NCD981927502_19920801_Geigy Chemical Corporation_FRBCERCLA ROD_Record of Decision - Summary of Remedial Alternative Selection-OCR

I
I
I
I
-I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
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
RECBVEO
AUG 31 1992
SUPERFUNDGION
D
D
I
I
I
I
I
I
I
I
I
I
I
I
I
I
II
-•
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 concurrs 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, whichever 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
D
I
I
I
I
I
I
I
I
I
I
I
I
I
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.
I Gc;riWz,Yrl~
1,4,,\Greer C. Tidwell
r·Regional Administrator
Date
I
I
I
I
I
I
B
I
I
I
I
I
I
I
I
I
I
I
TABLE OF CONTENTS
SECTION PAGE NO.
I. SITE NAME, LOCATION AND DESCRIPTION ......... . 1-1
II.
III.
IV.
v.
VI.
VII.
A. Introduction. . . ............. 1-1
B. Site Description ................... 1-1
C. Topography . . . . . . . . . . . . . : . . . . . . . . 1-1
D. Geology . . . . . . . . . . . . . . . . . . . . . . . 1-1
E. Surface Water ..................... 1-4
F. Hydrology . . . . . 1-4
G. Meteorology . . . . 1-4
H. Demography and Land Use 1-5
I. Utilities . . . . . 1-5
SITE HISTORY AND ENFORCEMENT ACTIVITIES
A. Site History . . . . . . . . . . . .
B. Previous Investigations ............... . c. Enforcement Activities ............... .
HIGHLIGHTS OF COMMUNITY PARTICIPATION.
SCOPE AND ROLE OF RESPONSE ACTION WITHIN SITE STRATEGY
SUMMARY OF SITE CHARACTERISTICS
A. Groundwater ....... .
B. Initial Removal Activity
C. Soil Investigation ..
D. 1991 Removal .....
E. Sediment Investigation
2-1
2-1
2-1
2-2
3-1
4-1
5-1
5-1
5-3
5-3
5-9
5-9
SUMMARY OF SITE RISKS .................. 6-1
A. Contaminants of Concern 6-1
B. Exposure Assessment. . 6-1
C. Toxicity Assessment . . 6-5
D. Risk Characterization Summary 6-7
E. Environmental (Ecological) Risk 6-10
F. Soil Remediation ................... 6-10
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARS)
A. Action-Specific ARARs .
B. Location-Specific ARARs
-i-
7-1
. . . 7-1
I
I
I
I
I
I
I
I
I
I
I
I
I I
I
I
I
I
I
TABLE OF CONTENTS (CONT'D)
SECTION PAGE NO.
C. Chemical Specific ARARs ............. .
Groundwater ......... .
Maximum Contaminant Levels
NC Groundwater Standards
Soils . . . . . . . . . . . .
( MCLs) . . . . . . . .
7-9
7-9
7-9
7-9
7-14
VIII. DESCRIPTION OF ALTERNATIVES ... 8-1
IX.
A. REMEDIAL ALTERNATIVES TO ADDRESS GROUNDWATER CONTAMINATION
B.
1. No Action . . . . . . . . . . . . . . . . . . 8-1
2. Slurry Wall and Cap ............... 8-4
3. Groundwater Recovery to Attain Remediation Levels 8-5
REMEDIAL ALTERNATIVES TO ADDRESS
i. No Action . . . .
2. Off-Site Disposal . . . .
3. Capping . . . . . . . . . .
4. On-Site Thermal Desorption
5. On-Site Incineration . . .
SOIL
. . . . .
. .
CONTAMINATION
. . . . . . . . . . . .
. . . . . .
.
. . . .
.
8-6
8-6
8-7
8-7
8-8
8-9
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES . . . . 9-1
9-2
9-4
9-4
9-4
9-4
9-5
9-5
9-5
A.
B.
C.
GROUNDWATER REMEDIATION ............... .
Overall Protection of Human Health & the Environment .
Compliance with ARARs ............... .
Long-term Effectiveness and Permanence ; .
Reduction of Toxicity, Mobility, or Volume
Short-term Effectiveness
Implementability
Cost . . . . . . . . . . •' .
SOIL REMEDIATION . . . . . . . . . . . . . . . . . . .
Overall Protection of Human Health & the Environment .
Compliance with ARARs ............... .
Long-term Effectiveness and Permanence ..
Reduction of Toxicity, Mobility, or Volume
Short-term Effectiveness
Implementability.
Cost . . . . . . . . . .
MODIFYING CRITERIA . . . . . . . . . . . . . . . . . .
State Acceptance ..
Community Acceptance ................ .
-ii-
9-5
9-5
9-6
9-6
9-6
9-6
9-6
9-6
9-6
9-7
9-7
I
I
I
I
I
n
I
I
I
I
I
I
I
I
I
I
I
I
I
TABLE OF CONTENTS (CONT'D)
SECTION PAGE NO.
x.
XI.
SELECTED REMEDY . . . . . . . . . . . . . . . . . . . .
A. Groundwater Remediation ............ .
B. Soil Remediation
C. Cost ..................... .
STATUTORY DETERMINATIONS ... . . . . . .
Protection of Human Health and the Environment
Compliance with ARARs ............... .
Cost-Effectiveness ............... .
Utilization of Permanent Solutions and Alternative
Treatment Technologies or Resource Recovery
Technologies to the Maximum Extent Practicable
Preference for Treatment as a Principal Element
XII. DOCUMENTATION OF SIGNIFICANT CHANGE.
APPENDIX A -TABLES OF ANALYTICAL RESULTS
APPENDIX B -RESPONSIVENESS SUMMARY
-iii-
10-1
10-1
10-4
10-5
11-1
11-1
11-1
11-1
11-2
11-2
12-1
D
m
LIST OF FIGURES
I
FIGURE PAGE NO.
I 1 Site Location Map. . . . . . . . . . . . . . . . 1-2
2 Site Map . . . . . . . . . . . . . . . . . . . . 1-3
I 3
4
5
Phase 1 Groundwater Sampling Locations ...... 5-2
Phase 2 Groundwater Sampling Locations ...... 5-4
Feb. 1989 Removal Locations . . 5-5
I 6
7
8
Phase 1 Soil Sampling Locations . . . 5-7
Phase 2 Soil Sampling Locations .......... 5-8
Phase 4 Soil Sampling Locations .......... 5-10
9 1991 Removal Locations .............. 5-11
D 10
11
Sediment Sampling Locations ............ 5-13
Conceptual Flow Diagram for Groundwater Treatment .10-3
I
I
I
I
I
I
I
I
I
I
I -iv-
I
B
I
I
TABLE
I 1
I 2
3
D 4
5
I 6
I 7
8
I 9
10
11
I 12
I 13
14
15
16
I 17
18
6-1
I 6-2
6-3
6-4
6-5
I 7-1
7-2
7-3
I 7-4
7-5
8-1
8-2
I 9-1
I
I
I
LIST OF TABLES
PAGE NO.
Phase 1 Groundwater Analytical Results
Volatiles and Semi-Volatiles
Phase 1 Groundwater Analytical Results
Pesticides
Phase 1 Groundwater Analytical Results
Metals
Phase 2 Groundwater Analytical Results
Volatiles
Phase 2 Groundwater Analytical Results
Pesticides
Phase 1 Soil Analytical Results ..
Volatiles and Semi-Volatiles
Phase 1 Soil Analytical Results
Metals
Phase 1 Soil Analytical Results ..
Pesticides
Phase 2 Soil Analytical Results ..
Background Soil Analytical Results ......... .
Phase 3 Soil Analytical Results .
Pesticides and Metals
Phase 3 Soil Analytical Results .
Volatiles and Semi-Volatiles
Soil Boring Analytical Results ........... .
Phase 4 Soil Analytical Results .... .
1991 Post Removal Soil Analytical Results
Phase 1 Sediment Analytical Results
Phase 2 Sediment Analytical Results .
Phase 3 Sediment Analytical Results •
Contaminants of Concern ...... .
Toxicity Criteria for Contaminants of Concern
Total Risks Associated with Current Land-Use .....
Total Risks Associated with Future Land-Use
Soil Remediation Levels .....
Potential Action-Specific ARARs.
Potential Location-Specific ARARs
Potential Chemical-Specific ARARs
Groundwater ARARs ....... .
Groundwater Remediation Levels .......... .
Groundwater Remediation Technologies Considered .. .
Soil Remediation Technologies Considered ...... .
Remedial Alternatives Summary ........... .
-v-
A-1
A-2
A-3
A-5
A-6
A-7
A-8
A-10
A-11
A-18
A-19
A-24
A-25
A-~6
A-28
A-31
A-34
A-38
6-2
6-6
6-8
6-9
6-12
7-2
7-6
7-10
7-13
7-15
8-2
8-3
9-3
I
I
I
I
I
D
I
I
I
I
I
I
I
I
I
I
I
I
I
DECISION SUMMARY
I. SITE NAME, LOCATION AND DESCRIPTION
A. Introduction
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 w~ter
supply well. The well water was probably used for process
operations, lavoratories, showers, and on-site drinking water.
C. Topography
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.
1-1
-liiiiilil liiliil liiiii iiliil -!!!!! I!!!!!!!!
f
1-2
I
I
I
I
• I
I
I
I
I
I
I
I
I
I
I
1.
~
' ! i
0 6
', ''
1
I :
,'
\.r-~--> --~
ill!/
' ' ' l., ! I
]I : I ' ' ~
,Ii
0 ; •
1
I
1
I
I I
/
' I .
[D
:.; :...: -~ :.... :.... :r,
'
'"" I
t
B
R
I
I
I
I
I
g
n
H
I
I
I
I
I
I
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.
Drainage ditches at the Site
Surface water runoff during
well-drained soils in the
F. Hydrogeology
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.
Potentiometric data from the shallow monitoring wells indicate
groundwater flow from the eastern and western portions of the Site
meet in an elongated zone of convergence. East of the convergence
zone, groundwater flows west and northwest 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
north westerly.
The Upper Cape Fear confining unit
over the Upper Cape Fear aquifer.
uppermost aquifer ranges from 10
overlies the crystalline bedrock.
is generally to the northwest.
G. Meteorology
(approximately 60 feet thick) is
In the Aberdeen area, the third
to 20 feet thick and directly
Groundwater flow in this aquifer
I Average daily maximum temperature is 90 degrees F. in July and
I
I
1-4
u
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
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.
1-5
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
II. SITE HISTORY AND ENFORCEMENT ACTIVITIES
A. Site History
The Geigy Site has been leased and operated by various companies
since approximately 1947. From approximately 1947 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 du1:ing
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
An EPA Site Investigation (SI) was conducted in March
purpose of the SI was to collect soil and water samples
the Hazard Ranking System (HRS) evaluation.
1988. The
to support
Isomers of BHC
off-site locations:
were detected in five groundwater samples
two private wells and three of the municipal
from
2-1
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
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
therefore
work.
was regraded by the railroad after this investigation, the soil sample locations were not relied upon for future
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) oc_curred.
The Geigy Chemical
National Priorities
October 4, 1989.
Corporation Site was proposed for inclusion on the List (NPL) in 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 5. 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.
2-2
u
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
III. HIGHLIGHTS OF COMMUNITY PARTICIPATION
Pursuant to CERCLA Sl13(K)(2)(Bl(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.
3-1
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
IV. SCOPE AND 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.
4-1
ROD is to reduce
will remove the
is the only ROD
units have been
I
I
I
I
a
D
I
I
I
I
I
I
I
I
I
I
I
I
I
V. SUMMARY OF SITE CHARACTERISTICS
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 1, Appendix A. 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 1:g/l respectively. The compound 1,2,4-trichlorobenzene was found n 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, Appendix A. As indicated, pesticides were detected in all the shallow wells except MW-lS, 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, Appendix A. The secondary drinking water standard for iron (300 ug/1) was exceeded in six wells including both upgradient wells (MW-lS and M W-1 D). Copper was detected in the water supply well at a concentration of 1,180 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.
5-1
---
......
--...... ....... 1 ....
-
,z-1
~c • \r£nt 1c cUN-~nvu1 ,.,......,U'l .......
I ,. tl.w'lllAII.JC( tC') ..,._.,11 .. UH-~1l W,llH wt't'\-1 WlU.
l!!!!!!I
•
... , ....
--------~ t,.------' ' I S:C: • IOID ...... L--/ ' ....
.,.__..,
SC • ZII .... ,., 'I • 11.I
L[LLND
.,._ ..
\C • lOO .... 4.l l • 11.1
fl\,-1,\& ~ ~ g,IIUIIIL vU-1..
MW ... J+t,. V M:Ullllli ,_.u. ..-,aa -AU-
t>l ·l() ~ ,a,.llflA .-,Al~ IJ\il-
~
~
F ll:IIKI•: ·1 l'il-";1-. I ,:KOIINl>WATEK
'.;AMl'il NC 1.rn:1\T IONS
I
I
I
I
I
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-l0S, MW-12S and MW-13S). In addition, three monitoring wells were installed in the intermediate aquifer (MW-11D, MW-14D, and MW-15D) (Figure 4). Two of the intermediate wells, MW-14D and MW-15D, were installed to try to determine if the trichloroethene found in wells MW-4D and MW-6D, was coming from an upgradient source. In addition, two private wells were also sampled. Monitor wells MW-7S through MW-l0S, MW-12S, MW-13S, MW-11D, MW-14D, and MW-15D were analyzed for TCL pesticides and volatile organics. Wells MW-1D, MW-4D, 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, Appendix A. 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-4D, MW-6D and PZ-1. The two upgradient deep wells, MW-14D and MW-15D, did not contain any trichloroethene.
The TCL pesticide results are shown in Table s, Appendix A. Pesticides were found in two wells, MW-l0S and MW-11D.
B. Initial Removal Activity
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.
C. Soil Investigation
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
5-3
;-----------·
I
I
. .
!
' . i
I
C
I
I
I
I
I
I
I
I
I
I
B
I
I
I
I
I
I
-------------------
DOOR 5
LU~ DOOR 6
WAREHOUSE B
LEGEND
DOOR J DOOR 2
WAREHOUSE A
WJN RAILROAD TRACK
~ AREAS DESIGNATED FOR REMOVAL
•
DOOR 1
0 JO 60
SCALE IN fECT
FIC:IIHE '> FE»HIIAHY ANII oC'l'Ol/1-:H I <JH'J REMOVAi. 1.111:AT IONS
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, Appendix A. 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, Appendix A. 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 8, Appendix A).
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, Appendix A. 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, Appendix A.
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, Appendix A 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 (SO 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, Appendix A shows the results of these analyses.
5-6
I I I I I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
1l
-00 lli]
tJ I l
i
~
I
I •
I
..J '
f
I '0/ Ir
\
\ :
I I
I
I l
f I X -. ~ ·~ ~ --<
------
-\
--
EJ
-
-
u-n •
liiii -
tlllJrl; -CilNl'I°" JllU ~ ~ .................
•••
• I-
..
l ___...,u1
-
,,
I I
I I
''
PIIASE l
f!GURE 7 SOIL SAl'll'LlNG LOCATI•
I
I
I
H
I
I
I
I
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, Appendix A.
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, Appendix A. 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, Appendix A. A total of approximately 2000 tons of
soil were removed from the Site.
E. Sediment Investigation
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.
5-9
- - ---- -
.....
fS'la.i•ltD l"IICPulr, lM
-
:J fo.aGA ...
'"
-
.........
en-1
h111-1l 1u111,.r, 1un. l.OCAl&Oll ~-·'°"''""'-DtllNIAIUJNJ
,uw .. w \IMIAII 1 ......... , ,oc ... nQ,11..-111111, .. u,o 1,,LIAIUI\
11<1 .. l'-'ID Ol,toL.._. OUJtlt1·Al"lilll. l't'II ltll•UVAI IJIUolf•
• II I i1 I• iu1, 11 .. IHl,
5-10
I
-iiil
EJ
. .. -1:.:-....,l___:_--
}(Atl &H Hl I
FICIIKF H
1!!!11!1
l'IIA~iE 11 SOIi. ~;AMl'I.INC I.OCATlilf
----
•
0
e
(,)
l · l
-
-· . .,
sul<fACC SOIL/lll\Rltll, I \\LAIIIIN;')
Sl UlMl.NI SJ'\M''I IHI, I\\\ J\\11111'.
5-11
t· 1
-
\
l·l
"
•.1 iH I J/1 I I I I
-
\
I!!!!
!·l
M
M
!!!9
0
~
F!O!HF (j ! ,;IJ \ KLMt 1V /\t. UlCAT I ON~~
I
I
•
I
I
I
I
D
D
D
I
I
I
I
I
I
The first
surface to
from the
collected
increased
deposited
Figure 10.
phase sediment samples were collected from the ground
a maximum depth of one-foot. Sample OSD-28 was collected
surface to a depth of 1.5 feet and sample OSD-29 was
from the same location at a depth of 1.5 to 3 feet. The
depth sampling was due to the presence of sediments
at these locations. All sediment samples are shown in
Analytical results are given in Table 16, Appendix A. The same
pesticides that were found· in the soil samples were also found in the
sediment samples, namely, the BHC isomers, the DDT isomers and
toxaphene. Samples that contained noteworthy amounts of total
pesticides include SD-1 (36 mg/kg), SD-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 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 detected 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 ug/kg.
Sample results for the next phase of the sediments investigation are
presented in Table 1 7, Appendix A. These samples, taken down to a
depth of 2. 5 feet, still contained contaminants. Samples that
contained noteworthy amounts of total pesticides include S D-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 collee;ted
from four sample locations SD-10, SD-11, SD-12 and SD-14. These
sample locations exhibited surface pesticide concentrations greater
than 500 mg/kg prior to the 1991 removal.
Total pesticide concentrations on the whole, were lower than the
shallow samples. Sample locations 12 and 14 showed significant
amounts of contamination (Table 18, Appendix A).
5-12
-l!!!!!!!!!!I Ill! l!!!!!I li!li:I == 11,;11;1 -
wooos
IIIOOOS
Llc.lND
•ll--11 -Ila .. u, IU(-_, --I.JI,
5-13
iiii liliil
' I
-
-c:)-("_' ______ _
... ~ •
..... •
l .J 'I ---
Fl<:IIHE 10
SEil i MENT SAMl'I. I NG I.OCAT I /IN::
I
I
I
I
I
I
I
I
I
I
I
I
g
I
I
VI, SUMMARY OF SITE RISKS
The Geigy Site is releasing contaminants into the environment. The Baseline Risk Assessment Report presents the results of a comprehensive risk assessment that addresses the potential threats to public health and the environment posed by the Site under current and future conditions assuming that no remedial actions take place and that no restrictions are placed on future use of the Site.
The Baseline Risk Assessment report consists of the following sections: identification of chemicals of potential concern; toxicity assessment; human exposure assessment, risk characterization; and environmental assessment. All sections are summarized below.
A. Contaminants of Concern
Data collected during the RI were reviewed and evaluated to determine the contaminants of concern at the Site which are most likely to pose risks to public health. These contaminants were chosen for each environmental media sampled.
