NCD981927502_19920701_Geigy Chemical Corporation__FRBCERCLA ROD_Record of Decision - Summary of Remedial Alternative Selection-OCR

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RECORD OF DECISION
SUMMARY OF REMEDIAL
ALTERNATIVE SELECTION
GEIGY CHEMICAL CORPORATION SITE
ABERDEEN, MOORE COUNTY
NORTH CAROLINA
PREPARED BY:
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV
ATLANTA, GEORGIA
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DECLARATION
FOR
THE RECORD OF DECISION
SITE NAME AND LOCATION
Geigy Chemical Corporation
Aberdeen, Moore County, North Carolina
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for the Geigy Chemical Corporation Superfund Site in Moore County, North Carolina, chosen in accordance with the Comprehensive Environmental Response, Compensation, and Liability Act of 1980, as amended by the Superfund Amendments and Reauthorization Act of 1986 and, to the extent practicable, the National Contingency Plan. This decision is based on the administrative record file for this Site.
The State of North Carolina conditionally with the selected remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this Site, if not addressed by implementing the response action selected in this Record of Decision, may present an imminent and substantial endangerment to public health, welfare, or the environment.
DESCRIPTION OF THE SELECTED REMEDY
This remedy addresses the principle threat posed by this Site. The major threat is the contaminated groundwater emanating from beneath the Site. This remedial action will also address soil contamination.
The major components of the selected remedy include:
GROUNDWATER
Extraction of groundwater across the Site in the upper aquifer and the second uppermost aquifer that is contaminated above Maximum Contaminant Levels or the North Carolina Groundwater Standards, which ever are more protective;
On-site treatment of extracted groundwater via carbon adsorption to remove contaminants;
Discharge of treated groundwater to the local POTW or an infiltration gallery. The discharge location will be determined in the Remedial Design; and
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SOIL
Continued analytical monitoring for contaminants in groundwater.
Demolition of former warehouse foundation; Disposal at a municipal or secure landfill;
Excavation of the top foot of on-site soils contaminated above the performance standards;
TCLP testing of the stockpile of contaminated soil to determine final disposition;
Off-site incineration of contaminated soils that fail the TCLP test;
Off-site disposal in an approved hazardous waste landfill of contaminated soils that pass the TCLP test;
Backfilling, grading and revegetation of excavated area;
ADDITIONAL SAMPLING AND MONITORING
Additional sampling and analyses of the second uppermost aquifer to determine the extent of pesticide contamination, and to determine if the trichloroethylene (TCE) found in two wells is site-related. Until it is proven that the TCE is not site-related, it will be assumed that the TCE is site-related and thus, it will be included as a contaminant of concern.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the environment, complies with Federal and State requirements that are legally applicable or relevant and appropriate to the remedial action, and is cost-effective. This remedy utilizes permanent solutions and alternative treatment technology to the maximum extent practicable, and satisfies the statutory preference for remedies that employ treatment that reduces toxicity, mobility, or volume as a principal element. Since this remedy may result in hazardous substances remaining on-site above health based levels, a review will be conducted within five years after commencement of remedial action to ensure that the remedy continues to provide adequate protection of human health and the environment.
Greer C. Tidwell Date I Regional Administrator
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1. TABLE OF CONTENTS
I SECTION PAGE NO.
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I. SITE NAME, LOCATION AND DESCRIPTION. . . . . . . . . . 1
A. Introduction . . . . . . . . . . . . . . . . • . . . . 1 B. Site Description ................• .'. 1 C. Topography . . . . . . . . . . . . . . . . . . . . . . 1
D. Geology . . . . . . . . . . . . . . . . . . . . . • . 1
E. Surface Water. . . . . . . . . . . .' • . . • . . . . . 4 F. Hydrology. . . . • 4 G. Meteorology. . . . 4 H. Demography and Land Use 5 I. Utilities . . . 5
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES 6
A. Site History. . . . . . . . . . . . 6 B. Previous Investigations ..............•. 6 C. Enforcement Activities ...............• 7
III. HIGHLIGHTS OF COMMUNITY PARTICIPATION. . . . . . . . 8 I IV. SCOPE AND ROLE OF RESPONSE ACTION WITHIN SITE STRATEGY 9
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V. SUMMARY OF SITE CHARACTERISTICS 10
10
16
16
42
42
VI.
VII.
A. Groundwater ....... . B. Initial Removal Activity
C. Soil Investigation .. D. 1991 Removal .....
E. Sediment Investigation
SUMMARY OF SITE RISKS .•.•...........••. 61
A.
B. c.
D.
E.
F.
Contaminants of Concern .. . Exposure Assessment ..... . Toxicity Assessment ..... . Risk Characterization Summary. Environmental (Ecological) Risk Soil Remediation. . . .....
61
61
64
66
69 • • • • • • • • • 6 9
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARS)
A. Action-Specific ARARs . B. Location-Specific ARARs
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TABLB OF CONTENTS (CONT'D)
SECTION
PAGE NO. c. Chemical Specific ARARs . . . . . . . . . . . . . . 72
Groundwater ......... . Maximum Contaminant Levels NC Groundwater Standards
Soi 1 s . . . . . . . . . . . . .
• • • • • • • • • • • 7 2
( MCLs) . . . . . . . 7 2
72
75
VIII. DESCRIPTION OF ALTERNATIVES ... • • • • • 7 7
IX.
A.
B.
REMEDIAL ALTERNATIVES TO ADDRESS GROUNDWATER CONTAMINATION 1. No Action . . . . . . . . . . . . . . . . . . 77 2. Slurry Wall and Cap ............... BO 3. Groundwater Recovery to Attain Remediation Levels Bl
REMEDIAL ALTERNATIVES TO ADDRESS 1. No Action . . . .
2 • Off-Site Disposal . . . . 3. Capping . . . . . . . . . 4. On-Site Thermal Desorption 5. On-Site Incineration .
SOIL
. . . .
. .
CONTAMINATION
. . . . . . . . . . . .
. . . . . . .
.
. .
.
. .
82
82
83
83
84
85
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES ..... 87
A. GROUNDWATER REMEDIATION .........•..... 88 Overall Protection of Human Health & the Environment 90 Compliance with ARARs .........•....... 90 Long-term Effectiveness and Permanence . . 90 Reduction of Toxicity, Mobility, or Volume 90 Short-term Effectiveness 91 Implementability 91 Cost • • . . . . . . . . 91
B. SOIL REMEDIATION. . . . . . . . . . . . . . . . . . 91 Overall Protection of Human Health & the Environment 91 Compliance with ARARs ................ 92 Long-term Effectiveness and Permanence . • 92 Reduction of Toxicity, Mobility, or Volume 92 Short-term Effectiveness 92 Implementability . . . . . . . . . . . . . 92 Cost
C. MODIFYING CRITERIA . • . . . . • . . . . . . • . . . . 92 State Acceptance . • 93 Community Acceptance ................ 93
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DECISION SUMMARY
I I. SITE NAME. LOCATION ARD DESCRIPTION
I A. Introduction
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The Geigy Chemical Corporation Site ( Geigy Site) is located just east_ of the corporate city limits of Aberdeen, North Carolina on Highway 211 in southeastern Moore County (Figure -1). The Site was operated as a pesticide blending and formulation facility from approximately 1947 to 1967 and was operated by retail distributors of agricultural chemicals from 1968 to 1989.
B. Site Description
The Geigy Site is an approximately one-acre parcel located on the Aberdeen and Rockfish Railroad right-of-way. The property is in the form of an elongated triangle between Highway 211 and the railroad, with the highway and railroad intersecting at the apex of the triangle.
The Site is currently vacant and consists of foundations from two former warehouses, an office concrete tank pad (Figure 2).
partial concrete
building, and a
At the east end of the former warehouse buildings is an on-site water supply well. The well water was probably used for process operations, lavoratories, showers, and on-site drinking water.
I C. Topography
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The Site is in the Sandhills physiographic province, characterized by rolling hill underlain by well-drained, unconsolidated sands. Site elevations range from approximately 460 to 480 feet above mean sea level (MSL). The Site is essentially flat.
D. Geology
Generally, the geology under the Site consists of unconsolidated sedimentary rocks which were deposited on top of crystalline basement rocks. The thickness of the sedimentary rocks in the Aberdeen area is approximately 200 to 250 feet. The surface geology consists of Coastal Plain sediments, crystalline rocks of the Piedmont province, and Triassic basin rocks.
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Site soils are of the Candor series and are deep, excessively drained
sandy soils (e.g., sand, silty sand, loamy sand, sandy loam).
E. Surface Water
There is no surface water at the Site.
are dry except during storm events.
storms is rapidly absorbed into the
vicinity of the Site.
F. Hydrogeology
Drainage ditches at the Site
Surface water runoff during
well-drained soils in the
Three aquifers
Creek (second
aquifer.
underlie
uppermost),
the Site: the shallow
and Upper Cape Fear
(uppermost), Black
(third uppermost)
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 and 2.8
feet/day, respectively.
Potenti6metric 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 and west of the
convergence zone, groundwater flow is predominantly to the
east-southeast.
The Black Creek confining unit is between the surficial aquifer and
the second uppermost aquifer.
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. Groundwater flow in the second uppermost aquifer is generally
northwesterly.
The Upper Cape Fear confining unit (approximately 60 feet thick) is
over the Upper Cape Fear aquifer. In the Aberdeen area, the third
uppermost aquifer ranges from 10 to 20 feet thick and directly
overlies the crystalline bedrock. Groundwater flow in this aquifer
is generally to the northwest.
D G. Meteorology
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Average daily maximum temperature is 9 0 degrees F. in July and
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average daily minimum is 30 degrees F. in January. Average annual
precipitation is 48 inches. Precipitation is fairly uniform
year-round, ranging from three to five inches per month.
H. Demography and Land Use
The Site is bordered to the north by Route 211, to the south by a
wooded area and to the west .by Route 211 and the Aberdeen and
Rockfish railroad. A residential property borders the east. A farm
is located to the southeast of the site while the property
immediately north on the opposite side of Route 211 is used for
commercial purposes. A housing development is located 1/4 mile to
the northwest of the site.
Moore County occupies a total area of 672 square miles and has an
estimated population of 59,013 (1990 census). Approximately 2700
people live in Aberdeen. Within 0 - 1 mile of the site, there are
355 families and a total of 1,208 people with a median age of 34
years. Approximately 132 people or 11% of the population within the
0 - 1 mile radius are between the ages of 7 to 13 years.
I. Utilities
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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II. SITE HISTORY AND ENFORCEMENT ACTIVITIES
A. Site History
The Geigy Site has been leased and operated by various companies since approximately 194 7. From approximately 194 7 to 1967, the Site was leased by several companies for pesticide formulation and retail sales. Since 1968, the Site has been used by retail distributors of agricultural chemicals, mainly fertilizers. The most recent occupant, Lebanon Chemical Corporation, operated a farm service center on the Site for retail distribution of agricultural pesticides and fertilizers. The Site is currently unoccupied; however, the Aberdeen and Rockfish Railroad which traverses the southern portion of the Site is still active.
Known operators at the Site and approximate dates of operation are as follows:
* White & Peele (1947-1948) * Blue Fertilizer ( 1948-1949) * Geigy Chemical Corporation (now Ciba-Geigy) (1949-1955) * Olin-Matheison Corporation (now Olin Corp) (1956-1967) * Columbia Nitrogen Corporation (1968) * Kaiser Aluminum & Chemical Corporation (1969-1984) * Lebanon Chemical Corporation (now Kaiser-Estech Corp) ( 1985-1989)
Agricultural fertilizers, both liquid and dry, in bulk and bagged form, have been distributed from the facility at various times during the operating history. Micronutrients, such as copper and zinc, were added to fertilizers in small quantities (i.e. 0.05% to 0.3%) to increase the quality and yield of crops. The pesticides DDT, toxaphene, and BHC were known to have been formulated on-site. Technical grade DDT, toxaphene, and BHC were shipped in bags or barrels to Aberdeen. The technical grade pesticide was blended with clay or other inert materials to form a usable product and repackaged for sale to local cotton and tobacco growing markets. Pesticides were not manufactured at the Site, but rather only formulated (i.e., blended) into a product suitable for local consumer use.
B. PREVIOUS INVESTIGATIONS
II An EPA Site Investigation (SI) was conducted in March II purpose of the SI was to collect soil and water samples the Hazard Ranking System (HRS) evaluation.
1988. The
to support
D Isomers of BHC
off-site locations:
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were detected in five groundwater samples two private wells and three of the municipal
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wells. Lead was detected in concentrations exceeding the drinking water standards in two private wells. Lead was not detected in the on-site groundwater sample.
The Site was regraded by the railroad after this investigation, therefore the soil sample locations were not relied upon for future work.
C. Enforcement Activities
There is no information of any past enforcement actions or violation citings at the Site. In addition, no known inspections by the North Carolina Department of Environmental Management ( DEM) or the Department of Natural Resources (DNR) occurred.
The Geigy Chemical Corporation Site National Priorities List (NPL) in October 4, 1989.
was proposed for inclusion on the June 1988 and became final on
In March 1988, EPA sent notice letters to the following companies:
1. Ciba-Geigy Corp
2. Olin Corp
3. Kaiser Aluminum & Chemical Corp 4. Lebanon Chemical Corp S. Aberdeen and Rockfish Railroad 6. Columbia Nitrogen Corporation
The letters requested that the PRPs conduct a Remedial Investigation and Feasibility Study (RI/FS) for the Site. The notice letters also informed the PRPs of their potential liability for past costs. On December 16, 1988, EPA entered· into an Administrative . Order on Consent (AOC) wherein three of the PRPs, Ciba Geigy, Olin, and Kaiser, agreed to perform the RI/FS.
The AOC was amended on January 23, 1991 to include the removal and proper disposal of contaminated soils containing toxaphene greater than 500 mg/kg and/or lindane at 100 mg/kg.
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III. HIGHLIGH'rS OF COMXUHITY PARTICIPATION
Pursuant to CERCLA §113(K)(2)(B)(i-v) and 117, the RI/FS Report and the Proposed Plan for the Geigy Site were released to the public for comment on March 26, 1992. These documents were made available to the public in the administrative record located in an information repository maintained at the EPA Docket Room in Region IV and at the Aberdeen Town Hall in Aberdeen, North Carolina. The notice of availability for these documents was published in the Pilot Newspaper (Southern Pines) and in the Moore County Citizen News (Aberdeen) on March 26, 1992. A public comment period on the documents was held from March 26, 1992 to April 24, 1992. Due to several requests, the public comment period was extended to May 25, 1992. Notice of this extension was placed in both newspapers on April 23, 1992. A copy of the notice was mailed to the public. In addition, a public meeting was held on March 31, 1992. At _this meeting, representatives from EPA answered questions about problems at the site and the remedial alternatives under consideration.
Other community relations activities included:
* Issuance of a Fact Sheet on the RI/FS process in May 1990.
* An availability session to address citizen concerns in June 1990.
* Issuance of a Fact Sheet on the RI results in December 1991.
* Issuance of a Fact Sheet on the Proposed Plan in March 1992.
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IV. SCOPE ARD ROLE OF RESPONSE ACTION WITHIN SITE STRATEGY
The intent of
future risks
threat posed
contemplated
identified at
this remedial action presented in this at this Site. This remedial action by contamination at the Site. This for the Site. No other operable this Site.
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ROD is to reduce
will remove the
is the only ROD
units have been
,:, I v. SUMMARY OP SITE CHARACTERISTICS
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The RI at the Geigy Site included the characterization of groundwater, soil and sediment contamination. Surface water samples were not collected because there are no nearby surface water bodies.
In addition, two removals (in three phases) were conducted during the RI. Results of these removals will be summarized below.
A. Groundwater Investigation
The groundwater investigation was conducted in two phases. In the first phase, ten groundwater monitoring wells were installed: six (MW-lS through MW-6S) in the shallow aquifer; three (MW-1D, MW-4D, and MW-6D) in the intermediate aquifer; and one in the deep aquifer. In addition, the water supply well was also included in the investigation (Figure 3).
(, The sampling was conducted in November 1990. Analytical parameters included field parameters (pH, temperature, specific conductance), Target Compound List (TCL) volatiles, semivolatiles, and pesticides and Target Analyte List (TAL) metals.
The results of the volatile and semi-volatile analyses is shown in Table l. Acetone was found in three wells, but is believed to be a laboratory contaminant because acetone was also found in the blank samples. Xylene and bis(2-ethylhexyl)phthalate were each found in only one well at 4J. ug/1 and 7J ug/1 respectively. The compound 1,2,4-trichlorobenzene was found in two wells, MW.;.SS and MW-6S, at 4J ug/1 and SJ ug/1 respectively. Trichloroethene was found in two deep wells, MW-4D and MW-6D, at 200 ug/1 and 11 ug/1 respectively.
The pesticide results are shown in Table 2. As indicated, pesticides were detected in all the shallow wells except MW-1S, which is a background well. Pesticides were not detected in the intermediate or deep wells. Gamma-BHC (lindane) was the most prevalent, ranging in concentration from 0.4 ug/1 to 30 ug/1. The Maximum Contaminant Level (MCL) for gamma-BHC is 0.2 ug/1. Toxaphene was found in three wells in concentrations up to 10 ug/1. The MCL for toxaphene is 3 ug/1.
Results of the metal analyses are summarized in Table 3. The I secondary drinking water standard for iron (300 ug/1) was exceeded in six wells including both upgradient wells (MW-1S and MW-1D). Copper was detected in the water supply well at a concentration of 1,180 I ug/1 which is above the secondary drinking water standard of ·1000 ug/1. The MCL for lead of 50 ug/1 was exceeded in the water supply well at 51B ug/1. None of the other wells contained lead above the MCL or the CERCLA cleanup level of 15 ug/1. · I
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ACETONE
·XYLENE
1,2,4-
TRICHLOROBENZENE
BIS(2-ETHYLHEXYL)
PHTHALATE.
TRICHLOROETHENE
ND l0B
ND 4J
ND ND
ND ND
ND ND
TABLE 1
PHASE 1 GROUNDWATER ANALYTICAL RESULTS
VOLATILES AND SEMI-VOLATILES (PPB)
WELL NUMBER . ·
. • ..
4D ss.
130B ND l00B ND ND ND
ND ND ND ND ND ND
ND ND ND ND ND 4J
ND ND 7J ND ND ND
ND ND ND ND 200 ND
B -Detected in Blank at Similar Concentrations
J -Quantitative Estimate
ND-Not Detected
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. -:',
6S 6D PZ-1
ND ND ND
ND ND ND
SJ ND ND
ND ND ND
ND 11 ND
-------------------
ALPHA-BHC ND
BETA-BHC ND
DELTA-BHC ND
GAMMA-BHC ND
ALDRIN ND
DIELDRIN ND
ENDRIN KETONE ND
TOXAPHENE ND
J -QUANTITATIVE ESTIMATE
ND-NOT DETECTED
ND
ND
ND
ND
ND
ND
ND
ND
TABLE 2
PHASE 1 GROUNDWATER ANALYTICAL RESULTS
PESTICIDES (PPB)
WELL NUMBER
.
JS 4S. 4D SS
ND 3 1 1 ND 5
ND 5 0.7 3 ND 12
ND 4 0.1 6 ND 12
ND 3 0.4 0.5 ND 5
ND ND ND 0.1 ND 0. 4J
ND ND ND 0.2 ND 0. 4J
ND 0.4 ND 0.2 ND 0.BJ
ND 10 0.BJ 5 ND ND
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6S . 6D PZ,-1
36 ND ND
12 ND ND
29 ND ND
30 ND ND
ND ND ND
ND ND ND
0.6J ND ND
ND ND ND
liilil liliill - - - ----- --- -
./ :<· • .. •· ·.·• i ,··.•··•·· ····i); +:; .. . ..,
·•··•· COMPOUl,U> .· >,sw ;:-, I i 'iir:·.•· ··-.. ; ____ .,_: ··'·· ?/
ALUMINUM ND 172
ARSENIC ND ND
BARIUM 3.lB 13.3B
CADMIUM 5.4 ND
CALCIUM 531 438
CHROMIUM ND 4.8
COBALT ND 18
COPPER 1180 ND
IRON 4790J 955J
LEAD 51B ND
TABLE 3
PHASE 1 GROUNDWATER ANALYTICAL RESULTS
METALS (PPB)
. . : \i ·.· · .... ·.>,..·· . . · .. · ·--. WELL.NUMBER
,_-_:_,=,:.-·-:·-·_:::.-.:_,:; .. -.:-;: :· .. ·:• . ·.. . . .· . )i·1O••··· 2S 3S 4S · 4D 5S .··
7620 17100 8660 1040 3650 972
2. 2B ND ND ND 2.6B ND
25.8B 284 78.6 13.4B 22.lB 15.6B
ND ND ND ND 5.9 5.3
3370 37600 26500 918 4410 2650
9.5 ND 4.3 6.5 ND ND
22.7 ND ND ND ND ND
ND ND 23.9 ND ND ND
4280J 84.3J 36.7J 3290J 2180J ND
10.2 1.8B 2. lB ND 9.2 ND
B -Detected in Blank at Similar Concentrations J -Quantitative Estimate
ND-Not Detected
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6S 6D
46.3 214
ND ND
156 13.2B
7.6 ND
49800 1010
ND ND
ND ND
ND ND
ND 76.9J
1.4B ND
liiil '. iiiil .
1
: .... •.-.·\,·
_,:•··.·
PZ-1··
2570
2.0
31.0B
ND
7640
ND
25
14.9
1750J
2.0B
- - - - - - - - - - - - - - --iiiil iiiil '. liilil·
TABLE 3 (CONT'D)
PHASE 1 GROUNDWATER ANALYTICAL RESULTS
METALS (PPB)
. · .. .. .. i < . r··.•••·•·······•··· t· ·r •.·• . 1-=-_-, .. :·:== -·--_:-: .. _::·:T.'< --·WELL NUMBER COMPOUND. •• ~· • ii . >,:: 'Is·•? 1 ·· ·. •.· .
• <.WSW'• · 10 · ' 2S 3S
MAGNESIUM 246B 481B 1540 14200 3800
MANGANESE 42.2 13.3 91. 2J 104 61. 2J
MERCURY ND ND ND ND ND
POTASSIUM ND 706 875 71400 21900
SELENIUM ND ND 2.2 1. 2 1.2
SILVER ND ND ND ND 10.6B
SODIUM 2010 8150 4620J 12000 9120J
VANADIUM ND ND ND ND ND
ZINC 936 19.7 69.3 236 243
B -Detected in Blank at Similar Concentrations
J -Quantitative Estimate
ND-Not Detected
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.
4S 4D
745 1410
11. 2B 118J
ND ND
1010 ND
ND 2.5
ND ND
6030J 5070J
38 ND
11.9 37.1
5S
1610
16.0B
ND
3200
ND
ND
4270J
ND
43.8
6S 6D PZ-1
18100 620 1120
44.0J 14.7B 157J
l.0J ND ND
160000 869 881
2.4 ND 1.0
ND ND ND
12900J 2780J 13600
15.4 ND ND
579 32.4 43.9
I ..
I
I
I
I
I
I
I
I
I
I
I
I
I
Based on the results of the first phase of groundwater sampling, the investigation expanded laterally. Six monitoring wells were installed in areas downgradient of the existing monitoring well system in the shallow aquifer (MW-7S through MW-lOS, MW-12S and MW-13S). In addition, three monitoring wells were installed in the intermediate aquifer (MW-110, MW-140, and MW-150) (Figure 4). Two of the intermediate wells, MW-140 and MW-150, were installed to try to determine if the trichloroethene found in wells MW-40 and MW-60, was coming from an upgradient source. In addition, two private wells were also sampled. Monitor wells MW-7S through MW-lOS, MW-12S, MW-13S, MW-110, MW-140, and MW-150 were analyzed for TCL pesticides and volatile organics. Wells MW-10, MW-40, PZ-1, and the two private wells, Allred and PMP, were analyzed for TCL volatiles only.
The results of the TCL volatile analyses is presented in Table 4. The . compounds 2-butanone, 1,1,1-trichloroethane, 4-methyl-2-pentanone, and toluene were found in only one well, the PMP well, at concentrations below MCLs. Trichloroethene was found in the two private wells as well as monitoring wells MW-40, MW-60 and PZ-1. The two upgradient deep wells, MW-140 and MW-150, did not contain any trichloroethene.
The TCL pesticide results are shown in Table s. found in two wells, MW-lOS and MW-110.
B. Initial Removal Activity
Pesticides were
The initial site reconnaissance in January 1989 identified obvious areas of pesticide contamination in surface soils near the warehouse loading doors and railroad dock. The removal was conducted in two phases, one in February 1989 and the other in October 1989 (Figure 5).
Visually contaminated soils were sent to a landfill in South Carolina for disposal as hazardous waste. In addition, railroad ties were removed from the Area C spur track and were disposed with the soils. A total of 462 tons of waste were disposed. On March 1, 1989, a ban was issued by the Governor of South Carolina which precluded the disposal of any hazardous waste from North Carolina in South Carolina. Once the ban was lifted, the remainder of visually contaminated soils were removed. In .October 1989, 227 additional tons of contaminated soils were shipped to South Carolina.
I C. Soil Investigation
I
I
I
I
The soils investigation was conducted in four phases. Phase 1 provided a definition of potential Site-specific parameters for soils (TCL pesticides, copper, lead, zinc); Phase 2 defined the horizontal extent of contamination; Phase 3 delineated the vertical extent of
-16-
1-. I I I I
I
I
I
I
I
I
I
••
I
I
I
I
I
I
--□
I
C
~I • .~ .. ----=--...;~..._.~' ~ i :i~i #~,.!_ ! ~ @ /1 .1 •·--::;:;:=t-~:.c:-:-. i~i~t~~ • 5j,i• , ' ._,,.a,.. --' ., • -. , . . & !fr,.... = ;:· ~ ,, It I• . I I ~ I i,.
81
g,
!· ~~1
I
' ' !
I • ,-!
I ;
-
I
---

