified assumptions. The actual restoration time
would likely be higher than the estimated value. The estimated values should, therefore, be used
only for the purpose comparing one alternative with the other.
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GS-02-134 \
GS-02,_-1
,,ClS-02-3
CITY WELL #4
434
432----
WOODS
430---
428
426
LEGEND
GS-02-2 GEOLOGICAL SURVEY WELL ~
~ MW-7S MONITORING WELL
~ PZ-1 PRODUCTION ZONE WELL
r;;iEW-7
..
PROPOSED GROUNDWATER
EXTRACTION WELL
SURFICIAL AQUIFER CONTOUR
(DASHED WHERE .INFERRED)
CAPTURE ZONE BOUNDARY
60 120 180 n .
426
\
\
MW 7S ~
)
?
... -
WOODS ~ EW-7 r.l ~
<28 ~~-1'1"'
432 /
434
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436
434
/
I
wo7
438
WOODS
FIGURE D.1
N
LRED
ROPERTY
ASSUMED CAPTURE ZONE FOR
ESTIMATING GROUNDWATER FLOW RATE
GEIGY CHB.tlCAL CORPORATION SITE
ABERDEEN, NORTH CAROLINA
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CJ
CITY WELL #4
WOODS
LEGEND
GS-02-2
GS-02-1 GS-02-3
GS-02-5
~GS-02-2 GEOLOGICAL SURVEY WELL
~MW-7S
~PZ-1
60 • 60
MONITORING WELL
PRODUCTION ZONE WELL
SECOND UPPERMOST AQUIFER CONTOUR
CAPTURE ZONE LIMIT
tal UIO rT ..
WOODS
MW-7S ~
~ MW-12S
WOODS~
~w-9 ■
~W-BD
\
\
\
WOODS
=1~J~~ II CONSULTANTS
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FIGURE 0.2
ESTIMATED CAPTURE ZONE FOR THE
SECOND UPPERMOST AQUIFER
GEIGY CHEMICAL CORPORATION SITE
ABERDEEN, NORTH CAROt.lNA
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APPENDIX E • PRELIMINARY COST ESTIMATES
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COST BASIS
PRELIMINARY COST ESTIMATES
GEIGY CHEMICAL CORPORATION SITE
FEASIBILITY STUDY
Preliminary costs for remedial alternatives considered in Section 6 were generated using the Cost
for Remedial Actions (CORA), Final Version 3.0 (EPA, 1990a) Table E.1 summarizes the costs
of each alternative. The total present worth costs are equal to total capital costs plus long-term
operations and maintenance (O&M) costs. Present worth O&M costs are based on a discount
rate of five percent and 30 years of operation.
The CORA software is not currently capable of estimating the cost for chemical oxidation or an
interception trench construction and operation and maintenance. Preliminary chemical oxidation
treatment costs were derived from a detailed cost estimate for a different CERCLA site (Sirrine,
July 1991 ). The interception trench cost estimate was developed from a detailed cost estimate
(Table E.1). Cost estimates for Alternatives GWC-1A (No action) and EC-1 (No further action)
were developed using a detailed cost estimate (Table F.2) which assumes a review of remedy
and report preparation every five years for 30 years. The preliminary costs of GWC-1 B, long-term
monitoring, was calculated by adding the preliminary cost for the 5 year remedy review (GWC-1 A)
and groundwater monitoring cost, CORA cost module 503. CORA cost modules were used to
generate costs for all other groundwater and exposure control alternatives. Similarly numbered
CORA cost modules can be distinguished by the indicated "scenario" or "notes" to determine
under which alternative the cost module was used.
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Alternative
GWC-1A
GWC-18
GWC-2
GWC-3A
GWC-38
GWC-3C
GWC-3D
EC-1
EC-2A
EC-2B
EC-3A
EC-38
Table E.1
SCREENING-LEVEL COSTS ESTIMATES
GEIGY CHEMICAL CORPORATION SITE
Capltol
Description Costs
GROUND WATER CONTROL
No action $ 0
Long-term monitoring $ 40,000
Slurry wall and cap (including $ 5,500,000
groundwater extraction, treatment and
discharge to POlW)
Groundwater extraction carbon $ 490,000
adsorption, POTW
Groundwater extraction chemical $ 1,300,000
oxidation, POTW
Interception trench, carbon adsorption, $ 950,000
POTW
Interception trench, chemical oxidation, $ 1,800,000
POTW
Annual
O&M
Costs
$ 140,000
$ 160,000
$ 26,000
$ 110,000
$ 2,200,000
$ 350,000
$ 2,700,000
EXPOSURE CONTROL (AND FOUNDATION REMOVAL)
No further action $0 $ 140,000
Off-site disposal of surficial soils $127,000
(10·5 LECR) 10 $0
$330,000
Off-site disposal of surficial soils $510,000
(10'6 LECR) to $0
$1,500,000
Capping surficial soils (10'5 LECR) $ 120,000 $ 60,000
Capping surficial soils (10 .. LECR) $ 290,000 $ 60,000
Total Present
Worth Costs
$ 140,000
$ 200,000
$ 5,500,000
$ 600,000
$ 3,500,000
$ 1,300,000
$ 4,500,000
$ 140,000
$127,000
to
$330,000
$510,000
to
$1,500,000
$ 180,000
$ 350,000
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TABLE E.2
GEIGY CHEMICAL CORPORATION SITE
ABERDEEN, NORTH CAROLINA
INTERCEPTION TRENCH -PRELIMINARY COST ESTIMATE
UNIT
DESCRIPTION QUANTITY UNITS PRICE($) TOTAL($)
CONSTRUCTION
MOBIUDEMOBIL
SITE WORK
TRENCH CONSTRUCTIO
SELECT FILL
EXTRACTION WELL
MONITORING WELL
WELL HEAD
PUMPS
AIR PIPING
COMPRESSOR
DISCHARGE PIPING
ELECTRICAL CONDUIT,
WIRE, FIXTURE
DATA AQUISITION
SYSTEM
FACTORED COSTS
1
1
1
500
150
200
3
3
1,500
1
1,500
1
1
LS
LS
LS
CY
LF
LF
EA
EA
LF
EA
LF
LS
LS
SUBTOTAL-
2,500
5,000
270,000
15
140
120
5,000
2,500
4
2,500
5
12,000
30,000
HEAL TH & SAFETY
BOND & INSURANCE
CONTINGENCY
CONST.MANAGEMENT
3% OF CONSTRUCTION COST
2% OF CONSTRUCTION COST
25% OF CONSTRUCTION COST
10% OF CONSTRUCTION COST
TOTAL CONSTRUCTION COST
OPERATION & MAINTENANCE
SUBTOTAL-
POWER HP 5
INSPECTION & REPAIR 5% OF TOT. CONST. COST
MONITORING LS 1 4,500
SUBTOTAL-
PRESENT WORTH FACTOR (10 YEARS, 5%) 7.7220
PRESENT WORTH FACTOR (30 YEARS, 5%) 15.3720
PRESENT WORTH O & M COST (10 YEARS)
PRESENT WORTH O & M COST (30 YEARS)
TOTAL PRESENT WORTH COST (10 YEARS)
TOTAL PRESENT WORTH COST (30 YEARS)
2,500
5,000
270,000
7,500
21,000
24,000
15,000
7,500
6,000
2,500
7,500
12,000
30,000
410,500
12,315
8,210
102,625
41,050
164,200
574,700
3,300
28,735
4,500
36,535
282,123
561,616
856,823
1,136,316
I PAGE--'-----OE i-
SIRRINE CALCULATION SHEET
ENVIRONMENTAL CONSULTANTS
CLIENT Ge-r"cm ;s,·-fe. LOCATION A~ ere,/ et:,,,t I A( C ~OB NO. <i-1 o 2 'f
SUBJECT ?re/,-,,,,.__/,1ad CoJ.f £s-hi,,,fA.fe. -C/,i~'cJ. cJx/d.,__f-i~
I BY .:JJ c DATE /-6-9 2-cHECKED BY i/ r J DATE 1 )t,, ! "i 2-.
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Q_ -=-Z O 'U f,,..._ I C0 = 2 vn6 Col)/ .e_
('.. ~ U ""'-d Cou/.e_
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A--ssess..-i~: Flow ~ cr,M.u.d-rk--h.rM...s ~e <-J,'Jk,,.._ Mc;...JCM.,,,t_/e .,.-~e..
hr ~M-.._f-iv~ p~ores. lAse O,C, ,.A.,,.,</e. +-v, C4/ltS1Y/A.C11-___ c,,1fs.
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I SIRRINE
PAGE 2 OF 2-
CALCULATION SHEET
ENVIRONMENTAL CONSULTANTS
LIENT ___________ LOCATION ________ JOB NO. (r/o2'1
SUBJECT ___________________________ _
I BY :J]C. DATE~/-_C::,_-_7_2. __ CHECKED BY____ecU__:7_..J ___ DATE /It/,;-c
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CO'AJfn..c/-i~ t h-i11uJ Ot!;t,,/ * P/A (s-?.J 3°21)
920 ooD +-/4-0 OOO;'/. /~,372 I I
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***** VERSION 3.0 DRAFT***** DATE: 01/19/92
TIME: 08:22:03
SITE NAME:
OPERABLE UNIT:
SCENARIO:
RUN BY:
CORA ASPHALT CAP COST MODULE (102)
GEIGY CHEMICAL
ENTIRE SITE ESTIMATED START: EARLY FY 1993
LECR lOE-5
PHONE NUMBER:
INPUTS RESULTS
Component Parameter Value Total
Area of site (acres)
Leveling layer (ft)
Protection level
0.25
0.50
C
60
M
CAPITAL COST 59,000
Average temp (degrees F)
Confidence level
0 & M COSTS 12,000
*** Costs for areas larger than 50 acres do not take into
account potential variations for material availability.
