NCD980843346_19910806_Aberdeen Pesticides Dump_FRBCERCLA ROD_Record of Decision OU-2-OCR

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[BECORD OF DECISIOH
OPERABLE UNIT ONE
SURFACE AND SUBSURFACE SOIL CONTAMINATION
AKEHDED RECORD OF DECISIOH
OPERABLE UNIT TWO
STOCKPILE OF CONTAMINATED SOIL -FAIRWAY SIX AREA
AUG O 6 1991
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ABERDEEN PESTICIDE DUMPS SITE
OPERABLE UNIT ONE
MOORE COUNTY, ABERDEEN, NORTE CAROLINA
PREPARED BY TEE
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV
ATLANTA, GEORGIA
THIS RECORD OF DECISION CONTAINS TEE FOLLOWING PARTS:
PART I -'l'BE DECLARATION
PART II -'l'BE DECISION SUHKARY
PART III -THE RESPONSIVENESS SUHKARY
AUGUST 1991
PART ,I, --DECLARATION FOR THE RECORD OF DECISION (ROD)
site Name and LOcation
Aberdeen Pesticide Dumps site (Operable Unit One)
Aberdeen, Moore County, North Carolina
statement of Basis and Purpose
This decision document represents the selected remedial action for the
Aberdeen Pesticide Dumps Site developed in accordance with the
Comprehensive Environmental Response, compensation and Liability Act of
1980 (CERCLA), as amended by the superfund Amendments and Reauthorization
Act of 1986 (SARA) and, to the extent practicable, the National Oil and
Hazardous Substances Pollution contingency Plan (NCP). This decision is
based upon the contents of the administrative record for the Aberdeen
Pesticide Dumps site. The State of North Carolina concurs on 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 (ROD), may present an imminent and substantial endangerment to
public health, welfare, or the environment.
Description of the Selected Remedy
This interim remedy addresses source control of groundwater contamination
via soil contamination by eliminating or reducing the continuing risks
posed by the site. The major components of the selected remedy include:
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Treatability study using ex-situ thermal desorption;
Excavation of an estimated 99,193 cubic yards of contaminated
soil;
Decontamination of 123,933 cubic yards of contaminated soil from
all areas comprising the site using on-site ex-situ thermal
desorption process (includes 3200 cy and 22,000 cy of previously
excavated and stockpiled contaminated soil at the Mciver and
Fairway Six Areas, respectively);
Proper transportation and storage of RCRA hazardous wastes;
Treatment.of the concentrated organic contaminants, which will be
vendor specific;
Sample and analysis of the treatment residue;
On-site disposal of the non-hazardous treated soil into the
original excavated areas, backfilling with soil to grade and.
revegetation with native grasses;
On-site solidification and disposal of treatment residue remaining
hazardous after thermal treatment; and
sample and analysis of potential trench areas at Farm chemicals,
Fairway Six and Twin Sites Areas;
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0 Lateral and vertical characterization through sample and analysis
of Mciver Area C; and
·0 Asbestos removal and building demolition at the Farm chemicals
Area and proper disposal of building debris offsite.
Description of the Contingency Remedy
The contingency remedy includes all items under the selected remedy with
the exception of the treatment technology. Incineration will be used to
treat the contaminated soil should the results of the treatability study
conclude that thermal desorption is ineffective in rendering the soils
non-hazardous or proves to be cost prohibitive.
Description of the ROD Amendment for Operable unit Two, now designated as
Operable unit Four
A Record of Decision for Operable Unit Two signed by Region IV'S
Administrator on June 30, 1989 is amended to fundamentally change the
selected remedy from incineration to thermal desorption. A contingency
remedy, incineration, will apply should thermal desorption not meet EPA's
criteria, in which case the contingency remedy would be implemented.
Operable Unit Two, now designated as Operable Unit Four, will be combined
with Operable unit one for the purpose of excavation and treatment of
contaminated soils at the site.
statutory Determinations
The selected remedy and the contingency remedy are both 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 are cost-effective. The selected and contingency
remedies utilize permanent solutions and alternative treatment (or
resource recovery) 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. Because
neither of these remedies will not result in hazardous substances
remaining on site above health-based levels, the five-year facility review
will not apply to this action.
Greer c. Tidwell
Regional Administrator
Date
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PART II -THE DECISION SUHHARY
TABLE OF CONTENTS
section Page
1.0 SITE NAME, LOCATION, AND DESCRIPTION ••••••••••••••••••••••••••••••l
l. l Farm chemicals Area •••.•••••••••••••••••••••••••••••••••••••••• 1
l. 2 Twin Sites Area ••••••••••••••••••••••••••••••••••••••••••••••• 3
l. 3 Fairway Six Area .............................................. 4
1. 4 Mc Iver Area •••••••.•• _ ••••••••••••••••••••••••.•.•.•.•.••• -.-.-.-••••••• 4
Ls Route 211 Area •••••••••••••••••••••••••••••••••••••••••••••••• 4
·2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES •••••••••••••••••••••••••••8
2 .1 site History •••••••••••••••••••••••••••••••••••••••••••••••••• 8
2. 1. 1 Farm Chemicals Area •••••••••••••.•••••••••••••••••••.••• 8
2. 1. 2 Twin Site Area •••••••••••••••••••••••••••••••••••••••••• 9
2. l. 3 Fairway six Area ••••.•••••••••••••••••••••••••••••••••• 11
2. l. 4 Mc Iver Area ••••••••••••••.••••••••••••••••••••••••••••• 12
2.1.5 Route 211 Area ..•••.••••••••..•••.•.••••••••••••••••••• 14
2 .2 Enforcement Activities •••••••••••••••••.••••••••••••••••••••• 14
3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION ••••••••••••••••••••••••••••15
4.0 SCOPE AND ROLE OF OPERABLE UNITS WITHIN SITE STRATEGY •••••••••••• 16
5. 0 SUMMARY OF SITE CHARACTERISTICS •••••••••••••••••••••••••••••••••• 17
5 .1 Farm Chemicals Area •••••••••••••••••••••••••••••••••••••••••• 17
5.2 Twin Sites Area •••••••••.••••••••••••••.•.••••••••••••••••••• 22
5. 3 Fairway six Area ••••••••••••••••••••••••••••••••••••••••••••• 2 8
5.4 Mciver Area •••••••••••••••••••••••••••.•••••••••••••••••••••• 34
5 • 5 Route 211 Are a .•••••••••••••.•••••••••.•••••••••••••••••••••• 4 0
6. 0 SUMMARY OF SITE RISKS •••••••••••••••••••.•••••••••••••••••••••.•• 45
6 .1 contaminants of concern ............. ~ ........................ 45
6.2 Exposure Assessment .......................................... 47
6.3 summary of Toxicological criteria •••••••••••••••••••••••••••• 51
6. 4 Risk characterization ••••••••••••••••••••••••••••••••••••••• ·• 53
6. 4 .1 Farm Chemicals Area •••••••••••••••••••••••••••••••••••• 53
6.4.2 Twin sites Area •••.•••••••••••••••••••••••••••••••••••• 55
6.4.3 Fairway Six Area ••••••••••••••••••••••••••••••••••••••• 57
6.4.4 Mciver Area •••••••••••••••••••••••••••••••••••••••••••• 57
6.4.5 Route 211 Area ••••••••••••••••••••••••••••••••••••••••• 57
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TABLE OF CONTENTS CONTD
s.ection Page
7. 0 DESCRIPTION OF ALTERNATIVES ••••••••••••••••••••••••••••••••••••••• 61
8.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES ••••••••••••••••••• 72
9 • 0 THE SELECTED REMEDY •••••••••••••••••••••••••••••••••••••••••••••• 7 6
9 .1 Common Elements •• , •..•••••••••••••••.•.••.•••••••• ; ..•.•.••. 76
9 .2 Elements Unique to Each Area ................................ 86
9.3 Contingency for soils Remediation •.••......••..••••••••••••• 89
10.0 AMENDMENT TO OPERABLE UNIT TWO RECORD OF DECISION •••••••••••••••• 90
11. 0 THE STATUTORY DETERMINATIONS ••••••••••••••••••••••••••••••••••••• 9 3
11.1 Protection of Human Health and the Environment •..••••••••••• 94
11.2 compliance with Applicable
or Relevant Appropriate Requirements ......................... 9 4
11. 3 Cost-effectiveness •••••••••••••••••••••...•...•.•••.•••••.•• 94
11.4 utilization of Permanent Solutions and Alternative
Treatment Technologies or Resource Recovery Technologies
to the Maximum Extent Practicable ............•.........•.... 95
11.5 Preference for Treatment as a Principal Element ........•..•• 95
ATTACHMENT
State Letter of Concurrence
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I Figure
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Figure 8. I Figure 9.