-

-
--

-
----liiii -

-

-
-liiii)··-·
TABLE 4
PHASE 2 GROUNDWATER ANALYTICAL RESULTS
VOLATILES (PPB)
METHYLENE CHLORIDE ND ND ND ND
ACETONE ND ND 4B 20B
2-BUTANONE
1,1,1-
TRICHLOROETHANE
TRICHLOROETHENE
4-METHYL-2-
PENTANONE
TOLUENE
ND
ND
160
ND
ND
ND ND
ND ND
47 ND
ND ND
ND ND
B -Detected in Blank at Similar Concentrations J -Quantitative Estimate
ND-Not Detected
ND
ND
SJ
ND
ND
-18-
....
.. . ·_ -: .. . .
1sD· · ALLRED
ND ND ND
19B 59B 9B
ND ND ND
ND ND ND
ND ND 72
ND ND ND
ND ND ND
PMP
lB
21B
15
lJ
360
2J
2J
-------------------
TABLE 5
PHASE 2 GROUNDWATER ANALYTICAL RESULTS
PESTICIDES (PPB)
·••.···.·••·················••·I•··•.6i:I•1t]~•·•··•···.···)····/·.·········
l·•··•····•···•··.<·••··•·•·••••••·•·.•••·•··•·•··••·· .. •r·.··•·••••••··•··•···<•·i
•() ....... . •.
:· . :.1...:1 .vudlJ I < 75> ·•·· <BS .
..
') .. ·.. ·····•.•. .·• ·• 9S 10S
ALPHA-BHC ND ND ND 2
BETA-BHC ND ND ND 25
DELTA-BHC ND ND ND 2
GAMMA-BHC ND ND ND O.BJ
HEPTACHLOR EPOXIDE ND ND ND 0.2J
DIELDRIN ND ND ND 2
4,4'-DDE ND ND ND 0.2J
ENDRIN KETONE ND ND ND 4
B -Detected in-'Blank at Similar Concentrations
J -Quantitative Estimate
ND-Not Detected
.
WELL NUMBER
.
llD 12S 13S.
16 ND ND
7 ND ND
4 ND ND
11 ND ND
ND ND ND
0.3 ND ND
ND ND ND
0. 4J ND ND
-19-
14D. lSD USGS-02
ND ND ND
ND ND ND
ND ND ND
ND ND ND
ND ND ND
ND ND ND
ND ND ND
ND ND ND
DOOR 5
DOOR 6
WAREHOUSE 8
LEGEND
DOOR 3 DOOR 2
WAREHOUSE A
MAIN RAILROAD TRACK
~ AREAS DESIGNATED FOR REMOVAL
DOOR 1
0 30 60
SCALE IN FEET
FIGURE 5
FEBRUARY AND OCTl)BER 1989
REMOVAL LOCATIONS
I-
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
contamination~ and Phase 4 provided additional information to complete the data set.
The Phase 1 soil sampling locations are shown on Figure 6. The volatile and semi-volatile results are given in Table 6. Acetone was found in all the samples, but was also found in the associated blank. Benzoic Acid was found in three samples ranging in concentrations from 360J ug/kg to 3600J ug/kg. The metals results are shown in Table 7. Most of the metal concentrations were within the range of the concentrations detected in the background sample (SS-04).
Pesticides were detected in all the samples. Total DDT was the most prevalent compound found. Toxaphene was found in three samples, with concentrations ranging up to 400,000 ug/kg (Table B).
For the Phase 2 soils investigation, a forty-foot grid was established over the Site as shown in Figure 7. The samples were analyzed for TCL pesticides, along with copper, lead, and zinc. Analytical results are given in Table 9. Toxaphene and DDT were the most prevalent compounds found during this phase.
In addition, two background soil samples, SS-121 and SS-122, were obtained north and east of the Site. Analytical results are given in Table 10.
For Phase 3, the analytical results were reviewed to determine which sample locations contained significant concentrations of Site specific parameters. . The term significant was defined as a soil concentration level of 10 mg/kg or greater total BHC, total DDT, or toxaphene. Sample grid locations exhibiting concentrations between 10 mg/kg and 100 mg/kg were resampled at two-foot and five-foot depth intervals. Sample grid locations with concentrations greater than 100 mg/kg were sampled at two, five, and ten-foot depth intervals.
Table 11 shows the analytical results for the sample locations that contained pesticides. Twenty samples at the two-foot depth contained pesticide constituents. Of those, only three samples contained a significant total pesticide concentration; SS-51-2 (50 mg/kg), SS-58-2 ( 32 mg/kg), and SS-100-2 ( 24 mg/kg). Pesticides were detected in 11 samples at a depth of five feet. Noteworthy is sample SS-73-5, which · contained a total pesticide concentration of 302 mg/kg. Four samples contained pesticides at the ten-foot interval. Sample SS-76-10 contained the highest total pesticide level at 6 mg/kg.
The samples were also analyzed for TCL volatile and semi-volatile compounds. Table 12 shows the results of these analyses.
-21-
- - - -------lilll --- -
iiiil .
1/ ~ ~ // // //
// // -~ // u
// /1/ -' // ✓t /'-.. _,_
~ 1 I El 1/ I I
I I ..... ' // Til"IM.Dt·U ' OHO
I TDTM. .C:. U-1 -.... I I ~--=--+-~/ ma&. m -" \ fO'IM.~-.. • nlTJri. K · •
/ I.__· • ~-u m-.•-u ............ u I ' STA.Tl taatUY %11
I \ ..: ,. '
I ,i --= ..... __ \ --~ -. ---.. '-. _.,.1 '11' ~6 -,.J'-..._ --I .. ., .... -s ,...., '\ '\ --.... .. _,, ..➔~ r, ~-=1 l
\ ' ' --~ -' ,.,
i-----' l ! ~ ,c-... -: -c::.., • ---~'\ --. . 7 ,w ,,, /-_, ,,
Bll,u,llD ~rr lH: .
~'\ . \
• ' ..... ~ 'l'PT/li. .-c:-u .,_ m11.IIT·H . nl'fM.~--
111'TM..., -" 11nM.~--
----D --..
~~ ....
'' ------'' ' ' ' ....... ,,
'' ,,
' ' • • ,, ,,
wooos ""'-'"nr< '> __ >
LEGEND
U·1g IIGTW. 1',#ltt::S.. am. ~ UXATP FI c:IIK I·: h
NII • ICJT DCTlC-l'UI ,U lHl irn:rTJDt UMfJ SOIi. SAMl'L I NG l'IIASE I llt..n.l..11 IN "'8""'e 1.0C:ATIONS ,..__,.,.
--- - - --- - ---- - -----·
ACETONE
BENZOIC ACID
TABLE 6
PHASE 1 SOIL ANALYTICAL RESULTS
VOLATILES & SEMI-VOLATILES (PPB)
. ssios
18B 30B 18B 12B
3600J ND 200J ND
B -Detected in Blank at Similar Concentrations
J -Quantitative Estimate
ND-Not Detected
-23-
16B 6B
ND 360J
ALUMINUM 7650
ARSENIC 2.0J
BARIUM 22.7
BERYLLIUM 0.09
CADMIUM ND
CALCIUM 687
CHROMIUM 6.8
COPPER 9.9B
IRON 6050
TABLE 7
PHASE 1 SOIL ANALYTICAL RESULTS
METALS (PPM)
8590 9630 3580
0.91J 2. 4J ND
9.7 21. 7 5.9
ND ND ND
ND ND 0.92
5540 1108 11200
9. 1 5.7 2.0
6.2B 8.lB 3.3B
6870 7080 2400
B -Detected in Blank at Similar Concentrations
J -Quantitative Estimate
ND-Not Detected
-24-
6950 1820
0.72J 0.84J
5.8 14.3
0.62J ND
0.87 ND
4780 4750
3.9 2.8
6.9B 8.0B
4670 2810
-----------
TABLE 7 (CONT'D)
PHASE 1 SOIL ANALYTICAL RESULTS
METALS (PPM)
:i>; is~;?••·•••····••
.. ,,, ' :;·r :c·· > .• .. i. >i ·•·•·· ·•··· ,, ' '' .•..• ··.·.,:·•:< ,,·•, •<>.'·•·· >••· .... '·.··· ,, ..... ,,, ----. ,.,.·, ··:,_:, :==··:,_=-= .,_:::.,·,, ,_~OIL SAMPLE .. · ... ·.··. " ' ···•·: 1asro·1rrr··· <··ss'...03 > ' ,·,,
' ::'·:
.. . ·,:-:
LEAD 92.4 4 . 6
MAGNESIUM 97.5B 1850
MANGANESE 33 . 9J 11 .OJ
MERCURY ND ND
POTASSIUM 243 327
SELENIUM 0.38B ND
SODIUM 24.0B 31. 6B
VANADIUM 9.7 11 .4
ZINC 46.2 25.5B
B -Detected in Blank at Similar Concentrations J -Quantitative Estimate ND-Not Detected
SS--04
', .-.. ; :: ,' ', ., ''.' •.. ,, .• ',. :-: SS-05 . • SS-06
74 . 0 13.7 9.4
208 5130 2330
13. 7J 18.5J 16. lJ
0. 18B ND ND
314 234 ND
0.94B 0. 43B ND
38.9B 28.8B 18.4B
9.6 ND 5 .9
38.3 52 . 8 78.3
-25-
--liiiiiil ijiil
' ,·
SS-09
24 .o
2000
29J
ND
221
0.56B
30. 3B
ND
70.7
--------------------
TABLE 8
PHASE 1 SOIL ANALYTICAL RESULTS
PESTICIDES (PPB)
··• •· •.---_._._.--7. ·-· . .-:-·-:>' :·,::: ,:·.: •+' 1•·•·.·•·r···.-••<r· .. _••·••·•· . . :··· . /<_ ..• __ .... 2 ---·-·-· -.. -fl < _\SOIL SAMPLE .... ·• ::: ·,:•': . •,::. • --••·~-;.rss..:0·1.)· 7+ ss::.oJ>_-·-· i.• · .. __ ;•,· -: ... ·.; •.-·-_ -... : . --·-.::: ·-·-_ss,::04 . . ·•
ALPHA-BHC ND 7500C ND
BETA-BHC ND 3300C ND
GAMMA-BHC ND 8I°0J ND
ALDRIN ND 1600C ND
DIELDRIN ND 1300J ND
4,4'-DDE 90 4200C 770J
4,4'-DDD 24 4700C 680J
4,4'-DDT 85 20000C 3500JC
TOXAPHENE 340 ND ND
B -Detected in Blank at Similar Concentrations
J -Quantitative Estimate
ND-Not Detected
-26-
. It ss,::06 SS-_05 ·.
2200C ND
2900C 4100JC
ND ND
ND 13000C
ND 9400C
2500 7900J
ll000C 30000C
25000C 49000C
120000C 400000C
~
SS-09
ND
ND
ND
ND
ND
350
390
1800
ND
- -- ----
-\
\
u-JJ u!.o u-~ ss~ ..
u!11 SS~l• • e e U-il S:S-lt s:s-O
u!a a!» • • • • H-U S:S-J,5 H-la SS-H
B
--
u-n
-
n-111 • ·-
UCEND
-
u
--
• a-,a:-.u,t,IJIQN
-
' I .,
STATE HIQIWAY :m
fCJl'I.: S1'f IXNIJOt lrflDI ~ cx»0,CTm p.-..i ~ ,.1.
-27-
U-111 ·-
-
11'.,1,Lt II IUl
--liiil ljliil
-----'-----
FIGURE 7
PHASE 2 SOIL SAMPLING LOCATION:
TABLE 9
PHASE 2 SOIL ANALYTICAL RESULTS
•··· .· •···•···\r . r. . ~ Li•i> <··•···•>>··.·.··.·;;;oix.··.·sA.MPLE.·•·•r·.•·<<·•·/. ....... '., > Lssf29 ss+:ii \ ssi.2:2 . ss'...23 /ss'.::242 •• ::_ .. -:.'::--::?:'.:.:::\:e:·_· .,•, ..... . ..
ALDRIN 5.9J ND
DIELDRIN 13J ND
4,4 '-DOE 58 110
4,4 • -DOD 69 93
4,4 '-DDT 250J 360J
TOXAPHENE 1500 1800
COPPER 16 . 9 12. 1
LEAD 207J 67.4J
ZINC 139J 169J
Pesticides results given in ppb
Metals results given in ppm
J -Quantitative Estimate
ND-Not Detected
ND ND
ND ND
130 24
62 8J
250J 32J
1300 ND
32 . 1 7.6
41 . 0 25. 4J
732 98.5J
-28-
:-:-:=_;:c,-,.:,_.:_:-· ': ···: .. · ..
·.SS-,-25 SS-'26 .sS-27
ND ND 5.9J ND
llJ ND ND ND
58 540 14J 83J
22 780 ND 48J
40J 3300 9 . 4J 130J
810 5600 ND 860
27.4 14.9 20. 5 6 3
29.8J 113J 33 . 2J 94 . 6J
37 .3J l00J 21 .SJ 69.2J
··•. ..·. / i <
. .-.,:. -·:,··:_..-_. ss:..28 SS"-29
ND ND
ND ND
110 120
40 48
130J 170J
850 920
29.8 6 . 8
35.6J 66 . 4J
18.2J 41. lJ
- - - - --- ----- ---- -liiiiill -·
TABLE 9 (CONT'D)
PHASE 2 SOIL ANALYTICAL RESULTS
BETA-BHC ND ND ND ND 28J ND ND ND ND ND
4,4'-DDE 23 160 49 280J 610J 960J 6.0J 220 190 85
4,4'-DDD 13J 87 22 74J 320J 360J 8.7J 99 69J 83
4,4'-DDT 30J 260J 59J 360J 590J 1300J 23J 170J 220J 300J
TOXAPHENE 490 1300 430 ND 3300 ND ND ND ND 920
COPPER 6.7 9.1 9.0 32.4 13.3 37.7 4.4 5.7 19.0 4.9
LEAD 13.2J· 40.0J 32.lJ 46.5 44.lJ 69.7J 120J 18.5J 27.6 82.0
ZINC 14.9 52.2 24.0 102 27.7 63.8 36.5 19.8 49.1 28.9
Pesticides results given in ppb
Metals results given in ppm
J -Quantitative Estimate
ND-Not Detected
-29-
•.• ... / . \. .. . ? ~ 0 .. ...•·• . ·.. .,.-,: ;:,:
·•··· . g~f .
····•·.. ·•••)< .... i\ 55441 ssfii2 )/
ALPHA-BHC ND ND
BETA-BHC ND ND
DIELDRIN ND ND
4,4'-DDE 180 170
4,4'-DDD. 50 55
4,4'-DDT 210J 150
TOXAPHENE 760J 740J
COPPER 9.9 25.6
LEAD 45.4 43.1
ZINC 28.0 62.9
Pesticides results given in ppb
Metals results given in ppm
J -Quantitative Estimate
ND-Not Detected
TABLE 9 (CONT'D)
PHASE 2 SOIL ANALYTICAL RESULTS
..···\ .................... /·•.•·····•>t?·•·tt•.•···•• .. ··········•·•····••··•····· •. ·
...
•.• > •···•··. . .•. \·. > :: \··•···. . ·•·.•.··•••·•••>/).T•<I • SOIL SAMPLE .... ··. . . '-<-.. . ... :>· : ".
ssl;43/ 55244/ . --.. :.----. .-·-.--. t .· .. ··.··.·• ...• •. ·•·•·•·•· ... ·•. .. . . .. -... ·,-·•.,:
. · SS~4s•• 55...:45 .•.•. ss'.'.i41 •. ss:,.49 SS'-50 ··ss.::51/
ND ND ND ND ND 330J ND ND
ND ND 4.9J 120J ND 150J ND ND
ND ND ND ND ND ND ND 390J
470 140J 140 1600J 800J lOOOJ 370J 550J
360 80J 54 1500J 660J 1900J 580J 2000J
2800J 210J 180J 5200J 1600J 4900J lOOOJ 3000J
2300 llOOJ 860 llOOOJ 8000J 15000J 5800J 18000J
3.7 16.9 18.7 ND 16. 1 4.3B 14.5 24. 1
96.0 40.4 25.0 76.2 22.7 65.5 22.7 26.4J
40.7 30.2 32.0J 42.7 17.7B 130 33.7J 45.4
-30-
- - - -----