Costs for this module are sensitive to the material costs
for the soil barrier and top soil. Material costs used to
develop the algorithm are $21.50/cy for the soil barrier
(clay) and $14.00/cy for top soil. Should local costs vary,
the estimate should be adjusted to reflect the local economy.
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***** VERSION 3.0 DRAFT***** DATE: 01/18/92
TIME: 11:07:53
CORA ASPHALT CAP COST MODULE (102)
SITE NAME: GEIGY CHEMICAL
OPERABLE UN IT:
SCENARIO:
ENTIRE SITE ESTIMATED START: EARLY FY 1993
MODULES COMMON TO ALL SCENARIOS
RUN BY:
INPUTS
Parameter
PHONE NUMBER:
Value
Area of site (acres) O. 34
Leveling layer (ft) 0.50
Protection level C
Average temp (degrees F) 60
Confidence level M
RESULTS
Component Total
CAPITAL COST 67,000
0 & M COSTS 13,000
*** Costs for areas larger than 50 acres do not take into
account potential variations for material availability.
Costs for this module are sensitive to the material costs
for the soil barrier and top soil. Material costs used to
develop the algorithm are $21.50/cy for the soil barrier
(clay) and $14.00/cy for top soil. Should local costs vary,
the estimate should be adjusted to reflect the local economy.
NOTES:
Achieve a Site-wide LECR of lOE-6
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***** V ERS JON 3. 0 DRAFT ***** DATE: 01/19/92
TIME: 08:21:37
CORA ASPHALT CAP COST MODULE (102)
SITE NAME: GEIGY CHEMICAL
OPERABLE UNIT:
SCENARIO:
ENTIRE SITE ESTIMATED START: EARLY FY 1993
LECR IOE-6
RUN BY: PHONE NUMBER:
INPUTS
Parameter
Area of site (acres)
Leveling layer (ft)
Protection level
Average temp (degrees F)
Confidence level
Value
0.45
0.50
C
65
M
RESULTS
Component
CAPITAL COST
0 & M COSTS
*** Costs for areas larger than 50 acres do not take into
account potential variations for material availability.
Costs for this module are sensitive to the material costs
for the soil barrier and top soil. Material costs used to
develop the algorithm ,ire $21.50/cy for the soil barrier
(clay) and $14.00/cy for top soil. Should local costs vary,
the estimate should be adjusted to reflect the local economy.
Total
75,000
14,000
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***** VEllS ION 3. 0 DRAFT ***** DATE: Ol/lB/92
TIME: 15:2B:15
CORA MULTILAYERED RCRA CAP COST MODULE (103)
SITE NAME: GEIGY CHEMICAL
OPERABLE UN IT:
SCENARIO:
ENTIRE SITE ESTIMATED START: EARLY FY 1993
MODULES COMMON TO ALL SCENARIOS
RUN BY: PHONE NUMBER:
INPUTS RESULTS
Parameter
Area of site (acres)
Soil type
Leveling layer (ft)
Clay barrier (ft)
Value
4.00
Gravel
1.0
2.0
60
1.0
8
0.5
1.0
D
Synthetic membrane (mils)
Granular drainage layer (ft)
Filter fabric (oz)
Protective layer (ft)
Topsoil layer (ft)
Protection above grade
Protection below grade
Average temp (degrees F)
Confidence level
D
65
L
Component
CAP IT AL COST
0 & M COSTS
*** Costs for areas larger than 50 acres do not take into
account potential variations for material availability.
Costs for this module are sensitive to the material costs
for the soil barrier and top soil. Material costs used to
develop the algorithm are $21.50/cy for the soil barrier
(clay) and $14.00/cy for top soil. Should local costs vary,
the estimate should be adjusted to reflect the local economy.
Total
1,000,000
25,000
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***** vrns ION 3. 0 DRAFT ***** DATE: 01/18/92
TIME: 11:18:41
CORA SOIL/BE:NTONITE SLURRY WALLS COST MODULE (104)
SITE NAME: GEIGY CHEMICAL
OPERABLE UNIT:
SCENARIO:
ENTIRE SITE ESTIMATED START: EARLY FY 1993
MODULES COMMON TO ALL SCENARIOS RUN BY: PHONE NUMBER:
INPUTS
Parameter Value
Trench length (ft) 2240
Trench width (ft) 4
Trench depth (ft) 60
RESULTS
Component
CAPITAL COST
0 & M COSTS
Total
4,500,000
7,840
Distance from Wyoming (miles) 1500
Excavation conditions D
Slurry wall keyed into bedrock? N
BYPRODUCTS FOR TRANSPORT/DISPOSAL:
Percent slurry loss 30
Percent bentonite required 9
Miles to bentonite mix site 100
Percent contaminated 10
Percent unsuitable mat'l 90
Miles to disposal site 100
Protection level D
Average temp (degrees F) 65
Confidence level L
CONTAMINATED SOIL (CY)
SLURRY (CY)
2,788
35,646
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***** VERSION 3.0 DRAFT***** DATE: 01/18/92
TIME: 11:05:24
CO~\ SOIL EXCAVATION COST MODULE (201)
SITE NAME: GEIGY CHEMICAL
OPERABLE UNIT:
SCENARIO:
ENTIRE SITE ESTIMATED START: EARLY FY 1993
MODULl:S COMMON TO ALL SCENARIOS
RUN BY: PHONE NUMBER:
INPUTS
Parameter Value
LECR lOE-6
Soil type
Depth of excavation (ft)
I. Steel sheeting or
2. side slope?
Horizontal component
Length of excavation (ft)
Width of excavation (ft)
Depth of cover above
contaminated materials (ft)
Depth of contaminated excav.
w/o continuous sampling (ft)
Depth of contaminated excav.
w/continuous sampling (ft)
Thickness of lifts (inches)
Number of drums
Pct. of contaminated zon,~
Base air monitoring required?
Pct. of backfi 11 ava i 1 ab·1 e
on site
2
1
2
2
120
120
0
0
1
12
0
0
N
0
RESULTS
Component Total
BYPRODUCTS FOR TRANSPORT/DISPOSAL:
DRUMS 0
CONTAMINATED SOIL (CY)
(SWELL FACTOR=!. 25) 689
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***** vrns ION 3. 0 DRAFT ***** DATE: 01/18/92
TIME: 11: 05: 26
SITE NAME:
OPERABLE UN IT:
SCENARIO:
RUN BY:
CORI\ SOIL EXCAVATION COST MODULE (201)
GEIGY CHEMICAL
ENTIRE SITE ESTIMATED START: EARLY FY 1993
MODULES COMMON TO ALL SCENARIOS
PHONE NUMBER:
INPUTS RESULTS
-----------------------··-----------------------------------------------Parameter Value Component Total
----------------------------------------------------------------
Protection level for: COST FOR ALL EXCAVATIONS
Uncontaminated materials C
Contaminated materials C CAPITAL COST 77,000
Temperature (degrees F) 65 0 & M COSTS O
Confidence level M
*** Excavation depth cannot exceed 25 feet. For excavations
deeper than 25 feet, complex site-specific sheeting, bracing,
dewatering, terracing' and haul roads may be required.
Excavation for depths deeper than 25 feet should be scoped and
costed on a site-specific basis.
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***** VEHSION 3.0 DRAFT ***** DATE: 01/18/92
TIME: 11:33:50
SITE NAME:
OPERABLE UN IT:
SCENARIO:
RUN BY:
CORA SOIL EXCAVATION COST MODULE (201)
GEIGY CHEMICAL
ENTIRE SITE ESTIMATED START: EARLY FY 1993
LECR lOE-5
l'HONE NUMBER:
INPUTS
Parameter Value
RESULTS
Component
-----------------------------------------------------
Total
LECR lOE-5
Soil type BYPRODUCTS FOR TRANSPORT/DISPOSAL:
Depth of excavation (ft)
1. Steel sheeting or
2. side slope?
Horizontal component
Length of excavation (ft)
Width of excavation (ft)
Depth of cover above
contaminated materials (ft)
Depth of contaminated excav.
w/o continuous sampling (ft)
Depth of contaminated excav.
w/continuous sampling (ft)
Thickness of lifts (inches)
Number of drums
Pct. of contaminated zone
Base air monitoring required?
Pct. of backfill available
on site
2
1
2
2
60
60
0
0
1
12
0
0
N
0
DRUMS 0
CONTAMINATED SOIL (CY)
(SWELL FACTOR=l.25) 178
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***** VERSION 3. 0 DRAFT ***** DATE: 01/18/92
TIME: 11: 33: 51
SITE NAME:
OPERABLE UN IT:
SCENARIO:
RUN BY:
CORI\ SOIL EXCAVATION COST MODULE (201)
GEIGY CHEMICAL
ENTIRE SITE ESTIMATED START: EARLY FY 1993
LECR lOE-5
PHONE NUMBER:
INPUTS RESULTS
-----------------------------------------------------------------------Parameter Va 1 ue Component
-----------------------------------------------------
Protection level for:
Uncontaminated materials
Contaminated materials
Temperature (degrees F)
Confidence level
COST FOR ALL EXCAVATIONS
C
C CAPITAL COST
65 0 & M COSTS
M
*** Excavation depth cannot exceed 25 feet. For excavations
deeper than 25 feet, complex site-specific sheeting, bracing,
dewatering, terracing and haul roads may be required.