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FIGURES
Page
site Map -Aberdeen Pesticide Dumps Site ••••••••••••••.•• 2
Site Layout -Farm chemicals Area ••••••••••••.••..••••••• 3
Site Layout -Twin Sites Area ••••••••••.•..•••••....••••• 4
site Layout -Fairway six Area .•••...•.•••••••••.•••••••• 6
Site Layout -Mc Iver Area •.••••..•..•..•••••••••••••••••. 6
Site Layout -Route 211 Area •••••••••......•••••.•••.•..• 7
Total Pesticide Concentrations In surficial and
Subsurface soils and Location of suspected Buried
Trenches-at the Farm chemicals Area •••••••••••.••••••••• 20
Area of Contaminated soil Reguiring Remediation at
the Farm Chemicals Area ••.•••.•••••••••••.•.•••••••••••• 2 3
Total Pesticide Concentrations In surficial and
subsurface soils and Location of suspected Buried
· Trenches at the Twin Sites Area .••••.•••.•.••••.•••.•••. 27
Area of Contaminated Soil Reguiring Remediation at
the Twin Sites Area ••••...•.••..•.•...•......••.......•. 29
Total Pesticide concentrations In surficial and
Subsurface Soils and Location of suspected Buried
Trenches at the Fairway Six Area •••••••••••••••••••••••• 33
Area of contaminated Soil Reguiring Remediation at
the Fairway Six Area •••••••••••••••••••••••••••••••.•••• 35
Total Pesticide concentrations In surficial and
subsurface Soils at the Mciver Area ..•••.•••....•...•.•• 38
Area of contaminated soil Reguiring Remediation at
the Mciver Area ••••••••••••••••••.•••••••••••••.•••••••• 41
Total Pesticide concentrations In surficial and
Subsurface Soils at the Route 211 Area ••••••••••••••••.• 44
Area of Contaminated soil Requiring Remediation at
the Route 211 Area .....•...•••.•.•.•.••.•••••.•..•...•.. 46
Area Reguiring Excavation at the Farm chemicals Area •.•• 78
Area Reguiring
Area Reguiring
Area Reguiring
Area Requiring
Excavation at
Excavation at
Excavation at
Excavation at
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TWin sites Area •••••••• 7 8
Fairway six Area ••••••• 7 9
Mciver Area ............ 7 9
Route 211 Area .......•. 8 0
Table
Table l.
Table 2.
Table 3.
Table 4.
Table 5.
Table 6.
Table 7.
Table 8.
Table 9.
Table 10.
Table 11.
Table 12.
Table 13.
Table 14 •
. Table 15.
TABLES
sample Matrix for the Farm chemicals Area •••••.••••••••.• 17
Significant Contaminants and Their Maximum
Concentrations at the Farm Chemicals Area ..••••••..•••••• 18
Sample Matrix for the TWin sites Area •....••..•..•.•••••• 24
Significant Contaminants and Their Maximum
Concentrations at the TWin Sites Area .....••...•••••••••. 25
sample Matrix ~or the Fairway Six Area ..••••••••••.•••.•. 30
significant Contaminants and Their Maximum
Concentrations at the Fairway six Area .•.••.•.••••••••••• 31
Sample Matrix for the Mciver Area .•.•••••••.•..•••••.•.•• 36
Significant contaminants and Their Maximum
concentrations at the Mciver Area •••.•..•••••••......•.•• 37
sample Matrix for the Route 211 Area ••••..••••••••••••••• 40
Significant contaminants and Their Maximum
Concentrations at the Route 211 Area ...•••••••....••••••• 42
Contaminants of concern and Exposure Concentrations
For All Environmental Media •••••.•.•....••••••••••••••••• 48
Estimated Exposure Frequencies For Target Populations
Under Current and Future Land Use Conditions •••••• : •••..• 50
Exposure Time or Ingestion Rate Per Event ••.••••••••••••. 50
summary of Toxicological Criteria •••••.•..•.•.••••••••••. 52
current Land Use Risk Characterization -
Farm Chemicals Area ••••••••••••......••• _ ••••••••...•••••• 54
Table 16. Future Land Use Risk characterization -
Table 17.
Table 18.
Table 19.
Table 20.
Table 21.
Table 22.
Table 23 •·
Table 24.
Table 25.
Table 26.
Table 27.
Table 28.
Table 29.
Table 30.
Table 31.
Farm chemicals Area •••••..•..•••.•••••••••••..••••••••••. 54
Current Land Use Risk characterization -TWin Sites Area .56
Future Land use Risk Characterization -Twin sites Area .. 56
current Land use Risk characterization -
Fairway Six Area ......................................... 58
Future Land Use Risk characterization -Fairway Six Area .58
Current Land Use Risk characterization -Mciver Area ..... 59
Future Land Use Risk characterization -Mciver Area ...... 59
Current Land Use Risk characterization -Route 211 Area .. 60
Future Land Use Risk Characterization -Route 211 Area ••• 60
Summary of the Comparative Analysis of the Alternatives •. 74
Cost Summary for Alternative 7-Low Temperature
Thermal Desorption •••.••••••..•...••••••••..••••••••••••• 77
Volume of Material Requiring Remediation for
cleanup to 10-6aealth Based Levels at Each Area •••••••• 80
Lifetime Excess Cancer Risk Target cleanup Goals
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for soil at Each Area ••.••••••••••••••.•••••••••.•••.•.•.• 81
Alternate Treatability Variance Levels and Technologies
for structural/Functional Groups ••••••••••......•••••••••• 85
Maximum Allowed Concentrations for RCRA Delisting
Decision Making •••••••.•.•.••..••••...•.•••••••••••••••.•• 87
cost Summary for the Contingency Remedy .•••••••.••....•..• 91
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l.0 SITE NAME, LOCATION AND DESCRIPTION
The Aberdeen Pesticide Dumps Site (the •site"), consisting of five
distinct areas, is located near the town of Aberdeen, Moore County, North
Carolina (Figure l). The five separate areas are Farm Chemicals, Twin
Sites, Fairway Six, Mciver and Route 211.