-

-

-

-
liiil --
--iiiiil , liiill, ,
TABLE 9 (CONT'D)
PHASE 2 SOIL ANALYTICAL RESULTS
ALPHA-BHC ND ND ND ND ND 75J ND ND ND ND
BETA-BHC ND 5. 9J ND 43J ND 220J ND 60J ND ND
DELTA-BHC ND ND ND ND ND 33J ND ND ND ND
GAMMA-BHC ND ND ND ND ND 41J ND ND ND ND
DIELDRIN ND ND ND ND 1500J ND ND ND ND ND
4,4'-DDE 34 120 460J B00J 7300 4100J 1600J 670J 3000J 4000J
4,4'-DDD 32 220 430J 830J -5700J 5700J 1200J 730J 3500J 4800J
4,4'-DDT 62J 340J 740J l000J 8900J 9000JC 2300J l000J 7800JC 8200JC
TOXAPHENE 400 3600 4100J 5400J 37000J 83000J 14000J 9300J 54000J 59000J
COPPER 4.1 4.1 16.7 21. 9 11.1 18.3 10.9 20.1 17.9 21.7
LEAD 6.9J 16.2J 21.lJ 33.2J 32.3 33.7 38.0J 24.SJ 26.3J 29.9J
ZINC l.6J 46.1 8.4J 7. 7J 26.0J 16.7J 25.SJ 23. 2J 7.0J 5.4J.
Pesticides results given in ppb
Metals results given in ppm
J -Quantitative Estimate
ND-Not Detected
-31-
----------------
ALPHA-BHC ND ND
BETA-BHC ND 62J
DELTA-BHC ND ND
GAMMA-BHC ND ND
4,4'-DDE 4400J 560J
4,4'-DDD 6100J 660J
4,4'-DDT ll000JC ll00J
TOXAPHENE 130000J l0000J
COPPER 21.6 19.3
LEAD 37.0j 21.8J
ZINC 12.6J 2.lJ
Pesticides results given in ppb Metals results given in ppm
J -Quantitative Estimate
ND-Not Detected
TABLE 9 (CONT'D)
PHASE 2 SOIL ANALYTICAL RESULTS
· ssia.ii >ss.'..95
ND ND ND ND ND ND
ND ND ND ND ND 65J
ND ND ND ND ND ND
ND ND ND ND ND ND
32J 2300J 160 41 120J 390
14J 6100J 320 110 210 710
27J 19000JC 830 310 550 1900
250J 54000J 3600 510 1900 2900
5.3 7.8 15.5 6.2 6.9 9.0
10.6J 23.0J 336J 222J 125 4 7. 3J
ND 76.4J 99.3J 49.7J 35.4J 56. 6J
-32-
-iiiil . liiijiil .
.. · __ issLaar• SS-87
ND 91
ND 380
ND 69
ND 46J
250J 530
570J 1200
lS00J 2400
4300J 8800
5.8 5.6
13.3J 24.4J
lllJ 26.9J
-iii) iiiiil . .... . lliiii lliiii --