Once these contaminants of concern were identified, exposure concentrations in each media were estimated. The maximum concentrations detected were compared to the calculated 95% confidence level of the arithmetic average of all samples, and the lower of these values was chosen as the estimated exposure concentration. Table 6-1 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 assessment 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 ingestion of chemicals in on-site and off-site surface soil/sediment by an older child trespasser (8-13 years),
6-1
I
I
I
I
I
I
I
I
I
I
I
I
I
D
I
D
D
D
•
TABLE 6-1 CONTAMINANTS OF CONCERN AND EXPOSURE CONCENTRATIONS FOR ALL ENVIRONMENTAL MEDIA
EXPOSURE POINT CONCENTRATIONS FOR OFF-SITE
SURFACE SOIL/SEDIMENT
BETA-BHC 540
4,4'-DDD 25,000
4,4'-DDE 6,600
4,4'-DDT 52,000
DIELDRIN 12
TOXAPHENE 190,000
EXPOSURE POINT CONCENTRATIONS FOR ON-SITE SURFACE SOIL/SEDIMENT
540
25,000
6,600
52,000
12
190,000
I;( ·•••·>··.·•••••••••ffiM'.iw•·••·••7
.:.-:-..
ALDRIN 4.5 5.9
ALPHA-BHC 130 . 1,500
BETA-BHC 270 2,000
GAMMA-BHC 120 840
BENZOIC ACID 3,700 3,600
ALPHA-CHLORDANE 42 45
GAMMA-CHLORDANE 49 49
4,4'-DDD 3,700 15,000
4,4'-DDE 2,000 11,000
4,4'-DDT 9,000 54,000
DIELDRIN 250 1,500
TOXAPHENE 37,000 220,000
6-2
I
I
I
I
I
I
I
I
I
g
g
0
D
u
D
D
I
I
I
.
TABLE 6-1 (CONT) CONTAMINANTS OF CONCERN AND EXPOSURE CONCENTRATIONS FOR ALL ENVIRONMENTAL MEDIA
EXPOSURE POINT CONCENTRATIONS FOR GROUNDWATER
ALDRIN 2.0E-01
ALPHA-BHC 3.6E+0l
BETA-BHC 2.SE+0l
DELTA-BHC 2.9E+0l
GAMMA-BHC 3.0+01
BIS(2-ETHYLHEXYL)PHTHALATE 6.4E+00
DIELDRIN l.2E+00
4,4'-DDE l.0E-01
ENDRIN KETONE 3.7E+00
HEPTACHLOR EPOXIDE 3.0E-01
TOXAPHENE 5.9E+00
TRICHLOROETHENE l.8E+02
1,2,4-TRICHLOROBENZENE 5.0E+O0
6-3
4.0E-01
3.6E+Ol
2.SE+0l
2.9E+0l
3.0E+0l
7.0E+00
2.0E+0O
2.0E-01
4.0E+00
3.0E-01
9.6E+00
l.8E+02
5.0E+00
I
I
I
I
g
D
D
I
I
I
I
I
B
I
I
I
I
I
I
*
*
*
*
*
Dermal
surface
years),
absorption of chemicals in on-site and off-site soil/sediment by an older child trespasser (8-13
Inhalation of volatilized surface soil/sediment chemicals by an older child trespasser (8-13 years),
Inhalation of volatilized surface soil/sediment chemicals by a merchant north of the site,
Inhalation of volatilized surface soil sediment chemicals by a nearby child resident ( 1-6 years) and a nearby adult resident northeast of the site,
Inhalation of chemicals in wind blown dust particles by a nearby child resident (1-6 years) and a nearby adult resident northeast of the site.
* Inhalation of chemicals in wind blown dust particles by a nearby merchant north of the site.
The exposure pathways that were evaluated under future land use conditions were:
*
*
*
*
*
Incidental ingestion of on-site surface soils/sediment by future on-site adult and child (1-6 years) residents and by a future on-site merchant,
Dermal absorption
soils/sediments by
years) residents and
to surface
child ( 1-6
of chemicals absorbed
future on-site adult 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,
Inhalation of volatile organic chemicals · while showering with groundwater by a future on-site adult and child ( 1-6 years) residents,
Dermal absorption of groundwater by future
residents, and
chemicals while showering with on-site adult and child ( 1-6 years)
* 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
residents and 120
assumed to work 5
soil, an exposure frequency of 170 days/yr for days/yr for merchants was assumed. (A merchant is days/wk, 50 wks/yr (2 weeks subtracted for
6-4
I
I
m
I
D
I
I
I
I
I
I
I
I
I
I
I
I
I
I
vacation), minus 9 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 during the 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.
For ingestion of groundwater, an exposure frequency of 350 days/yr
for residents and 241 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 Assessment
Under current EPA guidelines, the likelihood of adverse effects to
occur in humans from carcinogens and noncarcinogens are considered
separately. These are discussed below. Table 6-2 summarizes the
toxicity criteria for the contaminants of concern.
Carcinogens
EPA uses a ·weight of evidence system to classify a chemical's
potential to cause cancer 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 in animals and inadequate or no evidence in
humans; Class C Possible human carcinogen; Class D Not
classifiable as to human carcinogenicity; and Class E -Evidence of
noncarcinogenicity for humans.
Cancer slope factors have been developed by EPA for estimating excess
lifetime cancer risks associated with exposure to potentially
carcinogenic chemicals. Slope factors, which are expressed in units
of (kg-day/mg), are multiplied by t,he estimated intake of a potential
carcinogen, in mg/kg-day, 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
makes underestimation of the actual cancer risk highly unlikely.
Cancer potency factors are derived from the results of human
epidemiological studies or chronic animal bioassays to which
animal-to-human extrapolation and uncertainty factors have been
applied.
Noncarcinogens
Reference doses (RfDs) have been developed by EPA for indicating the
potential for adverse health effects from exposure to chemicals
6-5
TABLE 6-2
TOXICITY CRITERIA FOR CONTAMINANTS OF CONCERN
CARCINOGENIC TARGET ORAL CHEMICAL CLASSIFICATION ORAL SF INHALATION SF ORGAN RfD
Aldrin B2 1. 7E+0l 1. 7E+0l LIVER 3E-05 Alpha-BHC B2 6.3E+00 6.3E+00 LIVER Beta-BHC C l.BE+00 1. BE+00 LIVER Delta-BHC D
Gamma-BHC B2/C l.3E+00 LIVER 3E-04 Benzoic Acid 4E+00 Bis(2-ethylhexyl) B2 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-01 3.4E-01 LIVER SE-04 Dieldrin B2 l.6E+0l l.6E+0l LIVER SE-05 4-Methyl-2-SE-02 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-day)-l
6-6
I
I
I
I
u
I
•
I
I
I
I
I
I
I
I
I
I
I
exhibiting noncarcinogenic effects. RfDs, which are expressed in units of mg/kg-day, are estimates of lifetime daily exposure levels for humans, including sensitive individuals. Estimated intakes of chemicals from environmental media can be compared to the RfD. RfDs are derived from human 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.
D. Risk Characterization
To quantitatively assess the risks from the Geigy Site, the chronic daily intakes (CDI) were combined with the health effects criteria. For potential carcinogens, 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 pathway was obtained by summing the ~hemical-specific risk estimates. A cancer 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 specified exposure 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 gene:ral, a hazard index value 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 LO for the HI were barium, manganese, mercury, vanadium, and zinc.
Tables 6-3 and 6-4 summarize 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 total cancer risks were in the lE-03 range. For non-cancer risk, the baseline of 1 for the HI was exceeded for ingestion of surficial groundwater.
6-7
I
I
I
I
I
D
D
I
I
I
I
I
I
I
I
I
I
I
TABLE 6-3
TOTAL RISKS ASSOCIATED WITH CURRENT LAND-USE CONDITIONS
Area/Pathlliay
Ingestion of Surface Soil/Sediment
Dermal Absorption from Surface
Soil/Sediment
Inhalation of Volatile Chemicals
Released from Surface Soil/Sediment
Inhalation of Oust Particulates
Total Cancer Risk
Area/Pat~ay
Ingestion of Surface Soil/Sediment
Dermal Absorption from Surface
Soil/Sediment
Inhalation of Volatile Chemicals
Released fra11 Sur1ace Soil/Sediment
Inhalation of Oust P1rtieul1tn
Caru:er Risk Due to All Chemicals
On-Site
Older C!'lild
Trescasser
(8-13 yrs>
7.0E-07
4.0E-07
2.0E-08
1E·06
OH·Sit!
Older Child
(8-13 yrs)
2.CE-06
9E-06
Off·Si-;e
Adul,
Merc-:iant
6.0E-07
6.0E-10
6E-07
OH-Site
Adult
Resiaent
9.0E-08
1.0E-10
9E-08
Noncancer Ri5k Due to All Chemicals
On·Site
Older Child Off-Site
Tresoasser Older Child
(8-13 yrs) (8-13 yrs)
4.0E-03 4. □E-02
l-OE-02 1.0E-02
(al <•>
---<•> ---<•>
Off-Site
Adult
~ei-enant
(,1)
---(I)
Off-Site
Adult
Resident
(1)
---(I)
(a) No inhalation toxicity cr;teria were available to assess noncarcincgenic risks.
a Not evaluated.
6-8
Off·Si~e
'fou,g Child
il:es i ::ent
C,·6 Y!"Sl
1.□E-07
8.00E-11
1E-07
Off-Site
Young Child
Resident
C1·!i yrs)
( a)
---(a)
I
I
I
I
u
I
I
I
I
g
I
I
I
I
I
I
I
I
TABLE 6-4 TOTAL RISKS ASSOCIATED WITH FUTURE LAND-USE CONDITIONS
Cancer 11:isk:
Oue to All Chemicals
Area/Dathway
Surface Soil/Sediment:
Ingestion of Surface Soil/
Sediment
Oennal Absorption frca Surface Soil/Sediment
Inhalation of Chmi;cals Released fri::m Surface Soil/Sediment
Groundwater:
Ingestion of Surficial groundwater
Inhalation of Volatiles white Shower; ng
Dermal Absorption of Chemicals while Showering
Total Cancer Risk
Child
11:esioent
JE-05
4E·06
1E·06
2!·03
JE·OS
2E·06
2E·Ol
Adult
Resioent
1E·OS
1E·06
9E·07
4E·Ol
4E·08
6E·06
4E·Ol
Merchant
6E•07
6E•07
1E·Ol
1E-Ol
Noncancer R i sic Due to All Chemicals
Area/Pathway
Surface Soil/Sec:Hant: Ingestion of Surface soil/ Sediment
Dermal Absor-ption frca Surface Soil/Sediment
Child
Resident
2E·01
2E·02
Inhalation of Chem;cals Released ···Ca) fraa Surface Soil/SedtMnt
GrO\.ndw■ter: 1ngution of 5urf;cial
gr°'-l'di,ater
lrlltlttlan o1 Volatiles wllt It SIi-ring
> I
liver= 8.9
kidney• 6.5
7E-05
Dermal Absor-pt; an of Ch1111i cal s while Showring 1E-02
Adult
Resident
2E·02
1E·OJ
>1
liver•4.1
kidney : 3.2
1E·OS
SE·OJ
(a) No iMal1t;on toaicity criteria wre available to assess nonc:arcinogenic riska.
• This pathway wu not evaluated.
6-9
Merchant
6E·Ol
9E·Ol
···(a)
>I
liver• 1.2
(kict,ey • 1.0)
I
I
I
I
I
I
0
I
I
I
I
I
g
I
I
I
I
I
I
E. Environmental (Ecological} Risk
The vegetative community at the site is dominated by native grasses,
which were planted following a previous removal action. Other
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 bamboo
occurs in the northeast corner of the site and a small number of pine
trees occur in the eastern and western portions of the site.
Terrestrial plants may be exposed to chemicals of concern in soil as
a result of direct contact with subsequent plant uptake via the
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.
The site is not expected to support extensive wildlife populations,
given its small size, the limited diversity of the vegetative
community, and the availability of higher quality habitat in adjacent
areas. Resident vertebrate species of the site are likely limited to
small mammals such as voles and other field mice. Some snakes and
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
accumulated pesticides from the site are not likely to be
significant. None of the chemicals of potential concern accumulate
extensively in vegetation and therefore, significant exposure in the
herbivorous species that may inhabit the site is unlikely. Some
accumulation in soil invertebrates is possible and therefore ani.Jr?als
that feed on these organisms could be exposed to chemicals in the
food. The degree to which chemicals in soils · at the site could be
bioaccumulated is unknown.
Red-cockaded woodpeckers (a State and federal listed endangered
species) which live in colonies located within one mile of the site
are unlikely to be affected by chemicals in soil at the site. These
woodpeckers feed on insects in trees, and generally do not feed below
the understory layer.
F. Soil Remediation
Table 6-4 shows the estimated upperbound total carcinogenic risk
posed by soil contaminants under a future 5esidential exposure
scenario. The calculated risk· level of 3 x 10-is based on soils
contaminated at the level of the site-wide average being ingested by
a child. ( The site-wide soil data was used to develop a reasonable
maximum exposure (RME) which is the 95% upper confidence limit of the
samples arithematic average).
6-10
I
I
I
I
I
•
I
D
I
I
I
I
I
I
I
-•
I
The future residential risk could have been calculated based on an assumption that a residence was placed at the site of the highest contaminant concentraton detected (sample SS-06) in the sampling program. The assumption in this case would be that a child was constantly exposed to this higher valfe. This assumption gives an estimated upperbound risk of ( 4.4 x 10-) .
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 6-5. Table 6-5 also indicates the maximum concentration of each contaminant found at the site .
6-11
g
D
I
I
I
I
I
I
I
I
I
I
1.
I
I.
I
I
I
I
TABLE 6-5
SOIL REMEDIATION LEVELS
ALDRIN 14 0.113
ALPHA-BHC 21 0.28
BETA-BHC 4.1 1.15
DELTA-BHC 1.9 NC
GAMMA-BHC 3.2 1.5
DIELDRIN 9.7 0.13
ENDRIN KETONE 0.28 NC
TOXAPHENE 450 2.0
DDD 28 7.6
DDE 11 5.5
DDT 54 4.75
GAMMA-CHLORDANE 0.049 1.43
ALPHA-CHLORDANE 0.045 1.4
NC -Not Calculated
6-12
1.0 X lOE-6
1.0 X lOE-6
l.OX lOE-6
l.OX lOE-6
l.OX lOE-6
l.OX lOE-6
1.0 X lOE-6 -1.0 X lOE-6
l.OX lOE-6 /
1.0 X lOE-6 /
1.0 X lOE-6
1.0 X lOE-6
l.OX lOE-6
I
I
I
I
g
0
I
I
I
I
I
I
I
I
I
I
I
I
I
VII. APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARs)
Section 121(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 requirement. A listing of potential location-specific ARARs and their consideration towards the Site is given in Table 7-1
Federal classification guidelines for groundwater are as follows:
* Class I: Groundwater that is irreplaceable with no alternative source or is ecologically vital;
* Class II: A -Groundwater currently used for drinking water; B -Groundwater potentially available for drinking water;
* Class 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.
7-1
I
I
I
m
g
D
D
I
I
I
I
I
B
I
R
I
I
I
I
VII. APPLICABLE OR RELEVABT ABD APPROPRIATE REQUIREMENTS (ARARs)
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. Potential action-specific ARARs are shown in
Table 7-1.
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 requirement. A listing
of potential location-specific ARARs is given in Table 7-2.
Federal classification guidelines for groundwater are as follows:
* Class I: Groundwater that is irreplaceable with no alternative
source or is ecologically vital;
* Class II: A -Groundwater currently used for drinking water;
B -Groundwater potentially available for drinking
water;
* Class 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.
7-1
-a1i ---1!1!!!1 11111 ml a; 1iii11ii1 lilliil -I!!!!! 1!!11111;1 =:I r:ail liiiiil liiii -
..
STANDARD, RBQUTRBMEN'l',
CRITERIA, OR LIMITATION
RCRA, AS AMENDED
Identification of Hazardous
Waste
Treatment· of Hazardous
Wastes in a Unit
Requirements for Generation,
Storage, Transportation, and
Disposal of Hazardous Waste
Land Disposal Ban and
Restrictions
TABLE 7-1
POTENTIAL ACTION-SPECIFIC ARARS
SOILS AND GROUNDWATER
CITATION DESCRIPTION
40 use Sect 1609 et seq
40 USC Sect 6901 et seq
40 CFR 261 Federal requirements for
classification and identification
of hazardous wastes
40 CFR 264.601 Rules and requirements for the
40 CFR 265.400 treatment of hazardous wastes
40 CFR 263 Regulates storage, transportation,
40 CFR 264 and operation of hazardous waste
generators.
40 CFR 268.10-12 Disposal of contaminated soil and
40 CFR 268 (Subpart D) debris resulting from CERCLA
response actions are subject to
federal and disposal prohibitions.
Establishes treatment standards
for hazardous wastes.
7-2
TABLE 7 -1 (CONT)
STANDARD, REQUIREMENT, CITATION DESCRIPTION
CRITERIA,. ORJ,IMITATION
CLEAN WATER ACT (CWA) 33 USC Sect 1251-1376
Requires Use of Best 40 CFR 122 Use of best available technology
Available Treatment economically achievable is
Technology (BACT) required to control discharge of
toxic pollutants to POTW
National Pollutant Discharge 40 CFR 122 Subpart C Use of best available technology
Elimination System Permit economically achievable for toxic
Regulations pollutants discharged to a POTW.
Discharge must be Consistent 40 CFR 122 Discharge must comply with EPA-
with the Requirements of a approved Water Quality Management
Water Quality Management Plan.
Plan Approved by EPA
Superfund Amendments and 42 USC Sect 9601 et Discharge must comply with Federal
Reauthorization Act (SARA) seq Water Quality Criteria
Discharge must not increase Section 121 Selected remedial action must
contaminant concentrations (d) (2) (B) (ii) establish a standard of control to
in offsite surface water maintain surface water qua·lity.
7-3
TABLE 7-1 (CONT)
STANDARD, REQOI~;··· CITATION DESCRIPTION
CRITERIA, OR LIMITATION
CLEAN AIR ACT
Air Use Approval 40 CFR 60 (Subpart A) Requires notification and
performance testing by owner or
operator.
Particulate Discharge 40 CFR 60 (Subpart B) Defines limitations for
Limitations and Performance · particulate emissions, test
Testing methods, and monitoring
requirements for incinerators
SAFE DRINKING WATER ACT
Maximum Contaminant Level 40 CFR 142 EPA has also established Maximum
Goals 50 FR 46936 Contaminant Level Goals (MCLGs).
(November 13, 1985) The nonenforceable standards are
based on health criteria. The
MCLGs are goals for the nation's
water supply.
Primary Maximum Contaminant 40 CFR 142 Primary MCL are adopted for the
Levels protection of human health but
include an analysis of feasibility
and cost of attainment.
7-4
---._ 1!111 1B1!1 _. ,_ 11111 a; liail liliil -l!l!I 1!!!!!1 ==i m= r:;;;; liiiliiil
TABLE 7-1 (CONT)
:-: .. · ;-····,•,•,:'·_
STANDARD, REQUJ:REMENT, CITATION DESCRIPTION
CRITERIA, OR.LIMITATION
STATE
North Carolina Water Quality NCAC-15A-2B Surface Water quality standards
Standards
North Carol1na Groundwater NCAC-15A-2L Groundwater quality standards,
Standards regulates injection wells
Wastewater Discharge to NCAC-15A-2H Regulates surface water discharge
Surface Waters and discharges to POTW.
North Carolina Hazardous NCAC-15A-13A Siting and design requirements for