All of the areas are located in the •sandhills Region• of the Atlantic
coastal Plain Province. The Region is characterized by rolling hills with
200-300 feet of topographic relief. The primary aquifer in the Aberdeen
area, the sandhills aquifer, is comprised of both the Middendorf and,
where present, the overlying Pinehurst Formations. _The thickness of the
aquifer varies with topographic relief and ranges_from a few feet in the
stream valleys to 300-feet at the crest of the higher ridges. Soils in
the area of the five sites belong to the candor series. Characteristics
of this series are well to very well drained sandy surface soils and sandy
to sandy clay loam soils of the coastal Plain uplands. These· sandy soils
have excellent permeability and are ineffective as filters when used for
waste disposal.
According to the 1980 census, the population within the study area is
about 2,000. However, more recent information obtained from the Town of
Aberdeen indicates that the population in 1988 was about 2,735.
Groundwater is the main water supply within a three mile radius of
Aberdeen. Twelve municipal water wells operated by the Town of Aberdeen
draw water from the sandhills aquifer. The system currently has l,640
hookups, but the exact number of people served is unknown. However, the
Town Manager estimates that about 3,500 people are served by the Town
supply. The remaining population of about l,5O0 -2,000 people are served
by private·wells.
The Aberdeen area is primarily residential with some light industry. The
Twin, Fairway Six, and Mciver Areas are all zoned residential, while the
Farm Chemicals Area is zoned commercial/residential. The Route 211 Area
is zoned industrial, being included in a small strip of land which offsets
the railroad tracks with an industrial zoning. The area outside this
industrial zoning is zoned residential.
The primary recreation in the area is golf with 36 championship golf
courses within a 10-mile radius of Aberdeen. There are no endangered
species or critical habitats, national parks, national wildlife refuges or
Indian reservations in the vicinity of Aberdeen.
Four of the five areas are in the Aberdeen creek drainage basin. The
Route 211 Area is outside the drainage basin. Aberdeen creek is a north -
south flowing tributary to Drowning Creek with a drainage area of
approximately 38 square miles.
Figure 1 shows the location of each area and the Town of Aberdeen. The
site location and description of each area are summarized below.
1.1 Farm Chemicals Area
The Farm Chemicals Area is located immediately south of North Carolina
Highway 5 (Pinehurst Road), on the western corporate limit of the
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Town of Aberdeen, and west of Pages Lake (Figure 2).
latitude 35°08'24"N; longitude 79°25'58". According
the estimated population within a 1-mile distance of
than 1,000.
Coordinates are:
to the 1980 census,
the area is greater
The Area is situated on flat terrain •• However, downgradient (north) of
the Area and at a distance of approximately 500-700 feet is Pages Lake,
which is used far swimming, fishing, and general recreational use. It is
a man-made body that is fed by Aberdeen Creek, which flows to the south.
The land to the south and west of the Area is occupied by commercial or
light industrial properties. Residential property bounds the .Area to the
east. The nearest residents live approximately 250 feet-from-the-Area.
North of the Area is Highway5and directly across Highway 5 is the Twin
Site Area. The Area accommodates an abandoned chemical blending facility
consisting of 14 structures.
1.2 Twin Sites Area
The Twin Site Area lies immediately north of Highway 5, at the western
corporate limit of the Town of Aberdeen, and west of Pages Lake.
Coordinates of the Area are: latitude 35°08'24"N; longitude 79°25'58"W.
The estimated population within a 1-mile distance of the Area is greater
than 1,000.
ABERDEEN
HOSIERY
AEPCO
Not1h
@
Allnldlal ffi11llgltlcn'Ft1slblllty SI\J!tr (RLf'S) Aberdeen Pttllddt Dumps S111
Awdttn, Moon County, North Clrollnt
SCALE:
Figure 2. Site Layout -Farm chemicals Area.
3
The Twin Sites Area·consist of three disposal areas (Figure 3). Area A
and Bare both open dumps within wooded areas. Area A is approximately
400' x 250'; Area Bis approximately 235' x 120'; and the two areas lie
approximately 350' from one another. Pesticide-like materials are buried
and partially visible in a small patch of woods in Area c.between Areas A
and B. Since most of the pesticide-like materials are buried, the
dimensions cf Area Care unknown.
The Twin sites Area is situated on moderately sloping terrain (5%) in a
N-NE direction towards Pages Lake. Pages Lake is about 350 feet
downgradient from the disposal areas. Groundwater seeps and standing
water pools are formed between the disposal areas and Pages Lake.
south of the Area is Highway 5. East of the Area is wooded property. A
road bounds the western edge of the Area. North of the Area is Pages
Lake. The nearest residents live about 350' upgradient from disposal Area
B. A Jaycees But and Boy scout camp are located 350' downgradient of the
Twin Sites Area. Although the Jaycees But had not been used since 1985,
the facility has been used as a day center by a drug rehabilitation group
since August 1990. The Boy scout camp is used 2-3 times per week for
scout meetings and activities, but is not used as a camping area.
However, during a recent EPA site visit a newly constructed beach area was
observed directly downgradient of the Boy Scout Camp along the western
shore of Pages Lake.
AEPCO
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1--... -"-h--l Remedlll lnve1tlg1t100'F111lblllty Study {RllfS) AbenSetn Ptstlcldt Durnpt s11, @ --Coon~.-Cnllna
-370,--Elevatlon (FNt. Mean Sea leveT)
(-_: ', Arau of Densa Vegetation
Fence SCALE: f • 1
Figure 3. site Layout -Twin sites Area.
PAGES
LAKE
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1.3 Fairway six Area
The Fairway six Area is situated off NC Highway 5 west at "The Pit• Golf
Links. coordinates of the area are latitude 35°08'~0"N; longitude
79°27'27"W. Located about 1.6 miles west-northwest of the Aberdeen
Corporate limits, the Area is rural and sparsely populated. The estimated
population within a 1-mile.distance of the Area is less than 1,000.
The Area consists of a cleared area utilized during a test burn conducted
in December 1986, an area of surface contamination (approximately 345' x
225') on the south and north sides of Fairway No. 6 immediately adjacent
to the tee area, and six excavated trenches (Figure 4).
The Area is-•bound-to the north by the-P"it · Golf Links golf course. South,
east and west of the Area is wooded property which is privately owned and
was once planned for residential development.