-

-

-

-

-
--

-
liiiil --
1·io·-\i, :., :·•.·/•·• ·. :; {'.}"··· // / (. .J >II.
··.·····~-. ·.
" ;;;1;11 ,-;:::: . .::::" ,=/::':;':·.:: \:=; .. : .. =.:::.:::::.: ,.,-.-::.:\\:\,.-: {$S;"90(
ALPHA-BHC 130J NO
BETA-BHC 260 750J
DELTA-BHC 54J ND
GAMMA-BHC SlJ ND
DIELDRIN ND ND
4,4 '-DOE 660 1400J
4,4 '-DOD 360 3800J
4,4 '-DDT 4300 9300JC
ALPHA-CHLORDANE ND ND
GAMMA-CHLORDANE ND ND
TOXAPHENE 8700 26000J
COPPER 5.2B 19.3
LEAD 14.9J 25.8J
ZINC 15. 6J 77. 2J
Pesticides results given in ppb
Metals results given in ppm
J -Quantitative Estimate
ND-Not Detected
TABLE 9 (CONT'D)
PHASE 2 SOIL ANALYTICAL RESULTS
·-•·· ... >•·>•· r.-_iSOIL·•··smiE•• >). >//_•\· .. · ..
•. ;} .
tss:9£• _··•?ss·::.9•Ji•·•··:• <ssl94•f·
-.'. :· . .-,-,:·:·· _-:-._,:·-··:··:·::. I . •·· . · .. · •'ss;t&,> . ss__,95\ :. SS,;-96 _SS-97.
ND 360J NO ND ND ND ND
180J lSOOJ 53J 5. lJ ND S.SJ ND
ND ND NO NO ND ND ND
ND NO ND NO NO ND ND
NO ND ND 22J ND ND ND
llOOJ 5900J 320 120J 3. 7J 65 lBOOJ
2400J 12000JC 590 160J 7 . 7J 100 3300J
3900J 38000JC 1600 460J 25 300 68000JC
ND ND ND 45J ND ND ND
ND ND ND 49J ND ND ND
35000J 78000J 3900 1500 ND 850 21000J
5.6 9.7 33.7 5.6 3.3B 6 . 9 9 .4
26 .4J 87. lJ 22. 3J 72 . SJ ll.8J 84 .3J 198J
51.SJ 43. lJ 24 .6J 43.9J 7 .6B 51.0J 121J
-33-
--- - - --·-------lliil iilll iiiil iiiil ~
TABLE 9 (CONT'D) PHASE 2 SOIL ANALYTICAL RESULTS
~ .... i) .... IY ' :t·sAMJ?LE< / : ·.·.·.· .••· \< ;··/; . · .. ;cO~oim1:1 ;; ·-:-_ .. -·.,=:,. ,::;,: _ ..... •.:=:::-/:/,,::"/{:: t-f}??/?)!/i ... ·-·-: ··< ,: .,-;: __ .. ,_ ;·:' ·: ... : : :':'>:::::<::.: ;ss4116II;: -;,_;:::,:"•,-:·-:-·-••,• wrss.;1os··
ALPHA-BHC ND ND
BETA-BHC ND ND
DELTA-BHC ND ND
GAMMA-BHC SlJ ND
HEPTACHLOR ND ND
ALDRIN ND ND
DIELDRIN ND ND
4,4'-DDE 300J 870J
4,4 '-ODD 590J 2600J
4,4 '-DDT 1300J 5700J
TOXAPHENE 7100J 18000J
COPPER 4 .1 3.5B
LEAD 32 .4J 9 .3J
ZINC 47.7J 12.0J
Pesticides results given in ppb Metals results given in ppm J -Quantitative Estimate ND-Not Detected
:·::-·,,::-:.:.-:·.:.::-:-·-:··:::.•·
.5S'"106
ND
ND
ND
ND
ND
ND
ND
920J
1800J
4900J
18000J
7.3
23 .6J
60.SJ
)• .. ·ss·~101'..•·• ·•ss;lioi iss--ii4; sssiis·
ND ND ND ND
ND 520J 62J 130J
ND ND ND ND
ND ND ND ND
ND ND ND ND
ND ND ND 60J
ND ND ND ND
130 5800J ND 180J
260 lSOOOJC 480 800J
660 41000JC 760 1600J
2100 130000J 4700 8500J
14.8 29 .6 4 .1 4.0
188J 53. 6J 5. 2J 6.6J
102J 219J 14.4J 12.9J
-34-
.. ·\.:X?§=.:-. , .. :·, ..... ... .. .... .
. ss--ii1 'ss;•tti•••··•···
ND 130J
130J 970J
ND llOJ
ND llOJ
ND 190J
44J 350J
ND 630J
230J 790J
900J 3300J
1700J 3800J
18000J 34000J
ND 5.9
3.9J 3.2J
18.SJ 82 .6J
I·.
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
TABLE 10
BACKGROUND SOIL SAMPLES
ANALYTICAL RESULTS
I •· ~b~6UND•••>•· •·.,>· ..
SOIL SAMPLE
SS""-121 ·
4,4'-DDE 75
4,4'-DDD 32
4,4'-DDT 110
TOXAPHENE 260
ALUMINUM 2660
ARSENIC ND
BARIUM 1.2B
CALCIUM 105
CHROMIUM 2.7
COPPER ND
IRON 1640
LEAD 7.6J
MAGNESIUM 83.3B
MANGANESE 12.7
NICKEL ND
SELENIUM 0.23
SODIUM 90.2
VANADIUM ND
ZINC 15.3J
Pesticides results given in ppb
Metals results given in ppm
J -Quantitative Estimate
ND-Not Detected
I SS-122
76
22
74
180
2140
0.71
8.9
907
2. 1
2.7
1380
20.0J
158
20.2
3. 4B
ND
50.3B
3.2
20. SJ
B -Detected in Blank at Similar Concentrations
-35-
l
TABLE 11
PHASE 3 SOIL ANALYTICAL RESULTS
ALPHA-BHC ND
BETA-BHC 12
DELTA-BHC ND
GAMMA-BHC ND
DIELDRIN ND
4,4'-DDE 130
4,4'-DDD ND
4,4'-DDT 180
ENDRIN KETONE ND
TOXAPHENE 1000
COPPER 5.4
LEAD . 3. 7B
ZINC 9.0
Pesticides results given in
Metals results given in ppm
J -Quantitative Estimate
ND-Not Detected
ND
ND
ND
ND
ND
58
ND
170
ND
810
7.0
8.40B
17.3
ppb
ND ll0J
510C 180J
ND 120J
ND 78J
ND 280J
2500C l000JC
1400C 1300JC
8000C 5400JC
ND ND
38000C 24000JC
17.7 14.9
27.5B 25.7
57.9 22.4
B -Detected in Blank at Similar Concentrations
C -Confirmed by GC/MS -36-
ND ND
36 ND
42 ND
ND ND
49 ND
ND ND
ND ND
ND 190
ND ND
330 460
9.4 5.7
9.0 7.9
11.7 3.4
ND 210C
67J 400C
ND 33
13J 45
ND 36
ND 74
ND ND
ND 430C
ND 280
260J 1400
2.9 4.2B
4.5 2.4
6.3B 5.9B
TABLE 11 (CONT'D)
PHASE 3 SOIL ANALYTICAL RESULTS
'•••.·· :, \ L :::-:< · -___ ,_. :, -\~---:::,,, -:' ,, ,_, ,. , -/_ . :· : :: . ·: /,,.,=: . ·-·-·· -,.:,.,_:,. ,= .. ::::---: >}/\}-= ·.· ·:·,·\:}\:!?.\}::_\-<:'::Y({i',f:-gq ,.,...., ·
SAMPLE>····•·••i(>i> >•·•·.•.·· .. ···t• · . .·· .. /, \i . ,.
. .. .:: .. , •.
. ·· ii.? }.I $iJ1t+sf·· s~J➔2Js. -'.s~~):2i ·••ss21i;4sL ..
··•· . _· _,·-.;:.:,_,':=j.TwFc
ALPHA-BHC ND ND
BETA-BHC 19 59
DELTA-BHC ND ND
GAMMA-BHC ND ND
ALDRIN ND ND
DIELDRIN ND ND
4,4'-DDE ND 32
4,4 '-DDD ND ND
4,4 '-DDT ND 56
METHOXYCHLOR ND ND
TOXAPHENE ND 200
COPPER 8.2 8.1
LEAD 2.9 3.5
ZINC 10.4 17.2
Pesticides results given in ppb
Metals results given in ppm
J -Quantitative Estimate
ND-Not Detected
12000C
2100C
1900C
lS00C
1600C
3400C
ND .
ND
ND
ND
280000C
8.5
6 . 1
16.6
B -Detected in Blank at Similar Concentrations
/ss,;16;1O(
ND ND
ND ND
ND ND
ND ND
ND ND
ND ND
100 59
270 230
2600C 3300C
180 110
3400 1900
8. 8 3.7
4 .SB 2.3B
8. 1B 3.2B
C -Confirm~d by GC/MS -37-
ss+90L2t
-;··:= :: . . :-. ·.::::· ss+i:i+2i . $S-,,90-5i
89J ND 1600C
180J 11 820C
59J ND 890C
48J ND 360C
ND ND ND
32J ND ND
ND ND 370C
ND ND 630C
ND ND 3000C
ND ND ND
310J 2200 ND
1.5 2.8 ·3. 0
2.0J 3. 50J· 2.6
10. 1 3. 1 4.2
----------------
TABLE 11 (CONT'D)
PHASE 3 SOIL ANALYTICAL RESULTS
·: :"'; -::_·,:::,: ::-: ·,:·::-:_=_: iL••••·-i-•i ~ ••.··•·•./.-••···· <t>•••·•·ii · F i\ < ;;_{}.···••·•··.•.··. ··_· SAMPLE•c::·.. '~?W'TI\••· .. ·.•·· :, ¢ .• .·•·•· ._·:-__ -.,. --, .. ,_ ._.-_=-----=-= __ .-., _·.. soiL, i.mb
I ·/ :.• / •}/ ·.=:::·:=:=.,·::, gi~;I.t.1;r f···ss~9liio.
ALPHA-BHC ND ND
BETA-BHC 31 18
DELTA-BHC 18 ND
GAMMA-BHC ND ND
HEPTACHLOR ND ND
ALDRIN ND ND
DIELDRIN ND ND
4,4'-DDE ND ND
4,4 , -DOD ND ND
4, 4 , -DDT ND ND
TOXAPHENE ND ND
COPPER 6 . 3 3.6B
LEAD 4 .8 2 .OB
ZINC 7.8 6.0
Pesticides results given in ppb Metals results given in ppm
J -Quantitative Estimate
ND-Not Detected
rssJiJ22.2r <ssi..922.s{
24 46
12 38
ND 23
11 21
ND ND
ND ND
ND ND
ND ND
ND ND
ND 53
ND 440
1. 1B 6.4
1 .2B 4 . 7
3.5B 8.7
B -Detected in Blank at Similar Concentrations
: :,_-·:::· --::.:---:-:·:,:·:,· ,_. :::·
SS-,93~2
ND
27
ND
ND
ND
ND
ND
69
44J
340
810
2.40B
5.40
6 .70
C -Confirmed by GC/MS -38-
.--:-:-:::-I ssi..100J2 ss;99;2
ND 1200C
ND ND
ND ND
ND ND
48 ND
130 ND
250 ND
27 ND
ND ND
370 7600C
ND 15000C
1.7 3.3
68. 9J 40. 1
10.5 49.7
liill iiiil.
-~ : ·•·· .·· .
$s~ipo:.£~-
11
48
ND
ND
ND
ND
ND
ND
ND
140
ND
7.6
4 . 8
21 .3
-----------------
TABLE 11 (CONT'D)
PHASE 3 SOIL ·ANALYTICAL RESULTS
1:-· ........ ·.·. ··•• t .. ·c••i.••.r r>so:ii.. swi..Ei'•t•··/ii/?\; > > )>>}•.•··· ... •, ;t
'>•·····coMPOUND I ss+i0'fF2} "ss:Ploi#!i'.}. ··•·ss:io322 •. ·. ··.·•ss---los:2· l•ss--io9:2( ;sc:ffo ... 2 . ss---110 ... 5
BETA-BHC 43J
4,4'-DDE ND
4,4'-DDD ND
4,4'-DDT 18J
TOXAPHENE 300
COPPER 1.2B
LEAD 1.5B
ZINC 5.0
Pesticides results given in
Metals results given in ppm J -Quantitative Estimate
ND-Not Detected
50 ND
ND 36J
ND ND
42 160J
220 560J
5.1 8.5
3.8 2,9B
7.1 7.2
ppb
B -Detected in Blank at Similar Concentrations
C -Confirmed by GC/MS
12 1600C ND ND
30 570C 31 27
ND ND 89 92C
230 ND 950C sooc
1400 ND 1100 1000
6.9 11. 8 11.5 7.7
1. 9B 27.6 4.2 4.7
10.5 76.2 10.2 12.8
iiiil.
•
r ------1!!!!!!!!11 1!!!11!!1 1!!!!111 l!!Bl ~ IIICI 111111:1 liliiil .iiiiiiil fial .-i iiiilll ., --1 ·
TABLE 11 (CONT'D)
PHASE 3 SOIL ANALYTICAL RESULTS
BETA-BHC ND 26 16 13J
DELTA-BHC ND ND 54 ND
4,4'-DDT 55 ND ND ND
TOXAPHENE ND ND ND ND
COPPER 16.6 2.0 9. 1 10.2
LEAD 2.2 2.3 4.8J 4.5
ZINC 11.7 4.8 12.2 11. 5
Pesticides results given in ppb
Metals results given in ppm
J -Quantitative Estimate
ND-Not Detected
B -Detected in Blank at Similar Concentrations
C -Confirmed by GC/MS
-40-
liiii lliii -- - - - - - - - ----.. iiiil liiil •. iliiiil.
METHYLENE CHLORIDE
ACETONE
BIS(2-ETHYLHEXYL)
PHTHALATE
17B
180B
59J
J -Quantitative Estimate
ND-Not Detected
TABLE 12
PHASE 3 SOIL ANALYTICAL RESULTS
VOLATILES AND SEMI-VOLATILES (PPB)
issi,fli;io•·
18B 39B 35B
29B 42B 35B
60J ND ND
B -Detected in Blank at Similar Concentrations
-41-
21B 28B
llB 41B
ND 68J
I
I
I
I
I
I
I
I
I
I
I
For the Phase 4 investigation, sampling was conducted to further
delineate the extent of contamination. During the Site investigation
conducted in 1988, soil samples were collected near an old foundation
located south of the Geigy property line. Previous use of the
foundation site and its original purpose are unknown. The results of
the study indicated isomers of BHC and toxaphene at a depth of 22
feet below ground surface.
Samples were collected near this foundation at the following depth
intervals: 0-1 foot, 5-7 feet, 10-12 feet, 15-17 feet, ·and 20-22
feet. The analytical results are presented in Table 13. The surface
sample contained the highest concentration of total pesticides. The
Phase 4 sampling locations are shown in Figure 8.
To further define the horizontal extent of contamination, additional
samples were collected. The sampling locations are shown in Figure 8
and the analytical results are given in Table 14. Sample SS-58-20S
contained the highest concentration of total pesticides at 290
mg/kg. Other samples with noteworthy total pesticide concentrations
include SS-61-20S (6 mg/kg), SS-'62-20S (9 mg/kg), SS-63-20S (73
mg/kg), and SS-91-l0N (32 mg/kg).
D. 1991 Removal
In accordance with an amendment to the Consent Order, the warehouse
superstructures, pump house, and contaminated soils were removed from
the Geigy Site during March and April of 1991. The removal limits
were 500 mg/kg toxaphene and 100 mg/kg gamma-BHC. The excavated
areas are shown on Figure 9 and the post-removal sampling results are
shown in Table 15. A total of approximately 2000 tons of soil were
removed from the Site.
I E. Sediment Investigation
I
g
I
D
I
I
The sediment investigation was conducted in three phases. The first
phase was performed to define the horizontal extent of contamination.
The next phase included .the collection of samples at one and two-foot
depth intervals as well as samples downgradient of the first phase
samples that contained significant concentrations of pesticides. The
last phase consisted of samples collected at the two, five, and ten
foot depth at locations exhibiting significant concentrations of
pesticides in surface soils.
There are no surface water bodies on-site. The nearest perennial
surface water body is Aberdeen Creek located approximately 4,000 -
5,000 feet west of the Site. The ditches convey stormwater runoff
from the highway, railroad, and the Site, and are normally dry.
-42-
liiiiiiil liiil iiii -- - - - - ---------·-:iiiil.
TABLE 13
SOIL BORING ANALYTICAL RESULTS
4,4'-DDE 21
4,4'-DDD 8. 4J
ENDOSULFAN SULFATE ND
4,4'-DDT 28
COPPER 3.9B
LEAD 21.5
ZINC 7.1
Pesticides results given in ppb
Metals results given in ppm
J -Quantitative Estimate
ND-Not Detected
ND
ND
llJ
ND
2.5B
3.2S
2.2B
B -Detected in Blank at Similar Concentrations
ND
ND
17J
ND
ND
4.2
2.BB
-43-
SB 15;.::_17' SB 20'-22'
ND ND
ND ND
22 24
ND ND
3.6B ND
2.2 2.0
1.7B ND
lliiiil liiiii iiiii --
AHfROITN AN D RDa<nsH RAIIROAO
U'IIMAJD> l"lto>ottv la,("
- --
en-1
""''" L[GfNO
1~-,a
-
€) PHAS£ Z Sl.llf -'Cl mu.. U)CA TIOfI
---
u
-
... ,,...
.,.,..
U-!ial.. PHAs:f 4 SlJkfA(f sun. LCJCAJl(J,,IS OOllllCIHt ... L Df'l 1"11 AJIONI
111-1. fORl'l£R StJRl4(1' SAW't[ lOCAn()t,fS ,._,,110 fUW Sil'll·VllAIIII~
01(14.lVLD DUIIIN(, """RCH-APRll. 1,'fl Rf"1lJV,t.l IIIUWJI
-•,: iiiiJ·
EJ
' "
..
SCA&.[ IN f(l T
FIWKE 8
!'HASE 4 SOIi. SAMl'I.INC LOCATION:;
'
liiiiil ---------------iiiiJ liiiil •riiiii) •
TABLE 14
PHASE 4 SOIL ANALYTICAL RESULTS (PPB)
ALPHA-BHC
BETA-BHC
DELTA-BHC
GAMMA-BHC
DIELDRIN
4,4'-DDE
4,4'-DDD
4,4'-DDT
TOXAPHENE
J -Quantitative Estimate
ND-Not Detected
lSOOC
2000C
840C
620C
ND
llOOOC
ND
54000C
220000c
13
27
ND
ND
ND
lOOOC
26
lOOOC
3900
B -Detected in Blank at Similar Concentrations
C -Confirmed by GC/MS
-45-
....
SS-'63'-20S
ND ND
ND 640C
ND ND
ND ND
ND ND
1400C 1300C
ND ND
2000C 6700C
5200C 64000C
SS-64-20S
ND
160
ND
ND
130
380
ND
400
ND
- --- -·-- - --.. - - ----·-·liiiiiil
TABLE 14 (CONT'D)
PHASE 4 SOIL ANALYTICAL RESULTS (PPB)
. ---... ... Pkfff:_'.'":· ·_ ... :·:_:,.:·;::; --:• ·., ,-::-::. ==:: ·-:--:-:-· <• •·•••···••0:. --:::\, . :,--=,:: -.. -.. i .-·>.···
--, ,, " ··•····••· ss!..5i;t2os •,•-:: . __ ·•··<.••·••"'-... -;., .... _ .. ...
BETA-BHC
DELTA-BHC
GAMMA-BHC
4,4'-DDE
4,4 , -DOD
4,4 , -DDT
TOXAPHENE
J -Quantitative Estimate
ND-Not Detected
290C
150
55
660C
ND
620C
ND
:·:-... -_
>••-·•---9}:'.:ioN ••·:·ss
850C
ND
ND
640C
lOOOC
14000C
15000C
B -Detected in Blank at Similar Concentrations
C -Confirmed by GC/MS
SOIL SAMPLE
------
SS-'92-'-lON
230C
ND
ND
800C
300
4600C
ND
-46-
.
ss-93.:.10N
ND
ND
ND
480
ND
1500C
3800
SS-93-20E
16
ND
ND
180
30
440
1900
------------
rsm.v. TrD PROPERTY UN[
0
0
LEGEND {
tel suRF ACE S□IL/B(]RJNG L(l(A I JflNS
Fl srn·11-1ENT SAMPLING t_i)CAI HlNS 0 [XCAVA 1 J[JN AREAS (H/\Rr:tl· f,l'ldL. \'J'Jl>
-----' iiiil
~-@ /@
SS-113 L ( -ss-120
/ -----\
( 0\...\.®
\ ss-99 •\. ._.._____
. 102 >, .'-
··· ...... , '---·::: · ·:· , ... ------\ I t1,:~ I ... '---Lss-96 -------..._ '·
ss-69~ .... -.· "-@ L!J
M
M
4•-v--so-11 •="-Ct--~-------t·l
~
t · l
Fll;UKE 9 l'J9 I KJ'.MOVAI. LOCATIONS
(l '.ltl
t-!':-.,,,l
SCAI t UJ I If I
----