Waste Management Rules hazardous waste TSDs.
North Carolina Sedimentation NCAC-15A-4 Requirements for prevention of
Control Rules sedimentation pollution.
North Carolina Air Pollution NCAC-15A-2D Air pollution control air quality
Control Requirements and emissions standards.
7-5
TABLE 7-2
POTENTIAL LOCATION-SPECIFIC ARARS
I SITE FEATURE/LOCATION_ I CITATION I DESCRIPTION I
Within 61 meters (200 ft) of a 40 CFR 264 .18 (a) New treatment, storage, or ' fault displaced in Holocene disposal of hazardous waste
time prohibited; applies to RCRA
hazardous waste, treatment,
storage, or disposal.
Within 100-year floodplain 40 CFR 264.18 (b) Facility must be designed,
constructed, operated, and
maintained to avoid washout:
applies to RCRA hazardous waste
treatment, storage or disposal.
Within floodplain Protection of floodplains ( 40 Action to avoid adverse
CFR 6, Appendix A) ; Fish and effects, minimize potential
Wildlife Coordination Act (16 harm, restore and preserve
USC 661 ·et seg): 40 CFR 6.302; natural and beneficial values;
Floodplains Executive Order (EO applies to action that will
11988) occur in a floodplain, i.e.,
lowlands, and relatively flat
areas adjoining inland and
coastal waters and other flood
prone areas.
Within area where action may National Historical Requires that action be taken
-cause irreparable harm loss or Preservation Act (16 USC to recover and preserve
destruction of significant Section 469) ; 36 CFR Part 65 artifacts when alteration of
artifacts terrain threatens significant
scientific, prehistorical,
historical, or archaeological
data.
7-6
I SITE FEATURE/LOCATION • I
Critical habitat upon which
endangered species or
threatened species depends
Wetlands
Wetlands
TABLE 7-2 (CONT)
POTENTIAL LOCATION-SPECIFIC ARARS
CITATION
Endangered Species Act of 1973
(16 use 1531 et seg) : 50 CFR
Part 200, 50 CFR Part 402: Fish
and Wildlife Coordination Act
(16 USC 661 et seg); 33 CFR
Parts 320-330
Clean Water Act Section 404; 40
CFR Part 230, 33 CFR Parts 320-
330.
40 CFR-Part 6, Appendix A
7-7
I DESCRIPTION I
' If endangered or threatened
species are present, action
must be taken to conserve
endangered or threatended
species, including consultation
with the Dept of Interior.
For wetlands as defined by US
Army Corps of Engineers
regulations, must take action
to prohibit discharge of
dredged or fill material into
wetlands without permit.
For action involving
construction of facilities or
management of property in
wetlands, action must be taken
to avoid adverse effects,
minimize potential harm and
perserve and enhance wetlands
to the extent possible.
I SITE FEATURE/LOCATION
Wilderness Area
Within area affecting
national wild, scenic
or recreational rivers
Classification and
potential use of an
aquifer
Construction within
State highway system
right-of-way.
Construction within a
railroad right-of-way
----------I!!!!! 111!!!!!!1 l!!l!!1 I!!!!!!!
TABLE 7-2 (CONT)
POTENTIAL LOCATION-SPECIFIC ARARS
I CITATION I DESCRIPTION
Wilderness Act (16 use For federally-owned area designated as wilderness 1131 et seg:); 50 CFR area, the area must be administered in such 35.1 et seg:. manner as will leave it unimpaired as wilderness and to preserve its wilderness.
Wild and Scenic Rivers For activities that affect any of the rivers Act (16 use 1271 et specified in section 1271 (a); must avoid taking seg:) :section 7 (a) ; 40 or assisting in action that will have direct CFR 6.302(e) adverse effect on scenic river.
Guidelines for GW Consider Federal and State aquifer Classification, EPA GW classifications in the assessment of remedial Protection Strategy response objectives. and NCAC-15A
NCAC, Subchapter 2E, Written permission from the NC DOT is required Section .0420, for construction on state highway right-of-ways. Construction Within
Right of Way
Federal Railroad Permission from the Railroad prior to Administrative, Tel. construction withing their right-of way. Conversation 9/4/91.
7-8
I
I
D
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
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 shown
in Table 7-3 and 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 (MCLs)
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 7-4.
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 essentially identical to
the SOWA MCLs established by the EPA (Table 7-4). North Carolina
Groundwater Standards (North Carolina Administrative Code (NCAC)
Title 15A, Chapter 2, Subchapter 2L) are for Class GA groundwater,
best usage as a source of drinking water. As seen in Table 7-4, 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.
7-9
l!!!!l!I I!!!!!! !!!!I I!!!!!
TABLE 7-3
POTENTIAL CHEMICAL-SPECIFIC ARARS
.
STANDARD, REQUIREMENT, CITATION DESCRIPTION CRITERIA, OR LIMITATION.
Safe Drinking water Act 40 use Sect 300
National Primary Drinking 40 CFR Part 141 Established health-based standards Water Standards for public water systems (MCLs)
National Secondary Drinking 40 CFR Part 143 Establishes welfare-based Water Standards standards for public water systems
(secondary MCLs)
Maximum Contaminant Level Pub.L No 99-399,100 Establishes drinking water quality Goals Stat. 642 (1986) goals set at levels of no known or anticipated adverse health effect.
Clean Water Act 33 use sect 1251-1376
Water Quality Criteria 40 CFR Part 131 Sets criteria for water quality based on toxicity to aquatic
organisms and human health.
RCRA, as amended 42 use 6905, 6912,
6924, 6925
RCRA Groundwater Protection 40 CFR Part 264 Provides for gw protection
standards, general monitoring
requirements and technical
requirements.
Dept of Transportation 49 use 1801 Regulates off-site transportation Hazardous Materials of specific hazardous chemicals Transportation Act and wastes.
7-10
!II!! 1B! al 111111 -1111111 m:; 1111!1 al lillil ;aa liilE liill .. --!!!!!!!!I l!!!!!l!!!I I!!!!!!!
. ··.·•,.· ,.·. ·':'• .
STANDARD, REQUTRBMBNT;
CRJ:TERIA, OR LIMITATION.
RCRA SWMU Requirements
Solid Waste Disposal Act
Land Disposal
CERCLA
Clean Air Act
National Primary and
Secondary Ambient Air
Quality Standards
Occupational Safety and
Health Administration
National Emissions Standards
for Hazardous Air Pollutants
TABLE 7-3 (CONT)
POTENTIAL CHEMICAL-SPECIFIC ARARS
·CITATION DESCRIPTION
.
40 CFR Part 254.3-4 Provides for protection of gw at solid
waste management unit.
42 USC 6901 et seq
40 CFR Part 268 Established a timetable for restriction
of land disposal of hazardous waste.
42 USC 9601 et seq. Provides for response to hazardous
substances released into the
environment and the cleanup of inactive
hazardous waste disposal sites.
40 USC 1857
40 CFR Part 50 Sets primary and secondary air
standards at levels to protect public
health and welfare.
29 CFR 1910 Part Provides safety rules for handling
120 specific chemicals for site workers
during remedial activities.
40 CFR Part 61 Provides emissions standard for
hazardous air pollutants for which no
ambient air quality standard exists.
7-11
11111 ma 1111111 11111 lliiil a.a aa llliil liliiiil ----illii
. ··. .-:-·
STANDARD, REQUJ"R~; > ·.·. CRITERIA, OR LIMITATION •
STATE
NC Water Quality Control
Standards
NC Drinking Water Act
NC Drinking Water and
Groundwater Standards
NC Solid and Hazardous waste
Management Act
NC Comprehensive
Environmental Response Act
TABLE 7-3 (CONT)
POTENTIAL CHEMICAL-SPECIFIC AR.ARS
.. .
CITATION DESCRIPTION
15A NCAC 2B Establishes water quality requirements applicable to all surface waters of NC which protect publich health and the environment.
130A NCAC 311-327 Regulates water systems within the State which supply drinking water that may affect the public health.
15A NCAC Chapter 2L Establishes groundwater classification and water quality standards.
130 A NCAC
130A 310.1-310.23
7-12
-
I
I
I
I
I
I
I
I
PESTICIDE
ALDRIN
ALPHA-BHC
BETA-BHC
DELTA-BHC
GAMMA-BHC
DIELDRIN
ENDRIN KETONE
TOXAPHENE
TRICHLOROETHENE
MAX.GW
CONC.
0.1
36
25
29
30
2
4
10
200
TABLE 7-4
GROUNDWATER ARARs
SDWA NORTH
MCL CAROLINA
DWS
NA NA
NA NA
NA NA
NA NA
0.2 0.2
NA NA
NA NA
3 3
5 5
NORTH
CAROLINA
GWQS
NA
NA
NA
NA
0.0265
NA
NA
0.031
2.8
I Concentrations are given in ug/1
SDWA MCL -Safe Drinking Water Act Maximum Contaminant Level.
North Carolina DWS -NC Drinking Water Standards I North Carolina GWQS -NC Groundwater Quality Standards
CRQL -Contract Required Quanititation Limit
CERCLA
CRQL
0.05
0.05
0.05
0.05
0.05
0.1
0.1
1. 0
1.0
I MCL for Gamma-BHC currently is 4 ug/1, New MCL (0.2) effective July 30, 1992
I
I
I
I
I
I
NA -Not Available
7-13
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
Groundwater remediation levels are provided in Table 7-5.
Soils
There are no promulgated Federal or State standards applicable for
contaminants in soils at the Site.
7-14
D
R
m
I
I
m
I
I
I
I
I
I
I
I
I
I
I
I
I
TABLE 7-5
GROUNDWATER REMEDIATION LEVELS
MAXIMUM GW GROUNDWATER CORRESPONDING BASIS OF
PESTICIDE CONCENTRATION REMEDIATION RISK LEVEL GOALS
(UG/L} LEVEL
(UG/L}
ALDRIN 0.1 0.05 5. 0 X l0E-6 CRQL
ALPHA-BHC 36 0.05 1. 3 x l0E-6 CRQL
BETA-BHC 25 0.05 4.0 X l0E-7 CRQL
DELTA-BHC 29 0.05 ND CRQL
GAMMA-BHC 30 0.05 3.0 x l0E-7 CRQL
DIELDRIN 2 0.1 8.3 X l0E-6 CRQL
ENDRIN KETONE 4 0.1 ND CRQL
TOXAPHENE 10 1.0 6.7 x l0E-6 CRQL
TRICHLOROETHENE 200 2.8 1.0 X l0E-6 NCGWQS
CRQL -Contract Required Quanititation Limit
NCGWQS North Carolina Groundwater Quality Standards
ND -Not Determined, Toxicity data unavailable, risk levels could not be
calculated.
7-15
D
I
I
I
u
u
I
I
I
I
I
I
I
I
I
I
VIII. DESCRIPTION OF ALTERNATIVES
Tables 8-1 and 8-2 summarize the technologies considered for
remediating the groundwater and soil contamination, respectively, at
the Geigy Site. These 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 1B: 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 activities 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
based
be no
alternative involves no capital costs. Operating costs are
on the review of Site conditions every five years. There would
maintenance costs.
Total Construction Costs -
Present Worth O & M Costs
Total Present Worth Costs -
$ 0
$140,000
$140,000
Alternative 1B: Long-term Moµitoring 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
8-1
TABLE 8-1
I GROUNDWATER REMEDIATION TECHNOLOGIES CONSIDERED
I
I
I
I
I
I
TECHNOLOGY
GROUNDWATER RECOVERY
Extraction Well
Interception Trenches/
Subsurface Drains
No Action
GROUNDWATER TREATMENT
Air Stripping
Activated Carbon Adsorption
Sorptive Resins
Chemical Oxidation (UV-Ozone)
Biological Treatment
Land Treatment
I GROUNDWATER DISCHARGE
I
I
Horizontal Infiltration Gallery
Injection Wells
Surface Water Discharge
POTW
I GROUNDWATER CONTAINMENT
I
I
I
I
I
Slurry Wall, Capping and
Well Point Extraction
STATUS
8-2
Retained
Retained
Retained
Rejected
Retained
Rejected
Retained
Rejected
Rejected
Retained.
Rejected
Rejected
Retained
Retained
REASON
Effectiveness
Effectiveness/
Reliability
Effectiveness
Effectiveness
Provisionally
Depending on
Application Rates
Not permittable
Not cost effective
I
I
TABLE 8-2
I SOIL REMEDIATION TECHNOLOGIES CONSIDERED
I
I
I
I
I
I
I
I
I
TECHNOLOGY
DIRECT TREATMENT
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
I OFF-SITE TREATMENT
I
I
I
I
I
I
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
Re'jected
Retained
8-3
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
I
D
D
I
I
I
I
I
I
I
I
I
I
I
I
I
I
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 five 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 wculd require special excavation equipment with extended reach capability. Permeability of the slurry wall would be lE-07 cm/sec. The slurry wall could be constructed using the. hie-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 HDPE liner, drainage net, filter fabric, soil cover and vegrjation. 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.
8-4
D
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
B
I
I
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 wall would have no effect upon groundwater in the second uppermost aquifer. Groundwater recovery would be implemented outside of the cap/slurry wall system for groundwater exceeding 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, review of the effectiveness and protectiveness of this alternative every five years would be required by SARA.
Total Construction Costs
Present Worth O & M Costs
Total Present Worth Costs -
$ 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 Cocnty 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.
8-5
I
I
I
I
I
I
I
I
I
I
I
I
I
•
I
I
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 RD.
Costs for this alternative are based on discharge to the POTW, would have both higher construction and operating costs discharge to an infiltration gallery. Costs are based remediation period of thirty years.
Total Construction Costs
Present Worth O & M Costs
Total Present Worth Costs -
$ 710,000
$1.500,000
$2,210,000
B. Remedial Alternatives to Address Soil Remediation
The 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
which
than
on a
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 -
8-6
$ 0
$140,000
$140,000
I
I
B
H
I
I
I
I
I
I
I
I
I
I
I
I
_I
Alternative 2 -Off-Site Disposal
This alternative would involve the excavation and off-site disposal
of the top foot of soils exceeding the remediation levels. Soils
would be taken to either a secure landfill or a fixed-based
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 would be considered hazardous by
characteristic and incinerated to satisfy land disposal restrictions
(LOR). 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 ya:!:ds)
went either to a secure landfill (lowest cost) or to an incinerator
(highest cost). The greatest likelihood is tli.at 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
Landfilling
$600,000
0
$600,000
Alternative 3 -Cappingr-----
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
8-7
I
I
I
g
I
R
I
I
I
I
I
I
I
I
I
I
I
I
I
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 the 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
In this alternative, soils exceeding the remediation levels would be excavated and treated utilizing low temperature thermal technology. The treated soil will be returned 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
8-8
I
g
I
0
D
D
I
I
I
I
I
I
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 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 low (approximately 1,000 cubic
yards), the treatment unit utilized would probably be small; 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, materials screening and
handling will require a approximately four to six additional months.
This alternative may also require implementation of a treatability
study, which would add an additional twelve months to the estimated
time to implement this alternative. Implementation time for this
alternative will be approximately two years, with a total cost as
shown below.
Total Construction Costs -
Present Worth O & M Costs
Total Present Worth Costs-
Alternative 5 -On-Site Incineration
$700,000
$700,000
0
Incineration is a thermal treatment technology which util.i.zes
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 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 F is
maintained at all times to ensure that any volatile and
8-9
I
n
0
R
I
I
I
I
I
I
I
I
I
I
I
I
I
I I
I
semi-volatile organic constituents in the waste stream are driven 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
The air pollution control system will achieve performance standards of ( 1) hydrogen chloride of less than 4 lb/h~ 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 incineration is similar to on-site thermal desorption with regard 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, several assumptions were made and a relative cost was derived for this option, whicl'. is shown below.
Total Constructon Cost -$1,327,100 Present Worth O & M Cost -0 Total Present Worth Cost -$1,327,100
8-10
D
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
IX. SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
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.
2.
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.
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. 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.
4.
5.
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.
9-1
I
I
I
I
I
I
I
R
I
I
I
I
I
I
I
I
I
I
6.
7.
Imolementability 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
a.
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 Acceotance 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 USC 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 9-1 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
9-2
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
GROUNDWATER
Alternative lA
Alternative 1B
Alternative 2
Alternative 3
SOIL
Alternative 1
Alternative 2
Alternative 3
Alternative 4
Alternative 5
TABLE 9-1
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
On-Site Incineration
9-3
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
$1,327,100
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
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, Alternatives 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 7 0 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 t.reatment.
9-4
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
Short-term Effectiveness
All of the alternatives can be implemented without significant risks