At the Fairway Six Area, the general topography dips gently to the
northeast (1.5% grade) towards the golf course lake. Two swells drain
surface water from the area of known contamination. Due to prior removal
actions at the Area, surface runoff from the immediate area drains into
the existing trenches.
1.4 Mciver Area
The Mciver Area is located approximately 0.5 mile north of the junction of
SR 1112 and SR 1106, west of Aberdeen (Figure 5). The coordinates are
approximately latitude 35°07'40"N; longitude 79°27'40"W. The estimated
population within a 1-mile distance of the Area is approximately 300.
Situated in a sparsely populated rural area, the Mciver Area consists of
three disposal areas:
Area A -primarily a rubble dump known as "Luck's Landfill".
Area B -also known as the "bag site" consist of a natural depression
approximately one acre in size and 15 feet deep.
Area C -located between Areas A and B covers approximately 22,000
square feet.
Land use in the area is primarily agricultural. other land use in the
area is the landfill itself (Area A) and a borrow pit nearby that is used
by Bill Luck. The Area is bound to the north by an unnamed tributary of
Aberdeen creek. This tributary lies approximately 100 feet north of Area
Band flows east-southeast into Aberdeen creek.
1.5 Route 211 Area
The Route 211 Area is located in Moore County approximately 1 mile east of
the Town of Aberdeen (Figure 6). It is in a wooded area roughly 1,000
feet southwest of Route 211 East and is accessible by an unpaved road.
The coordinates of the Area are latitude 35°07'02"N; longitude 79°23'4l"W.
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---~c,-.--~ ,:::.---........... c,1----
FIGURE 'I. site Layout -Fairway Six Area.
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,..,._,..._C....,,Ml>IIIIC...... "<-"LP Action
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FIGURE s-·. Site Layout -Mciver Area.
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Aemedlal rrtt1tigallon'Fuslb11Uy Study (RI/FS)
Aberdeen Pt1llclde Dumps su,
Abtrdttn, Moorl County, Nol1tl ClfOIINI
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= --450---Elevation (Feet, Mean Sea Lewi)
~ Surface Depreuion EEffi Commerclal/lndustrlalFacllity
■ Buildlng SCALE: O
Figure 6. site Layout -Route 211 Area.
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The Area is an old sand mining pit or basin, the bottom of which
approximates a circle 78 feet in diameter and 8-20 feet deep. The area of
contamination is estimated to be approximately 0.11 acres.
The Area _is located in a sparsely populated area. The land surrounding
the Area is generally pine woods with scattered abandoned sand-mining
pits. The Area is approximately 1,000 feet southwest of Route 211 East
and 100 feet northeast of the main track of the Aberdeen and Rockfish
Railroad. TWo active commercial/industrial facilities are known to be
located within 1,000-2,000 feet·of the Area. The nearest homes are
located 0.25 to 1 mile from the Area. The population within 1 mile of the
Area was estimated at 543 residents.
The Area is basically a basin, separated from surface water by areas of
higher elevation. However, groundwater in the area may be threatened by
the site contaminants. Two community water supply systems use groundwater
within 3 miles of the Area. Homes and businesses not served by community
systems are believed to be on private wells. Local well logs show the
upper portion of the aquifer to be the source of drinking water. The
water table is as high as 15 feet below the land surface.
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2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES
2.1 site History
2.1.1 Farm chemicals Area
Pesticides were produced at the Farm chemicals Area plant from 1936 to
1978. Taylor Chemicals owned and operated the plant from 1936 to 1964.
In 1964, Grower Service bought-out Taylor Chemicals. Grower Service,
operating under the name E-Z Flo and a subsidiary of union Carbide,
operated the facility until it was purchased by Farm Chemicals, Inc. in
1972. Farm Chemicals, Inc. is the current owner.
Taylor Chemicals was reportedly one of the largest pesticide product
distributors in North Carolina in tpe 1940s. Their operations consisted
of purchasing technical grade pesticide dusts and blending them with
fillers such as sodium bicarbonate for application under the br_and name
•superkill•. In 1955, Taylor chemicals registered over 60 different
grades of superkill. The number of registered superkill blends increased
to between 90 and 110 during 1962-1965. Raw pesticide materials included
sulphur, DDT, toxaphene, parathion, aldrin, benzenehexachloride (BHC),
chlordane, dieldrin, endrin, and malathion. Among Taylor's major products
were cotton dust 3-5-40 (3% BHC, 5% DDT, and 40% sulphur), 20% toxaphene
dust, and 60% tox~phene dust.
During Farm Chemicals' ownership, the plant was known in the chemical
industry as a blending, as opposed to a manufacturing plant. The blending
process was an all-liquid one. Basically, the plant purchased raw
materials such a parathion, EPN, and toxaphene from·standard vendors in
the industry, mixed these raw materials in desired combinations (along
with an emulsifying agent) to produce a marketable product. The products
were principally soil micronutrients and insecticides for cotton·
producers. Storage containers for the products were· either 55-gallon
steel drums, or 5-gallon (usually plastic) containers of micronutrients.
The mixing-blending process utilized a 2,000 gallon mixing vat in which
desirable ratios of technical materials were combined with an emulsifying
agent to produce a marketable product. The end product was then placed in
55-gallon steel drums, sealed, labeled and placed in above-ground storage
until it was removed for the appropriate agricultural usage. The residual
product, which did not fill the last 55-gallon drum in the blending cycle,
was marked and identified as to batch number, product, and number of
pounds. These partially filled drums were sealed and stored until the
next batch of similar product was scheduled for formulation, at which time
sufficient quantities of product were available to fill the semi-filled
drums. Any broken containers of technical materials were placed in
salvage containers immediately upon discovery, the· ·relevant vendors were
notified, and such materials were shipped back to the originating company
for their disposal. Prior to 198~, Farm Chemicals released empty
technical material containers to commercial companies specializing in
reclaiming these containers. Residual wastes from containers were -held in
storage prior to their release to the commercial reclaimers •. When the
wastes were in a diluted state,. they were spread on farmland owned by the
company or _its stockholders,: according to recommended usage. The company
also donated empty and cleaned drum containers to the general public for
use as trash-burning receptacles. This practice was eventually curtailed
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when more stringent storage practices were introduced at Farm Chemicals.
The plant's continuous process of blending and storing full containers, as
well as incomplete quantities of product continued. A 1,200-gallon truck
was acquired to facilitate the temporary storage of residual materials
until they could be removed for spreading on company farmland. A residual
build-up of triple-washed drum containers occurred due to decreased demand
by commercial reclaimers. Hence, many of these drums were transported to
a local landfill site for subsequent removal, washing, and further
disposal in accordance with more recent regulations.
The solvent xylene was used to clean the 2,000 gallon stainless steel
mixing vats after each blending process was completed. Wastes from
cleaning vats were placed in temporary storage in the mobile J,200 gallon
tank for removal and spreading on company farmland.
During the site reconnaissance conducted by EPA's remedial contractor, the
REM V Team, sulfur and possibly pesticide-like odors were noticed on site.
crystallized finger-shaped substances (presumed to be pesticide) with
yellowish or black tips were found on site. The chemicals or materials
were similar to those identified at the TWin sites Area across the street
from the Farm chemicals Area.