-
--·iiiil ------------ -
TABLE 15
1991 POST-REMOVAL SOIL ANALYTICAL RESULTS
,.:c'-:r:.·:?i ,:;:c,:::,./.:'?;'<•:?t?'.-/:·--,::\-0' \_:: __ \_'Pi/::<·.:·.-· .:::·:_: .... :._:. .. .. .\(
CO~O~D
;::· _: ·'. ~ ;-:-:.;--/_\· .. . SOILSAMPLE . . I • =c:::,.··:··= ... _::/)/-i l>i·••x> Ii t· <\/c < .<k>· .. >•·I . ..
•• .. -.,-=-:-:·:_.
·····
. ··•·.
.D> I i <F G H I J.( -. ..
ALPHA-BHC 130 99 170 27 70 960 69 3800 64 28
BETA-BHC 45 45 ND 21 33 180 65 610 61 55
DELTA-BHC 120 250 150 52 67 230 250 540 46 110
GAMMA-BHC 54 140 ND 30 39 260 120 390 ND 20
HEPTACHLOR ND ND ND ND 18 500 43 490 ND 18
ALDRIN ND ND 480 ND 270 3300 140 1300 ND 43
ENDOSULFAN I ND ND ND ND ND ND ND ND ND 18
4,4'-DDD ND ND ND ND ND 860 ND 750 ND ND
ENDOSULFAN ND ND ND ND ND 2000 ND ND ND 44 SULFATE
4,4'-DDT 160 52 ND ND 87 ND 170 5800 77 ND
TOXAPHENE 1200 490 56000 ND 6500 110000 1800 42000 1200 2600
ND -Not Detected
-48-
--- - ----- -.. --- - - -... iiiil
TABLE 15 (CONT'D)
1991 POST-REMOVAL SOIL ANALYTICAL RESULTS
_-.: . . ··::;-=::-/_= _:·\\{://:'
! isv •·•··••·•·· .. · ... •·•·••?•··••.··· .. · / f .·•·•• i'·• . . ...., ..... ;.--: .. :-_-.: __ ::: .. ·•,-.. :··. . <-: . .· .. SOIL SAMPLE··
. COMPOUND .. > rss:::4·•a·•··••·i -:·-:; . .-·:··•--'-::·.·.-:··:: ... •-·.•·,· . . .. .··.:: . :,---it /) SS:C:64 SS-66 ··ss:.;:59 .ss.:13 55_;_75 .SS-91 SS-98 SS-99
ALPHA-BHC 46 130 ND 18 72 ND 210 21000 170 200
BETA-BHC 87 160 130 71 870 ND 420 4100 780 280
DELTA-BHC 150 ND ND 500 970 ND 410 ND 150 130
GAMMA-BHC 45 ND ND ND ND ND ND 3200 190 ND
HEPTACHLOR 28 ND ND ND ND ND ND 250 25 330
ALDRIN 78 ND ND ND ND ND 230 760 ND 4400
HEPTACHLOR ND ND ND ND ND ND ND ND 21 ND
EPOXIDE
DIELDRIN ND ND ND ND 61 ND ND ND 41 ND
4,4'-DDE ND 670 ND ND ND ND 320 1100 ND ND
4,4'-DDD ND 610 290 ND ND ND 650 770 ND 260
4,4'-DDT ND 5100 570 ND ND ND 12000 10000 230 1100
TOXAPHENE 3600 22000 16000 440 2600 7600 18000 27000 2200 6900
ND -Not Detected
-49-
- - - - - ---- ----- - - -.. ,iiiil
TABLE 15 (CONT'D)
1991 POST-REMOVAL SOIL ANALYTICAL RESULTS
· ... ···• I\/ ... , .. ,.
~-COMPOUND~ · ........ ·•• :,
SS--108
ALPHA-BHC 19
BETA-BHC 240
DELTA-BHC 48
GAMMA-BHC ND
ALDRIN ND
DIELDRIN 53
4,4'-DDE 52
4,4'-DDD 120
4,4'-DDT 330
TOXAPHENE 6400
J -Quantitative Estimate
ND-Not Detected
.. 1.-. . .. ss;..113
220
190
130
50
ND
ND
ND
ND
71
ND
·soIL SAMPLE
• . .
SD"-9 SD-12 SD-14
ND ND ND
ND 150 ND
ND ND ND
ND ND ND
ND ND ND
ND 270 ND
ND ND ND
ND ND ND
82J 860 ND
2200J 35000 5500
-50-
SD-15
ND
92
ND
ND
25
120
ND
ND
170
4000
I-
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
The first phase sediment samples were collected from the ground
surface to a maxim~m depth of one-foot. Sample OSD-28 was collected
from the surface to a depth of 1.5 feet and sample OSD-29 was
collected from the j same location at a depth of 1.5 to 3 feet. The
increased depth sampling was due to the presence of sediments
deposited at these locations. All sediment samples are shown in
Figure 10.
Analytical results are given in Table 16. The same pesticides that
were found in thej soil samples were also found in the' sediment
samples, namely, the BHC isomers, the DDT isomers and toxaphene.
Samples that conta~ed noteworthy amounts of total pesticides include
SD-1 (36 mg/kg), sq-2 (14 mg/kg), SD-3 (21 mg/kg), SD-6 (50 mg/kg),
SD-8 (17 mg/kg), SD-13 (23 mg/kg), SD-19 (19 mg/kg), SD-20 (16
mg/kg), SD-21 (17 I mg/kg), OSD-24 (72 mg/kg), OSD-27 (77 mg/kg),
OSD-28 (30 mg/kg), and OSD-29 (55 mg/kg). Toxaphene concentrations
ranged from not de:tected to 400,000 ug/kg. Also noteworthy is the
concentration of DDT in Sample OSD-24 at 44,000 ug/kg and in sample
OSD-27 at 52,000 ug1kg.
Sample results for the next phase of the sediments investigation are
presented in Table !17. These samples, taken down to a depth of 2.5
feet, still contained contaminants. Samples that contained
noteworthy amounts j of total pesticides include SD-1-1.5 ( 12 mg/kg),
SD-6-1.5 (64 mg/kg,), SD-9-2.5 (144 mg/kg), SD-11-1.5 (76 mg/kg),
SD-11-2.5 (16 mg/kg), SD-12-1.5 (71 mg/kg), SD-12-2.5 (15 mg/kg),
SD-21-1.5 (30 mg/kg), OSD-27-1.5 (29 mg/kg), OSD-27-2.5 (7 mg/kg),
OSD-28-5 (5 mg/kg), 'and OSD-43-0.5 (52 mg/kg).
In the final phase,\ two, five, and ten foot samples were collected
from four sample locations SD-10, SD-11, SD-12 and SD-14. These
sample locations ex'.hibited surface pesticide concentrations greater
than 500 mg/kg prior to the 1991 removal.
Total pesticide conlcentrations on the whole, were lower than the
shallow samples. 'sample locations 12 and 14 showed significant
amounts of contamina'tion (Table 18).
-51-
--------
WOODS
- - --
., " • ...
~ AiHO lt00!Tl»t IWI.Jto.l,o
......... 0 .......... , ...
EJ
WOODS
UCiCND
"fl' ••• -•II,_ "'lH u .. i.o <,Pft...Ut -DU
UN ~ .... llll lU ...... 1 ............. U •• AllOO
<n• PJ C!II i.f•Ull UD-~I , ............ LUJII~
-52-
----
u
---
STAil ~•·"' rn
--------------
• •.... __ ,.
FIC:UHE 10
lilill ' iii!
I \
' ....
SEDIMENT SAMPLING LOCATIONS
--------------....
ALPHA-BHC ND
BETA-BHC llOJ
DELTA-BHC ND
GAMMA-BHC ND
4,4'-DDE 1000
4,4'-DDD 2800
4,4'-DDT 3900J
TOXAPHENE 28000
J -Quanititative Estimate
ND-Not Detected
TABLE 16
PHASE 1 SEDIMENT ANALYTICAL RESULTS
(PPB)
ND ND ND
ND ND ND
ND ND ND
ND ND ND
420J 760J 63J
1200J 2300 14J
1800J 4300 54J
11000 14000 ND
-53-
SD-7
ND NO
ND 4. 4J
ND ND
ND ND
970J 7 9.
4500J 5:l
4800J 84
40000J 540
-.. , liiiJ
.. ·-
so-8 <·
ro
300J
24J
52J .
220J
ll00J
1400J
14000J
- - - - - - - - - - --- - ---lill)'iiii)
TABLE 16 (CONT'D)
PHASE 1 SEDIMENT ANALYTICAL RESULTS
(PPB)
... · .. ··.• · .. \ t.••/··t>• < > . . • /9?~g~p.· I··
l,i .• ) .. ·•· 0i \ .....•...•...... ·· .·· ... SOIL SAMPLE
. ·,. sn:.lj >I> sD-1a .·· ·•·
ALPHA-BHC ND
BETA-BHC 94J
4,4'-DDE ll00J
4,4'-DDD 1400J
4,4'-DDT 2400J
TOXAPHENE 18000J
J -Quantitative Estimate
ND-Not Detected
ND
ND
410
290
440
2200
SD-19· sD.,.20 SD-21
46J ND ND
130J 43J ND
3200J 2400J 570J
1500J 980J 1600
2700J 2400J 2300
11000 9700 13000
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· . OSD-21 0SD-22
ND ND
ND ND
llJ 1500J
9.2J 1900
33 4400
ND ND
----------- -------·-
PHASE 1
TABLE 16 (CONT'D)
SEDIMENT ANALYTICAL RESULTS
(PPB)
·.· ··.··• •.•.···· .i >·· > •···· [·{/ i\• .. >· t ·•.······
..
.. ·. COMPOUND
. SOIL· SAMPLE
· .. OSD-23 ·.
DIELDRIN ND
4,4'-DDE 29
4,4'-DDD 13J
4,4'-DDT 73
TOXAPHENE 200
J -Quantitative Estimate
ND-Not Detected
OSD-24
ND
6600J
21000
44000
ND
. . .
OSD-25 OSD-26 ' OSD-27
ND 12J ND
900J 77 ND
1400J 28 25000
3700 BO 52000
ND 280 ND
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.
.
OSD-28· 0SD-29 1.5-3'
ND ND
890J 1700J
2600 4600
5300 13000
21000 36000
- - - - - - - - - -----------
TABLE 17
PHASE 2 SEDIMENT ANALYTICAL RESULTS
(PPB)
. ): :•""
:r::::l
•· > :,:·• ... ·.•i•••:•:•·· .. ·.·.• ···•· ·• ... ,)• .::,.: )••·: ::,·,.:: ::: . . ..... :· .· . SOIL SAMPLE
COMPOUND .·.·::·so:_:t~•:1: s····· iis6c1..:2 :si · sD.::.3.::.1. s : -':_:·., .. _:.r: -SD-3-2.5 SD-6-1.5
ALPHA-BHC ND ND ND ND 540C
BETA-BHC ND ND 15 ND 580C
GAMMA-BHC ND ND ND ND 510
4,4'-DDE 340 100 ND 34 ND
4,4 , -ODD 410 ND ND ND ND
4,4'-DDT 3700C 1400C 61 130 4200C
TOXAPHENE 0000c ND 540 920 58000c
ND -Not Detected
C -Confirmed by GC/MS
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.
. ·.
SD,.;0..:1. s SD-8-2.5
ND 1fil_
ND 21
-ND ND
ND ND
ND ND -
190 68
2800 1200
- - - - - --- - ---------·-
ALPHA-BHC ND
BETA-BHC ND
DELTA-BHC ND
HEPTACHLOR 470C
DIELDRIN ND
4,4'-DDE ND
4,4'-DDD ND
4,4'-DDT 14000C
TOXAPHENE 130000C
ND -Not Detected
C -Confirmed by GC/MS
TABLE 17 (CONT'D)
PHASE 2 SEDIMENT ANALYTICAL RESULTS
(PPB)
SOIL SAMPLE
· ..
SD-ll',-.2.5 . SD-12-1.5 SD-12-2.5
ND ND 260C ND ND ND
ND ND 730C ND ND ND
ND ND 150 ND ND ND
ND ND ND ND ND ND
ND ND 1600C 180 ND ND
ND ND 270 ND ND ND
ND ND 970C ND ll00C 250
ND ND 4400C 370 l000C ND
4600 1300 68000C 15000C 69000C 15000C
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-liiiiil iiiii liiil - - - - --- -.. -...... -· ..
TABLE 17 (CONT'D)
PHASE 2 SEDIMENT ANALYTICAL RESULTS
(PPB)
. i/·•·.
1 ·•••·t•·•·•···.•••+·•••······•·•>·•·•·•••J•··•••·r r··•<···•··•·•·•·····•
1
••··•·•·.•·•·•···•····•·•••·· ·.•.• .. ··•·•··••·•·••· ·. •··•••
··•• .. ·,:·-·.::. SOIL.SAMPLE
COMPOUND ·soitj:::t:s so~Ii-fjs
.•. .
:_.•:-·_ -·:·. . .. so'..:21-1. s SD-21-2.5 SD-41~0.5
4,4'-DDE ND 40 ND ND 170
4,4'-DDD ND ND ND ND ND
4,4'-DDT ND 23 4000C 470 180
TOXAPHENE 180 ND 26000C 4000 2300
ND -Not Detected
C -Confirmed by GC/MS
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..
.
OSD-24-1.5 OSD-24-2.5
ND ND
ND ND
460C ND
2700 790 -
------
ALPHA-BHC ND
BETA-BHC ND
HEPTACHLOR ND
DIELDRIN 320
4,4'-DDE 100
ENDRIN 140J
4,4'-DDD 230J
4,4'-DDT 3·1ooc
TOXAPHENE 25000C
ND -Not Detected
C -Confirmed by GC/MS
----
-.. .. .. -liiiil
ND
ND
ND
110
ND
ND
ND
ll00C
6200C
TABLE 17 (CONT'D)
PHASE 2 SEDIMENT ANALYTICAL RESULTS
(PPB)
ND 12 ND
ND 26 ND
ND ND ND
ND ND ND
ND so 45
ND ND ND
41 97 ND
180 560C 140
920 4200 1100
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OSD-42-
0.5
ND ND
ND ND
ND ND
ND ND
ND 150
ND ND
ND ND
ND saoc
1200 1300
. . . .; : .. -.. ·.·
OSD-43,,-
0.5
ND
540JC
ND
ND
390J
ND
ND
7200JC
44000JC
liiiiiil -