to the community or on-site workers and without adverse environmental
impacts. Construction schedules would be as follows: Alternative lA
-None; Alternative 1B -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, 1B, and 3 would not pose significant concerns
regarding implementation. Construction
Alternative 2 would approach the limits of
to the required depths (up to 70 feet).
system for Alternatives 2 and 3 could
discharge requirements were defined.
Cost
of the slurry wall for
technical feasibility due
Design of the treatment
not be conducted until
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 Incineration
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).
9-5
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
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 remediation
levles were achieved.
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.
§.b,ort-term Effectiveness
All of the alternatives can be implemented without significant r::.sks
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, however the low volume of contaminated soils
requiring remediation renders these alternatives impractical at this
site.
Total present worth costs foi:: the soil remediation alternatives are
presented in Table 9-1.
C. Modifying Criteria
State and community acceptance are modifying criteria that shall be
considered in selecting the remedial action.
9-6
I
D
m
I
I
I
I
I
I
I
I
I
I
I
R
I
I
I
I
State Acceptance
The State of North Carolina concurs with the selected remedy.
Community Acceptance
A proposed plan fact sheet was released to the public on March 26, 1992. The proposed plan public meeting was held on March 31, 1992. The public comment period on the proposed plan was held from March 26, 1992 to May 25, 1992. The letters, comments, and questions asked during the March 31st meeting and received during the comment period . are summarized in the attached Responsiveness Summary.
9-7
D
I
I
I
I
I
I
I
I
I
I
I
I
I
•
D
I
I
I
X. THE SELECTED REMEDY
section 121 of CERCLA, as amended, 42 u.s.c. §9621, and the National Oil and Hazardous Substance Pollution 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 2 -Off-Site ''Disposal of Soils exceeding
Soil Remediation Levels
A. Groundwater Remediation
The treatment technology selected for remediation of the contaminated groundwater shall consist of a groundwater extraction and treatment systems. An overall monitoring program shall be developed and implemented for the Site. Groundwater contaminated above the remediation levels indicated in Table 7-2 shall be extracted across the entire Site. Extraction will continue until the remedia-::ion levels are achieved
Actual design of the extraction system shall be established during the Remedial Design. For costing purposes, nine recovery wells (seven in the uppermost aquifer and two in the second uppermost aquifer) have been anticipated.
Treated ground water shall be discharged to the Moore County Publicly Owned Treatment Works (POTW) or an infiltration gallery. The treated groundwater shall meet Moore County POTW preliminary discharge requirements. Discharge to the POTW will require the construction of a force ma'in to the nearest manhole, approximately 1/2 mile away. Actual discharge and operating parameters shall be established during the Remedial Design.
The treatment system shall •involve at least two carbon adsorption canisters in series, to maximize carbon usage and provide protection against breakthrough. Breakthrough of the carbon will be monitored as part of the annual operation and maintenance requirements. The spent carbon shall be shipped offsite for destruction, disposal or reactivation. The most cost efficient option will be identified and selected. Actual treatment requirements shall be determined during the Remedial Design and will be dependent on the final discharge limits.
10-1
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
n
The conceptual flow diagram for groundwater treatment is presented. in Figure 11. The groundwater treatment shall involve the follow1.ng 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 to 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.
10-2
Pesticides = IO lb/yr
Extraction
Wells (9)
Equalization
Tank .
-
, '' ... Monitoring
► ~ -Discharge to .-.. I I -I I -
~ Moore
' '>. ' County ~
' POT\V or Q ~ 20 gpm Carbon On-Site
Adsoq~tion Infiltration
Gallery
Figure I I
Groundwater Treatment
Flow Diagram
IO -3
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
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
adsorbate 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.
If it is determined, on the basis of the preceding criteria and the
system performance data, that certain portions of the aquifer cannot
be restored to their beneficial use, all of the following measures
involving long-term management may occur, for an indefinite period of
time, as a modification of the existing system;
a) engineering controls such as physical barriers, or long-term
gradient control provided by low level pumping, as containment
measures;
b) chemical-specific ARARs will be
those portions of the aquifer
impracticability of achieving further
waived for the cleanup of
based on the technical
containment reduction;
c) institutional controls will be provided and maintained to
restrict access to those portions of the aquifer which remain
above health-based goals, since this aquifer is classified as a
potential drinking water source;
d) continued monitoring of specified wells; and
e) periodic re-evaluation of
groundwater restoration.
remedial technologies for
The decision to invoke any or all of these measures may be made
during a periodic review of the remedial action, which will occur at
intervals of at least every five years, in accordance with CERCLA
121( c). To ensure State and public involvement in this decision at
this Site, any changes from the remediation goals identified in this
ROD will be formalized in either an' Explanation of Significant
Difference document or an Amendment to this Record of Decision,
thereby providing an opportunity for State and public comment.
10-4
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
Soil Remediation
The treatment technology selected for remediation of pesticide
contaminated soils at the Geigy Site is off-site disposal.
The top foot of soil exceeding the remediation levels in Table 6-5,
shall be excavated and stock-piled on-site. 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 shall be
considered hazardous by characteristic and incinerated to satisfy
land disposal restrictions (LDR). Soils passing the TCLP shall 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 te'sting.
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.
C. Performance Standards
Performance standards are. defined as any applicable or relevant and
appropriate standards/ requirements, cleanup goals and/or levels, or
remediation goals and/or levels to be achieved by the remedial
action. The performance levels to be attained by the Geigy remedial
action are specified in the following tables:
Groundwater Remediation Levels
Soil Remediation Levels
Table 7-5
Table 6-5
All treatment and disposal of soils shall comply with
relevant and appropriate requirements (ARARs).
construction and operation of the groundwater treatment
be conducted in accordance with all ARARs. See Section
of potential ARARs.
D. Cost
applicable or
The design,
system shall
7 for a list
The total present worth cost for the entire remedial action will
range between $2,810,000 and $4,650,000.
10-5
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
XI. STATUTORY DETERMIBATIONS
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 7-2) 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 more
cost-effective than the other acceptable alternatives considered.
The selected remedies provide greater benefit for the cost because
they permanently treat the waste.
11-1
I
u
m
I
B
I
I
I
I
I
I
I
I
I
I
I
I
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.
11-2
I
D
D
D
I
w
I
I
B
I
I
I
I
I
I
I
I
I
XII. Documentation of Significant Change
Based on c?mments received during the comment period, the Agency no longer believes the preferred alternative presented in the proposed plan (Alternative 4 -On-Site Thermal Desorption for soil) provides the most appropriate balance among the alternatives with respect to the nine evaluation criteria.
Information available to the Agency suggests that alternative 2, Off-site Disposal, presented in the proposed plan provides the best balance of trade-offs. The Agency has selected off-site disposal of the contaminated soil in conjunction with Groundwater Pump and Treat System as the final remedy.
More specifically, the practicality of on-site treatment at this site has been greatly reduced. The main reason for this is the reduction of soil requiring treatment. The originally estimated amount of 2,200 cubic yards of contaminated soil has been reduced to 1,000 cubic yards. This 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.
The Agency's initial volume estimate of contaminated soil was the result of a conservative approach. The original estimate considered the risk to human health based on future excavation at the site that could bring contaminated subsurface soil to the surface and thereby cause adverse health or environmental effects by direct contact. Further evaluation of the data revealed that under any scenario the contamination in the subsurface soils posed no threat to human health or the environment when brought to the surface and distributed. This evaluation also revealed that excavation of surface soil to the depth of one foot would provide adequate protection of human health and the environment.
This remedy is
comment period
the State.
in accord with the concerns expressed during by the affected community, responsible parties,
12-1
the
and
I
I
I
I
I
I
I
I
I
I · APPENDIX A
I
I
I
I
I
I
I
I
I
COMPOUND WSW 1S
ACETONE ND 108
XYLENE ND 4J
1,2,4-ND ND
TRICHLOROBENZENE
81S(2-ETHYLHEXYL) ND ND PHTHALATE
TRICHLOROETHENE ND ND
TABLE 1
PHASE 1 GROUNDWATER ANALYTICAL RESULTS
VOLATILES AND SEMI-VOLATILES (PPB)
NELL NUMBER
1D. 2S 3S 4S 4D 5S
1308 ND 1008 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
8 -Detected in Blank at Similar Concentrations J -Quantitative Estimate
ND-Not Detected
A-I
l!!lll!!!I 1!!!!!113
6S 6D PZ-1
ND ND ND
ND ND ND
5J ND ND
ND ND ND
ND 11 ND
---------
·•· < COMPOUND·
WSW
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
..
· 1S
ND
ND
ND
ND
ND
ND
ND
ND
TABLE 2 PHASE 1 GROUNDWATER ANALYTICAL RESULTS PESTICIDES (PPB)
WELL NUMBER
lD 2S 3S 4S 4D 5S
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
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
-----
·••(){ \ '
COMPOUND . •· WSW -·-1S
ALUMINUM ND 172
ARSENIC NO ND
BARIUM -3 .18 13.38
CADMIUM 5.4 NO
CALCIUM 531 438
CHROMIUM ND 4.8
COBALT ND 18
COPPER 1180 NO
IRON 4790J 955J
LEAD 51B ND
'I'ABLE 3 PHASE 1 GROUNDWATER ANALYTICAL RESULTS
METALS (PPB)
WELL NUMBER
10 2S 3S 4S 40 5S
7620 17100 8660 1040 3650 972
2.28 NO ND ND 2.68 ND
25.88 284 78.6 13.48 22.18 15.68
ND ND ND ND 5.9 5.3
3370 37600 26500 918 4410 2650
9.5 ND 4.3 6.5 ND NO
22.7 ND ND ND ND ND
ND ND 23.9 ND ND NO
4280J 84.3J 36.7J 3290J 2180J ND
10.2 1.8B 2.1B ND 9.2 ND
e -Detected in Blank at Similar Concentrations J -Quantitative Estimate
ND-Not Detected
A-3
6S 60 PZ-1
46.3 214 2570
ND ND 2.0
156 13.28 31. OB
7.6 ND ND
49800 1010 7640
ND ND ND
ND ND 25
ND ND 14.9
ND 76.9J 1750J
1.4B ND 2.08
·,···.: -·:· :-· ·,: . . ·.-·:·:.:.
COMPOUND
WSW 1S
MAGNESIUM 2468 4818
MANGANESE 42.2 13.3
MERCURY ND ND
POTASSIUM ND 706
SELENIUM ND ND
SILVER ND ND
SODIUM 2010 8150
VANADIUM ND ND
ZINC 936 19.7
TABLE 3 (CONT'D)
PHASE 1 GROUNDWATER ANALYTICAL RESULTS
METALS (PPB)
..
WELL NUMBER
10 2S 3S 4S 40 5S
1540 14200 3800 745 1410 1610
91.2J 104 61. 2J 11.28 118J 16.08
ND ND ND ND ND ND
875 71400 21900 1010 ND 3200
2.2 ·1. 2 1. 2 ND 2.5 ND
NO ND 10.6B ND ND ND
4620J 12000 9120J 6030J 5070J 4270J
ND ND ND 38 ND ND
69.3 236 243 11. 9 37.1 43.8
B -Detected in Blank at Similar Concentrations J -Quantitative Estimate
ND-Not Detected
A-4
6S 60 PZ-1
18100 620 1120
44.0J 14. 7B 157J
l.OJ ND NO
160000 869 881
2.4 ND 1.0
ND ND NO
I2900J 2780J 13600
15.4 ND NO
579 32.4 43.9
.... ---------_ ..... _ ---11!!1 --= 111111 -
.•· ·.. \ i ···· .. · ..
COHPOUNI) •·. :_;;· ,-=. -.:·
• <4D
METHYLENE CHLORIDE ND
ACETONE ND
2-BUTANONE ND
1,1,l-ND TRICHLOROETHANE
TRICHLOROETHENE 160
4-METHYL-2-ND PENTANONE
TOLUENE ND
TABLE 4
PHASE 2 GROUNDWATER ANALYTICAL RESULTS VOLATILES (PPB)
WELL NUMBER
6D 8S PZ-1 14D 15D ALLRED
ND ND ND ND ND ND
ND 4B 20B 19B 59B 9B
ND ND ND ND ND ND
' ND ND ND ND ND ND
47 ND BJ ND ND 72
ND ND ND ND ND ND
ND ND ND ND ND ND
B -
J -
ND-
Detected in Blank at Similar Concentrations Quantitative Estimate
Not Detected
A-5
PMP
lB
21B
15
lJ
360
2 ,J
2J
-------------!1!!!!1!1--
. ' . . .-.
COMPOUND
7S
ALPHA-BHC ND
BETA-BHC ND
DELTA-BHC ND
GAMMA-BHC ND
HEPTACHLOR EPOXIDE ND
DIELDRIN ND
4,4'-DDE ND
ENDRIN KETONE ND
TABLE 5
PHASE 2 GROUNDWATER ANALYTICAL RESULTS PESTICIDES (PPB)
WELL NUMBER
es 9S l0S llD 12S 13S
ND ND 2 16 ND ND
ND ND 25 7 ND ND
ND ND 2 4 ND ND
ND ND 0.8J 11 ND ND
ND ND 0.2J ND ND ND
ND ND 2 0.3 ND ND
ND ND 0.2J ND ND ND
ND ND 4 0.4J ND ND
B -Detected in Blank at Similar Concentrations J -Quantitative Estimate
ND-Not Detected
A-6
14D
ND
ND
ND
ND
ND
ND
ND
ND
15D USGS-02
ND ND
ND ND
ND ND
ND ND
ND ND
ND ND
ND ND
ND ND
....... ·.··.·~ : \
·• COMPOUHD . .
ACETONE
BENZOIC ACID
B -Dete
TABLE 6 PHASE l SOIL ANALYTICAL RESULTS VOLATILES & SEMI-VOLATILES (PPB)
k\/ .....
SOIL SAMPLE
· ss.:.01 SS-03 SS-04 SS-05
188 308 18B 12B
3600J ND 200J ND
A-7
SS-06 SS-09
168 68
ND 360J
··t)}/\!?c ::::":: I i.i · :-:::•:.·
COMl'OUND : _::{,:/_:)\'?. •·•··)t••·asLo·1· .. : , .
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)
SOIL SAMPLE
. . ·SS-03 SS-04 SS-05
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
A-8
SS-06 SS-09
6950 1820
0.72J 0.84J
5.8 14. 3
0.62J ND
0.87 ND
4780 4750
3.9 2.8
6.9B 8.08
4670 2810.
··•.•</Y <:<:·: "\)J;:::<_f:;\:-_.,_,; ·_ . :' ; ,::' '. -~.' ': ••, ' COMPOUlfD t ····:_;/•:·-: ·•:?),'"<•i·· ... •···. ss-01 ..
LEAD 92.4
MAGNESIUM 97.58
MANGANESE 33.9J
MERCURY ND
POTASSIUM 243
SELENIUM 0.388
SODIUM 24.08
VANADIUM 9.7
ZINC 46.2
PHASE
SS-03
4.6
1850
II.OJ
ND
327
ND
31.68
11.4
25.58
TABLE 7 (CONT'D)
1 SOIL ANALYTICAL
METALS (PPM)
RESULTS
SOIL SAMPLE
SS-04 SS-05
74.0 13.7
208 5130
13.7J 18.5J
0.188 ND
314 234
0.948 0.438
38.98 28.88
9.6 ND
38.3 52.8
B -Detected in Blank at Similar J -Quantitative Estimate Concentrations ND-Not Detected
A-9
SS-06 SS-09
9.4 24.0
2330 2000
16.IJ 29J
ND ND
ND 221
ND 0.568
18.48 30.38
5.9 ND
78.3 70.7
-----------
TABLE 8 PHASE l SOIL ANALYTICAL RESULTS
PESTICIDES (PPB)
COMPO~<···· / Ii•· ···<·) .· < •· -
SOIL Yss-oi . •·· .. c:. "· r • '.• SS-03 SS-04 ' . -· ·.-:, '
ALPHA-BBC ND 7500C ND
BETA-BBC ND 3300C ND
GAMMA-BBC ND BI0J ND
ALDRIN ND I600C ND
DIELDRIN ND . I300J ND
4,4'-DDE 90 4200C 770J
4,4'-DDD 24 4700C 680J
4,4'-DDT 85 20000C 3500JC
TOXAPBENE 340 ND
B -Detected in Blank at Similar Concentrations J -Quantitative Estimate
ND-Not Detected
ND
SAMPLE
SS-05
2200C
2900C
ND
ND
ND
2500
II000C
25000C
120000c
---
SS-06 SS-09
ND ND
4100JC ND
ND ND
13000C ND
9400C ND
7900J 350
30000C 390
49000C 11100
400000C ND
--------------
. -:-·.' :./ -··.::--::.
COMPOUND . . . ij$;_;20 ss:,.21 ·
ALDRIN 5.9J ND
DIELDRIN 13J ND
4,4'-DDE 58 110
4,4'-DDD 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
TABLE 9
PHASE 2 SOIL ANALYTICAL RESULTS
..
SOIL SAMPLE
SS-22 SS-23 SS-24 SS-25 SS-26
ND ND ND ND 5.9J
ND ND llJ ND ND
130 24 58 540 14J
62 BJ 22 780 ND
250J 32J 40J 3300 9.4J
1300 ND 810 5600 ND
32.1 7.6 27.4 14.9 20.5
41.0 25. 4J 29.8J 113J 33.2J
732 98.5J 37.3J lOOJ 21.8J
A-11
SS-27 SS-28 SS•29
ND ND ND
ND ND ND
83J 110 120
48J 40 48
130J l30J l70J
860 850 920
6.3 29.8 6.8
94.6J 35.6J 66.4J
69.2J I8.2J 41. lJ
---------
TABLE 9 (CONT'D)
PHASE 2 SOIL ANALYTICAL RESULTS
. -. :::·.::•.-·:::. l~i.•.· ''//\/St
QOKl>OUlfl:! \i\_;\\·:· uLio ·/r.,: ... -. ,:,-.·=,::_.-,
:-··-. . -.:. >SS-31
BETA-BHC ND ND
4,4'-DDE 23 160
4,4'-DDD 13J 87
4,4'-DDT 30J 260J
TOXAPHENE 490 1300
COPPER 6.7 I 9.1
LEAD 13.2J 40.0J
ZINC 14.9 52.2
Pesticides results given in ppb Metals results given in ppm
J -Quantitative Estimate ND-Not Detected
.
SOIL SAKPLB ...
SS-32 SS-34 SS-35 SS-36
ND ND 28J ND
49 280J 610J 960J
22 74J 320J 360J
59J 360J 590J 1300J
430 NO 3300 ND
9.0 32.4 13.3 37.7
32. lJ 46.5 44.lJ 69.7J
24.0 102 27.7 63.8
A-12
11!!!!!1 !!!!I
·•.•··-'··
SS-37 SS-38 SS-39 ss.J,o
ND ND ND ND
6.0J 220 190 85
8.7J 99 69J 83
23J 170J 220J 300J
ND ND ND 920
4.4 5.7 ]9.0 4.9
120J 18.5J 27.6 82.0
36.5 19.8 49.l 28.9
-- ---
.·· \~····.
COHPOU!IIO.· ..•• i ssfil4.ti .ss~,2•.···
ALPHA-BHC ND ND
BETA-BHC ND ND
DIELDRIN ND ND
4,4'-DDE 180 170
4,4'-DDD so 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
SOIL SAMPLE
SS-43 SS-44 SS-45 SS-46 SS-47
ND ND ND ND ND
ND ND 4.9J 120J ND
ND ND ND ND ND
470 140J 140 1600J OOOJ
360 BOJ 54 1500J 660J
2800J 210J lBOJ 5200J 1600J
2300 llOOJ 860 llOOOJ 8000J
3.7 16.9 18.7 ND 16.1
96.0 40;4 25.0 76.2 22.7
40.7 30.2 32.0J 42.7 17.7B
A-13
liliiii -
i',>'.r.·•
.,··· .. SS-49 SS-50 ss.,.51
330J ND ND
lSOJ ND ND
ND ND 390J
lOOOJ 370J 550J
I 1900J 580J 2000J
4900J IOOOJ 3000J
15000J 5BOOJ 18000J
4.3B 14 .5 24.1
65.5 22.7 26.4J
130 33.7J 45.4
-------. --