Between May 11-16, 1986, high frequency ground penetrating radar (GPR),
terrain conductivity, and magnetic field surveys were conducted on the
southern portion of the plant. The GPR profiles indicated the presence of
an extensive trench system underlying the southern portion of the Farm
chemicals• property. Low terrain conductivity measurements over the
trench area suggested nonconductive trench contents; i.e., paper, plastic,
and drums. Augering confirmed the nature of the trench contents and
subsequent analysis of subsurface material revealed contamination by
several pesticides and PCBS. Scattered spots of magnetic field anomalies
were also detected, possibly indicating the presence of buried metallic
objects (E~A-TAT, July 1986).
The GPR survey was extended onto the Brooks-Perkins property south of and
immediately behind Farm ·hemicals' property. This survey identified a
possible trench like structure along with several buried drum like
objects. Terrain conductivity and magnetic field surveys were not
conducted to verify the GPR findings due to time constraints. It was
recommended at the conclusion of the GPR survey that additional data be
collected to verify the findings (EPA-TAT, July 1986).
Four soils samples from the southern part of the Farm chemicals' property
and the adjacent Brooks-Perkins property were collected and analyzed. A
soil sample collected at a depth of 7 feet on the Farm Chemicals• property
confirmed the presence of a buried trench with contamination levels of 800
ppm 4,4'-DDT and 100 ppm PCBs.
2.1.2 TWin sites Area
The North Carolina state Division of Highways reported the first disposal
area discovered at the TWin Sites Area to the NC SIIWMB in July 1984. NC
SIIWMB performed investigative work in August 1984, and learned of another
nearby disposal area through an employee of the Town of Aberdeen. A third
disposal area was suspected and subsequently confirmed during the remedial
investigation. Waste types and disposal methods are similar for all
areas. The disposal areas will be referred to individually when necessary
as Area A, Area B.,, and Area C. Taylor chemicals Company, the name printed
on toxaphene bags:found on site, indicates that it is possible that
disposal activities may date back as early as 1936.
On October 22, 1984, RCRA 3012 personnel of the NC SBWMB conducted a site
investigation at the Twin sites Area. Pesticides bags and colored powdery
material (believed to be pesticides) lay strewn over Areas A and B.
Strong odors were noticed during the investigation. The moderately
sloping terrain has facilitated considerable contaminant run-off in the
direction of Pages Lake. samples of the wastes and soil were collected
from Areas A and B. Laboratory analyses showed the presence of DDD, DDT,
toxaphene, aldrin, heptachlor, lindane, dieldrin, and lead.
During the site reconnaissance by the REM V Team and EPA personnel on
October 26, 1987, a third area (hereinafter known as Area C) of possible
pesticide disposal was found between disposal Areas A and B. sulfur-and
possibly pesticide-like odors were noticed. Crystallized finger-shaped
substances (presumed to be pesticides) with yellowish or black tips were
found throughout the three disposal areas.
In 1985, EPA initiated an emergency response cleanup at the Twin Sites
Area during the periods of June 17th through the 24th and July 30th
·through August 5th. seventy-one truck loads of surface contaminants
containing pesticides and contaminated soil were excavated from Area B.
After partial excavation of Area A; an approximately 200' x 20' x 10' deep
trench containing pesticide wastes (concentrations up to 1,000 ppm) was
identified. A total of 165 truck loads of pesticide waste were excavated
from Area A. contaminants from the Twin Sites Area were shipped to the
GSX facility at Pinewood, s.c. for disposal.
During the site restoration, about 6,500 cubic yards of additional
pesticide wastes were discovered in Area A. Since these wastes did not
appear to pose an immediate threat, they were not excavated as a part of
the emergency response cleanup.
contamination detected in 4 municipal wells and 3 private wells caused the
EPA to reevaluate the Twin sites Area in May 1986. Geophysical surveys
(ground penetrating radar (GPR), terrain conductivity, and magnetometer)
and limited groundwater and soil sampling were conducted between May
11-16, 1986 at and around Area A to identify and delineate potential
contamination sources.
These surveys suggested that no substantial trench structures or
subsurface metallic debris remained in Area A after the 1985 emergency
cleanup activities. Terrain conductivity findings did indicate the
existence of a residual contaminant plume. A groundwater sample, taken
from the top of the water table (13 feet below the surface) near the
center of Area A, confirmed this contamination. Concentrations of up to
76.6 ppb of lindane were reported. soil samples showed the area just west.
of Area A to be free of pesticide contamination, however samples collected
at the northern edge of the excavated area (depths of 11 and 4-6 fe,et,)
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revealed that extensive contamination still existed on the Area.
Concentrations of up to 19 ppm lindane and nearly 300 ppm for the other
BBC isomers were reported along with elevated levels of DDT, DDD, DDE,
aldrin, heptachlor, endrin ketone, and chlordane.
An additional geophysical investigation was conducted with an EM-31
terrain conductivity meter during March 1987. Other than some residual
contamination, no new pesticide deposits were found during this survey
(Roy F. Weston, Inc., no date). The area covered by the survey is
unknown.
2.1.3 Fairway six Area
Prior to devel9pment_of "The Pit" Golf Links, the site was a field within
a wooded area. Access to this field was possible via two dirt roads from
NC Highway 5.
NC SHWMB personnel discovered the. site in August 1984 through an employee
of the Town of Aberdeen, who indicated that pesticide wastes had been
disposed of at and around the Area from time to time for a number of
years.
on October 22, 1984, RCRA 3012 personnel of the NC SHWMB conducted a site
investigation at the Fairway six Area. During the investigation,
household rubbish, old car parts, etc., were observed within the vicinity
of the Area. The general area, therefore, is believed to have served as a
trash dump for many years prior to .the construction of the "Pit" golf
course. Records of waste disposal activity do not exist. several
pesticide bags labeled "toxaphene" were noted, as were colored powders and
fines believed to be waste chemicals, possibly pesticides. The most
prevalent indication of pesticides, however, was strong chemical odor.
Samples of these wastes and soils were collected in October 1984 before
EPA emergency removal action and subsequent analysis revealed the presence
of 2,253 ppm DDT, 573 ppm DDD, 601 ppm toxaphene, and traces of lindane.
EPA initiated an emergency response actions at the site Area on June 25,
1985. The materials on the surface and in Trench No. 1 were excavated and
transported to the GSX facility in Pinewood, south Carolina for disposal.
During the site restoration, Trench No. 2 was discovered, excavated, and
the material was shipped to the GSX facility.
Emergency response action at the Fairway six Area initially terminated on
July 16, 1985·. As a result of the identification of pesticide
contamination in the drinking water in 4 municipal wells and 3 private
wells, the EPA reevaluated the Fairway six Area in May 1986.
Ground penetrating radar (GPR), terrain conductivity, and soil sampling (4
sta~ions) studies were conducted at the Area during May 11-16, 1986. The
geophysical surveys revealed a third buried trench ranging in depth from 4
to 10 feet and containing highly conductive material. Exploratory
augering and sampling verified the presence of pesticide contamination up
to 1,500 ppm. Trench No. 3 was estimated to contain 12 million pounds of
pesticide wastes.