-

-

-

-

-

-

-

-

-

-
--

-
-.i -.i liill'lliil
COMPOUND··/ /fg~ig~ \jg~tgR -
.·-:., ' ·: :·::??/·')':':?":":\\~:?:•·,-.
ALPHA-BHC ND ND
BETA-BHC ND ND
DELTA-BHC ND ND
GAMMA-BHC ND ND
HEPTACHLOR ND ND
EPOXIDE
DIELDRIN ND ND
4,4 • -DDT 35 ND
ENDRIN ND ND
KETONE
TOXAPHENE 600 200
J -Quantitative Estimate
ND-Not Detected
C -Confirmed by GC/MS
TABLE 18
PHASE 3 SEDIMENT ANALYTICAL RESULTS
(PPB)
SOI-L-SAMPLE .
>sbL1iL ·. -··< . .
SD-11-, SD-12-,-SD-12-SD-,14-
1·:<< . ···-.·· '2 5 2 5 2
ND ND 190J ND ND
41 ND 160J 43 10
ND ND 60J ND ND
ND ND 53J ND ND
ND ND ND ND 15
100 32J ND ND 65
ND ND ND ND ND
ND ND ND ND 29
1900 3200J 6900JC ND 5200C
-60-
SD-14-SD-14-
. 5 10 .
ND ND
ND ND
ND ND
ND ND
16J ND
ND 72J
ND 240J
ND ND
8500JC 7900JC
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VI. SODARY OF SIT RISKS
The Geigy Site is ~eleasing contaminants into the environment. The Baseline Risk Assessment Report presents the results of a comprehensive risk ~ssessment that addresses the potential threats to public health and the environment posed by the Site under current and future conditions a'ssuming that no remedial actions take place and that no restrictions are placed on future use of the Site.
The Baseline Risk A~sessment report consists of the following sections: identification of chemicals of potential concern; toxicity assessment; human e~posure assessment, risk characterization; and environmental assessment. All sections are summarized below.
A. Contaminantl of Concern
Data collected duriJg the RI were reviewed and evaluated to determine the contaminants of \concern at the Site which are most likely to pose risks to public hea]th. These contaminants were chosen for each environmental media \sampled.
Once these contaminants of concern were identified, exposure concentrations in ea'ch media were estimated. The maximum concentrations detec1ted were compared to the calculated 95% confidence level of ~he arithmetic average of all samples, and the lower of these values was chosen as the estimated exposure concentration. Table 19 identifies the contaminants of concern and the reasonable maximum exposure (RME) concentration in each media sampled which was analyzed in the risk assessment.
\ B. Exposure Assessment
The exposure assessmlnt identified potential pathways and routes for contaminants of concern. Two overall exposure conditions were evaluated. The first was the current land use condition, which considers the site as it currently exists. The second was the future land use condition, which evaluates potential risks that may be associated with any probable change in site use assuming no remedial action occurs.
The exposure pathways that were evaluated under current land use conditions were:
* Incidental ihgestion of chemicals in on-site and off-site surface soil1/sediment by an older child trespasser (8-13 years),
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TABLE 19 \ CONTAMINANTS OF
FOR
CONCERN AND EXPOSURE CONCENTRATIONS ALL ENVIRONMENTAL MEDIA
!!D'OSURZ POIN'f coNCZNT'RATIONS Jl'OR OFP-SI'n S(JRfACZ SOILISZDIXJ!N'f
I
B!TA-BHC
4,4•-ooo
s40 l s40
4,4•-00E
4,4'-DDT
OIEt.DRIM
TOXAP""""
2s,Ooo I 2!,000
6,600
s2, o'oo
121
1
1!10,0oo
I I
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6,600
52,000
12
190.000
%%PO~ POINT CONC"ENTRATIONS POR ON-SITE SURFACZ SOIL/SEDIMENT
ALDRm • '5
ALP!!A-RHC 130
BH.A-BHC 270
120
BENZOIC ACID 3,700
ALPRA-cm.oRDANE .,
GAMMA-cm.aP.O.ANE .,
4,4'-000 J,700
4,4'-00!: 2,000
4,4'-0DT 9,000
OIELDRIH 250
37,000
J!XPOSUR.E POINT CONCENTRATIONS POR GROUNDWATER I
' ALDRIN
ALPHA-BHC
BETA-BBC
DEL'l'A-BHC
BISl2-l!THYLIIEXYL)P!ITJIALATE
DIEioRIN
4,4~-DOE
BNDRINl l<ETONE
HEPTACBLOR EPOXIDE
roXAPHEw
TRICBLOROETRENE
1,2,4-TRICu:i:.oROBENZENE
\
2.0E-01
3.6E+Ol
2.SE+Ol
2 .9E+0l
3.0+01
6.4E+OO
1.2E+OO
1. OE-01
3.7E+OO
3.0E-01
5.9E+OO
1.8E+02
5.0E+OO
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MAXIXDM , oETEcTr · -9-CONCENTRATION ?,·,,,;;:_,:i:,-;cuG/L} \:•.
4.0E-01
3.6E+Ol
2.SE+0l
2. 9E+Ol
J.0E+0l
7.0E+OO
2.0E+OO
2,0E-01
4.0E+OO
J.OE-01
9.6E+OO
1.8E+02
5.0E+OO
''' 1. 500
2,000
840
J,600
45 .,
15,000
U,000
54,000
1,500
220,000
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R
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*
*
*
*
*
*
Dermal absJrption of chemicals in on-site and off-site surface so~l/sediment by an older child trespasser (B-13
years),. \
Inhalation pf volatilized surface soil/sediment chemicals by an older child trespasser (8-13 years), I Inhalation pf volatilized surface soil/sediment chemicals by a merchant north of the site I I
Inhalation 9f volatilized surface soil sediment chemicals by a n7arby chfld resident (1-6 years) and a nearby adult resident northeast of the site,
Inhalation bf chemicals in wind blown dust particles by a nearby child resident (1-6 years) and a nearby adult resident northeast of the site.
Inhalation lf chemicals in wind blown dust particles by a nearby merchant north of the site.
I The exposure pathways that were evaluated under future land use conditions were:
*
*
*
*
*
*
Incidental ingestion of on-site surface soils/sediment by future on-sjJte adult and child (1-6 years) residents and by a future on-1site merchant,
Dermal absor~tion o~ chemicals absorbed to surface soils/sediments by future on-site adult and child (1-6 years) residents and by a future on-site merchant,
Ingestion of\groundwater by future on-site adult and child (1-6 years) residents and by a future on-site merchant, I Inhalation of volatile organic chemicals while showering with groundwater by a future on-site adult and child (1-6 years) residents,
Dermal absoJtion of chemicals while showering with groundwater by future on-site adult and child (1-6 years) residents, and
I Inhalation of volatilized surface soil/sediment chemicals by future on-site adult and child (1-6 years) residents, and by future on-site merchants.
For ingestion of soil,\ an exposure frequency of 170 days/yr for~ 1 residents and 120 days/yr for merchants was assumed. (A merchan (7 assumed to work 5 daysl/wk, 50 wks/yr (2 weeks subtracted for
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vacation), minus j\ days for federal holidays and is to spend half of that time outside. Values for adult and child residents are based on 5 days/wk ~uring t?e warmer months, April through October, and 1 day/wk during November through March). The exposure duration used was 6 years for a child, 30 years for an adult, and 25 years for a merchant. I
For ingestion of g~oundwater, an exposure frequency of 350 days/yr for residents and ~41 days/yr for merchants was assumed. An ingestion rate of one liter per day was used for a child resident and an adult merchant.\ An ingestion rate of two liters per day was used for an adult resident.
c. Toxicity Ajsessment
Under current EPA J.iidelines, the likelihood of adverse effects to occur in humans from carcinogens and noncarcinogens are considered separately. These are discussed below. Table 20 summarizes the
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:::::::.::iteria fir the cont~i~nt, of concern.
EPA uses a weight of evidence system to classify a chemical's potential to cause dancer in humans. All evaluated chemicals fall into one of the following categories: Class A -Known human carcinogen; Class B \-probable human carcinogen, Bl means there is limited human epidemiological evidence and B2 means there is sufficient evidence lin animals and inadequate or no evidence in humans; Class C -Po1ssible human carcinogen; Class D -Not classifiable as to human carcinogenicity; and Class E -Evidence of noncarcinogenicity for humans.
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Cancer slope factors\have been developed by EPA for estimating excess lifetime cancer risks associated with exposure to potentially carcinogenic chemicais. Slope factors, which are expressed in units of (kg-day/mg), are multiplied by the estimated intake of a potential carcinogen, in mg/kg1day, to provide an upper-bound estimate of the excess lifetime cancer risk associated with exposure at that intake level. The term "upperbound" reflects the conservative estimate of the risks calculated \from the slope factor. Use of this approach I makes underestimation of the actual cancer risk highly unlikely. Cancer potency factor's are derived from the results of human epidemiological studi'es or chronic animal bioassays to which animal-to-human extrapolation and uncertainty factors have been I applied. \
Noncarcinogens \ I Reference doses (RfDs) have been developed by EPA for indicating the potential for adverse health effects from exposure to chemicals I
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I TABLE 20 I TOXICITY CRITERIA FOR CONTAMINANTS OF CONCERN
CHEMICAL
Aldrin
Alpha-BHC
Beta-BHC
Delta-BHC
Garoma-BHC
Benzoic Acid
Bis(2-ethylhexyl)
phthalate
Alpha-Chlordane
Gamma-Clordane
4,4'-DDD
4,4'-DDE
4,4'-DDT
Dieldrin
4-Methyl-,2-
pentanone
Toxaphene
1,2,4-Trichloro-
benzene
UNITS
\
\
CARCINOGENIC
CLASSIFICATION
\ B2 B2
C
D
B2/C
B2
B2
B2
B2
B2
B2
B2
B2
D
RfD -mg/kg-day
SF (mg/kg-day)-!
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ORAL SF
1. 7E+Ol
6.JE+OO
l.8E+OO
l.JE+OO
l.4E-02
l.JE+OO
l.3E+OO
2.4E-01
3.4E-01
3.4E-01
l.6E+Ol
l.lE+OO
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INHALATION SF
1. 7E+Ol
6.JE+OO
l.8E+OO
l.JE+OO
1. JE+OO
3.4E-01
l.6E+Ol
l.lE+OO
TAR
ORG
LIV
LIV
LIV
LIV
LIV
LIV
LIV
LIV
LIV
LIV
LIV
LIV
liiiiil iiiiil
CHEMICAL
Aldrin
Alpha-BHC
Beta-BHC
Delta-BHC
liiii iiiiil ---------TABLE 20 TOXICITY CRITERIA FOR CONTAMINANTS OF CONCERN
CARCINOGENIC
CLASSIFICATION ORAL SF INHALATION SF
B2 1. 7E+0l 1. 7E+0l B2 6.3E+00 6.3E+00 C l.BE+00 l.BE+00 D
- -
TARGET ORAL ORGAN RfD
LIVER 3E-05 LIVER
LIVER
Gamma-BHC B2/C l.3E+00 ~~LIVER----3E--04-Benzoic Acid
4E+00 Bis.(.2-ethyl·hexyl·J----132 ____ l.4E-02 LIVER 2E-02 phthalate
Alpha-Chlordane B2 l.3E+00 l.3E+00 LIVER 6E-05 Gamma-Clordane B2 l.3E+00 1.3E+00 LIVER 6E-05 4,4'-DDD B2 2.4E-01 LIVER 4,4'-DDE B2 3.4E-01 LIVER 4,4'-DDT B2 3.4E-0l 3.4E-01 LIVER SE-04 Dieldrin B2 1. 6E+0l l.6E+0l LIVER SE-05 4-Methyl-2-
SE-04-pentanone
Toxaphene B2 l.lE+00 l.lE+00 LIVER 1,2,4-Trichloro-D lE-03 benzene
UNITS
RfD -mg/kg-day
SF -(mg/kg-dayJ-1
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exhibiting noncarcilnogenic effects. RfDs, which are expressed in units of mg/kg-day,I are estimates of lifetime daily exposure levels for humans, including sensitive individuals. Estimated intakes of chemicals from envilronmental media can be compared to the RfD. RfDs are derived from hupian epidemiological studies or animal studies to which uncertainty factors have been applied. These uncertainty factors help ensure\ that the RfDs will not underestimate the potential for adverse noncarcinogenic effects to occur. l D. Risk Characterization
To quantitatively a~sess the risks from the Geigy Site, the chronic daily intakes (CDI)lwere combined with the health effects criteria. For potential carci~ogens, excess lifetime upperbound cancer risks were obtained by multiplying the estimated CDI for each chemical by its cancer slope factor. The total upperbound excess lifetime cancer risk for each pathwhy was obtained by summing tge chemical-specific risk estimates. A 9ancer risk level of 1 x 10-represents an upper bound probability of one in one million that an individual could develop cancer due to exposure to the potential carcinogen under the specifiedlexposure conditions. Significant contributors to the exceedance of the cancer risk levels were toxaphene, dieldrin, and DDT.
Potential risks for noncarcinogens are presented as the ratio of the CDI to the reference dose for each chemical. The sum of the ratios of all chemicals under consideration is called the hazard index. The hazard index is useful as a reference point for gauging the potential effects of environmental exposures to complex mixtures. In general, a hazard index valu~ greater than 1.0 indicates that the potential exists for adverse health effects to occur from the assumed exposure pathways and durations, and that remedial action may be warranted for the site. Significant contributors to the exceedance of 1.0 for the HI were barium, manganese, mercury, vanadium, and zinc.
Tables 21 and 22 swknarize the quantitative estimates of risk under the current and future land use scenario for each target population respectively.
Currently, the site is vacant, and a current consumer of contaminated ground water from the site has not been identified. The total cancer risks for current land use ranged from lE-06 to 9E-08. For future land use, it was assumed that the site would be used for residential purposes. The totai cancer risks were in the lE-03 range. For non-cancer risk, th~ baseline of 1 for the HI was exceeded for ingestion of surficlal groundwater.
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TOTAL RISKSIASSOCIATED
TABLE 21
WITH CURRENT LAND-USE CONDITIONS
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Area/Pathway
I Ingestion of Surface so;L/Sediment I Dermal Absorption from Surface
Soil/Sediment I
Inhalation of Volatile Chemicals Released from Surface sOil/Sediment
I Inhalation of Oust Particulates
I '
Total Cancer Risk I
Area/Pat~ay
I Ingestion of Surface Soil/Sediment
. I Dermal Absorpt1on from Surface Soil/Sediment I
Jnhalatlon of Volatile Chemicals Released from Surface Soil/Sediment . I Inhalation of Dust Particulates
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Cancer Risk Due to All Chemicals ----------------------------------------------------------------------On-Site
Older Child Off-Site Off ·Site Off-Site Tres~asser Older Child Adult Adult (8-1 yrs) (8-13 yrs) Merchant Resident
7.0E-07 7.0E-06
4.0E-07 2.0E-06
2.0E-08 6.0E·07 9.0E-08
6.0E-10 1.0E-10
1E-06 9E-06 6E·07 9E·08
Noncancer Risk Due to All Chemicals
On-Site
Older Child Off·Site Trespasser Older Child (8·13 yrs) (8-13 yrs)
4.0E-03
3 .OE-02
(a)
(a)
4.0E·02
1.0E-02
(a)
(a)
Off-Site
Adult
Merchant
(a)
(a)
Off-Site
Adult
Resident
(al
<al
Off-Site
Young Child
Resident
(1-6 yrs)
1.0E·07
8.00E-11
1E-07
Off-site
Young Child
Resident
(1·6 yrs)
(a)
Ca)
(a) No inhalation toxicitylcriteria were available to assess noncarcinogenic
= Not evaluated. ! risks.
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D
TABLE 22 TOTAL RISKS ASSOCIATED WITH FUTURE LAND-USE CONDITIONS
Cancer Risk
Due to All Chemicals ----------. ------.. ---. ------. ------.. ---
Area/Pathway
I
Surface Soill/Sediment: Ingestion of Surface Soil/
Sediment \
Dermal Absorption from Surface S0il/Sediment
Inhalatio~ of Chemicals Released from SurfDce Soil/Sediment I Groundwater:
Jngestionlof Surficial groundwater
Inhalatio~ of Volatiles
whi ll! ShoWering
Oermal Abs\orption of Chemicals while Showering
Total Cance~\Risk
Area/Pathway
I Surface Soil/Sediment: Ingestion of Surface Soil/
Sediment \
Dermal Absorption from Surface Soil/Sediment
Inhalation lt Chemicals Released from Surface Soil/Sediment
Grouidwater: I
Child Adult Resident Resident
3E·05 1E·05
4E·06 1E·06
1E·06 9E•07
2E·03 4E·03
3E·08 4E-08
· 2E·06 6E·06
2E·03 4E·03
Noncancer Risk Due to All Chemicals
Child Adult Resident Resident
2E·01 2E·02
2E·02 1E·03
···Ca) ···(a)
>1 >1 groi.ndwater liver=8.9 liver=4.1
Merchant
4E·06
6E•07
6E•07
1E·03
1E·03
Merchant
6E·03
9E·03
···(a)
>1
liver:::i:1.2
Ingestion ofl Surficial
kidney = 6.5 kidney= 3.2 (kidney = 1 .0) I Inhalation of Volatiles 7E·05 1E·OS while Sh"""ring
Oermal Absorition of while Showering Chemicals 1E·02 5E·03
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I (a) No inhalation toxicity cr;teria were ava;lable to assess noncarcino9enic risks.
= This path1way was not evaluated.
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E, Jaty_ironmental (Ecological) Risk
I 'l'he vegetative co~ti'nity at the: :~:it~-is dominated by native grasses,
which were planted following a previous removal. action. Other
I herbaceous species which occur infrequently and along the perimeter
of the site include poison ivy, cinquefoil, honeysuckle,
passionflower, great ragweed, and goldenrod. A stand of brunboo
occurs in the northeast corner of the site and a small number of pine
I trees occur in the eastern and western portions of the site,
Terrestrial plants may be exposed to chemicals of concern in soil aa
a result of direct contact with subsequent plant uptake via the
I roots. No data are available on the toxicity of the chlorinated
insecticides of concern on natural vegetation, The data that are
available suggest that phytotoxic effects are likely to occur only at
very high soil concentrations,
I The site is not expected to support extensive wildlife populations,
given its small size, the limited diversity of the vegetative
I community, and the availability of higher quality habitat i.n adjacent
areas. Resident vertebrate speciE,S of the site are likely limited to
small mammals such as voles and other field mice, Some snakes and
I lizards also could occur at the site. Other wildlife species could
occasionally use the site while foraging.