Excavation for depths deeper than 25 feet should be scoped and
costed on a site-specific basis.
Total
55,000
0
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***** vrns ION 3. 0 DRAFT ***** DATE: 01/18/92
TIME: 15:49:14
SITE NAME:
OPERABLE UNIT:
SCENARIO:
RUN BY:
CORA SOIL EXCAVATION COST MODULE (201)
GEIGY CHEMICAL
ENTIRE SITE ESTIMATED START: EARLY FY 1993
LECR lOE-6
PHONE NUMBER:
INPUTS RESULTS
Parameter Value Component Total
SOIL BYPRODUCTS FOR TRANSPORT/DISPOSAL:
Soil type 2
Depth of excavation ( ft:, 1 DRUMS 0
1. Steel sheeting or
2. side slope? 2
Horizontal component 2
CONTAMINATED SOIL (CY)
(SWELL FACTOR=l.45) 689
Length of excavation (ft) 120
Width of excavation (ft) 120
Depth of cover above
contaminated materials (ft) 0
Depth of contaminated excav.
w/o continuous sampling (ft) 0
Depth of contaminated excav.
w/continuous sampling (ft) 1
Thickness of lifts (inches) 12
Number of drums 0
Pct. of contaminated zone O
Base air monitoring required? N
Pct. of backfill available
onsite 70
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***** VERSION 3.0 DRAFT***** DATE: 01/18/92
TIME: 15:49:15
SITE NAME:
OPERABLE UNIT:
SCENARIO:
RUN BY:
CORA SOIL EXCAVATION COST MODULE (201)
GEIGY CHEMICAL
ENTIRE SITE ESTIMATED START: EARLY FY 1993
LECR lilE-6
PHONE NUMBER:
INPUTS RESULTS
Parameter Value Component Total
FOUNDATION BYPRODUCTS FOR TRANSPORT/DISPOSAL:
Soil type 4
Depth of excavation (ft) 3 DRUMS 0
1. Steel sheeting or CONTAMINATED SOIL (CY)
2. side slope? 0 (SWELL FACTOR=l.45) 2,513
Horizontal component 0
Length of excavation (ft;, 260
Width of excavation (ft) 60
Depth of cover above
contaminated materials (ft) 0
Depth of contaminated excav.
w/o continuous sampling (ft) 0
Depth of contaminated excav.
w/continuous sampling (ft) 3
Thickness of lifts (inches) 24
Number of drums 0
Pct. of contaminated zone O
Base air monitoring requfred? N
Pct. of backfill available
onsite 0
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SITE NAME:
OPERABLE UNIT:
SCENARIO:
RUN BY:
***** VERSION 3. 0 DRAFT ***** DATE: 01/18/92
TIME: 15:49:17
CORA SOIL EXCAVATION COST MODULE (201)
GEIGY CHEMICAL
ENTIRE SITE ESTIMATED START: EARLY FY 1993
LECR lOE-6
PHONE NUMBER:
INPUTS RESULTS
Parameter Value Component Total
Protection level for: COST FOR ALL EXCAVATIONS
Uncontaminated materials C
Contaminated materials C CAPITAL COST 210,000
Temperature (degrees F) 65 0 & M COSTS O
Confidence level M
BYPRODUCTS FOR TRANSPORT/DISPOSAL:
DRUMS 0
CONTAMINATED SOIL (CY)
(SWELL FACTOR=l.45) 3,203
*** Excavation depth cannot exceed 25 feet. For excavations
deeper than 25 feet, ,:omplex site-specific sheeting, bracing,
dewatering, terracing and haul roads may be required.
Excavation for depths deeper·than 25 feet should be scoped and
costed on a site-spec1fic basis.
NOTES:
Excavate soils and foundation to achieve a LECR of lOE-6
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SITE NAME:
OPERABLE UNIT:
SCENARIO:
RUN BY:
***** vrnsION 3.0 DRAFT ***** DATE: 01/18/92
TIME: 11:24:07
CORA GROUNDWATER EXTRACTION COST MODULE (206)
GEIGY CHEMICAL
ENTIRE SITE ESTIMATED START: EARLY FY 1993
MODULES COMMON TO ALL SCENARIOS
PHONE NUMBER:
INPUTS RESULTS
Parameter Va 1 ue Component Total
Number of wells known? Y CAPITAL COST 49,000
Number of wells 2
Pumping rate per well (GPM) 7.5
Well diameter (inches) 6
Wi 11 we 11 s be grave 1 packed? Y
Average we 11 depth (ft) 110
Transfer piping length (ft) 1000
Pumping water level/well (ft) 90
Average temp (degrees F) 65
Confidence level H
Protection above grade D
Protection during drilling D
NOTES:
0 & M COSTS 12,000
BYPRODUCTS FOR TRANSPORT/DISPOSAL:
WELL CUTTINGS (CY)
(SWELL FACTOR=l.25)
6
I Secondary aquifer extraction wells
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***** VERSION 3. 0 DRAFT ***** DATE: 01/18/92
TIME: 11:35:19
CORA OFFSITE INCINERATION COST MODULE (302)
SITE NAME:
OPERABLE UN IT:
SCENARIO:
RUN BY:
GEIGY CHEMICAL
ENTIRE SHE ESTIMATED START: EARLY FY 1993
LECR 10E··5
PHONE NUMBER:
INPUTS RESULTS
--------------------------·-----------------------------------------------Unit
Parameter Value Cost Component Total
------------------------------------------------------------------
WASTES WITH PCB: OFFSITE INCINERATION Materials to be packaged: CAPITAL COST 230,000 Soils (CY) 0 0 & M COSTS 0
PCB concentration (PPM) 0
Liquids (GAL) 0
PCB concentration (PPM) 0 TRANSPORTATION
Water wastes (GAL) 0 CAPITAL COST 46,000 Level of protection C 0 & M COSTS 0 Bulk liquids (LBS) 0 0.00
PCB Concentration (PPM) 0
Steel drums 0
Drums with soils 0 0.00
PCB concentration (PPM) 0
Drums with liquids 0 0.00
PCB concentration (PPM) 0
Drums .with water wastes 0 0.00
Tax per ton 27.00
WASTES WITHOUT PCB:
Material to be packaged
Soils (CY) 140 Water wastes (GAL) 0
Sludges & Tars (CY) 0
Low chloride org. (GAL) 0
High chloride org. (GAL) 0
Level of protection D
Drums with soils 0 177. 00
Drums with water wastes 0 200.00
Drums with sludges & tars 0 375.00
Drums w/low chlor. org. 0 170.00
Drums w/high chlor. org. 0 325.00
Steel drums 0
Pumpable sludges (LBS) 0 0.45
Water wastes (LBS) 0 0.30
High chloride org. (LBS) 0 0.35
Low chloride org. (LBS) 0 0.10
Tax per ton 19.00
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***** VERSION 3.0 DRAFT***** DATE: 01/18/92
TIME: 11:35:21
CORA OFFSITE INCINERATION COST MODULE (302)
SITE NAME: GEIGY CHEMICAL
OPERABLE UNIT:
SCENARIO:
ENTIRE SITE ESTIMATED START: EARLY FY 1993
LECR lOE-5
RUN BY: PHONE NUMBER:
INPUTS RESULTS
Unit
Parameter Value Cost Component Total
Miles to offsite facility 1200
Demurrage time/load (hrs) 2
Average temp ,(deg. F) 65
Capital or O&M incin. cost? C
Capital or O&M transport cost? C
Confidence level H
*** Material-handling equipment at commercial incinerators are
generally not amenable to handling bulk solids and sludges.
Costs for packaging these materials will be added to the
disposal costs. Additionally, the user may wish to place
liquid wastes in drums for reasons of small quantity or
compatibility concerns.