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During December 10-12, 1986, the EPA Emergency Response Team conducted a
test burn of contaminated soil at the Area. Twelve thousand pounds of
material were incinerated in an a-million BTU rotary kiln mobile
incinerator owned and operated by Vesta Tech Ltd. contaminated disposable
supplies and incinerator residue were stored in 55-gallon drums on-site.
An EPA Technical Assistance Team conducted another geophysical survey with
an EM-31 terrain conductivity meter at the Area on March 10, 1987. During
this investigation, the fourth pesticide trench was discovered with
pesticide contamination levels up to 1,500 ppm.
Excavation of the most recently discovered pesticide wastes (in Trench
Nos. 3 and 4) began in August 1988. During this activity, two additional
pesticide waste trenches·were discovered, Trench Nos. 5 and 6. This
material was also excavated; screened, and stockpiled adjacent to the
Area •. The stockpile is isolated from the environment with both bottom and
top liners of 30-mil PVC plastic. These liners were chemically affixed to
prevent migration of this material from the stockpile, while the top liner
was also weighed down by rubber tires.
The stockpile area was enclosed by a 6-foot fence with a locked gate on
the west side near the northwest corner. The dimensions of the pile are
roughly 215• x 110• x 28•. It is estimated to contain about 22,000 cubic
yards of pesticide-contaminated materials. The waste pile was designated
as Operable Unit Two (OU Two) within the overall site strategy for the
Aberdeen Pesticide Dumps Site.
From March 30, 1989 to May 14, 1989, a REM V Remedial Investigation Team
conducted a Feasibility study on OU Two. A Record of Decision was signed
on June 30, 1989. The selected remedy included on-site incineration and
on-site disposal of the residual ash. A potentially responsible party has
agreed to implement the remedy. However, field activity has been
postponed pending the outcome of the remedy selection for Operable Unit
One. The PRP will undertake measures to ensure liner integrity of the
soil stockpile.during this period until field activities begin.
2.1.4 Mciver Area
The Mciver Area was discovered in November 1984 when NC Department of
Agriculture (NCDA) personnel found 200-300 55-gallon pesticide drums
dumped in a rubble landfill ( known as "Lucks Landfill" and Area A),
Further investigation revealed that parathion residues remained in at
least some of the drums.
During the initial investigations by the NC SHWMB, a second area (Area B,
previously known as the Bag Site) was discovered approximately 1,000 feet
to the northwest of Area A. Area B consists of an approximately one-acre
tract where trash, old building materials, and a large number of bags
containing pesticides and pesticide residue had been dumped. The bags
were allegedly disposed by GEIGY chemical, who once had a pesticide
formulation plant in Aberdeen, located along Route 211. The disposal
dates are estimated to be late'1960s to early 1970s.
The property on which the site lies is owned by the estate of Rev. Mary E.
and John Mciver. Their heirs include Rev. Ruth Monroe, who lives about
1,000 feet from the site. Part of the property was leased by Bill Luck,
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and is known as "Luck's Landfill." According to Rev. Monroe, Area A had
been used for an undetermined number of years as a rubble dump. Access to
this Area was not controlled. Although several contractors apparently
used the site to dump rubble, Bill Luck seems to have been the primary
user. Area A was investigated after it was discovered that 200 to 300
pesticide drums had been dumped there. Apparently no environmentally
related permits were obtained for the Area during its use.
In January 1985 Farm chemicals, Inc., Bill Luck and Luck's construction
company agreed to remediate Area A in accordance with a State issued
Administrative Order. The remediation consisted of the following:
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Removal of 686 drums. Drums were triple-rinsed,_crushed and
disposed of in the Moore county landfill.
Five of the 686 drums had liquid in them. Three of these
ruptured during the removal. As a result, contaminated soil was
removed from this area.
Post-removal soil sampling and analysis indicated that parathion
remained in the soil. Confirmation sampling indicated two areas
were contaminated at depths up to 24 inches.
Farm Chemicals then removed 2 to 2.5 feet of soil in those areas
and back filled the holes with clean fill.
Representatives of North Carolina Department of Bu.man Resources overviewed
the removal activities at Area A and determined that Area A of the site
had been remediated. As a result of these actions, and the concurrence of
North Carolina, EPA considers Area A to be completely remediated.
Therefore, EPA focused its remedial investigation in Area B only.
Area B of the site is presently inactive. According to Rev. Monroe,
dumping occurred at Area B approximately 20 to 30 years ago, when
pesticide bags containing residues and old pesticides were simply dumped
on the land surface. Access to Area B has reportedly never been
controlled.
The EPA initiated cleanup and removal actions at Area Bon June 10-16,
1985. Immediate removal activity resulted in disposal of pesticide waste
at the GSX facility in Pinewood, South Carolina.
In March of 1989, during the remedial field investigations, a new area of
dumped pesticide-like wastes was discovered between Areas "A" and "B".
The area, identified as Area C was appr'oximately 75·-x 300 feet and had a
strong chemical odor. The waste material (mostly decomposed cardboard
drums with fine grained white to light grayish, and some tarry black
material) rose 2 -4 feet above ground surface. The edge of the wastes
was within 50 feet of the unnamed tributary to Aberdeen creek which lies
just north of the site. An EPA emergency response action resulted in the
excavation and stockpiling of approximately 3,200 cubic yards of pesticide
wastes and contaminated soil. The method of containment and isolation of
the stockpile (i.e. liners and fence) was the same as was used for the
stockpile at the Fairway six Area.
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2. 1.5 Route 211 '.Area. ;,
Prior to 1964, the Route 211 Area was reportedly used as a sand-mining pit
by Superior Stone Company of Raleigh, North Carolina. The period during
which the Area was actively mineq is unknown at this. time. In 1959,
American-Marietta purchased both the Route 211 Area and Superior stone
Company. The current la~d owner reportedly discovered the waste pile in
the pit shortly after purchasing the property in 1964. However, the Area
appears to have remained unchanged and unused since that time.
There is no indication that any regulatory action had been taken at the
Area or that any environmentally related permits have been issued. On
July 12, 1985, NC SBWMB personnel inspected the Area. It appeared that
waste had been dumped in a pile on the southwest slope of the pit. The
pile contained decomposing cardboard containers, bags, and wastes ranging
from white-tan powders to dark-brown tarry residues. Samples from the
pile and the downgradient soil were collected. Laboratory analyses
indicated the presence of alpha-, beta-, and delta-Bae·, ODE, ODD, DDT,
heptachlor, and chlordane. Some or all of these compounds were detected
in samples taken from the waste pile and the downgradient surface soil.
EPA initiated an emergency response action at the Route 211 Area between
June 4-6, 1986. Five truck loads of surface contaminants or approximately
100 cubic yards of pesticides aAd contaminated soil were excavated from
the basin and disposed of at the GSX facility in Pinewood, south Carolina.