-
l!!!!l!!I
. .,. !fit·. ..
· .. ( :· .
COMPOUND· ss::s2/. ssL53). <ss:54 .
ALPHA-BHC ND ND ND
BETA-BHC ND 5.9J ND
DELTA-BHC ND ND ND
GAMMA-BHC ND ND ND
DIELDRIN ND ND ND
4,4'-DDE 34 120 460J
4,4'-DDD 32 220 430J
4,4'-DDT 62J 340J 740J
TOXAPHENE 400 3600 4100J
COPPER 4.1 4.1 16.7
LEAD 6.9J 16.2J 21.lJ
ZINC l.6J 46.1 8. 4J
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
. . .. .· SOIL SAMPLE
SS-56 . SS-57 . SS-58 SS-59
ND ND 75J ND
43J ND 220J ND
ND ND 33J ND
ND ND 41J ND
ND 1500J ND ND
800J 7300 4100J 1600J
830J 5700J 5700J 1200J
lOOOJ 8900J 9000JC 2300J
5400J 37000J 83000J 14000J
21.9 11. 1 18.3 10.9
33.2J 32.3 33.7 38.0J
7.7J 26.0J 16.7J 25.BJ
A-14
-
·.·.~
... _. ..
SS-60 SS-61 · ssif121
ND ND ND
60J ND ND
ND ND ND
ND ND ND
ND ND ND
670J 3000J 4000J
730J 3500J 4800J
lOOOJ 7800JC 8200JC
9300J 54000J 59000J
20.1 17.9 21.7
24.SJ 26.3J 29.9J
23. 2J 7.0J 5. 4J
- - --------
~ COMPOUNO ····.·•-:--,•,.-...:' .. :-:::·:-.,.-:,v--:·· :.-.,.:-..... ' ···.••·•ss.::,3r •· SS-67
ALPHA-BBC ND ND
BETA-BBC ND 62J
DELTA-BBC ND ND
GAMMA-BBC ND ND
4,4'-DDE 4400J 560J
4,4'-DDD 6100J 660J
4,4'-DDT llOOOJC llOOJ
TOXAPBENE 130000J lOOOOJ
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
SOIL SAMPLE
SS-68 SS-71 SS-82 SS-83
ND ND ND ND
ND ND ND ND
ND ND ND ND
ND NO ND ND
32J 2300J 160 41
14J 6100J 320 110
27J 19000JC 830 310
250J 54000J 3600 510
5.3 7.8 15.5 6.2
10.6J 23.0J 336J 222J
ND 76.4J 99.]J 49.7J
A-15
... · .,•·.
.
::·-·,:· .. ·• SS-84 SS-85 ss..:97 ss ... se
ND ND ND 91
ND 65J ND 380
ND ND NO 69
ND ND NO 46J I
120J 390 250J 530
210 710 570J 1200
550 1900 1500J 2400
1900 2900 4300J 8800
6.9 9.0 5.8 5.6
125 47.3J 13.]J 24.4J
35.4J 56.6J 11 lJ 26.9J
-