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***** VERSION 3.0 DRAFT***** DATE: 01/18/92
TIME: 12:26:49
CORA OFFSITE INCINERATION COST MODULE (302)
SITE NAME: GEIGY CHEMICAL
OPERABLE UN IT: ENTIRE SITE ESTIMATED START: EARLY FY 1993
SCENARIO: MODULES COMMON TO ALL SCENARIOS
RUN BY: PHONE NUMBER:
INPUTS RESULTS
-------------------------------------------------------------------------Unit
Parameter Value Cost Component Total
------------------------------------------------------------------
WASTES WITH PCB: OFFSITE INCINERATION
Materials to be packaged: CAPITAL COST 850,000
Soils (CY) 0 0 & M COSTS 0
PCB concentration (PPM) 0
Liquids (GAL) 0
PCB concentration (PPM) 0 TRANSPORTATION
Water wastes (GAL) 0 CAP IT AL COST 170,000
Level of protection C 0 & M COSTS 0
Bulk liquids (LBS) 0 0.00
PCB Concentration (PPM) 0
Steel drums 0
Drums with soils 0 0.00
PCB concentration (PPM) 0
Drums with liquids 0 0.00
PCB concentration (PPM) 0
Drums with water wastes 0 0.00
Tax per ton 27.00
WASTES WITHOUT PCB:
Material to be packaged
Soils (CY) 530
Water wastes (GAL) 0
Sludges & Tars (CY) 0
Low chloride org. (GAL) 0
High chloride org. (GAL) 0
Level of protection D
Drums with soils 0 177 .00
Drums with water wastes 0 200.00
Drums with sludges & tars 0 375.00
Drums w/low chlor. org. 0 170.00
Drums w/high chlor. org. 0 325.00
Steel drums 0
Pumpable sludges (LBS) 0 0.45
Water wastes (LBS) 0 0.30
High chloride org. (LBS) 0 0.35
Low chloride org. (LBS) 0 0 .10
Tax per ton 19.00
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***** VERSION 3.0 DRAFT***** DATE: 01/18/92
TIME: 12:26:51
CORA OFFSITE INCINERATION COST MODULE (302)
SITE NAME: GEIGY CHEMICAL
OPERAS LE UN IT:
SCENARIO:
ENTIRE SITE ESTIMATED START: EARLY FY 1993
MODULES COMMON TO ALL SCENARIOS
RUN BY: PHONE NUMBER:
INPUTS RESULTS
Unit
Parameter Value Cost Component Total
Mil es to off site facility 1200
Demurrage time/load (hrs) 2
Average temp (deg. F) 65
Capital or O&M incin. cost? C
Capital or O&M transport cost? C
Confidence level H
*** Material-h'andl ing equipment at commercial incinerators are
generally not amenable to handling bulk solids and sludges.
Costs for packaging these materials will be added to the
disposal costs. Additionally, the user may wish to place
liquid wastes in drums for reasons of small quantity or
compatibility concerns.
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***** VERSION 3.0 DRAFT***** DATE: 01/18/92
TIME: 11:24:56
SITE NAME:
OPERABLE UN IT:
SCENARIO:
RUN BY:
CORA GRANULAR ACTIVATED CARBON COST MODULE (309)
GEIGY CHEMICAL
ENTIRE SITE ESTIMATED START: EARLY FY 1993
MODULES COMMON TO ALL SCENARIOS
PHONE NUMBER:
INPUTS RESULTS
Parameter Value Component Total
----------------------------------------------------------------
Flow (GPM) 20 CAPITAL COST
Chlor. volatile org. (UG/L) 0 0 & M COSTS Total organic carbon (UG/L) 27
Protection level D CARBON USED (LB/YEAR)
Average temp (degrees F) 65
Confidence level L
*** Operation and maintenance costs are sensitive to carbon usage
and regeneration cost. Carbon cost (including regeneration)
was calculated at $1.50/lb .
130,000
39,000
3,518
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***** VERSION 3.0 DRAFT***** DATE: Ol/lB/92
TIME: 10:44:23
CORA OFFSITE RCRA LANDFILL COST MODULE (401)
SITE NAME: GEIGY CHEMICAL
OPERABLE UNIT:
SCENARIO:
ENTIRE SITE ESTIMATED START: EARLY FY 1993
MODULES COMMON TO ALL SCENARIOS
RUN BY: PHONE NUMBER:
INPUTS RESULTS
Unit
Parameter Value Cost Component
-----------------------------------------------------
RCRA AND NON-PCB SOLIDS: RCRA LANDFILL
Bulk (Tons)* 689 170.00 DISPOSAL COST
Mixed debris (CY)* 0 139.00 TAX
Drums (55-gallon) 0 66.50
Lab packs 0 110 .00 CAPITAL COST
Bulk waste requiring 0 & M COSTS
stabilization (Tons)** 0 225.00
Waste requiring TRANSPORTATION
stabilization (Drums)** 0 135. 00 CAPITAL COST
PCB/TOXIC SOLIDS: 0 & M COSTS
Bulk (Tons)* 0 237.00
Mixed debris (CY)* 0 222.00
Drums (55-gallon) 0 127.00
Tax per drum 0.00
Tax per cubic yard 0.00
Tax per ton 113 .00
Level of confidence H
Miles to offsite facility 600
Demurrage time/load (hrs) 2
Capital or O&M
landfi 11 cost? C
Capital or O&M
transportation cost? C
Total
-----------
120,000
78,000
-----------198,000
0
92,000
0
* These materials will be charged at minimum rate of 2,000 lbs/cy. When
converting tons to CY, CORA assumes a density of 90 lbs/cubic foot.
** Heavy/soft hammer wastes that have not been stabilized on site
NOTES:
Dispose of soil waste off-site at the CWM facility in Emelle, Alabama
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***** VERSION 3.0 DRAFT***** DATE: 01/19/92
TIME: 07:49:48
CORA OFFSITE RCRA LANDFILL COST MODULE (401)
SITE NAME: GEIGY CHEMICAL
OPERABLE UNIT:
SCENARIO:
ENTIRE SITE ESTIMATED START: EARLY FY 1993
LECR lOE-6
RUN BY: PHONE NUMBER:
INPUTS RESULTS
Unit
Parameter Value Cost Component
-----------------------------------------------------
RCRA AND NON-PCB SOLIDS: RCRA LANDFILL
Bulk (Tons)* 0 170.00 DISPOSAL COST
Mixed debris (CY)* 930 139.00 TAX
Drums (55-gallon) 0 66.50
Lab packs 0 110.00 CAPITAL COST
Bulk waste requiring 0 & M COSTS
stabilization (Tons)** 0 225.00
Waste requiring TRANSPORTATION
stabilization (Drums)** 0 135. 00 CAPITAL COST
PCB/TOXIC SOLIDS: 0 & M COSTS
Bulk (Tons)* 0 237.00
Mixed debris (CY)* 0 222.00
Drums (55-gallon) 0 127.00
Tax per drum 0.00
Tax per cubic yard 113 .00
Tax per ton 0.00
Level of confidence M
Miles to offsite facility 600
Demurrage time/load (hrs) 2
Capital or O&M
landfill cost? C
Capital or O&M
transportation cost? C
Total -----------
130,000
110,000
-----------240,000
0
150,000
0
* These materials will be charged at minimum rate of 2,000 lbs/cy. When
converting tons to CY, CORA assumes a density of 90 lbs/cubic foot.
** Heavy/soft hammer wastes that have not been stabilized on site
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***** VERSION 3.0 DRAFT***** DATE: 01/19/92
TIME: 08:01:51
CORA OFFSITE RCRA LANDFILL COST MODULE (401)
SITE NAME: GEIGY CHEMICAL
OPERABLE UN IT:
SCENARIO:
ENTIRE SITE ESTIMATED START: EARLY FY 1993
FOUNDATION
RUN BY: PHONE NUMBER:
INPUTS RESULTS
Unit
Parameter Value Cost Component
-----------------------------------------------------
RCRA AND NON-PCB SOLIDS: RCRA LANDFILL
Bulk (Tons)* 600 170.00 DISPOSAL COST
Mixed debris (CY)~ 0 139.00 TAX
Drums (55-gallon) 0 66.50
Lab packs 0 110.00 CAP IT AL COST
Bulk waste requiring 0 & M COSTS
stabilization (Tons)** 0 225.00
Waste requiring TRANSPORTATION .
stabilization (Drums)** 0 135.00 CAP IT AL COST
PCB/TOXIC SOLIDS: 0 & M COSTS
Bulk (Tons)* 0 237.00
Mixed debris (CY)* 0 222.00
Drums (55-gallon) 0 127.00
Tax per drum 0.00
Tax per cubic yard 0.00
Tax per ton 113. 00
Level of confidence H
Miles to offsite facility 600
Demurrage time/load (hrs) 2
Capital or O&M
landfi 11 cost? C
Capital or O&M
transportation cost? C
Total
-----------
100,000
68,000
-----------168,000
0
79,000
0
* These materials will be charged at minimum rate of 2,000 lbs/cy. When
converting tons to CY, CORA assumes a density of 90 lbs/cubic foot.
'
** Heavy/soft hammer wastes that have not been stabilized on site
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***** VERSION 3.0 DRAFT***** DATE: 01/18/92
TIME: 12:21:44
CORA OFFSITE RCRA LANDFILL COST MODULE (401)
SITE NAME: GEIGY CHEMICAL
OPERABLE UNIT:
SCENARIO:
ENTIRE SITE ESTIMATED START: EARLY FY 1993
LECR lOE-5
RUN BY: PHONE NUMBER:
INPUTS RESULTS
Unit
Parameter Value Cost Component
-----------------------------------------------------
RCRA AND NON-PCB SOLIDS: RCRA LANDFILL
Bulk (Tons) * 168 170.00 DISPOSAL COST
Mixed debris (CY)* 0 139.00 TAX
Drums (55-gallon) 0 66.50
Lab packs 0 ll0.00 CAP IT AL COST
Bulk waste requiring 0 & M COSTS
stabilization (Tons)** 0 225.00
Waste requiring TRANSPORTATION
stabilization (Drums)** 0 135.00 CAPITAL COST
PCB/TOXIC SOLIDS: 0 & M COSTS
Bulk (Tons)* 0 237.00
Mixed debris (CY)* 0 222.00
Drums (55-gallon) 0 127.00
Tax per drum 0.00
Tax per cubic yard 0.00
Tax per ton ll3 .00
Level of confidence H
Miles to offsite facility 600
Demurrage time/load (hrs) 2
Capital or O&M,
landfill cost? C
Capital or O&M
transportation cost? C
Total
-----------
29,000
19,000
-----------48,000
0
24,000
0
* These materials will be charged at minimum rate of 2,000 lbs/cy. When
converting tons to CY, CORA assumes a density of 90 lbs/cubic foot.