Terrestrial wildlife exposures via the ingestion of food that has
I accumulated pesticidee from the site t.1re not likely to be
significant. None of the chemicals of potential concern accumulate
extensively in vegetation and therefore, significant exposure in the
I herbivorous species that may inhabit the site is unlikely. Some
accurnula-Lion in soil invertebrates is possible and therefore animals
t;hat feed on these organisms could be exposed to chemicals in the
food. 'l'he degree to which chemicals in soils at the site could be I bioc,_ccumulated is unknown.
Red-cockaded woodpeckers (a State and federal listed endangered
I species) which live in colonies located within one mile of the site
are unlikely to be affected by chemicals in soil at the site. 'l'hese
woodpeckers feed on insects in trees, and generally do not feed below
1 the understory layer,
P. Soj_l Remediation
I Table 22 Hhows the estimated upperbound total carcinogenic risk posed
by soil contaninants unde1.-a future residential exposure scenario.
The calculated risk level of 3 x 10-J is based on soils m contamint.1ted at the level of the site-wide average being ingested by
a child, ( '.i'he site-wide soil data was used to develop a reasonable
maximum exposure (R11E) which is the 95% upper confidence limit of the I samples arithematic average), ·
The future residential riok could have been calculated based on an II assumption that a residence was placed at the site of the highes·~ II cor.taminant concentraton detected (sample SS-06) in the sampling
program. The assumption in this case would bE: that a chi.ld was D consto.ntly exposed to this higher value, This assumption gives an
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estimated ':1.PPBEl::>ou.crid ,risk of ( 4. 4. x 10-~).·: _:. .:...:.,__, ,. ·····-· --··---..::·,:--·----··---·-·----
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Soil Cleanup levels have been calculated at the 10-6 risk level based on direct exposure residential assumptions. The health-based soil cleanup levels are identified in Table 23. Table 23 also indicates t;he maximum concentration of each contaminant found at the site.
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TABLE 23
SOIL REMEDIATION LEVELS
ALDRIN 14
ALPHA-BHC 21
BETA-BHC 4.1
DELTA-BHC 1. 9
GAMMA-BHC 3.2
DIELDRIN 9.7
ENDRIN KETONE 0.28
TOXAPHENE 450
DDD 28
DDE 11
DDT 54
GAMMA-CHLORDANE 0.049
ALPHA-CHLORDANE 0.045
NC -Not Calculated
-71-
0.113
0.28
1.15
NC
1.5
0.13
NC
2.0
7.6
5.5
4.75
1.43
1.4
I VII. APPLICABLE OR RELEVANT AHO APPROPRIATE REQUIREMENTS (ARARs)
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section 12l(d) of CERCLA, as amended by 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 to the ( 1) potential remedial actions, ( 2) location, and ( 3) media-specific chemicals at the Site.
This Section examines the cleanup criteria associated with the contaminants found and the environmental media contaminated.
A. Action-Specific ARARs
Action-specific requirements set controls or restrictions on the design, performance, and other aspects of implementation of specific remedial activities. Because action-specific ARARs apply to discrete remedial activities, their evaluation will be discussed in greater detail in Section VIII. A retained alternative must conform to all ARARs unless a statutory waiver is involved.
B. 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 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 --2-r. 2 ~.
Federal classification guidelines for groundwater are as follows:
* Class I: Groundwater that is irreplaceable with no alternative I source or is ecologically vital;
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* Class II: A -Groundwater currently used for drinking water; B -Groundwater potentially available for drinking water;
* Class III: 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 IIB and the second uppermost aquifer is considered Class IIA. 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.
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'71? ""''D'P!" CC.1T'"'1
Wctwi 11 --QXI ra.J 0, 1 ta..a~ .. ....__...-
WV., 100-,.W ll:alal:m
W~N! arw,11 --,ccn ~
CDUI ffWgMal:lll l\3tm. loU. a,
~ 01 sqldarll v:itms
C."llllQll'la.OIIZlll:lln-"G'l
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ltft-~«:"IS~
TABLE 24 POTENTIAL LOCATION-SPECIFIC ARARs
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hml:lni::::ll.1111~~<UIL ·---"'--~ices~ ~a:,g,,-oeu..enaciin:s ......
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(II USC &II« wo_); ::0
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c. Chemical-Specific ARARs
Chemical-specific ARARs are concentration limits in the environment promulgated by government agencies. Health-based site-specific levels must be developed 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.
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 (MCLs), North Carolina Drinking Water standards, and North Carolina Groundwater Standards.
Maximum Contaminant Levels (MCLsl
The National Oil and Hazardous Substances Pollution contingency Plan (NCP) states that 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 (40 CFR S300.430 (e)(2)(i)(A)). The groundwater in the uppermost aquifer is a potential source of drinking water and the groundwater in the second uppermost aquifer is a current source of drinking water, therefore, MCLs will be considered the primary remediation goal. MCLs and proposed MCLs are provided in Table 24. 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 are~epentially identical to the SOWA MCLs established by the EPA (Table~. North Carolina Groundwater Standards (North Carolina Administrative Code (NCAC) Title lSA, Chapter 2, Subchapter 2L) are for Class GA groun~~ter, best usage as a source of drinking water. As seen in Tablesk, the North Carolina Groundwater Standards for gamma-BHC and toxaphene are below the CERCLA Contract Required Quantitation Limit (CRQL). The CRQL is the chemical-specific level that a laboratory must be able to routinely and reliably detect and quantitate in a specified sample. In such cases, the North Carolina Groundwater Standard defers to the quantitation limit as the maximum allowable concentration (15 NCAC 2L Section .0202(b)). In addition to the listed standards, section .0202(c) specifies that substances which are not naturally occurring and for which no standard is specified shall not be permitted in detectable concentrations. Therefore, since pesticides are considered man-made and not naturally occurring, the North Carolina Groundwater Standard is the quantitation limit.
Groundwater remediation levels are provided in Table-2-5":.Z.C,
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ALDRIN
ALPHA-BHC
BETA-BHC
DELTA-BHC
GAMMA-BHC
DIELDRIN
ENDRIN KETONE
TOXAPHENE
TRICHLOROETHENE
0.1
36
25
29
30
2
4
10
200
TABLE 25
GROUNDWATER ARARs
NA NA
NA NA
NA NA
NA NA
0.2 0.2
NA NA
NA NA
3 3
5 5
Concentrations are given in ug/1
NA
NA
NA
NA
0.0265
NA
NA
0.031
2.8
I SDWA MCL -Safe Drinking Water Act Maximum Contaminant Level
North Carolina DWS -NC Drinking Water Standards
North Carolina GWQS -NC Groundwater Quality Standards I CRQL -Contract Required Quanititation Limit
i ··,Ee •• ' •••• ,:, ,,.-:,.-,-, :,_,_,_,_,
}: :·:··,:··•·, .. , ....
••••
•.
.. .·
0.05
0.05
0.05
0.05
0.05
0.1
0.1
1.0
1.0
MCL for Gamma-BHC currently is 4 ug/1, New MCL (0.2) effective July 30, 1992 .
m NA -Not Available
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TABLE 26
GROUNDWATER REMEDIATION LEVELS
ALDRIN 0.1
ALPHA-BHC 36
BETA-BHC 25
DELTA-BHC 29
GAMMA-BHC 30
DIELDRIN 2
ENDRIN KETONE 4
TOXAPHENE 10
TRICHLOROETHENE 200
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0.05
0.05
0.05
0.05
0.05
0.1
0.1
1.0
2.8
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Soils
There are no promulgated Federal or State standards applicable for
contaminants in soils at the Site.
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VIII. DESCRIPTION OP ALTERNATIVES
Tables 27 and 28 summarize the technologies considered for
remedi~ting_the groundwater and soil co~tamination, respectively, at
the ~igy Site. ~hese tables also_provide the rationale as to why
certain technologies were not retained for further consideration
after the initial screening.
A. Remedial Alternatives to Address Groundwater Contamination
The following alternatives were developed to address groundwater
contamination at the site:
Alternative lA: No Action
Alternative lB: Long-term Monitoring of Site Groundwater
Alternative 2: Slurry Wall and Cap
Alternative 3: Groundwater Pump and Treat to Attain
Remediation Levels
The remedial response actions to address groundwater contamination
are discussed below.
Alternative lA: No Action
No ac~ivities would be conducted on 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 represents a true no action
alternative. A review of remedy would be conducted every five years.
This alternative involves no capital costs.
based on the review of Site conditions every
be no maintenance costs.
Operating costs are
five years. There would
Total Construction Costs -
Present Worth O&M Costs
Total Present Worth Costs -
$ 0
$140,000
$140,000
Alternative 1B: Long-term Monitoring of Groundwater
This alternative involves long-term monitoring of groundwater. Four
additional monitoring wells would be constructed in the second
uppermost aquifer. Sampling would be twice a year with analyses for
pesticides in the uppermost aquifer and pesticides and TCE in the
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TABLE 27
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GROUNDWATER REMEDIATION TECHNOLOGIES CONSIDERED
TECHNOLOGY
I GROUNDWATER RECOVERY
Extraction Well
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Interception Trenches/
Subsurface Drains
No Action
GROUNDWATER TREATMENT
Air Stripping
Activated Carbon Adsorption
Sorptive Resins
Chemical Oxidation (UV-Ozone)
Biological Treatment
Land Treatment
GROUNDWATER DISCHARGE
Horizontal Infiltration Gallery
Injection Wells
Surface Water Discharge
POTW
GROUNDWATER CONTAINMENT
Slurry Wall, Capping and
Well Point Extraction
STATUS
Retained
Retained
Retained
Rejected
Retained
Rejected
Retained
Rejected
Rejected
Retained
Rejected
Rejected
Retained
Retained
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REASON
Effectiveness
Effectiveness/
Reliability
Effectiveness
Effectiveness
Provisionally
Depending on
Application Rates
Not permittable
Not cost effective
TABLE 28
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SOIL REMEDIATION TECHNOLOGIES CONSIDERED
TECHNOLOGY
I DIRECT TREATMENT
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Land Treatment
Bioreactor
Supercritical CO2 Extraction
Critical Fluid Solvent
Extraction
Best Process
Supercritical Water Oxidation
Soil Washing
Stabilization/Solidification
Transportable Incineration
Thermal Desorption
Classification
IN-SITU TREATMENT
Soil Vapor Extraction
Enhanced Biodegradation
Soil Flushing
Vitrification
OFF-SITE TREATMENT
Commercial Landfilling
Commercial Incineration
CONTAINMENT
Capping
on-Site Landfill
No Action
STATUS
Rejected
Rejected
Rejected
Rejected
Rejected
Rejected
Rejected
Rejected
Retained
Retained
Retained
Rejected
Rejected
Rejected
Rejected
Retained
Retained
Retained
Rejected
Retained
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REASON/NOTES
Effectiveness
Effectiveness/
Implementability
Not a Demonstrated Technology
Not a Demonstrated Technology
Not a Demonstrated Technology
Not a Demonstrated Technology
Not Demonstrated Under Similar
Site Conditions/Implementation
Effectiveness
Soil Only
Soil Only
Treatability Testing Required
Effectiveness
Effectiveness
Effectiveness
Not Fully Developed
Soil and Foundation Debris
Soil Only
Soil and Foundation Debris
Implementation
Soil and Foundation Debris
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second uppermost aquifer. Deed restrictions on future uses of the property would also be included. Since wastes would remain at the Site, a review of this alternative would be conducted every five years as required by SARA.
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 fi:,re years. Monitoring costs are based on a period of 30 years. Maintenance costs would include inspection of the monitoring wells.
Total Construction Costs Present Worth O & M Costs Total Present Worth Costs -
Alternative 2 -Slurry Wall and Cap
$ 130,000
-$1,500,000
$1,630,000
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 and 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. Permeability of the slurry wall would he lE-07 cm/sec. The slurry wall could be constructed using the bio-polymer method, however, actual construction methods would be determined during the Remedial Design. The length of the circumferential slurry wall would be approximately 40 to 70 feet. Width of the slurry wall would be approximately three feet.
A low permeability cap would be constructed above the perimeter of the slurry wall to minimize infiltration within the slurry wall. The cap would consist of a compacted sub-base of common and select fill, 60-mil HOPE liner, drainage net, filter fabric, soil cover and vegr3ation. Permeability of the cap would be approximately 1 x 10-cm/s. The 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.
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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.
The slurry wa~l 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 the
remediation levels using groundwater extraction. One recovery well
would be placed in the uppermost aquifer and two recovery wells would
be placed in the second uppermost aquifer. Treatment of contaminants
would be by carbon adsorption. Disposal options for the treated
groundwater are the POTW and an on-site infiltration gallery. Actual
disposal requirements would be determined during the RD.
Since compound residuals would remain,
and protectiveness of this alternative
required by SARA.
Total Construction Costs
Present Worth O & M Costs
Total Present Worth Costs -
review
every
of the effectiveness
five years would be
$ 8,400,000
-S 1.800,000
$10,200,000
Alternative 3 -Groundwater Recovery to Attain Remediation Levels
This alternative involves the recovery of groundwater such that the
remediation levels would be attained. Contamination would be removed
through extraction wells placed in the uppermost and second uppermost
aquifers and reduced through treatment by activated carbon.
Discharge of the treated water would be either to the Moore County
POTW or to an on-site infiltration gallery.
The proposed extraction system would
approximately nine recovery wells; seven
two in the second uppermost aquifer.
involve the installation of
in the uppermost aquifer and
Carbon adsorption is considered to be the best available technology
for the removal of pesticides from water. The treatment system would
involve two carbon adsorption canisters in series, to maximize carbon
usage and provide protection against breakthrough. A standard
canister would be expected to last approximately two years. Spent
carbon would only be sent to a RCRA TSD facility in full compliance
with its Part B permit, in accordance with EPA's off-site policy.
Discharge of the treated groundwater would be to the Moore County
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. Construction requirements for an
infilt~tion gallery are based on a nominal application rate of 0.5
gpd/ft • The actual method of discharge and operating parameters
would be established during RD.
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Further characterization will be conducted in the second uppermost aquifer to determine the extent of pesticide contamination and to attempt to determine the source and extent of TCE contamination. If the source of the TCE cannot be determined, it will be assumed that the TCE is site-related. This characterization will be conducted during the pre-design activities associated with groundwater remediation. To achieve this, the installation of four additional groundwater monitoring wells in the second uppermost aquifer is included in the cost estimate. Actual requirements would be established during the RO.
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. Costs are based on a remediation period of thirty years.
The
Total Construction Costs -$ 710,000 Present Worth O&M Costs -Sl,500.000 Total Present Worth Costs -$2,210,000
B. Remedial Alternatives to Address Soil Remediation
response actions to address soil remediation are:
Alternative 1 -No Action
Alternative 2 -Off-Site Disposal
Alternative 3 -Capping
Alternative 4 -On-Site Thermal Desorption
Alternative 5 -On-Site Incineration
Each of the soil remediation alternatives is described below.
Alternative 1 -No Action
In this alternative, no soil remedial activities would occur. There are no construction costs. Operating costs would involve a review of the remedy every five years.
Total Construction Costs Present Worth O&M Costs Total Present Worth Costs
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$