In May 1989, during the installation of monitoring wells around the Area,
about 200 cubic yards of material which appeared to be similar to other
pesticide wastes found at the Area were discovered on the ground and
partially buried in a hillside about 100 yards north of the Area. This
material was removed by the EPA's Emergency Response Team during June 1989
and stockpiled with that material excavated from Area C of the Mciver
Area.
2.2 Enforcement Activities
The Aberdeen Pesticides Dumps site was proposed for inclusion on the
National Priorities List (NPL) in January 1987 and became final on the NPL
on March 31, 1989, Federal Register No. 54, Vol. 61 .. A potentially
responsible party (PRP) search conducted in 1985 identified several PRPs.
On May 15, 1985 and September 30, 1985, EPA notified PRPs of the
conditions at the Site and their potential liability for the costs of
remediating such conditions. certain information was also requested of
the PRPs. The notified PRPs were also ,invited to participate in a removal
" of hazardous substarices from the site. No PRPs came forward to take
action at the site.
On April 13, 1987 EPA sent special notice letters to four identified PRPs
and requested voluntary performance of a RI/FS to abate any release or
threatened release of hazardous substances. None of the PRPs notified
agreed to perform the requested work. EPA therefore, proceeded to conduct
.the RI/FS utilizing the superfund Trust money.
Following a remedy selection for OU Two (Fairway Six Stockpile) in June
1989, EPA issued special notice letters to twenty-two PRPs on Dec'ember 21,
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1989. The special notice letter invited PRPs to enter into negotiations
for implementation of remedial action at ou TWo. Due to the lack of PRP
interest to voluntarily implement the selected remedy, EPA issued Uni-
lateral Adminstrative orders to four PRPs during the week of March 5,
1990. One PRP, Union carbide, agreed to implement the selected remedy at
OU TWo.
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on June 28, 1991, EPA issued a general notice letter to 19 PRPs. The
notice letter provided an opportunity for the PRPs to meet with EPA in
o'rder for EPA to begin facilitating cooperation and coordination among all
parties ·involved. Following issuance of this Record of Decision, special
notice letters, pursuant to CERCLA Section 122(e), will be issued to the
PRPs. The special notice letters will request voluntary participation by
the PRPs in implementation of the selected remedy for OU one.
The Department of Justice (DOJ) filed a lawsuit ori behalf of EPA Region IV
against five defendants on March 31, 1989, pursuant to CERCLA section 107
for recovery of past and future response costs. The suit is docketed as
civil Action No. c-89-231-R and was filed ~n the u.s. District court for
Middle District of North Carolina, Rockingham Division, Greensboro, North
Carolina. As new information became available, the lawsuit was amen_ded to
add 15 new parties responsible for site contamination.
3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION
A Community Relations Plan for the Aberdeen Pesticide Dumps Site was
finalized in April 1988. This document lists contacts and interested
parties throughout government and the local community. It also
establishes communication pathways to ensure timely dissemination of
pertinent information. A fact sheet outlining the remedial investigation
sampling program was distributed in June 1988. subsequently, an
availability session was held on July 18, 1988 at the Aberdeen Railroad
Depot to answer questions concerning the upcoming RI/FS activities. The
RI/FS and the Proposed Plan for ou one were released to the public on May
23, 1991.
sections 113(k)(l)(B)(i-v) and 117 of CERCLA, as amended by SARA, requires
EPA to establish administrative records containing documents used to
select response actions under CERCLA. All documents were made available
in both the administrative record and information repository maintained at
the Aberdeen Town Ball. A public comment period was held from May 23,
1991 to July 24, 1991 and upon request was extended an additional 15 days
to August 8, 1991. A public meeting was held on May 30, 1991 to present
the results of the RI/FS and EPA's preferred alternative as presented in
the Proposed Plan for the Site. A transcript of the May 30, 1991 public
meeting is available for review in the Administrative Record. Prior to
the May 30 meeting a public notice was provided in two local newspapers.
The public meeting was also announced in the Proposed Plan fact sheet
which was distributed to approximately 200 interested parties. In
addition to the May 30, 1991 public meeting, an Availability session was
held on July 2, 1991 at the request of local citizens. The availability
session was held in order that the public had ample time to review the
administrative record and become knowledgeable on the basis for EPA•s
proposal of a preferred alternative. EPA staff at the availability •
session included te.chnical experts, legal counsel, a regional toxicologist
and community relations support.
All comments which·were received by EPA prior to the end of the public
comment period, including those expressed verbally at the public meeting,
are addressed in the Responsiveness summary which is Part III of this
Record of Decision.
4.0 SCOPE AND ROLE OF OPERABLE UNITS WITHIN SITE STRATEGY
As with many Superfund sites, the problems at the Aberdeen Pesticide Dumps
site are complex. As a result, EPA has organized the work into three
manageable components called Operable Units (OU).
Operable Unit·one (OU One) consist of surface and subsurface soil
contamination at the five areas comprising the site. In this ROD for OU
one, EPA is selecting an interim remedial action for source control of
contaminated groundwater. This operable unit will address contaminated
surface and subsurface soil at all of the five areas of the Aberdeen
Pesticide Dumps Site. This operable unit poses one of the principal
threats to human health and the environment because of the risks from
possible ingestion, inhalation or dermal contact with contaminated soils.
Moreover, contaminated soil remains· a continuing source for contaminant
migration from the soil into the underlying groundwater which is the sole
source of drinking water for the local residents. The purpose of this
response is to prevent current or future exposure to the contaminated
soils and to reduce _contaminate migration into the groundwater.
Operable Unit Two (OU Two) was designated for remediation of contaminated
soil excavated and now stored in the Fairway six stockpile in 1988. A
Record of Decision signed on June 30, 1989 for OU Two selected on-site
incineration of pesticide laden soil and debris and on-site disposal of
the treated residuals. After receipt of a Unilateral Administrative
Order, union carbide agreed in March 1990 to implement the selected
remedy. However, upon request by union carbide, EPA has allowed a
postponement of implementation of the selected remedy for OU Two pending
the issuance of this Record of Decision for OU one.
Because the operable units are related on the basis of geography, contain
similar or identical wastes and are related based on the threat posed,
Operable Units One and Two will be combined for purposes of implementing
this Record of Decision's selected remedy. Further discussion for the
basis of this revision on OU Two is provided in Section 10.0 AMENDMENT TO
OPERABLE UNIT TWO RECORD OF DECISION. OU Two henceforward will be
referred to as operable unit Four.
Operable Unit Three (OU Three) was designated for addressing groundwater
contamination at the five areas comprising the site. In addition, an
ecological assessment currently under review at all five areas comprising
the site will also be addressed and is designated as OU Three.