** Heavy/soft hammer wastes that have not been stabilized on site
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***** VERSION 3.0 DRAFT***** DATE: 01/19/92
TIME: 08:13:12
CORA OFFSITE SOLID WASTE LANDFILL COST MODULE (404)
SITE NAME:
OPERABLE UNIT:
SCENARIO:
RUN BY:
INPUTS
GEIGY CHEMICAL
ENTIRE SITE ESTIMATED START: EARLY FY 1993
FOUNDATION
PHONE NUMBER:
RESULTS
Parameter Value Component Total
Waste volume (CY) 400
20
10.00
H
2
Miles to landfill
Landfill cost per CY
Confidence level
Demurrage time/load (hrs)
Capital or O&M landfill
cost?
Capital or O&M transport
cost?
C
C
SOLID WASTE LANDFILL
CAP IT AL COST
0 & M COSTS
TRANSPORTATION
CAPITAL COST
0 & M COSTS
*** Landfill costs are generally assessed in tons. CORA assumes
a material density of 90 lb/cubic foot.
4,000
0
5,900
0
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***** VERSION 3.0 DRAFT***** DATE: 01/18/92
TIME: 11:26:03
SITE NAME:
OPERABLE UN IT:
SCENARIO:
RUN BY:
INPUTS
Parameter
CORA DISCHARGE TO P0TW COST MODULE (405)
GEIGY CHEMICAL
ENTIRE SITE ESTIMATED START: EARLY FY 1993
MODULES COMMON TO ALL SCENARIOS
PHONE NUMBER:
Value
RESULTS
Component Total
Transmission main
Flow (GPM)
Press.
20
2640
4
CAPITAL COSTS 230,000
Length of line (ft)
Depth of line (ft)
Sewer use fee
($/1000 Gal)
Average temp (degrees F)
Confidence level
Protection level
NOTES:
1.10
65
M
D
Discharge to the Moore County POTW
0 & M COSTS 12,000
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***** VERSION 3.0 DRAFT***** DATE: 01/18/92
TIME: 11:27:43
CORA WATER INFILTRATION COST MODULE (408)
SITE NAME: GEIGY CHEMICAL
OPERABLE UNIT:
SCENARIO:
ENTIRE SITE ESTIMATED START: EARLY FY 1993
MODULES COMMON TO ALL SCENARIOS
RUN BY: PHONE NUMBER:
INPUTS RESULTS
Parameter Value Component Total
Flow rate (GPM) 100 CAPITAL COST 65,000 Depth to water table (ft) 25 0 & M COSTS 0
Soil permeability 3
Average temp (degrees F) 65
Protection level D
Confidence level L
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***** VERSION 3.0 DRAFT***** DATE: 01/18/92
TIME: 10:24:06
CORA GROUNDWATER MONITORING COST MODULE (503)
SITE NAME: GEIGY CHEMICAL
OPERABLE UN IT:
SCENARIO:
ENTIRE SITE ESTIMATED START: EARLY FY 1993
MODULES COMMON TO ALL SCENARIOS
RUN BY: PHONE NUMBER:
INPUTS RESULTS
Parameter Value Component Total
Number of wells to install 4 CAPITAL COST 43,000 Average well depth (ft) 110 0 & M COSTS 23,000
Protection during setup of D
drill rig & installation
of above-grade piping
Protection during drilling D
Average temp (degrees F) 65
Confidence level M
Number of wells to monitor 23
Monitoring frequency 2
Monitoring requirements:
24 Plasma Metals N
Pest/PCB Y
GC-BN N
GC-Acid N
HSLORG N
VOA GC/MS N
Acid GC/MS N
B/N GC/MS N
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***** VERSION 3.0 DRAFT***** DATE: 01/18/92
TIME: I0:18:40
CORA SITE ACCESS RESTRICTIONS COST MODULE (504)
SITE NAME: GEIGY CHEMICAL
OPERABLE UNIT:
SCENARIO:
ENTIRE SITE ESTIMATED START: EARLY FY 1993
MODULES COMMON TO ALL SCENARIOS
RUN BY: PHONE NUMBER:
INPUTS
Parameter
Site perimeter (ft)
Permanent fence required?
Temporary fence required?
Lighting required?
Security guard required?
Access points req. guard
Guards per access point
Number of shifts
Temporary guardhouses
Vehicles required
Confidence level
Value
5100
y
N
N
N
0
0
0
0
0
M
RESULTS
Component Total
CAPITAL COST 110,000
0 & M COSTS 0
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APPENDIX F
DETAILED COST ESTIMATES
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TABLE F.1
COST SUMMARY TABLE
GEIGY CHEMICAL CORPORATION SITE
ABERDEEN, NORTH CAROLINA
GROUNDWATER CONTROL ALTERNATIVES
ALTERNATIVE DESCRIPTION
GWC-1A NO FURTHER ACTION
GWC-1B LONG-TERM
(10 Year) MONITORING
GWC-1B LONG-TERM
(30 Year) MONITORING
GWC-2 SLURRY WALL & CAPPING
GWC-3 EXTRACTION WELLS
(10 Year) CARBON ADSORPTION
DISCHARGE TO POTW
GWC-3 EXTRACTION WELLS
(30 Year) CARBON ADSORPTION
DISCHARGE TO POTW
INSTALLED PRESENT WORTH TOTAL PRESENT
COSTS($) O&M COST($) WORTH COSTS($)
0 140,000 140,000
130,000 740,000 870,000
130,000 1,500,000 1,600,000
8,400,000 1,800,000 10,000,000
710,000 760,000 1,500,000
710,000 1,500,000 2,200,000
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TABLE F.1 (CONTINUED)
COST SUMMARY TABLE
GEIGY CHEMICAL CORPORATION SITE
ABERDEEN, NORTH CAROLINA
EXPOSURE CONTROL ALTERNATIVES
ALTERNATIVE DESCRIPTION
EC-1 NO FURTHER ACTION
EC-2A
EC-2B
EC-3A
EC-3B
OF,F-SITE DISPOSAL
OF SURFICIAL SOILS
LANDFILULECR 1 0E-5
INCINERATION/LECR 10E-5
OFf-SITE DISPOSAL OF
SURFICIAL SOILS AND
FOUNDATION DEBRIS
LANDFILULECR 1 0E-6
INCINERATION/LECR 10E-6
CAP SURFICIAL SOILS
LECR 10E-5
CAP SURFICIAL SOILS AND
FOUNDATION DEBRIS
LECR 10E-6
INSTALLED PRESENT WORTH
COSTS ($) O&M COST ($)
0 140,000
110,000
360,000
380,000
to
540,000
1,300,000
to
1,500,000
60,000
90,000
0
0
0
0
180,000
180,000
Note: (1) All entries are rounded to 2 significant figures.
TOTAL PRESENT
WORTH COSTS($)
140,000
110,000
360,000
380,000
to
540,000
1,300,000
to
1,500,000
240,000
270,000
(2) Costs for Alternatives GWC-1A, GWC-2, EC-3A AND EC-3B are based on 30 Year O&M Costs
(3) LECR 1 0E-5 are surficial soils designated to be remediated to achieve
a lifetime excess cancer risk (LECR) of 1 0E-5 for the Site.
There is approximately 140 cubic yards of LECR soil at the Site.
(4) LECR 10E-6 are surficial soils designated to be remediated to achieve
a lifetime excess cancer risk (LECR) of 1 0E-6 for the Site.
There is approximately 530 cubic yards of LECR soil at the Site.