-

-

-
--liiiiii --

-

-

-

-
-----------
:,-•Ir > . ,--:
COMPOUND <i: }i '@•• .-
<:~ f'! SS-90
ALPHA-BHC 130J ND
BETA-BHC 260 750J
DELTA-BHC 54J ND
GAMMA-BHC 51J ND
DIELDRIN ND ND
4,4'-DDE 660 1400J
4,4'-DDD 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
SOIL SAMPLE
SS-92 SS-93 SS-94 SS-95
ND 360J ND ND
180J 1500J 53J 5. lJ
ND ND ND ND
.
ND ;_ .--ND ND ND
ND ND ND 22J
llOOJ 5900J 320 120J
2400J 12000JC 590 160J
3900J 38000JC 1600 460J
ND ND ND 45J
ND ND ND 49J
35000J 78000J 3900 1500
5.6 9.7 33.7 5.6
26.4J 87. lJ 22.3J 72.5J
51.SJ 43.lJ 24.6J 43.9J
Ac-I 6
·;
SS-96 SS-97 ss-ioj\
ND ND ND
ND 5.SJ ND
ND ND ND
ND ND ND
ND ND ND
3.7J 65 1800J
7.7J 100 3300J
25 300 68000JC
ND ND ND
ND ND ND
ND 850 2 lO_OOJ
3.38 6.9 9.4
ll.8J 84.3J 198J
7.68-51.0J 121J
----1!1111 == -liiii iiiii ---