0
-$140,000
-$140,000
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Alternative 2 -Off-Site Disposal
This alternative would involve the excavation and off-site disposal
of top foot of soils exceeding the remediation levels .. Soils would
be taken to either a secure landfill or a fixed-base incinerator,
depending on their regulatory disposition. Composite samples would
be collected from stockpiles and analyzed by the TCLP. The entire
stockpile would then be disposed according to its composite TCLP
analysis. Soils failing the toxicity characteristic leaching
procedure (TCLP) test for gamma-BHC or toxaphene would be considered
hazardous by characteristic and incinerated to satisfy land disposal
restrictions (LDR). Soils passing the TCLP would be sent to a
RCRA-approved landfill.
Confirmation sampling would be conducted to ensure that remediation
levels are attained. Excavated areas would then be covered with
clean fill and vegetated with a perennial grass.
This alternative would also involve the demolition of the building
foundation. Concrete debris should be acceptable for disposal at a
municipal landfill. Actual disposal requirements would be determined
during Remedial Design following confirmation testing.
Implementation time would depend on the number of crews involved but
should be approximately three months.
Construction costs associated with this alternative include
mobilization, excavation, earth work, disposal (landfill and/or
incineration), material and labor. There would be no operating
costs. To provide the greatest allowance for potential remediation
costs, it was assumed that all soils (approximately 1000 cubic yards)
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.
Total Construction Costs
Present Worth O&M Costs
Total Present Worth Costs
Alternative 3 -Capping
Landfilling
$600,000
0
$600,000
Incineration
$2,440,000
0
$2,440,000
This alternative involves construction and operation of an engineered
cover to deny human access to those Site soils exceeding the
remediation levels. The cap would be constructed of a non-woven
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polypropylene geomembrane impregnated and sealed with an asphalt
overlay. 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. Deed restrictions would 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
the remedial measures.
Periodic inspections would be required to check for erosion,
settling, and conditions of the drainage system. An established
inspection and maintenance schedule would be implemented following
construction and continued for as long as chemical residuals remained
at the Site.
Demolition of the building foundation would be required under this
alternative to gain access to some of the underlying soils. Disposal
of the foundation debris would be at a municipal landfill.
Implementation time would depend on the number of crews involved but
should be approximately two months.
Construction costs associated with this alternative include
mobilization, excavation, grading, earth work, materials, labor,
demolition and disposal. Operating costs include maintenance of
cap and review of the Site remedy every five years. Maintenance
costs include periodic inspections and grounds keeping.
Total Construction Costs -
Present Worth O&M Costs
Total Present Worth Costs -
$ 95,000
$180,000
$275,000
Alternative 4 -On-Site Thermal Desorption
the
In this alternative, soils exceeding the remediation levels would be
excavated and treated utilizing low temperature thermal technology.
The treated soil will be return to its original location.
The low temperature thermal treatment will volatilize the organic
contaminants at a temperature generally less than 1000 degrees F.
The off-gases will be captured and treated to prevent the release of
contaminants into the environment. Treatment of the soils will
continue until remediation levels are attained and the soil can pass
the TCLP test for toxaphene and gamma-BHC. Demoltion and disposal of
the building foundation would be required to gain access to
underlying soils.
The treatment selected to treat Off-gases will vary with the vendor
selected, but will normally consists of one of the following systems:
(1) thermal oxidation in a secondary thermal oxidation chamber
similar to incinerators; or (2) condensing and concentrating the
organics into a significantly smaller mass for further
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treatment (incineration); or (3) passing the off-gases through activated carbon to adsorb in the contaminants and then regenerating the carbon. For cost estimation purposes, the last treatment option (carbon adsorption) was used.
The practicality of on-site treatment for this site has been greatly reduced. The main reason for this loss of practicality is the reduction in soil requiring treatment. The original estimated amount of contaminated soil has been reduced form 2,200 cubic yards to 1,000 cubic yards.
The present volume of contaminated soil is below what the Agency feels is a sufficient amount of contaminated soil to attract the interest of qualified vendors to implement an on-site remedy. However, to provide a cost comparison with the other alternatives the following assumptions were made and a probable cost derived. The estimated amount of soil to be treated is very low (approximately 1,000 cubic yards), the treatment unit utilized would probably be small; on the magnitude of a pilot-scale operation. Assuming a process rate of 2.5 tons per hour, the actual treatment time is estimated to be approximately one month. The planning and materials screening and handling will probably require an additional four to six months. This alternative will also require implementation of a treatability study, that will add an additional twelve months to the estimated time to implement this alternative. The time required to implement this alternative will be in the range of two years, with a total cost as shown below.
Total Construction Costs -Present Worth O&M Costs Total Present Worth Costs-
$700,000
0
$700,000
Alternative 5 -On-Site Incineration
Incineration is a thermal treatment technology which utilizes elevated temperatures to destroy or detoxify hazardous waste. Under this alternative, contaminated soil and debris would be incinerated on-site. Residual ash from the incinerator would be redeposited on-site and covered with clean fill. The ash would have to pass the TCLP for toxaphene and lindane before depositing to ensure that the ash is non-hazardous.
Incineration is considered the Best Demonstrated Available Technology (BOAT) for halogenated organic compounds, which includes most of the pesticides found at the Site. The contaminated soil will be excavated, homogenized and sized, incinerated, tested, and disposed back on-site. Any process wastewater or scrubber blowdown sludge will be treated by reinjection into the incinerator.
The incinerator and air pollution control unit will be operated so that:
An operating temperature in the kiln of 1,800 degrees Fis maintained at all times to ensure that any volatile and semi-volatile organic constituents in the waste stream are driven
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out of the ash and that the fixed carbon remaining in the ash is
minimized;
An operating temperature in the afterburner of 2,000 degrees Fis
maintained at all times to oxidize and destroy all remaining
organic substances prior to exiting the afterburner and entering
the pollution control system;
The incinerator must achieve a destruction and removal efficiency
(DRE) of 99.99% for all designated principal organic hazardous
constituents (POHC); and
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The air pollution control system will achieve performance
standards of (1) hydrogen chloride of less than 4 lb/h3 and (2)
particulate matter of less than 0.08 grains per day ft in the
exhaust gas corrected oxygen content.
Because this is considered an "on-site" CERCLA response action, no
state, local, or federal permits are necessary. Operation of the
incineration unit will be in compliance with RCRA regulations.
Demolition and disposal of the building foundation would be required
to gain access to underlying soils.
On-site incinerations is very similar to on-site thermal desorption
as it pertains to practicality of implementation for such a small
amount of soil. For those reasons on-site incineration is not
considered a viable alternative. For sake of cost comparison we made
several assumptions and derive a relative cost for this option, which
is shown below.
Total Constructon Cost -$2,690,500.00
Present Worth O & M Cost -0.00
Total Present Worth Cost $2,690,500.00
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IX. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERBATIVES
The remedial alternatives to address groundwater and soil contamination were evaluated using the nine evaluation· criteria as set forth in the NCP, 40 CFR §300,430 (e)(9), A brief description of each of the nine evaluation criteria is provided below.
THRESHOLD CRITERIA
1. Overall Protection of Human Health and the Environment addresses how an alternative as a whole will protect human health and the environment. This includes an assessment of how the public health and the environment risks are properly eliminated, reduced, or controlled through treatment, engineering controls, or controls placed on the property to restrict access and (future) development. Deed restrictions are examples of controls to restrict development.
2. Compliance with Applicable or Relevant and Appropriate Requirements (ARARs) addresses whether or not a remedy complies with all state and federal environmental and public health laws and requirements that apply or are relevant and appropriate to the conditions and cleanup options at a specific site. If an ARAR cannot be met, the analysis of the alternative must provide the grounds for invoking a statutory waiver.
PRIMARY BALANCING CRITERIA
3.
4.
5.
Long-term Effectiveness and Permanence refers to the ability of an alternative to maintain reliable protection of human health and the environment over time once the cleanup goals have been met.
Reduction of Toxicity. Mobility. or Volume are the three principal measures of the overall performance of an alternative. The 1986 amendments to the Superfund statute emphasize that, whenever possible, EPA should select a remedy that uses a treatment process to permanently reduce the level of toxicity of contaminants at the site; the spread of contaminants away from the source of contaminants; and the volume, or amount, of contamination at the site.
Short-term Effectiveness refers. to the likelihood of adverse impacts on human health or the environment that may be posed during the construction and implementation of an alternative until cleanup goals are achieved.
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6.
7.
Implementability refers to the technical and administrative feasibility of an alternative, including the availability of materials and services needed to implement the alternative.
Cost includes the capital (.up-front) cost of implementing an alternative, as well as the cost of operating and maintaning the alternative over . the long-term, and the net present worth of both the capital and operation and maintenance costs.
MODIFYING CRITERIA
8.
9.
State Acceptance addresses whether, based on its review of the RI/FS and Proposed Plan, the State concurs with, opposes, or has no comments on the alternative EPA is proposing as the remedy for the Site.
Community Acceptance addresses whether the public concurs with EPA's proposed plan. Community acceptance of this proposed plan will be evaluated based on comments received at the public meetings and during the public comment period.
These evaluation criteria relate directly to requirements in Section .121 of CERCLA 42 use Section 9621, which determine the overall feasibility and acceptability of the remedy. Threshold criteria must be satisfied in order for a remedy to be eiligible for selection. Primary balancing criteria are used to weigh major trade-offs between remedies. State and community acceptance are modifying criteria formally taken into account after public comment is received on the proposed plan. Table 29 provides a summary of all the alternatives along with the total present worth costs. The evaluation of the potential remedial alternatives to address soil and groundwater were developed as follows.
A. Ground Water Remediation
The following alternatives were subjected to detailed analysis for groundwater remediation:
Alternative lA: No Action
Alternative 1B: Long-term Monitoring of Groundwater
Alternative 2:
Alternative 3:
Slurry Wall and Cap
Groundwater Recovery and Treatment to Attain Remediation Levels
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GROUNDWATER
Alternative 1A
Alternative lB
Alternative 2
Alternative 3
SOIL
Alternative 1
Alternative 2
Alternative 3
Alternative 4
R \1e,(<l(J1ive,,5
1..10, ooo
TABLE 29
REMEDIAL ALTERNATIVES SUMMARY
REMEDIAL ACTION
No Action
Long-term Monitoring
of Groundwater
Slurry Wall and Cap
Groundwater Extraction
for Remediation Levels;
Carbon Adsorption;
Discharge to POTW
No Action
Off-Site Disposal
Total Landfilling
Total Incineration
Capping
On-Site Thermal Desorption
z 1 Z./01 O'ui>
Zr qqo, o'-'o
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TOTAL PRESENT
WORTH COSTS
$140,000
$1,630,000
$10,200,000
$2,210,000
$140,000
$600,000
$2,440,000
$275,000
$700,000
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Overall Protection of Human Health and the Environment
Groundwater poses no risks to human health under current conditions.
Under the future use condition the no action alternative would not
address pesticide levels in groundwater and therefore would not be
protective of human health. Alternative 2 would attain the
remediation goals by containing groundwater in the uppermost aquifer
and recovering groundwater in the second uppermost aquifer.
Alternative 3 would attain the remediation goals by recovering
groundwater in the uppermost and second uppermost aquifer.
Therefore, ~lternatives 2 and 3 would be protective of human health
and the environment.
Compliance With ARARs
The no action alternative would not comply with ARARs. Alternative 2
would attain remediation levels outside of the slurry wall in the
second uppermost aquifer and prevent remediation levels from being
exceeded off-site in the uppermost aquifer. Alternative 3 would
attain remediation levels in both aquifers. The cap in Alternative 2
would be designed to conform to RCRA performance standards.
Construction of the groundwater recovery, treatment and discharge
systems for Alternatives 2 and 3 would satisfy action-specific
ARARs. Discharge to an on-site infiltration gallery would comply
with the substantive aspects of a NC Non-Discharge Permit.
Long-term Effectiveness and Permanence
Pesticide levels would decrease permanently through recovery outside
of the slurry wall for Alternative 2 and in both aquifers in
Alternative 3. Construction of a slurry wall under Alternative 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.
Carbon adsorption is considered Best Available Treatment _for
pesticides in groundwater. Alternative 2 would be a permanent
installation that would require review and maintenance indefinitely.
Alternative 3 would be discontinued once the remediation levels were
achieved.
Reduction of Toxicity. Mobility. and Volume
Alternative 2 would reduce the mobility of pesticides in the
uppermost aquifer through containment and reduce the volume of
pesticides in the second uppermost aquifer through recovery.
Alternative 3 would reduce the volume of pesticides in both aquifers
through recovery and treatment and comply with the statutory
preference for alternatives involving treatment.
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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 lA
-None; Alternative lB - 1 month; Alternative 2 - 8 months; and
Alternative 3 - 3 months. Construction of Alternative 2 could not
proceed until the rail line was rerouted, a potentially significant
obstacle on an institutional basis.
Implementability
Alternatives lA, lB, and 3 would not ·pose significant concerns
regarding implementation. Construction of the slurry wall for
Alternative 2 would approach the limits of technical feasibility due
to the required depths (up to 70 feet). Design of the treatment
system for Alternatives 2 and 3 could not be conducted until
discharge requirements were defined.
Total present worth costs for the groundwater alternatives are
presented in Table 29.
B. Soil Remediation
The following alternatives were developed for Site soils and were
subjected to detailed analysis:
Alternative 1: No Action
Alternative 2: Off-Site Disposal
Alternative 3: Capping
Alternative 4: On-Site Thermal Desorption
Alternative 5: On-Site Inceneration
A summary of the evaluation of these alternatives is presented below.
Overall Protection of Human Health and the Environment
Potential risks due to Site soils under current and potential future
conditions (residential scenario) are within the acceptable range of
risk specified by the National Contingency Plan (NCP). Alternatives
2, 3, and 4 would mitigate any further degradation of . the
groundwater.
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Compliance with ARARs
There are no Federal or State ARARs for pesticides in soils.
Alternative 2 would comply with EPA's off-site policy and applicable
land disposal restrictions. Alternative 3, consolidation of Site
soils and capping in place would not trigger any RCRA requirements.
Alternatives 4 and 5 would comply with all applicable ARARs,
including LDRs.
Long-term Effectiveness and Permanence
Alternative 1 would not be effective in reducing contaminant levels.
Alternatives 2 and 4 would result in a permanent reduction in Site
risks. Alternative 3 could be effective in the long term through
regular maintenance of the cap, but a review of remedy would be
required every five years since a cap is not considered a permanent
remedy. Alternatives 4 and 5 would maintain reliable protection of
human health and the environment over time once the cleanup goals
were meet.
Reduction of Toxicity, Mobility, and Volume
Pesticide levels would remain unchanged for Alternative 1.
Alternatives 2, 4 and 5 would reduce pesticide levels significantly.
Alternative 3 would not reduce the volume, but would reduce the
mobility and effective toxicity of the pesticides.
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.
Implementability
No implementation is needed for the no action alternative. Off-site
disposal to a RCRA-approved landfill and incinerator have been
conducted successfully in the past at the Geigy Site. Construction
of the cap would pose no significant difficulties. Alternatives 4
and 5 are implementable based on their technical ablilities as
alternatives, however the low volumes of contaminated soils in this
case renders these alternatives impractical at this site.
Cost
Total present worth costs for the soil remediation alternatives are
presented in Table 29.
C. Modifying Criteria
State and community acceptance are modifying criteria that shall be
considered in selecting the remedial action.
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x. THE SELECTED REMEDY
Section 121 of CERCLA, as amended, 42 U.S.C. §9621, and the National
Oil and Hazardous Substance Pollutim1 Contingency Plan (NCP)
establish a variety of requirements relating to the selection of the
remedial action under CERCLA. Having applied the evaluation criteria
to the groundwater and soil remediation alternatives, EPA has
selected the following remedy for the Geigy Site.
Groundwater Remediation
Alternative 3 -Recovery and Treatment of all Site Groundwater
exceeding Groundwater Remediation Levels using
Carbon Adsorption
Soil Remediation
Alternative 4 -Off-Site Disposal of Soils exceeding
Soil Remediation Levels
A. Groundwater Remediation
This remedial action will consist of a groundwater extraction and
treatment system, and an overall monitoring program for the Site:
Groundwater contaminated above the remediation levels indicated in
Table 25 shall be extracted across the entire Site.
For costing purposes,
aquifer and two in
anticipated. Actual
established during the
nine recovery wells (seven in the uppermost
the second uppermost aquifer) have been
design of the extraction system shall be
Remedial Design.
Discharge of the treated groundwater shall be to the Moore County
Publicly Owned Treatment Works (POTW). The Moore County POTW
preliminary discharge requirements are provided in Table 30.
Discharge to the POTW will require the construction of a force main
to the nearest manhole, approximately 1/2 mile away. Actual
discharge and operating parameters shall be established during the
Remedial Design.
Carbon adsorption is considered to be the best available technology
for the removal of pesticides from water. The treatment system shall
involve at least two carbon adsorption canisters in series, to
maximize carbon usage and provide protection against breakthrough.
The total loading to the treatment system is approximated at ten
pounds per year. A standard canister containing 200 pounds of carbon
will last approximately two years. Breakthrough of the carbon will
be monitored as part of the annual operation and
maintenance
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requirements. Actual treatment
during the Remedial Design and
discharge limits.
requirements shall be
will be dependent on
determined
the final
The conceptual flow diagram for groundwater treatment is presented in
Figure 11. The groundwater treatment shall involve the following
elements: manifolding of the extraction well piping to the treatment
system; concentration equalization; carbon adsorption canisters;
transfer pumps; flow measurement and sampling; and discharge line to
the Moore County POTW.
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.
Further characterization shall be conducted in the second uppermost
aquifer to determine the extent of pesticide contamination and to
determine the source and extent of trichloroethene contamination.
For costing purposes, the installation of four additional groundwater
monitoring wells in the second uppermost aquifer have been included.
Actual monitoring requirements shall be established during the
Remedial Design, determine if the trichloroethene is Site-related.
All site-related TCE shall be remediated through groundwater
extraction and activated carbon treatment. Until it is proven
otherwise TCE is considered a site related contaminant, and shall be
treated as an contaminant of concern.
The goal of this remedial action is to restore groundwater to its
beneficial use as a drinking water source. Based on information
obtained during the RI and on a careful analysis of all remedial
alternatives, EPA and the State of North Carolina believe that the
selected remedy will achieve this goal. It may become apparent,
during implementation or operation of the ground water extraction
system and its modifications, that contaminant levels have ceased to
decline and are remaining constant at levels higher than the
remediation level over some portion of the contaminated plume. In
such a case, the system performance standards and/or the remedy may
be reevaluated.
The selected remedy will include groundwater extraction for an
estimated period of 30 years, during which time the system's
performance will be carefully monitored on a regular basis and
adjusted as warranted by the performance data collected during
operation.
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Modifications may include any or all of the following:
* alternating pumping at wells to eliminate stagnation points;
* pulse pumping to allow aquifer equilibration and to allow adsorbed contaminants to partition into groundwater;
* installation of additional extraction wells to facilitate or accelerate remediation of the contaminant plume; and
* at individual
attained, and
discontinued.
wells where remediation levels have been after analytical confirmation, pumping may be
To ensure that remediation levels continue to be maintained, the aquifer will be monitored at those wells where pumping has ceased initially every year following discontinuation of groundwater extraction. This monitoring will be incorporated into an overall Site monitoring program which will be fully delineated in the Operations and Maintenance portion of the Remedial Design.
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B. Soil Remediation
The treatment technology selected for remediation of pesticide
contaminated soils at the Geigy Site is off-site disposal.
The soils exceeding the remediation levels shall be excavated and
stock-piled. Composite samples shall be collected from the
stockpiles and analyzed using the toxicity characteristic leaching
procedure (TCLP), and taken to either a secure landfill or a
fixed-base incinerator, depending on their regulatory requirements.
Soils failing the (TCLP) test would be considered hazardous by
characteristic and incinerated to satisfy land disposal restrictions
(LDR). Soils passing the TCLP would be sent to a RCRA-approved
landfill.
Confirmation sampling shall be conducted to ensure that remediation
levels are attained. Excavated areas shall then be covered with
clean fill and vegetated with a perennial grass.
The building foundations shall be demolished and the concrete debris
shall be disposed of at a municipal landfill. Actual disposal
requirements shall be determined during Remedial Design following
confirmation testing.
Remediation levels were developed for
contact with contaminated soil and are
protective risk range. The remediation
the protectton of direct
at the 10-end of the
levels are identified in
Table 26. Table 31 identifies the soil
pesticides above the remediation levels.
contaminated soil requiring excavation
approximately 1,000 cubic yards.
samples which contained
The total volume of
is estimated to be
The Geigy Site shall have a fence and proper warning signs posted in
visible locations in order to provide site control where humans have
access to the release.
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C. Cost
Table 32 provides a detailed cost summary for the selected remedial
alternatives. The total present worth cost for the entire remedial
action will ranges between $2,810,000 and $4,650,000.
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-· I XI. S'l'A'l'O'rORY DB'l'BRXIBA'l'IORS
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Under its legal authorities, EPA's primary responsibility at Superfund sites is to undertake remedial actions that achieve adequate protection of human health· and the environment. In addition, Section 121, of CERCLA, 42 u.s.c. §9621, establishes several other statutory requirements and preferences. These specify that when complete, the selected remedial action for this site must comply with applicable or relevant and appropriate environmental standards established under Federal and State environmental laws unless a statutory waiver is justified. The selected remedy also must be cost-effective and utilize permanent solutions and alternative treatment technologies or resource recovery technologies to the maximum extent practicable. Finally, the statute includes a preference for remedies that employ treatment that permanently and significantly reduce the volume, toxicity, or mobility of hazardous wastes as their principal element. The following sections discuss how the selected remedy meets these statutory requirements.
Protection of Human Health and the Environment
The selected remedy will permanently treat the groundwater and soil and remove or minimize the potential risk associated with the wastes. Dermal, ingestion, and inhalation contact with Site contaminants would be eliminated.
Compliance with ARARs
The selected remedy will comply with all Federal and State applicable or relevant and appropriate chemical-, location-, and action-specific requirements (ARARs).
Groundwater remediation levels (Table 25) would be met at the Site under this alternative. Discharge of groundwater to the POTW would comply with the MCSSA sewer use ordinance.
There are no Federal
selected remedy will
LDRs.
Cost Effectiveness
or State ARARs for pesticides in soils. The comply with all applicable ARARs, including
The selected groundwater and soil remediation technologies are most cost-effective than the other acceptable alternatives considered. The selected remedies provide greater benefit for the cost because they permanently treat the waste .
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Utilization of Permanent Solutions and Alternative Treatment Technologies or Resource Recovery Technologies to the Maximum Extent Practicable
The selected remedy represents the maximum extent to which permanent solutions and treatment can be practicably utilized for this action. Of the alternatives that are protective of human health and the environment and comply with ARARs, EPA and the State have determined that the selected remedy provides the best balance of trade-offs in terms of long-term effectiveness and permanence; reduction in toxicity, mobility, or volume achieved through treatment; short-term effectiveness, implementability, and cost; State and community acceptance, and the statutory preference for treatment as a principal element.
Preference for Treatment as a Principle Element
The preference for treatment is somewhat satisfied by the use of off-site disposal which emcompasses incineration for the soils containing characteristic hazardous waste and land disposal for the residual soils at an approved RCRA landfill. Groundwater meets the treatment preference with the use of carbon adsorption to treat contaminated groundwater at the Site. The principal threats at the Site will be mitigated by use of these treatment technologies.
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,;~ Documentation of Significant Change
l sed on information received during the comment period, the Agency longer believes the preferred alternative presented in the ~oposed plan provides the most appropriate balance among the 'Jternatives with respect to the nine evaluation criteria.
Information availible to the Agency suggests that alternative 2 If-site Disposal presented in the proposed plan plan provides the st balance of trade-offs, and the Agency has selected the off-site sposal of the contaminated soil in conjunction with Groundwater Pump and Treat System as the final remedy. More specifically the diacticality of on site treatment for this site has been greatly ~uced. The main reason for the loss of practicality is the reduction of soil requiring treatment. The original estimated amount !contaminated soil has been reduced form 2,200 cubic yards to 1,000 ic yards. The present volume of contaminated soil is below what Agency feels is a sufficient amount of contaminated soil to
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ract the interest of qualified vendors to implement an on-site edy.
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