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TABLE F.2
GEIGY CHEMICAL CORPORATION SITE
ABERDEEN, NORTH CAROLINA
ALTERNATIVE GWC-1A
NO ACTION (5-YEAR REVIEW OF REMEDY)
REMEDY REVIEW
EVERY 5 YEARS, $50,000 EACH
YEAR PWF(5%)
5 0.7835
10 0.6139
15 0.4810
20 0.3769
25 0.2953
30 0.2314
2.7820
PRESENT WORTH COSTS $139,100
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TABLE F.3
GEIGY CHEMICAL CORPORATION SITE
ABERDEEN, NORTH CAROLINA
ALTERNATIVE GWC-1B
NO ACTION (LONG-TERM MONITORING)
I
DESCRIPTION COST($)
I CONSTRUCTION (UNITS = LS)
SITE WORK 20,000
I MONITORING WELLS (4 at 110 ft.) 70,000
SUBTOTAL-90,000
I MONITORING COSTS (UNITS= LS)
WORK PLAN 10,000
I LABOR 10,000
TRAVEL & PER DIEM 3,000
SUPPLIES & SHIPPING 2,500
I ANALYSES 4,500
HEAL TH & SAFETY 3,000
REPORTING 10,000 -SUBTOTAL-43,000
INSTALLED COST 133,000
I ANNUAL COSTS
MONITORING (TWICE PER YEAR) 86,000
I PRESENT WORTH FACTOR (10 YEARS, 5%) 7.722
PRESENT WORTH FACTOR (30 YEARS, 5%) 15.372
I PRESENT WORTH O&M COST (1 0 YEARS) 664,092
PRESENT WORTH O&M COST (30 YEARS) 1,321,992
I REMEDY REVIEW -EVERY 5 YEARS 50,000
I PRESENT WORTH FACTOR (10 YEARS, 5%) 1.3974
PRESENT WORTH FACTOR (30 YEARS, 5%) 2.7782
I PRESENT WORTH O&M COST (10 YEARS) 69,870
PRESENT WORTH O&M COST (30 YEARS) 138,910
I TOTAL PRESENT WORTH O&M COST (10 YEARS) 733,962
TOTAL PRESENT WORTH O&M COST (30 YEARS) 1,460,902 ,. TOTAL PRESENT WORTH COSTS (10 YEARS) 866,962
TOTAL PRESENT WORTH COSTS (30 YEARS) 1,593,902
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TABLE F.4
GEIGY CHEMICAL CORPORATION SITE
ABERDEEN, NORTH CAROLINA
ALTERNATIVE GWC-2
SLURRY WALL & CAPPING
EXTRACTION WELLS, CARBON ADSORPTION &
DISCHARGE TO POTW
ITEM COMMENT
CAPPING
SLURRY WALL
GROUNDWATER EXTRACTION
SYSTEM
CARBON ADSORPTION
TREATMENT SYSTEM
DISCHARGE TO MOORE
COUNTY POTW
TOTAL COSTS
SEE TABLE F.11
SEE TABLE F.12
SEE TABLE F.13
SEETABLEF.14
SEE TABLE F.15
(30 YEAR)
PRESENT WORTH COSTS ($)
1,808,496
6,136,400
1,141,484
633,562
453,033
10,112,975 1
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TABLE F.5
GEIGY CHEMICAL CORPORATION SITE
ABERDEEN, NORTH CAROLINA
ALTERNATIVE GWC-3
EXTRACTION WELLS, CARBON ADSORPTION &
DISCHARGE TO POTW
ITEM
GROUNDWATER EXTRACTION
SYSTEM
CARBON ADSORPTION
TREATMENT SYSTEM
DISCHARGE TO MOORE
COUNTY POTW
TOTAL COSTS
COMMENT
SEE TABLE F.13
SEE TABLE F.14
SEE TABLE F.15
PRESENT WORTH COSTS ($)
(10 YEAR) (30 YEAR)
846,600 1,141,484
378,444 633,562
249,176 453,033
1,414,220 1 I 2,22a,019 1
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TABLE F.6
GEIGY CHEMICAL CORPORATION SITE
ABERDEEN, NORTH CAROLINA
ALTERNATIVE EC-1
NO FURTHER ACTION (5-YEAR REVIEW OF REMEDY)
REMEDY REVIEW
EVERY 5 YEARS, $50,000 EACH
YEAR PWF(5%)
5 0.7835
10 0.6139
15 0.4810
20 0.3769
25 0.2953
30 0.2314
2.7820
PRESENT WORTH COSTS $139,100
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TABLE F.7
GEIGY CHEMICAL CORPORATION SITE
ABERDEEN, NORTH CAROLINA
ALTERNATIVE EC-2A
OFF-SITE DISPOSAL OF SITE SURFICIAL SOILS
ITEM.
LANDFILL SOILS IN A RCRA APPROVED
LANDFILL TO ACHIEVE A LECR OF 10E-5
INCINERATE SOILS TO
ACHIEVE A LECR OF 1 0E-5
COMMENT
SEE TABLE F.16
SEE TABLE F.17
PRESENT
WORTH
COSTS($)
110,348 I
3ss.373 1
I
TABLE F.8
GEIGY CHEMICAL CORPORATION SITE
ABERDEEN, NORTH CAROLINA ' ALTERNATIVE EC-2B
OFF-SITE DISPOSAL OF SITE SURFICIAL SOILS AND FOUNDATION DEBRIS
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ITEM
LANDFILL SOILS IN A SECURE
LANDFILL TO ACHIEVE A LECR OF 10E-6
LANDFILL FOUNDATION DEBRIS
IN A SECURE LANDFILL
TOTAL COSTS
LANDFILL SOILS IN A SECURE
LANDFILL TO ACHIEVE A LECR OF 10E-6
LANDFILL FOUNDATION DEBRIS
IN A MUNICIPAL LANDFILL
TOTAL COSTS
It IcosT RANGE FOR LANDFILLING
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I
INCINERATE SOILS TO
ACHIEVE A LECR OF 10E-6
LANDFILL FOUNDATION DEBRIS
IN A SECURE LANDFILL
TOTAL COSTS
INCINERATE SOILS TO
ACHIEVE A LECR OF 10E-6
LANDFILL FOUNDATION DEBRIS
IN A MUNICIPAL LANDFILL
TOTAL COSTS
I ICOST RANGE FOR INCINERATION
I ,
I
COMMENT
SEETABLEF.18
SEE TABLE F.19
SEETABLEF.18
SEE TABLE F.20
SEE TABLE F.21
SEE TABLE F.19
SEE TABLE F.21
SEE TABLE F.20
PRESENT
WORTH
COSTS($)
294,896
248.500
543,396
294,896
84,980
379,876
379,876 to 543,396
1,224,161
248.500
1,472,661
1,224,161
84,980
1,309,141
1,309,141 to 1,472,661
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TABLE F.9
GEIGY CHEMICAL CORPORATION SITE
ABERDEEN, NORTH CAROLINA
ALTERNATIVE EC-3A
CAPPING -SURFICIAL SOILS (LECR 1 0E-5)
CAPITAL COSTS
SITE PREPATATION
General
Well abandonment
Surveying
Clearing/Grubbing
Soil Testing
CAPPING
Proof Rolling
Gravel
Item
Emulsion on Petromat for Chip Seal
Asphalt Binder Course
Drainage
TOTAL INSTALLED COST
FACTORED COSTS
Health and Safety
Bonds, insurance
Contingency
Engr ./Const. Mgmt.
TOTAL COSTS
I CAPPING MAINTENANCE
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,Item
Drainage Inspection, Repair
TOTAL ANNUAL CAPPING MAINTENANCE COSTS
PRESENT WORTH FACTOR (10 YEARS, 5%)
PRESENT WORTH FACTOR (30 YEARS, 5%)
TOTAL PRESENT WORTH O&M COSTS (10 YEARS)
TOTAL PRESENT WORTH O&M COSTS (30 YEARS)
,
TOTAL PRESENT WORTH COSTS (10 YEARS)
TOTAL PRESENT WORTH COSTS (30 YEARS)
I
3
2
20
15
Quantity Units
1 LS
1 LS
1 LS
0.10 AC
1 LS
575 SY
65 CY
575 SY
575 SY
150 LF
% of capital costs
% of capital costs
% of capital costs
% of capital costs
Frequency
2x/yr
Unit
Costs($)
20,000
4,000
3,000
2,500
5,000
3
30
2
5
20
Unit
Costs($)
6,000
7.722
15.372
Total
Costs($)
20,000
4,000
3,000
250
5,000
1,725
1,950
1,150
2,875
3,000
42,950
1,289
859
8,590
6,443
60,130
Annual
Costs($)
11,600
11,600
89,575
178,315
149,705
238,445
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TABLE F.10
GEIGY CHEMICAL CORPORATION SITE
ABERDEEN, NORTH CAROLINA
ALTERNATIVE EC-3B
CAPPING -SURFICIAL SOILS (LECR 1 0E-6) AND FOUNDATION DEBRIS
I CAPITAL COSTS
I Item
SITE PREPATATION
General
I Well abandonment
Surveying
Clearing/Grubbing
I Soil Testing
CAPPING
I Proof Rolling
Gravel
Emulsion on Petromat for Chip Seal
I Asphalt Binder Course
Drainage
It TOTAL INSTALLED COST
FACTORED COSTS
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I
Health and Safety
Bonds, insurance
Contingency
Engr./Const. Mgmt.