-

-
I
U··-ct\ .··· /--:<~: . .
COlU'OUND ss41 · w 0:ies~1os
ALPHA-BHC ND ND
BETA-BHC NO ND -DELTA-BHC ND ND
GAMHA-BHC SlJ ND
HEPTACHLOR ND ND
ALDRIN ND ND
DIELDRIN ND ND
4,4'-DDE JOOJ 870J
4,4'-DDD 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
TABLE 9 (CONT'D)
PHASE 2 SOIL ANALYTICAL RESULTS
SOIL SAMPLE
SS-106 SS-107 ss-110 SS-114
ND ND ND ND
ND ND 520J 62J
ND ND ND ND
ND ND ND ND
ND ND ND ND
ND ND ND ND
ND ND ND ND
920J 130 5800J ND
1800J 260 15000JC 480
4900J 660 41000JC 760
18000J 2100 130000J 4700
7.3 14.8 29.6 4.1
23.6J 188J 53.6J 5.2J
60.SJ 102J 219J 14.4J
A-17
----·-
. ·•·· ·••·· \ .· .• <:< : :.<·· <
··.·.: .·:··:·:.;·:,::::: ,:· .. -':'(· \: 1 SS-115 SS-117 ss.;11, ·.··
ND ND 130J
130J 130J 970J
ND ND llOJ
ND ND llOJ
ND ND 190J
60J 44J 350J
ND ND 630J
180J 230J 790J
BOOJ 900J 3300J
1600J 1700J 3800J
8500J 18000J 34000J
4.0 ND 5.9
6.6J 3.9J 3.2J
12.9J 18.SJ 82.6J
· TABLE 10 BACKGROUND SOIL SAMPLES ANALYTICAL RESULTS
SOIL SAMPLE COMPOUND
ss-121
4,4'-DDE 75
4,4'-000 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
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
A-18
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
TABLE 11
PHASE 3 SOIL ANALYTICAL RESULTS
...
COMPOUND. >
. is:it,1i+2'· SS-49~2
ALPHA-8HC ND ND
8ETA-8HC 12 ND
DELTA-8HC ND ND
GAMMA-8HC ND ND
DIELDRIN ND ND
4,4'-DDE 130 58
4,4'-DDD ND ND
4,4'-DDT 180 170
ENDRIN KETONE ND ND
TOXAPHENE 1000 810
COPPER 5.4 7.0
LEAD 3.78 8.408
ZINC 9.0 17.3
Pesticides results given in ppb
Metals results given in ppm J -Quantitative Estimate
ND-Not Detected
SOIL
SS-51-2 SS-58-2
ND llOJ
510C 180J
ND 120J
ND 78J
ND 280J
2500C lOOOJC
1400C 1300JC
0000c 5400JC
ND ND
38000C 24000JC
17.7 14.9
27.58 25.7
57.9 22.4
B -Detected in Blank at Similar ConcentLations C -Confirmed by GC/MS
SAMPLE
SS-65-2
ND
36
42
ND
49
ND
ND
ND
ND
330
9.4
9.0
11.7
A-19
SS-67-2
ND
ND
ND
ND
ND
ND
NO
190
ND
460
5.7
7.9
3.4
. > > . ·. ,, ..
SS-69-2 SS-71-2
ND 210C
67J 400C
ND 33
lJJ 45
ND 36
ND 74
ND NO
NO 4JOC
NO 280
260J 1400
2.9 4.28
4.5 2.4
6.3B 5.98
----------------..
TABLE 11 (CONT'D)
PHASE 3 SOIL ANALYTICAL RESULTS
. . -="'
SOIL COMPOUND .. :) 81*, SS-72-5 SS-73-5 SS-76-5
ALPHA-BHC ND ND
BF;TA-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
1500C
1600C
3400C
ND
ND
ND
ND
280000C
8.5
6.1
16.6
B -Detected in Blank at Similar Concentrations C -Confirm~d by GC/MS
ND
ND
ND
ND
ND
ND
100
270
2600C
180
3400
8.8
4.5B
8.1B
SAMPLE
SS-76-10 SS-90-2 SS-90-5
ND 89J ND
ND 180J 11
ND 59J ND
ND 48J ND
ND ND ND
ND 32J ND
59 ND ND
230 ND ND
3300C ND ND ..
110 ND ND
1900 310J 2200
3.7 1.5 2.8
2.3B 2.0J 3.50J
3.2B IO.I 3.1
A-20
..
. . .
. ss .. ,1;2,
1600C
820C
890C
360C
ND
ND
370C
630C
3000C
ND
ND
3.0
2.6
4.2
------------l!l!!!!!I
l!!!!!!I
TABLE 11 (CONT'D) PHASE 3 SOIL ANALYTICAL RESULTS
. , ... ·.·. ... \ .
COMPOUND •. D ;!a;9,;:J5. SS-91-10
ALPHA-BHC HD 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'-DDD ND ND
4,4'-DDT ND ND
TOXAPHENE ND ND
COPPER 6.3 3. 68
LEAD 4.8 2.08
ZINC 7.8 6.0
Pesticides results given in ppb Metals results given in ppm J -Quantitative Estimate ND-Not Detected
SS-92-2
24
12
ND
11
ND
ND
ND
ND
ND
ND
ND
1.18
1.28
3.58
B -Detected in Blank at Similar Concentrations C -Confirmed by GC/MS
SOIL SAMPLE
SS-92-5 SS-93-2 SS-99-2
46 ND ND
38 27 ND
23 ND ND
21 ND ND
ND ND 48
ND ND 130
ND ND 250
ND 69 27
ND 44J ND
53 340 370
440 810 ND
6.4 2. 408 1. 7
4.7 5 .40 68.9J
8.7 6.70 10.5
A-21
liiiiiiil . iili
··. :)
.,.,.• -. -· ·:::-:: SS-100-2 ss~100 .. 5
1200C 11
ND 48
ND ND
ND ND
ND ND
ND ND
ND ND
ND ND
ND ND
7600C 140
15000C ND
3.3 7.6
40. 1 4.8
49.7 21.3
-- - ---------1!!!!1
. COMPOUND i( ~--• .. • .. ····•· ...•. ··· . .·. . ss:--101-;.:r ss-101..;s
BETA-BHC 43J 50
4,4'-0DE NO ND
4,4'-000 NO ND
4,4'-DDT 18J 42
TOXAPHENE 300 220
COPPER 1.28 5.1
LEAD 1.58 3.8
ZINC 5.0 7. 1
Pesticides results given in ppb Metals results given in ppm J -Quantitative Estimate
ND-Not Detected
TABLE 11 (CONT'D) PHASE 3 SOIL ANALYTICAL RESULTS
SOIL SAMPLE
SS-103-2 SS-105-2 SS-109-2
ND 12 1600C
36J 30 570C
NO ND ND
160J 230 ND
560J 1400 ND
8.5 6.9 11.8
2.9B 1. 98 27.6
7.2 10.5 76.2
B -Detected in Blank at Similar Concentrations C -Confirmed by GC/MS
A-22
== liiiiill!I liiiiiiii
ss-110-2. SS-110-5
ND ND
31 27
89 92C
950C 500C
1100 1000
11. 5 7.7
4.2 4. 7
10.2 12.8
- - - - - --------I!!!!!! 1!!!19 -== lliiiiiiil iiii
TABLE 11 (CONT'D) PHASE 3 SOIL ANALYTICAL RESULTS
,,, .....
. tijsl;;iio-10
BETA-BHC ND
DELTA-BHC ND
4,4'-DDT 55
TOXAPHENE ND
COPPER 16.6
LEAD 2.2
ZINC 11. 7
Pesticides results given in ppb Metals results given in ppm J -Quantitative Estimate
ND-Not Detected
SOIL SAMPLE
SS-112-2 SS-113-10
26 16
ND 54
ND ND
ND ND
2.0 9. 1
2.3 4.8J
4.8 12.2
B -Detected in Blank at Similar Concentrations C -Confirmed by GC/MS
A-23
SS-116-5
lJJ
ND
ND
ND
10.2
4.5
11.5
- --------- -111!!!1 !!!!!I 1!11 == ;;;a liiliil liiiii . liiiiiil
TABLE 12
PHASE 3 SOIL ANALYTICAL RESULTS
VOLATILES AND SEMI-VOLATILES (PPB)
·•.·. < •• . • i\•·/·. +·· .. ·•
. .:• ... . . COMPOUND .· .
SS-48-5 SS-48-10
METHYLENE CHLORIDE 17B
ACETONE 180B
BIS(2-ETHYLHEXYL) 59J
PHTHALATE
J -Quantitative Estimate
ND-Not Detected
18B
29B
60J
SOIL SAMPLE
SS-63-5 SS-63-10
39B 35B
42B 35B
ND ND
B -Detected in Blank at Similar Concentrations
A-24
SS-66-5
21B
11B
ND
SS-113-10
28B
41B
68J
- - --· - ------ --· ------
TABLE 13
SOIL BORING ANALYTICAL RESULTS
·.:·.-;:::/:::. 1v•··· : . :
COMPOUN~ .. y··•<•·•·· :?/-: .
0'-1' SB
4,4'-DDE 21
4,4'-DDD 8. 4J
ENOOSULFAN 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
5_B 5'-7'
ND
ND
llJ
ND
2.5B
3.2S
2. 28
B -Detected in Blank at Similar Concentrations
SOIL SAMPLE
SB 10'-12'
ND
ND
l 7J
ND
ND
4.2
2.8B
A-25
SB 15'-17' SB 20•-22•
ND ND
ND ND
22 24
ND ND
3.6B ND
2.2 2.0
1. 7B ND
--------------------
TABLE 14
PHASE 4 SOIL ANALYTICAL RESULTS (PPB)
.. :• .,.·,.::•:-.:,\,:,:: :·--
.· .. -.---
.. CONPOUNl)
SS-58-20S
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
S5-61-20S
13
27
ND
ND
ND
lOOOC
26
lOOOC
3900
B -Detected in Blank at Similar Concentrations C -Confirmed by GC/MS
A-26
SOIL SAMPLE
SS-62-205 SS-63-205
ND ND
ND 640C
ND ND
ND ND
ND ND
1400C 1300C
ND ND
2000C 6700C
5200C 64000C
55:..54 20S
ND
160
ND
ND
130
380
ND
400
ND
-------------------
TABLE 14 (CONT'D)
PHASE 4 SOIL ANALYTICAL RESULTS (PPB)
···:-· -·
COJU>OUND .· .· · .. ·.·····> ·• ss,;.66-20s
BETA-BHC
DELTA-BHC
GAMMA-BHC
4,4'-DDE
4,4'-DDD
4,4'-DDT
TOXAPHENE
J -Quantitative Estimate
ND-Not Detected
290C
150
55
660C
ND
620C
ND
SS-91-lON
850C
ND
ND
640C
lOOOC
14 oooc .
15000C
B Detected in Blank at Similar Concentrations
C -Confirmed by GC/MS
SOIL SAMPLE
SS-92-lON
230C
ND
ND
000c
300
4600C
ND
A-27
SS-93-lON
ND
ND
ND
480
NO
1500C
3800
SS-93-20E
16
ND
ND
lUO
30
440 .
1900
- - - - ---------------
TABLE 15
1991 POST-REMOVAL SOIL ANALYTICAL RESULTS
., /.:·.:,.,,,.,, ,., ...
SOIL SAMPLE COMPO(JNl> /A ii ,: :·
. B C ·o E 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 NO NO NO NO 18
4,4'-000 ND ND ND ND NO 860 NO 750 ND ND
ENOOSULFAN ND ND NO NO NO 2000 NO NO NO 44 SULFATE
4,4'-DDT 1i;o· 52 ND ND 87 NO 170 5800 77 ND
TOXAPHENE 1200 490 56000 ND 6500 110000 1800 42000 1200 2600
ND -Not Detected
A-28
- - - - - - -_,_ ----------
TABLE 15 (CONT'D)
1991 POST-REMOVAL SOIL ANALYTICAL RESULTS
.-,,
:_' '' SOIL SAMPLE COMl'OUND .. .•· . . .. ·· . K : ·-.. ,
:· ·:· <SS-48 SS-64 SS-66 SS-69 SS-73 SS-76 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 4 I 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 llOO
TOXAPHENE 3600 22000 16000 440 2600 7600 18000 27000 2200 6900
ND -Not Detected
A-29
-------------------
TABLE 15 (CONT'D)
1991 POST-REMOVAL SOIL ANALY'I'ICAL RESUL'l'S
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
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
·2 200J 35000 5500
A-30
SD-15
ND
92
ND
ND
25
120
ND
ND
170
4000
-------
... :c;,.i ' . . · .. ''
COMPOUND. . ,· .. -. J.so..'.1
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)
SOIL SAMPLE
SD-2 SD-3 SD-4
ND ND ND
ND ND ND
ND ND ND
ND ND ND
420J 760J 63J
1200J 2300 14J
1800J 4300 54J
11000 14000 ND
A-31
SD-6
ND
ND
ND
ND
970J
4500J
4800J
40000J
-
SD-7 SD-8
ND :T4J
4.4J 300J
ND 24J
ND 52J
79 220J
5:3 llOOJ
84 1400J
540 14000J
- - - ---

-

-
-------.. --l!!!!!!J
. cc ; ·-::=:-, ·:·· ...
COMPOUND
SD-13
ALPHA-BHC ND
BETA-BHC 94J
4,4'-DDE ll00J
4,4'-DDD I400J
4,4'-DDT 2400J
TOXAPHENE 18000J
-J Quantitative Estimate
ND-Not Detected
PHASE 1
SD-18
ND
ND
410
290
440
2200
TABLE 16 (CONT'D)
SEDIMENT ANALYTICAL RESULTS
(PPB)
SOIL SAMPLE
SD-19 SD-20 SD-21
46J ND ND
lJ0J 43J ND
3200J 2400J 570J
lS00J 980J 1600
2700J 2400J 2300
11000 9700 13000
A-32
OSD-21 0SD-22
ND ND
ND ND
llJ 1500J
9.2J 1900
33 4400
ND ND
---

-

-
--------

-

-
---I!!!!!!!!
COMPOUND
OSD-23
DIELDRIN ND
4,4'-DDE 29
4,4'-DDD 13J
4,4'-DDT 73
TOXAPHENE 200
J -Quantitative Estimate
ND-Not Detected
PHASE 1
OSD-24
ND
6600J
21000
44000
ND
TABLE 16 (CONT'D)
SEDIMENT ANALYTICAL RESULTS
(PPB)
SOIL SAMPLE
OSD-25 OSD-26 OSD-27
ND 12J ND
900J 77 ND
1400J 28 25000
3700 80 52000
ND 280 ND
A-33
OSD-28 OSD-29 1.5-3'
ND ND
890J 1700J
2600 4600
5300 13000
21000 36000
-------------------
... ····). i '
CO!U'OUND ..
so-1-1. s
ALPHA-BHC ND
BETA-BHC ND
GAMMA-BHC ND
4,4' ODE 340
4,4'-DDD 410
4,4'-DDT 3700C
TOXAPHENE aoooc
ND -Not Detected
C ~ Confirmed by GC/MS
.·
TABLE 17 PHASE 2 SEDIMENT ANALYTICAL RESULTS (PPB)
SOIL SAMPLE
s0-1-2.s SD-3-1.5 SD-3-2.5 SD-6-1.5
ND ND ND 540C
ND 15 ND 580C
ND ND ND 510
100 ND 34 ND
ND ND ND ND
1400C 61 130 4200C
ND 540 920 58000C
A-34
SD-8-1,5 SD 8 2.5
ND blD-
ND 21
~D ND
ND ND
ND ND -
190 68
2800 1200
------
.· ·.
COMPOUND ...
SD-9-2.5
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-10-1.5 SD-10-2.5 SD-11-1. 5 SD-11-2.5
ND ND 260C ND
ND ND 730C ND
ND ND 150 ND
ND ND ND ND
ND ND 1600C 180
ND ND 270 ND
ND ND 970C ND
ND ND 4400C 370
4600 1300 6B000C 15000C
A-35
0
-l!!!!!!I -
SD-12-1.5 SD-12-2.5
ND ND
ND ND
ND ND
ND ND
ND ND
ND ND
ll00C 250
l0O0C ND
69000c 15000C
- - - - - - - ----------l!!!!!!I !El
.. · .. ·.• ..... :·. ·: : ... . .
COMl'OUND ..
SD-13-1.5
4,4'-DDE ND
4,4'-DDD ND
4,4'-DDT ND
TOXAPHENE 180
ND -Not Detected
C -Confirmed by GC/MS
PHASE 2
TABLE 17 (CONT'D)
SEDIMENT ANALYTICAL RESULTS
(PPB)
SOIL SAMPLE
SD-19-1.5 . SD-21-1.5 SD-21-2.5 SD 41-0.5
40 ND ND 170
ND ND ND ND
23 4000C 470 180
ND 26000C 4000 2300
A-36
OSD 24-1.5 OSD-24-2.5
ND ND
ND ND
460C ND
2700 790
I
---------- -
. i __ -i. . .. . . .. .. -_ -.,. ·-
TABLE 17 (CONT'D) PHASE 2 SEDIMENT ANALYTICAL RESULTS (PPB)
--.-
SOIL SAMPLE COMPOUND
OSD-27-· OSD-27-OSD-28-OSD-28-OSD-30-OSD-30-1.5 2.5 4.0 5.0 1.5 2.5 ALPHA-BHC ND ND ND 12 ND ND BETA-BHC ND ND ND 26 ND ND
. HEPTACHLOR ND ND ND ND ND ND DIELDRIN 320 110 ND ND ND ND 4,4'-DDE 100 ND ND 50 45 ND ENDRIN 140J ND ND ND ND ND 4,4'-DDD 230J ND 41 97 ND ND 4,4'-DDT 3700C llOOC 180 560C 140 ND TOXAPHENE 25000C 6200C 920 4200 1100 1200
ND -Not Detected
C -Confirmed by GC/MS
A-37
--1!!!!19
OSD-42-OSD-43-
0.5 0.5
I ND ND
ND 540JC
ND ND
ND ND
150 390J
--ND ND
ND ND
580C 7200JC
1300 44000JC
== -----iiiil liiii .., liiiiiil iiil
.•.. j/···
. ,··, 'i°.:.'· .. ·. COMPOUND · so--io+/ .s0-10.,. >< 2 . .. •: 5:.,, ....
ALPHA-BHC ND ND
BETA-BHC ND ND
DELTA-BHC NO NO
GAMMA-BHC NO NO
HEPTACHLOR NO NO EPOXIDE
OIELDRIN NO NO
4,4'-00T 35 NO
ENDRIN NO ND KETONE
TOXAPHENE 600 200
J -Quantitative Estimate NO-Not Detected
C -Confirmed by GC/MS
.
. '
TABLE 18 PHASE 3 SEDIMENT ANALYTICAL RESULTS (PPB)
SOIL SAMPLE
sD.,.11-SD-11-