TOTAL COSTS
CAPPING MAINTENANCE
Item
Drainage Inspection, Repair
TOTAL ANNUAL CAPPING MAINTENANCE COSTS
PRESENT WORTH FACTOR (10 YEARS, 5%)
PRESENT WORTH FACTOR (30 YEARS, 5%)
TOTAL PRESENT WORTH O&M COSTS (10 YEARS)
TOTAL PRESENT WORTH O&M COSTS (30 YEARS)
,
TOTAL PRESENT WORTH COSTS (1 0 YEARS)
TOTAL PRESENT WORTH COSTS (30 YEARS)
I
3
2
20
15
Quantity Units
1 LS
1 LS
1 LS
0.25 AC
1 LS
2,200 SY
250 CY
2,200 SY
2,200 SY
300 LF
o/o of capital costs
o/o of capital costs
o/o of capital costs
o/o of capital costs
Frequency
2x/yr
Unit
Costs($)
20,000
4,000
3,000
2,500
5,000
3
30
2
5
20
Unit
Costs($)
6,000
7.722
15.372
Total
Costs($)
20,000
4,000
3,000
625
5,000
6,600
7,500
4,400
11,000
6,000
68,125
2,044
1,363
13,625
10,219
95,375
Annual
Costs($)
11,600
11,600
89,575
178,315
184,950
273,690
I
TABLEF.11
GEIGY CHEMICAL CORPORATION SITE
ABERDEEN. NORTH CAROLINA
CAPPING
CAPITAL COSTS
I Unit Total
Item Quantity Units Costs($) Costs($)
SITE PREPATATION
General LS 20,000 20,000
I Well abandonment LS 10,000 10,000
Surveying 1 LS 3,000 3,000
Fence 2,700 LF 10 27,000
Gates 2 EA 750 1,500
I Clearing/Grubbing 3,5 AC 2,500 8,750
Soil Testing LS 5,000 5,000
Rail Line Removal 2,000 LF 20 40,000
Rail Line Reinstallation 2,000 LF 100 200,000
I Rail Line Grading 2,000 CY 15 30,000
CAPPING
Common Fill 25,000 CY 10 250,000
I Select Fill 9,000 CY 15 135,000
Proof Roll Site 3.5 AC 150 525
Geotextile Cushion 163,000 SF 0.20 32,600
60 mil HOPE Liner 163,000 SF 0,70 114,100
I Drainage Net 163,000 SF 0.30 48,900
Filter Fabric 163,000 SF 0.20 32,600
Treat Subbase 3.5 AC 1,000 3,500
Top Soil 3,000 CY 16 48,000
It Fine Grading 3.5 AC 1,500 5,250
Hydromulching 3.5 AC 1,800 6,300
Drainage 1,600 LF 20 32,000
Equipment Oecon Pad EA 50,000 50.000
I TOTAL INSTALLED COST 1,104,025
FACTORED COSTS
I Health·and Safety 3 % of capital costs 33,121
Bonds, insurance 2 % of capital costs 22,081
Contingency 20 % of capital costs 220,805
Engr./Const Mgmt. 15 % of capital costs 165,604 I TOTAL COSTS 1,545,635
CAPPING MAINTENANCE
I Unit Annual
Item Frequency Costs($) Costs($)
Fence inspection, Repair Annually 2,500 2,500
Grasa Cutting 3x/yr 1,000 3,000 I Drainage Inspection, Repair 2x/yr 5,800 11,600
TOTAL ANNUAL CAPPING MAINTENANCE COSTS 17,100
I PRESENT WORTH FACTOR (10 YEARS, 5%) 7.722
PRESENT WORTH FACTOR (30 YEARS, 5%) 15.372
I TOTAL PRESENT WORTH O&M COSTS (10 YEARS) 132,046
TOTAL PRESENT WORTH O&M COSTS (30 YEARS) 262,861 , TOTAL PRESENT WORTH COSTS (10 YEARS) 1,6TT,681
TOTAL PRESENT WORTH COSTS (30 YEARS) 1,808,496
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TABLE F.12
GEIGY CHEMICAL CORPORATION SITE
ABERDEEN, NORTH CAROLINA
SLURRY WALL .
CAPITAL COSTS
Unit
Item Quantity Units Cost($)
SLURRY WALL
Mobilization
Installation
QA/QC
TOT AL INSTALLED COSTS
FACTORED COSTS
Health an.d Safety
Bonds, insurance
Contingency
Engr./Const. Mgmt.
TOTAL COSTS
TOTAL PRESENT WORTH COSTS
1 LS 100,000
134,400 SF 30
1 LS 100,000
3 % of installed costs
2 % of installed costs
20 % of installed costs
20 % of installed costs
Total
Costs($)
100,000
4,032,000
100,000
4,232,000
126,960
84,640
846,400
846,400
6,136,400
s,13s.400 1
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TABLE F.13
GEIGY CHEMICAL CORPORATION SITE
ABERDEEN, NORTH CAROLINA
GROUNDWATER EXTRACTION SYSTEM
DESCRIPTION
WELL CONSTRUCTION
SITE WORK
EXTRACTION WELL
MONITORING WELL
WELL HEAD
PUMPS
AIR PIPING
COMPRESSOR
DISCHARGE PIPING
ELECTRICAL CONDUIT,
WIRE, FIXTURE
DATA AQUISITION
SYSTEM
FACTORED COSTS
HEAL TH & SAFETY
BOND & INSURANCE
CONTINGENCY
CONST.MANAGEMENT
TOTAL CONSTRUCTION COST
OPERATION & MAINTENANCE
POWER
INSPECTION & REPAIR
MONITORING
QUANTITY UNITS
1 LS
670 LF
440 LF
9 EA
9 EA
6,000 LF
1 EA
6,000 LF
1 LS
1 LS
SUBTOTAL-
UNIT
PRICE($)
20,000
140
120
5,000
2,500
4
4,000
5
50,000
50,000
3% OF CONSTRUCTION COST
2% OF CONSTRUCTION COST
25% OF CONSTRUCTION COST
10% OF CONSTRUCTION COST
SUBTOTAL-
HP 10
5% OF TOT. CONST. COST
LS 1 4,500
TOTAL($)
20,000
93,800
52,800
45,000
22,500
24,000
4,000
30,000
50,000
50,000
392,100
11,763
7,842
98,025
39,210
156,840
548,940
6,600
27,447
4,500
SUBTOTAL -38,547
PRESENT WORTH FACTOR (10 YEARS, 5%) 7.7220
PRESENT WORTH FACTOR (30 YEARS, 5%) 15.3720
PRESENT WORTH O & M COST (10 YEARS) 297,660
PRESENT WORTH O & M COST (30 YEARS) 592,544
TOTAL PRESENT WORTH COST (10 YEARS) 846,600
' TOTAL PRESENT WORTH COST (30 YEARS) 1,141,484
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TABLE F.14
GEIGY CHEMICAL CORPORATION SITE
ABERDEEN, NORTH CAROLINA
CARBON ADSORPTION TREATMENT SYSTEM
UNIT
DESCRIPTION QUANTIT UNITS PRICE($) TOTAL($)
EQUIPMENT
EQUALIZATION TANK 1 EA 1,000 1,000
PUMPS 3 EA 1,500 4,500
· FILTRATION UNIT EA 3,500 3,500
GAG ADSORPTION SYSTEM EA 4,500 4,500
SAMPLING STATION EA 4,000 4,000
INSTRUMENTATION LS 15,000 15,000
SUBTOTAL-32,500
INSTALLATION
ELECTRICAL 9,750
PIPING 9,750
INSTRUMENTATION 13,000
STRUCTURAL 11,375
SUBTOTAL-43,875
POWER CONNECTION LUMP SUM 10,000
TOTAL INSTALLED COST 86,375
FACTORED COSTS
HEAL TH & SAFETY 3% OF INSTALLED COSTS 2,591
BOND & INSURANCE 2% OF INSTALLED COSTS 1,728
CONTINGENCY 25% OF INSTALLED COSTS 21,594
CONST.MANAGEMENT 10% OF INSTALLED COSTS 8,638
SUBTOTAL -34,550
TOTAL CONSTRUCTION COSTS 120,925
OPERATION & MAINTENANCE
POWER HP 5 3,303
EFFLUENT SAMPLING EA 4 1,000 4,000
INSPECTION & REPAIR 5% OF TOT. CONSTRUCTION COS 6,046
MONITORING LS 20,000 20,000
SUBTOTAL-33,349
PRESENT WORTH FACTOR (10 YEARS, 5%) 7.7220
PRESENT WORTH FACTOR (30 YEARS, 5%) 15.3720
PRESENT WORTH O & M COST (10 YEARS) 257,519
PRESENT WORTH O & M COST (30 YEARS) 512,637
TOTAL PRESENT WORTH COST (10 YEARS) 378,444
TOTAL PRESENT WORTH COST (30 YEARS) 633,562
I
TABLE F.15
GEIGY CHEMICAL CORPORATION SITE
ABERDEEN, NORTH CAROLINA
DISCHARGE TO MOORE COUNTY POTW
I UNIT
DESCRIPTION QUANTITY UNITS PRICE($) TOTAL($)
I SEWER CONNECTION
SITE WORK 1 LS 5,000 5,000
I 1 • SCH 40. PVC PIPE 3,000 LF 2.50 7,500
TRENCHING & BACKFILL 3,000 LF 2.00 6,000
SEEDING 1 LS 1,500 1,500
I RAIL CROSSING 1 LS 10,000 10,000
MANHOLE TIE-IN 1 LS 500 500
CONNECTION FEE 1 LS 500 500
I
SUBTOTAL-31,000
I FACTORED COSTS
HEAL TH & SAFETY 3% OF CONSTRUCTION COST 930 -BOND & INSURANCE 2% OF CONSTRUCTION COST 620
CONTINGENCY 25% OF CONSTRUCTION COST 7,750
CONST.MANAGEMENT 10% OF CONSTRUCTION COST 3,100
I SUBTOTAL-12.400
I TOTAL CONSTRUCTION COST 43,400
OPERATION & MAINTENANCE
I WASTEWATER DISCHARGE 1000 GALJY 9,724 2.00 19,448
QUARTERLY MONITORING
I REPORT LS 4 1,000 4,000
QUARTERLY SAMPLING LS 4 800 3,200
I SUBTOTAL-26,648
PRESENT WORTH FACTOR (10 YEARS, 5%) 7.7220
I PRESENT WORTH FACTOR (30 YEARS, 5%) 15.3720
PRESENT WORTH O & M COST (10 YEARS) 205,776
I PRESENT WORTH O & M COST (30 YEARS) 409,633 , TOTAL PRESENT WORTH COST (10 YEARS) 249,176
TOTAL PRESENT WORTH COST (30 YEARS) 453,033
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TABLE F.16
GEIGY CHEMICAL CORPORATION SITE
ABERDEEN, NORTH CAROLINA
LANDFILL SURFICIAL SOILS AT THE USPCI FACILITY IN CLYDE, UTAH TO ACHIEVE A LECR OF 10E-5
CALCULATED SOIL VOLUME -140 CUBIC YARDS
ASSUMED SOIL DENSITY -1.3 TONS/CUBIC YARD
Capital Costs -Excavation And Disposal
Surficial Soils
Work Plan
Waste Sampling
Item
Waste Analysis -TCLP
Equipment Decon.
Excavation
Loading, hauling and landfilling
Clean fill
Quantity Units
LS
1 LS
4 EACH
1 LS
140 CY
182 TON
140 CY
TOTAL EXCAVATION AND DISPOSAL CAPITAL COSTS
FACTORED COSTS
Health and Safety
Bonds, insurance
Contingency
Engr./Const. Mgmt.
TOTAL FACTORED COSTS
TOTAL PRESENT WORTH COSTS
3 o/o of capital costs
2 o/o of capital costs
20 o/o of capital costs
15 o/o of capital costs
Unit
Costs($)
20,000
3,500
1,500
2000
50
210
15
Total
Costs($)
20,000
3,500
6,000
2,000
7,000
38,220
2,100
78,820
2,365
1,576
15,764
11,823
31,528
110.s4a 1
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TABLE F.17
GEIGY CHEMICAL CORPORATION SITE
ABERDEEN, NORTH CAROLINA
INCINERATE SURFICIAL SOILS AT A RCRA APPROVED INCINERATOR TO ACHIEVE A LECR OF 10E-5
CALCULATED SOIL VOLUME -140 CUBIC YARDS
ASSUMED SOIL DENSITY -1.3 TONS/CUBIC YARD
Capital Costs -Excavation And Incineration
Surficial Soils
Work Plan
Waste Sampling
Item
Waste Analysis -TCLP
Equipment Decon.
Excavation
Hauling-22 ton dump trailer
Rolloff Liners
Incineration -CWM, Port Arthur, Texas
Clean fill
TOTAL INCINERATION CAPITAL COSTS
FACTORED COSTS
Health and Safety
Bonds, insurance
Contingency
Engr./Const. Mgmt.
TOTAL FACTORED COSTS
TOTAL PRESENT WORTH COSTS
Quantity Units
1 LS
1 LS
3 EACH
1 LS
140 CY
8 'LOAD
8
182
140
3 % of capital costs
2 % of capital costs
20 % of capital costs
15 % of capital costs
LOAD
TON
CY
Unit
Costs($)
20,000
3,500
1,500
2000
50
4900
30
900
25
Total
Costs($)
20,000
3,500
4,500
2,000
7,000
40,536
248
163,800
3,500
245,085
7,353
4,902
61,271
36,763
110,288
355,373 1
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TABLE F.18
GEIGY CHEMICAL CORPORATION SITE
ABERDEEN, NORTH CAROLINA
LANDFILL SURFICIAL SOILS AT THE USPCI FACILITY IN CLYDE, UTAH TO ACHIEVE A LECR OF 10E-6
CALCULATED SOIL VOLUME-530 CUBIC YARDS
ASSUMED SOIL DENSITY -1.3 TONS/CUBIC YARD
Capital Costs -Excavation And Disposal
Item Quantity Units
Surficial Soils
Work Plan 1 LS
Waste Sampling 1 LS
Waste Analysis -TCLP 4 EACH
Equipment Decon. 1 LS
Excavation 530 CY
Loading, hauling and landfilling 689 TON
Clean fill 530 CY
TOTAL EXCAVATION AND DISPOSAL CAPITAL COSTS
FACTORED COSTS
Health and Safety
Bonds, insurance
Contingency
Engr./Const. Mgmt.
TOTAL FACTORED COSTS
TOTAL PRESENT WORTH COSTS
3 o/o of capital costs
2 o/o of capital costs
20 o/o of capital costs
15 o/o of capital costs
Unit
Costs($)
20,000
3,500
1,500
2000
50
210
15
Total
Costs($)
20,000
3,500
6,000
2,000
26,500
144,690
7,950
210,640
6,319
4,213
42,128
31,596
84,256
2s4,ss6 1
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TABLE F.19
GEIGY CHEMICAL CORPORATION SITE
ABERDEEN, NORTH CAROLINA
LANDFILL FOUNDATION DEBRIS AT THE USPCI FACILITY IN CL YOE, UTAH
CALCULATED FOUNDATION DEBRIS VOLUME -400 CUBIC YARDS
ASSUMED DEBRIS DENSITY -1.5 TONS/CUBIC YARD
Capital Costs -Excavation And Disposal
Item
Foundation Soils & Rubble
Work Plan
Waste Sampling
Waste Analysis -TCLP
Equipment Decon.
Excavation
Loading, hauling and landfilling
Quantity
1
1
4
1
400
600
Units
LS
LS
EACH
LS
CY
TON
TOTAL EXCAVATION AND DISPOSAL CAPITAL COSTS
FACTORED COSTS
Health and Safety
Bonds, insurance
Contingency
Engr./Const. Mgmt.
TOTAL FACTORED COSTS
TOTAL PRESENT WORTH COSTS
3 o/o of capital costs
2 o/o of capital costs
20 o/o of capital costs
15 o/o of capital costs
Unit
Costs($)
20,000
3,500
1,500
2000
50
210
Total
Costs($)
20,000
3,500
6,000
2,000
20,000
126,000
177,500
5,325
3,550
35,500
26,625
71,000
24a,5oo 1
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TABLE F.20
GEIGY CHEMICAL CORPORATION SITE
ABERDEEN, NORTH CAROLINA I
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I
LANDFILL FOUNDATION DEBRIS AT A MUNICIPAL LANDFILL
CALCULATED FOUNDATION DEBRIS VOLUME -400 CUBIC YARDS
ASSUMED DEBRIS DENSITY-1.5 TONS/CUBIC YARD
Capital Costs -Excavation And Disposal
Item
Foundation Soils & Rubble
Work Plan
Waste Sampling
Waste Analysis -TCLP
Equipment Decon.
Excavation & Loading
Hauling
Landfilling
Quantity
1
1
4
1
400
400
600
TOTAL EXCAVATION AND DISPOSAL CAPITAL COSTS
It FACTORED COSTS
Health and Safety
Bonds, insurance I Contingency
Engr./Const. Mgmt.
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I
TOTAL FACTORED COSTS
TOTAL PRESENT WORTH COSTS
3 % of capital costs
2 % of capital costs
20 % of capital costs
15 % of capital costs
Unit
Units Costs($)
LS 20,000
LS 3,500
EACH 1,500
LS 2000
CY 50
CY 8
TON 10
Total
Costs($)
20,000
3,500
6,000
2,000
20,000
3,200
6,000
60,700
1,821
1,214
12,140
9,105
24,280
s4,9so 1
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TABLE F.21
GEIGY CHEMICAL CORPORATION SITE
ABERDEEN, NORTH CAROLINA
INCINERATE SURFICIAL SOILS AT A AGRA APPROVED INCINERATOR TO ACHIEVE A LECR OF 10E-6
CALCULATED SOIL VOLUME -530 CUBIC YARDS
ASSUMED SOIL DENSITY -1.3 TONS/CUBIC YARD
Capital Costs-' Excavation And Incineration
Surficial Soils
Work Plan
Waste Sampling
Item
Waste Analysis -TCLP
Equipment Decon.
Excavation
Hauling-22 ton dump trailer
Rolloff Liners
Incineration -CWM, Port Arthur, Texas
Clean fill
Quantity
1
1
3
1
530
31
31
689
530
Units
LS
LS
EACH
LS
CY
LOAD
LOAD
TON
CY
Unit Total
Costs($) Costs($)
20,000 20,000
3,500 3,500
1,500 4,500
2000 2,000
50 26,500
4900 153,459
30 940
900 620,100
25 13,250
• TOTAL INCINERATION CAPITAL COSTS 844,249
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I
FACTORED COSTS
Health and Safety
Bonds, insurance
Contingency
Engr./Const. Mgmt.
TOTAL FACTORED COSTS
TOTAL PRESENT WORTH COSTS
3 % of capital costs
2 o/o of capital costs
20 % of capital costs
15 % of capital costs
25,327
16,885
211,062
126,637
379,912
1,224,161
f
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APPENDIX G -REFERENCES
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BioTrol Inc., Technology Qualification for BioTrol Soil Washing System, October 3, 1991.
Borden and kao, 1992. Evaluation of groundwater extraction for remediation of petroleum-
contaminated aquifers. Water Environment Research, Vol. 64, No. 1, 28-36,
January/February, 1992.
Borrow, H.S. and Kinsella, J.V., 1989. Bioremediation of Pesticides and Chlorinated Phenolic
Herbicides -Above Ground and In-Situ -Case Studies, Superfund '89, The Hazardous
Materials Control Research Institute, Washington, D.C.
C.F. Systems Corporation, personal communication, Mr. Chris Shallice, 7 January, 1992.
Chemical Waste Management, Inc., personal communication, Mr. Rick Chap, July 2, 1991.
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