S
D
-
1
2
-
SD-12-S0-14-2 5 2 5 2
ND NO 190J NO NO
41 NO 160J 43 10
NO NO 60J NO ND
NO ND 53J ND ND
NO NO ND ND 15
100 32J ND NO 65
NO NO ND NO NO
NO NO NO NO 29
1900 3200J 6900JC NO 5200C
A-38
Ill!! II!!!!
SD-14-SD-14-
5 10
ND NO
NO ND
NO ND
ND ND
16J ND --
NO 72J
NO 240J
NO NO
8500JC 7900JC
I
I
I
I
I
I
I
I APPENDIX B
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
RESPONSIVENESS SUMMARY
GEIGY CHEMICAL CORPORATION SITE
ABERDEEN, MOORE COUNTY, NORTH CAROLINA
A public comment period was held from March 26, 1992 through May
25, 1992 to receive comments from the public on the Proposed
Remedial Action Plan, and EPA's preferred remedial alternative for
the Geigy Site. A public meeting for the Geigy Site was conducted
on March 31, 1992 at 7:00 pm at the American Legion Hall in
Aberdeen, North Carolina. The public meeting was attended by EPA
staff, state regulatory representatives, local regulatory
representatives, potentially responsible parties, arid area
residents.
The purpose of the public meeting was to present and discuss the
findings of the RI/FS and to apprise meeting participants of the
EPA's preferred remedial alternative for the Geigy Site. Comments
received during the public meeting are swnmarized in Part 1 of this
Responsiveness Swnmary.
In addition to the comments made at the public meeting, written
comments were received from area residents and the potentially
responsible parties. Part 2 of this Responsiveness Swnmary
includes a brief swnmary of these written comments and EPA' s
response.
PART 1
SUMMARY OF COMMENTS RECEIVED DURING THE PUBLIC MEETING
1.1 Comment: An area resident asked what was in the drums
presently located on-site.
EPA Response:
1.2 Comment:
EPA Response:
The drums contain water that was removed from the
wells prior to sampling activities, water used for
decontamination, and soil from drilling the wells.
An area resident asked if the groundwater would be
treated until it was okay to put in the sewer
system.
After the
analyzed.
the POTW
achieved.
groundwater has been treated, it will be
The water will not be discharged into
until the remediation levels have been
1
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
1. 3 Comment: An area resident stated that North Carolina has
been shipping waste out-of-state for years, and
thought it was about time that North Carolina
started taking care of its own.
1. 4 Comment: An area resident asked if we could clean up the
Geigy waste with the Aberdeen Pesticide Site waste.
EPA Response: While the Geigy and Aberdeen Sites do have similar
wastes, the companies responsible for the
contamination at these sites are different. The
Geigy and Aberdeen Sites are also separate sites on
the National Priorities List. If the contaminated
soil from the Geigy Site is transported to the
Aberdeen Site and a spill or similar situation were
to occur, then the companies who were not
previously involved with the Aberdeen Site would
then be liable at that Site as well.
1.5 Comment: A corporate representative asked what was the main
criteria for choosing thermal desorption.
EPA Response:
1.6 Comment:
EPA Response:
1.7 Comment:
EPA Response:
1.8 Comment:
Thermal desorption is an innovative technology that
has shown on a limited basis that it is effective
in treating pesticides in soil. It meets the
statutory requirement for permanent remedies that
utilize treatment technologies to the maximum
extent practicable. It also reduces the volume,
toxicity and mobility of the contaminants.
An area resident asked how long it would take to
complete the thermal desorption.
Once the remedial design is
contractor is chosen, the actual
take approximately two months.
completed and a
processing should
An area resident asked whether there were any
on-site· treatment technologies that don't involve
thermal desorption or incineration.
We currently are not aware of any on-site treatment
technologies other than thermal desorption and
incineration that effectively treat pesticides.
An area resident asked if thermal desorption had
been tested.·
2
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
EPA Response:
1.9 Comment:
EPA Response:
1.10 Comment:
EPA Response:
1.11 Comment:
EPA Response:
Thermal desorption has been tested on the treatment
of pesticides on a small-scale. Two other sites in
Region IV have selected this alternative for the
treatment of pesticides. These sites are ahead of
the Geigy Site in the remedial process. All
information gathered on those sites will be
utilized for the Geigy Site.
An area resident asked what sort of criteria EPA
reviews to qualify thermal desorption units.
The thermal desorption units will be evaluated on
their ability to meet the requirements of the EPA.
approved remedial design.
An area resident asked if thermal desorption was
the only on-Site method that EPA considered.
EPA also considered on-site incineration. This
will be utilized if thermal desorption proves
ineffective or if costs of thermal desorption prove
prohibitive.
An area resident asked why wasn't
vitrification considered.
in-situ
In-situ vitrification was considered, but was
rejected. This alternative would not be a
permanent remedy, and.site restrictions would have
to be placed on the property indefinitely to limit
site activities. In addition, availability cf
vendors for this process are limited.
PART 2
WRITTEN COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD
2.1 Comment: A PRP stated that the recommended remediation
proposed by EPA represented a failure by EPA to use
scarce funds in a responsible and productive
manner. No action should be taken at this Site.
EPA Response: Cost was considered when EPA chose the selected
alternatives. However, before cost is considered,
the alternative must be protective of human health
or the environment. The no-action alternative does
not meet this basic criteria.
3
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
2.2 Comment: The PRPs stated that the Aberdeen community had not
had sufficient opportunity to evaluate and consider
the information in the RI/FS and the proposed plan.
The comment period should be extended.
EPA Response: The original 30-day public comment period was
extended an additional 30 days.
2. 3 Comment: The PRPs stated that the space requirements for
implementing on-site thermal treatment exceed
available area at the Geigy Site.
EPA Response: Space requirements are typically less than SO feet
by 150 feet for a thermal desorption unit. One
vendor contacted has a small unit designed to
handle treatment of low volumes of soil that
requires only 50 feet by 50 feet. Therefore, the
site should be adequate to accommodate the thermal
desorption unit, decon and staging areas. Command
trailers and other support necessary may have to be
located on adjacent property.
2.4 Comment: Thermal desorption is an unproven technology with
significant implementation difficulties.
EPA Response: Thermal desorption is considered to be an
innovative technology. While full-scale
application of this technology has not been
implemented, a recent treatability study for the
Arlington Blending Site was successful in treating
pesticides down to levels similar to those required
at the Geigy Site. This study also showed that air
emissions were within all regulatory limits.
2.5 Comment: Should thermal desorption be unsuccessful, on-site
incineration would have even greater implementation
difficulties.
EPA Response: On-site incineration was chosen as a contingency
remedy because it is a proven technology for the
effective and complete treatment of pesticides in
soils. Considerations would have to be given for
the availability of a pilot-scale incineration
unit. Even though there would be more regulatory
requirements for an incinerator ( air emissions,
monitoring, trial burn, etc.); these would be taken
into account during the design and bidding of the
system.
4
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
2.6 Comment: Testing and Design of
will significantly
greatest potential
groundwater.
the thermal treatment remedy
delay remediation of the
source of risks, site
EPA Response: While the design of a thermal treatment system may
indeed require more time than a design for off-site
disposal, the time differential is not significant
enough to eliminate the consideration of the
preference for on-site treatment. As mentioned
previously, both the Aberdeen Site and the
Arlington Blending Site in Region IV are utilizing
thermal desorption for the treatment of pesticides
in soil. Results of studies from these two sites
can provide valuable information for use at the
Geigy Site, thus reducing the amount of time
necessary to design the system.
2.7 Comment: The volume of soil to be treated is insufficient to
mobilize qualified contractors.
EPA Response: The question of whether a contractor is "qualified"
or not would have to based on their bid proposal
and past experience. EPA does not make
determinations of qualification based on limited
information about a contractor. While vendors with
full-scale thermal desorption units often specify a
minimum of 5,000 -10,000 cubic yards to warrant
mobilization at costs up to $600,000 for
mobilization, other vendors with smaller units will
mobilize for soil volumes as small as 2,500 cubic
yards at a cost of ·$250,000 for mobilization.
Eliminating thermal desorption from consideration
at this site for this reason would not be
justified.
2. 8 Comment: The evaluation of preferred remedies by EPA is
insufficient and inconsistent with requirements of
the NCP. Noise from the unit will be significant,
and will adversely affect neighboring residences.
EPA Response: All of the alternatives presented in the proposed
plan were evaluated equally using the nine
criteria. EPA's decision on a remedy is based on
this evaluation. If, during operation of the
thermal desorption unit, it is determined that 24
hour per day operation is adversely affecting the
surrounding community, adjustments can be made to
the number of hours per day that the unit operates.
5
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
2.9 Comment:
EPA Response:
Alternative
significant
and was not
2 (Off-Site Disposal) offers
advantages for overall site remediation given full consideration.
EPA considered off-site disposal as an option for
remediating the soils at the Geigy Site. EPA' s
initial selection of on-site thermal desorption was
chosen to best utilize permanent solutions via
alternative treatment technologies to the maximum
extent practicable. As a result of the reduction
of contaminated soil requiring treatment the
selected remedy has been changed to off-site
disposal. A complete discussion of the reasons
warranting the change from thermal desorption to
off-site disposal is located in Section 12 of the
Record of Decision.
6
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
ABERDEEN, NORTH CAROLINA
MOORE COUNTY
- - - - - - - - - - - - - -X
U.S. ENVIRONMENTAL
PROTECTION AGENCY
GEIGY CHEMICAL CORPORATION
SUPERFUND SITE
- - - - - - - - - - - - - -X
PUBLIC HEARING
* * *
March 31, 1992
7:oo p.m.
* * *
At the American Legion Hall
209 East Main Street
Aberdeen, North Carolina
* * *
Reported by:
Sonja L. Reeves
Professional Court Reporter
3460 Hastings Drive
Fayetteville, North Carolina 28311
[phone]
* * *
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
A P P E A R A N C ~ ~
Diane Barrett -NC community Relations Coordinator
Giezelle Bennett -Remedial Project Manager
Tony Able -Groundwater Expert
Solomon Pollard -Risk Assessment Expert
* * * * * *
£ B Q s:; ~ ~ ~ I li g ~
2
DIANE BARRETT: Ladies and gentlemen, my name is Diane
Barrett. I am the Community Relations coordinator for the State
of North Carolina, and I want to welcome you here tonight for
this public meeting. I would like to introduce our panel.
Giezelle Bennett is our Project Manager for the Geigy Site.
Tony Able is the Groundwater Expert. Solomon Pollard is the
Risk Assessment Expert.
Tonight we are here to meet on the Geigy Chemical
superfund Site. This is a public comment period meeting. We
have a court reporter who is taking all of the proceedings of
the meeting, and they will appear in the information composite
here in Aberdeen.
I hope there is no confusion regarding the purpose of
this meeting tonight, because there are three different
activities going on by the EPA here in the Aberdeen area. There
is the Aberdeen Pesticide Site. There is also the Crestline
water line that's being put in here down beyond the Geigy Site.
Of course, this meeting tonight is on the Geigy Site
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
itself. If there are any questions regarding the other two
Sites, I will be glad to address those after the meeting.
3
I'll just briefly go over this. How many of you have
been at a Superfund meeting before? Most everybody. Superfund
is a very long process, as most of you do know, and at the
moment we are in step number five, as the overlay displays.
We have received the results from the remedial
investigation and the feasibility study and now we are
presenting to the public these findings, as well as the various
alternatives and the one the EPA prefers.
So this is why we are here, to give you these results and
to let you make comments to us about what you prefer. This
30-day comment period will end April the 24th. During the
public comment period time we have, if citizens request, the
opportunity for an extension, a 30-day extension to that public
comment period if it is needed.
After the public comment period has ended, we take all
comments from this meeting and any written comments and those
are all reviewed and every consideration given to those
statements, and then a decision is made as to which alternative
the agency would prefer to have utilized to clean up the site.
This is called a record of decision. With that record of
decision is also the responsiveness report which is our
statement of all the comments that have been made and our
response to those. This is also placed in the composite, which
I
I 1
I 2
3
I 4
I 5
6
I 7
I 8
9
I 10
I 11
12
I 13
I 14
15
I 16
I 17
18
I 19
I 20
21
I 22
I 23
24
I 25
I
4
is down in the town hall in Aberdeen.
After that point, the agency starts negotiating with the
PRP's, after the record decision has been signed, to see who
will pay for the work to be done as far as remedial design and
implementation of that activity. Then once that is done, we
have a remedial design that is drawn up and then remedial
action.
So we have still have a little bit to go. We are about a
little over halfway as far as the various phases. During any of
this time period should there be more contaminants found, we can
have emergency removal if those contaminants cause an immediate
threat or anything like that to the population.
Also we have technical assistance that is available to
citizens at the Superfund Site. Since that pretty well covers
what I am going to say, I am going to turn the meeting over now
to Giezell,e Bennett, the Project Manager.
GIEZELLE BENNETT: Good evening. I'm Giezelle Bennett
and I'm the Project Manager for this Site. It is my
responsibility as Project Manager to make sure that the project
runs smoothly and is coordinated with the various federal and
state agencies as well as to communicate to the public.
I'm going to present the findings now of our remedial
investigation and feasibilty study. This is a site location map
which shows the location of the Geigy Site. As you can see, it
is located east of Aberdeen on Route 211. It was operated as a
I
I
1.
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
pesticide blending and formulation facility from 1947 to 1967,
and as a retail distributor of agriculture chemicals from 1968
to 1989.
The Site is bordered on one side by Highway 211 and
pretty much on the other side by the Aberdeen and Rockfish
Railroad. The Site is about one acre in size and is currently
vacant. It was placed on the NFL in 1989.
5
In December of 1988 three of our potentially responsible
parties signed a consent order to perform the work needed at the
Site. One of the first things that they did was to remove
visually contaminated soils from the Site. This figure depicts
the areas where those soils were removed. A total of 689 tons
of contaminated soil were removed from the Site before the
investigation even began.
During remedial investigation, extensive soil sampling
was done to determine the horizontal and vertical extent of the
soil contamination at the site. As you can see, it is pretty
well covered on site as well as some outside of the property
line. Based on those sample results, a second removal was done.
This removal removed approximately 200 tons of soil from the
Site. You can see the areas where those were removed.
This table shows the maximum soil concentrations that
were left at the Site after the second removal, and it also
shows EPA soil remediation goals for the Site. These clean up
goals are based on direct contact with the soils, and are based
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
on the fact that somebody may in the future live on the Site.
This is our most conservative approach.
6
This figure shows generally the areas that still need
cleaning up. In most areas it is limited to a foot. In some
areas it can be down to as far as ten feet. An investigation of
the groundwater was also performed. Wells were put in both the
shallow aquifer, which is designated by the "S", and a deeper
aquifer, which is designated by a "D".
As you can see, there is city well number four there. It
is the city well used for municipal drinking. It has been
closed now, and those other wells are United States Geological
Service w.ells. They are doing a study in the area.
This figure shows the general direction of groundwater
flow. As you can see, groundwater appears to be flowin9 toward
the center of the Site, west from the east side and east from
the west side. And the deeper aquifer, the limited amount of
monitoring wells we have show that the water is flowing in the
north, northwesterly direction.
This figure is kind of busy but it shows the
contamination that was found in each of the wells. As you can
see, the contamination is basically in the shallow aquifer. As
you can see, most of the shallow aquifers are contaminated. The
deeper aquifers or the background wells are clean. Two wells on
Site contain trichloroethene, and we found pesticides in only
one of the deeper wells, which is south of the site, number
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
7
11-0.
If you can't see these--! know I am going pretty fast
through these--all of these are in your handout that was at the
door, so you can look on that to see the actual numbers. This
one shows the maximum groundwater concentrations that were found
in any given well, and it shows our groundwater remediation
goals or clean-up goals that we want to do for the Site.
Now, these are based on North Carolina groundwater
standards. These are the remedial alternatives and their
present worth cost that we considered. As you can see, we
looked at a wide range of alternatives for both groundwater,
from no action to complete groundwater extraction and clean up.
In the soil we looked at from no action to off-Site
landfilling and incineration, to capping to on-Site treatment
alternatives. Now, once we had those alternatives, these are
the criteria the EPA uses for determining which alternative to
pick. There are nine of them.· They go from overall protection
of human health and environment, which means that first of all,
the alternative has to reduce risk to the people and the
environment around it. Second, it has to comply with all
federal and state laws. We also consider cost.
We consider how it can be implemented. Will it take a
lot of technical and administrative things to do? How fast can
it be implemented? The short term effectiveness is during the
clean-up how it is going to affect the community and workers
I
I
I
.
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
around it. Long term effectiveness is the permanence of it.
Once we finish, will the Site be clean? Will we be finished
with it?
8
One of the three things that we consider are it has to
reduce the toxicity of the contaminant, the mobility, and
preferably the volume of the contaminants that are left at the
Site. Of course, we have to have acceptance by the state and
acceptance by the community that the remedial action takes place
in.
This chart shows the alternative the EPA would prefer to
conduct at this Site. Alternative three for groundwater
remediation, which is complete groundwater extraction to attain
remediation levels; carbon adsorption.
For soil remediation we are looking at on-Site thermal
desorption. This shows a conceptual flow diagram for how the
groundwater treatment would work. The groundwater would be
extracted through wells, put into a tank, go through the
treatment system of carbon adsorption. We would monitor it to
make sure it met all the clean-up levels, and then we would
discharge it.
For thermal desorption you would have to excavate the
soil, get rid of anything oversized that couldn't fit into the
machine, do the thermal treatment of it. You would have your
clean soil coming off this way and your gases or your
contaminants here and then those would be cleaned as well either
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
9
through spent carbon, like you see here or a number of different
alternatives. It just depends on the vendor that you choose.
And that concludes my talk.
DIANE BARRETT: Since we have made our presentation, now
we are going to open the floor up for public comment. This is
your time. One thing I would like you to do, please, when you
do make a statement, come to the microphone, pronounce your name
and spell the last name for our court reporter so that she can
get it accurately.
• • •
CURT RICHARDS: I do have a few prepared comments to make
this evening. My name ~s curt Richards and I work for Olin
Corporation. Tonight I appear before you to express the
opinions of CIBA-GEIGY Corporation, Kaiser Aluminum and Chemical
Corporation, and Olin corporation.
CIBA-GEIGY, Kaiser, and Olin have been working together
to investigate and clean up the Geigy Site in an environmentally
appropriate and safe manner. We have recently completed the
remedial investigation, the feasibility study and the risk
assessment for the Site. During this process, the companies
collected and analyzed over 300 soil samples and installed and
sampled 15 groundwater monitoring wells.
Also during this process, over 3500 tons of contaminated
soil and building debris were removed from the Site. These
removals greatly reduced the volume and concentration of
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
contaminants remaining in the on-Site soils, thereby minimi the potential for contamination movement or direct contacts The removals, the remedial investigation, the feasibi study, and the risk assessment, conducted under the oversigh the U.S. EPA, were entirely funded by the three companies at cost exceeding three million dollars.
The feasibility study evaluates the possible remedies that could be used to clean up the Site. The EPA has propose preferred alternative of pumping and treatment for groundwatei contamination and on-Site thermal desorption for soil clean-uF with incineration as a backup technology.
CIBA-GEIGY, Kaiser, and Olin support the EPA's preferre, alternative of pumping and treatment for the groundwater clean-up. Pesticides have been found in the groundwater at the Site. A pump and treat system using activated carbon is proven technology for removal of pesticides from groundwater. The discharge of treated groundwater to the Moore County sewer system would comply with pre-treatment requirements and have no impact on the receiving facility. The pump and treat system could be in place within three months after the design is complete.
However, Olin, CIBA-GEIGY, and Kaiser do not support the EPA's proposed preferred alternative of on-Site thermal desorption for the soil clean-up with incineration as a backup technology. We do not support the alternative because of the
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
11
four following reasons:
Technology. First of all, thermal desorption is an
undemonstrated technology for the treatment of pesticide
contaminated soil. The EPA has stated that the preferred remedy
would involve some testing to verify that the clean up goals can
be reached. Testing will take time and the technology may not
reach the clean-up goals; further delaying the clean-up of the
Site.
Quantity. The second reason is the quantity of
contaminated soil involved. It is not large enough to justify
on-Site soil treatment. The EPA states that because there are
no federal or state clean-up standards for contamination in
soil, clean-up goals are established to reduce soil
contamination to within an acceptable risk range group. A risk
assessment performed on the Geigy Site identified 650 cubic
yards of contaminated soil that should be removed based upon a
reasonable health based risk assessment. Even if the quantities
are greater, quantities of less than 10,000 cubic yards would
not be considered for on-Site treatment by most capable
contractors.
Space. The .third reason why we do not support the
proposed alternative is the space needed for on-Site soil
treatment. There is not enough area at the. Geigy Site to
perform any on-Site soil treatment. The treatment unit would
have to be located on neighboring property not involved in the
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
12
clean-up of the Site.
Time. The fourth and perhaps the most important reason
why we do not support the alternative is the time that would be
required should the EPA require us to use on-Site thermal
desorption as the soil clean-up remedy. The EPA has stated
implementation of two months. We believe that that number does
not reflect the time involved for treatability studies,
mobilization and trial of the thermal desorption equipment, as
well as the actual soil processing time. We estimate that this
time period would likely exceed one year and perhaps exceed two.
Therefore, CIBA-GEIGY, Kaiser, and Olin all support
alternative two, off-Site disposal for the soil clean-up remedy.
This alternative would involve the excavation and off-Site
disposal of contaminated soils exceeding the clean-up goals.
The contaminated soil will be taken to either a fully approved
out-of-state secure landfill or an out-of-state incinerator if
needed.
This alternative would be the most community-friendly
alternative because it could be completed in a far shorter time
frame, two months, than the EPA proposed alternative of on-site
thermal desorption .. It would not involve untested technology.
It would not require the use of any surrounding property, and
best of all, it would meet all of the soil clean-up goals in the
shortest time frame.
This remedy is fully consistent with the soil removals
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
13
conducted previously at the Geigy Site. Those removals were
completed with very little environmental or community impact.
This final action for the Geigy Site can be handled in the same
way, quickly and efficiently by selecting the off-Site disposal
alternative.
CIBA-GEIGY, Kaiser, and Olin have worked with the EPA in
the clean-up of the Geigy Site in an environmentally appropriate
and safe manner. We wish to continue in that manner and request
that the EPA use an environmentally appropriate clean-up remedy
for this Site based upon the facts involved with this Site.
I encourage the citizens of Aberdeen to voice their
support for the alternative of off-Site treatment and disposal
and encourage the EPA to listen.
Thank you for your attention. We will be submitting
additional written comment to the EPA within the comment period.
* * *
DIANE BARRETT: Anybody else want to make a statement or
ask questions? The floor is open.
* * *
PHYLLIS KALK: My name is Phyllis Kalk, K-a-1-k. I am
the Chairman of the.Natural Resources Unit of the League of
Women Voters of Moore County. I would like to ask two questions
and then make a statement. First question is, there are some
drums that are on the eastern end of the Site, and they are
probably about as tall as this chair. I think there are
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
14
probably about 15 or 20 of them. What is in those?
* * *
GIEZELLE BENNETT: That was left from the remedial
investigation and that's just decontamination water and soil
from drilling the wells and things. That's going to be disposed
V of pretty soon.
* * *
PHYLLIS KALK: My next question was, when you showed the
thing about the water and you said that after it came out of the
wells that you would treat the water. If the water is not to
your standards will you just keep treating it until it is okay
to put in the sewer system?
* * *
GIEZELLE BENNETT: Right. We aren't going to discharge
it until it meets those clean-up rules that were in that table.
* * *
PHYLLIS KALK: As to Mr. Richards' comment about
alternative two, my only comment about that is that North
Carolina has been shipping their junk to other states for many
years, and I think it would be real nice if we started taking
care of our own. Thank you.
* * *
DIANE BARRETT: Any others statements?
* * *
RICK JOHNSON: My name is Rick Johnson. I'm the
I
I
I
I
I
I
I
I
I ~.
I
I
I
I
I
I
8
I
I
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
15
President of Moore Forest Local Environmental Group. I really
just looked over this this evening, so I'm not real up on
everything, but I just want to say that the organization that we
represent, we are opposed to thermal desorption and incineration
of any kind, but we are also opposed to taking materials
off-Site for treatment. And so we are in sort of a dilemma
here.
We don't have an alternative. We haven't come up with
one yet. We don't have an alternative yet but what we would
like to see is some type of technology that can treat hazardous
waste on-Site without burning it and putting it into our
atmosphere. Thermal desorption might be the answer but we
believe you at least have to dechlorinate. It seems like there
ought to be a way--a feasible way of treating those two
compounds on-Site without having to move it across state lines
or anywhere else.
* * *
DIANE BARRETT: Are there any other questions or
statements?
* * *
PHYLLIS KALK: I know you told us you didn't want to talk
about the other four Sites on the other side of the highway, but
the reason I am asking you about them is, have you thought about
would it be at all feasible to wait until you're going to clean
up the other four Sites and take the contaminated soil from the
I
I 1
I 2
3
I 4
I 5
6
I 7
I 8
9
I 10
I 11
12
I 13
I 14
15
I 16
I 17
18
I 19
I 20
21
I 22
I 23
24
I 25
I
16
211 Site and take it and clean it up at the same time you clean
up those other four Sites? Is that at all feasible?
* * *
GIEZELLE BENNETT: Well, we aren't looking at that at
this time. One of the main reasons is most clean-ups are going
to be performed by the responsible parties that are responsible
for the waste at each of those Sites and some of them are the
same but some of them are different. So when you start mixing
waste like that then you start mixing liability as well, so it
opens up a whole lot of other questions and concerns.
* * *
BILL SHELLER: My name is Bill Sheller and I'm with OHM
Corporation. What was the main criteria for thermal desorption
as the alternative choice?
* * *
GIEZELLE BENNETT: Well, like I said, we have nine
criteria. First, it has to reduce the risk to the public. But
one of the main things we consider is in North Carolina they
encourage, as much as possible, on-Site treatment of waste. I
don't know, maybe the person from the state would like to talk
to that. But in ad_dition to that this is the alternative that
was picked at the Aberdeen Site as well. That Site is about
nine months to a year ahead of this one so some of the
treatability tests and stuff that they do will apply to this
Site.
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
* * *
RICK JOHNSON: How long are we talking before anything
actually gets done if we do it through thermal desorption?
* * *
17
GIEZELLE BENNETT: What you are looking at is we have to
wait until the public comment period is over until we issue our
record decision. After that we go onto negotiations with the
responsible parties in order to do the work, and that can take
anywhere from four to six months. Then after that, they have to
design the treatment system, which takes about a year. So you
are looking at probably about a year-and-a-half before anything
starts no matter which alternative we pick.
* * *
RICK JOHNSON: No matter which, so even if we went with
Olin Chemical Company's suggestion it would be still a
year-and-a-half to two years.
* * *
DIANE BARRETT: Any other statements or comments anybody
wants to make?
* * *
CLAUDIA MADE: My name is Claudia Made. I spoke with Mr.
Richards earlier today and we explored something. If the PRP's
have their preferred method of cleaning it up, he said they
would move it out of state, out of the compact states, and I
wonder if he could elaborate a little bit about that, what
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
D
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
18
advantage that might be.
* * *
CURT RICHARDS: We have been told that there is some
concern in the State of North Carolina in regard to the compact,
some of you that know what that is. There are several states
that got together and said we will divide up how we handle our
hazardous waste. If you do this then we will do this for you.
Well, North Carolina has not lived up to some of their
obligations, and so they have basically been thrown out of the
compact. We are looking to take the soils outside of that
region in order to avoid any conflict/within the group of
states, and that would be our intention by the way.
* * *
RICK JOHNSON: Could you tell us, Curt, how quickly the
clean-up would occur if you had your way of doing it?
* * *
CURT RICHARDS: I can't answer that. There are some
technical people in the room.
* * *
JIMMY CLOONAN: My name is Jim Cloonan. If off-Site
disposal were to be.selected as the remedy for the Site, I can't
speak directly for them, but I believe the negotiation period
might be quicker than was indiciated by the EPA. The design
period would be much less involved and would be more along the
lines of preparing work plans that would be similar to those
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
19
conducted at the Site rather than trying to design three
separate phases.
Time wise, I think once the negotiations were done we
could have a contract within two months and the removal would
take another month. I think for thermal desorption or
incineration the designed time frame--we have just been selected
to do another thermal desorption design--that period would be
about three years following negotiations with the EPA.
* * *
BRUCE NICHOLSON: My name is Bruce Nicholson and I'm with
the State of North Carolina Superfund section, and it is the
responsibility of the Superfund Section to perform the state's
oversight for Superfund sites. I'm here today to gauge what the
community interests are on this site. Some comment has been
made about the state's policy· for preference for on-Site
treatment.
There are really two reasons for that policy. The most
important one is that it be demonstrated that the technology
chosen be protective of public health. Once that is satisfied,
then the State of North Carolina would prefer on-Site treatment
technology to off-Site disposal.
Given that statement of the current policy, if there is
any questions about that, I would be happy to take them.
* * *
HOMER GRUBBS: My name is Homer Grubbs and I'm also
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
20
associated with CIBA-GEIGY. Wouldn't impracticability in terms
of putting a desorber on the site which is too small to
accommodate it, plus the time frame indicated also, play into
those factors under the state's policy?
* * *
BRUCE NICHOLSON: There certainly could be a situation
where Site space constraints could cause the technology to be
more expensive. I think the key point for protectiveness of the
public health are the results of the treatability study and
there are issues to be worked out and question about that.
* * *
RICK JOHNSON: Are there any on-Site treatment
technologies that don't involve thermal desorption or
incineration?
* * *
GIEZELLE BENNETT: I don't know. It may be. It's just
that we don't know about them for this Site, and they were not
considered in our alternatives that we looked at.
* * *
PHYLLIS KALK: Have you tested the thermal desorption?
Was there a Site in the northeast somewhere that you were going
to test? Do you know if that has been tested yet?
* * *
GIEZELLE BENNETT: No. I don't know, but like I said,
it was chosen in Aberdeen and Aberdeen is about nine months to a
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
21
year ahead of this one so all the results of those tests, we'll
definitely look at for this Site.
* * *
BRUCE NICHOLSON: Also, for the record, I would like to
state although it does state in the fact sheet here that the
state has absolutely concurred with the proposed plan, official
concurrence has not been given. That is given at the stage
where the decision is signed, so that's one of the reasons why
I'm here tonight to understand what the community interests are.
So all that goes into our final decision process.
* * *
UNIDENTIFIED SPEAKER: You had mentioned depending on
what vendor, what sort of criteria would the EPA look at to
qualify thermal desorption units? What sort of design criteria,
whether it be a good design or a bad design?
GIEZELLE BENNETT: Well, they would have to be able to
demonstrate, I suppose, that they are able to perform the work
per the design that was approved by EPA. From what I
understand, there are a number of different ways to treat the
gases that come off the soil, and that depends on the vendor.
Some use carbon to absorb the gases. Some break it down and put
it in a liquid and dispose of that liquid, so we didn't want to
pick one of those and then limit the number of people who may be
able to do. the work.
* * *
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
22
PAGE BURNS: My name is Page Burns and I have two
questions. Thermal desorption was the only choice that you
showed up there as your way of handling the on-Site
contamination. That was the only on-Site method that you were
considering?
* * *
GIEZELLE BENNETT: The other was on-Site incineration.
That's a proven technology that has been used in the past. What
we have said is if for some reason the thermal desorption is
shown that it doesn't work or if the cost skyrockets, you know,
if it comes down to only one person and he charges a million
dollars for it or something so cost is prohibited, then we will
fall back on on-Site incineration.
* * *
PAGE BURNS: I think it was at one of the other meetings
I was at in Aberdeen, they were talking about
in-situvitrification as an option that they were considering,
and their problem with that was, one, that that was supposedly
very expensive when compared to thermal desorption, but it seems
like if you have a space problem and, of course, on-Site removal
that CIBA-GEIGY was talking about is very expense, would that be
an option that would solve the Site spacing problem as well as,
you know, dealing with concerns about moving the contamination
out of the state? Why wasn't that considered?
* * *
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
23
GIEZELLE BENNETT: As far as the in-situvitrification, I
think that was considered. I don't really remember why it was
thrown out for this Site particularly. One thing is when you do
a treatment like in-situvitrification then you always have
restrictions on what can be done on that property.
When you do something like on-Site thermal desorption you
are saying, "All right. Now, we can have a child come on here."
It is clean until somebody else comes along and contaminates it.
You know, we consider that a very permanent remedy without any
holds or bars on it. I don't know as far as the space thing for
thermal desorption. You know, we'll have to look at that during
the remedial design.
* * *
DIANE BARRETT: Well, if there are no more statements or
questions, we thank you for coming. Thank you for providing
your comments.
(The hearing was concluded at 7:45 p.m.)
* * * * * *
~ ' ' ·1
I
I
I
I
I
I
I
I
I
I
I
t
I ,-
I
I
I
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
5-9
STATE OF NORTH CAROLINA
COUNTY OF CUMBERLAND
24
I, Sonja L. Reeves, a Notary Public in and for the state
of North Carolina, duly commissioned and authorized to
administer oaths and to take and certify depositions and
hearings, do hereby certify that the hearing was reported by me
verbatim and then reduced to typewritten form as set forth .in
the preceding pages; that the foregoing is a true and correct
transcript of said proceedings to the best of my ability and
understanding; that I am not related to any of the parties to
this action; that I am not interested in the outcome of this
case; that I am not of counsel or in the employ of any of the
parties to this action ..
IN WITNESS WHEREOF, I have hereunto set my hand and
affixed my official notarial seal this 1st day of April, 1992.
My commission expires:
September 28, 1994