Operable Unit Four (OU Four), because of EPA's ROD tracking system, the
former operable unit Two henceforward will be referred to as ou ,,Four. An
amendment .to ,OU· Two's ROD is considered a new ROD and therefore an,:
operable unit.designation is assigned. •
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5.0 SUMMARY OF SITE CHARACTERISTICS
5.l Farm Chemicals Area
5.l.l Surface Soils (Farm Chemicals Area)
The Farm Chemicals Area operated as a previous pesticide formulation
facility. A total of 49 samples were collected during the field
investigation for pesticide analysis. TWo background stations were
selected in the area surrounding the Farm Chemicals Area. A total of 24
stations were sampled at two depths (3-4 and 5-6 feet) with the exception
of stations SSS-115 (3-4 feet), SSS-122 (5-6 feet) and SSS-119 and SSS-123
(surficial sample). Seven of these samples were al~o analyzed for TCL
metals, total organic-content, cation exchange capacity, and percent
moisture. Table l presents the number of samples collected in soil,
tanks, drums, insulation and air, in addition to the type of analysis
performed on these samples. The significant cont~inants and· their
maximum concentrations for all media at the Farm Chemicals Area are
presented in Table 2.
TABLE 1
SAMPLE MATRIX FOR THE FARM CHEMICALS AREA
No. of No. of
sample Depth Samples
Media Location stations (feet) Yieled Analysis
surface Background 2 2-4 1 Pesticides, PCBs
Soils
on-site 24 0-6 44 Pesticides, PCBS
Duplicates 3 3 Pesticides, PCBs
Splits 7 Pesticides, PCBs,
TCL Metals, TOC/CEC
% Moisture
sub-Background l 22-70 3 Pesticides, PCBs,
surface TCL Metals, TOC/CEC
Soils % Moisture
on-site 5 20-64 17 Pesticides, PCBs,
TCL Metals, TOC/CEC
% Moisture
Miscellaneous
Insulation ll NA ll Asbestos
Containers 13 NA 13 Pesticides, PCBs,
(4 swabs, 9 liquid) TCL Metals, TOC/CEC
svocs
Air on-site 1 NA l Pesticides, PCBs,
Asbestos
/1
TABLE Z
SIGNIFICANT CONTAMINANTS AND THEIR MAXIMUM CONCENTRATIONS
FARM CHEMICALS A(Efi
CHEMICAL SS (mg/kg) SI) (mg/kg) SB (r,g/kg) SW (ug/l) GIi (ug/ll AIR (ng/l) FISH (r,g/kg)
ANTIMONY
ARSENIC
BARIIM
BERYLLIIM
CAOMIIM
CHRCMIIM
COBALT
COPPER
LEAD
MANGANESE
MERCURY
NICKEL
SELENIIM
SILVER ,
VANADIIM
ZINC
5,000
360
110,000
20,000
150
2.4
31,000
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
11A
11A
11A
11A
3
74
8.7
58
15
NA
NA
11A
NA
NA
NA
11A
11A
11A
11A
NA
11A
NA
11A
11A
11A
100
6
430
2,400
5
4,100
6,000
11A
NA
NA
NA
NA
11A
11A
11A
11A
11A
11A
NA·
NA
NA
11A
11A
NA
NA
NA
NA
NA
NA
NA
11A
11A
NA
11A
11A
NA
NA
11A
11A
CHEMICAL
1,1,1•TRICHLOROETHANE
1,1•DICHLOROETHENE
1,2·DICHLOROETHAJIE
BENZENE
SS (ug/kg) SI) (ug/kg) SB (ug/kg) SW (u;/l) GIi (ug/l) AIR (ng/l) FISH (11111/kg)
CARBON DISULFIDE
CARBON TETRACHLORIDE.
ETHYL BENZENE
TETRACHLOROETHENE
TOLUENE
TRICHLOROETHENE
XYLENES (TOTAL)
1,2,4·TRICHLOR06ENZENE
2,4'DIMETHYLPHENOL
2-METHYLNAPHTHALENE
BIS(2·ETHYLHEXYL)PHTHALATE
NAPHTHALENE
4,4'·000
4,4'·DDE
4,4'-DDT
ALDRIN
ALPHA·BHC
BETA·BHC
DELTA•BHC
DIELDRIN
ENOOSULFAN 11 (BETA)
ENDRIN
ENOR IN UT ONE
GAMMA·BHC
GAMMA·CHLORDANE
HEPTACHLOR
HEPTACHLOR EPOXIDE
TOXAPHENE
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
11A
230,000 a,ooo
13,000,000
590
8,800,000
420,000
540,000
2,400
97
1,300,000
640
660
3,200,000
11A
11A
11A
NA
11A
11A
11A
NA
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
52,000
200,000
NA
11A
11A
11A
NA
650
120
1,300
160
85
52
100
4,500
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
NA
11A
500
21
6,700
17,000
970
1,100
17
64,000
11
48
9
13
18
9
6.9
0.4 o. 1
0.2
0.4
10
11A
NA
11A
11A
11A
11A
11A
11A
NA
11A
11A
11A
11A
11A
11A
11A
0.035
0.14
0.56
0.018
0.061
0.3
0.014
0.048
0.013
. 2.a
SS -Surficfal 1oil; SO• Sedhnent; S8 -Sf.bsurface ao;t; SW• Surface water; GW • Gro.ndwater;
AIR· Air; FISH· Fish tissue; 11A • Not available (enalysf• ••• not perfonoe<I) or not ■wlfcabla.
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A r~, ...............
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
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Across the Farm Chemicals Area, fourteen different pesticide species were
detected in the soil samples. Species, frequency of detection (number of
positive values over total number of samples not including split samples),
and the concentration range are summarized, in decreasing order of
detection.
Pesticide Frequency of
Species Detection Concentration tug/kgl
4,4'-0DT 41/47 (87%) 84 -13,000,000
toxaphene 29/47 ( 70%) 450 -3,200,000
alpha-BHC 26/47 (55%) 8.4 -8,800,888
gamma-BHC 19/47 (40%) 9 -1,300.,_000
beta-BHC --15/47 (32%) 11 -420,000
4,4'-00D 13/47 (28%) 34 -230,000
4,4'-DDE 13/47 (2 8%) 22 -230,000
delta-BHC 12/47 (26%) 9.5 -540,000
dieldrin 9/47 (19%) 39 -3,600
~ aldrin 5/47 ( 11%) 82 -590
gamma-chlordane 4/47 ( 9 % ) 89 -640
heptachlor 4/47 ( 9 % ) 12 -660
endrin ketone 2/47 (4%) 18 -97
methyloxychlor 1/47 (2%) 84
In general, most of the areas of elevated pesticide concentrations are
located either near the edges of buildings and/or loading dock areas, or
in suspected (or known) buried trench areas identified in the geophysical
survey. No PCBs were detected. Total pesticide concentrations in surface
soil samples is shown in Figure -1-.
No background sample for metals was collected. However, the metals
analyses from the shallow subsurface soil sample from the background
monitoring well for this area was used for comparison. Except for station
SSS-119, surficial soils samples revealed metals and.concentrations
typical of the area and mainly comparable to background, except for
elevated lead levels at the shallow interval at two stations detecting 21
and 26 mg/kg. Foreign material was encountered during augering at both
these stations, and may be related to these elevated concentrations of
lead. station SSS-119 was collected from an area of stained soil and
pesticide-like material. Arsenic was found at an extremely elevated
concentration, 5,000 ppm. Lead was also found here at 20,000 ppm, much
greater than that found elsewhere on-site.
For the purpose cf a baseline risk assessment, all compounds present at a
maximum concentration greater than 5 times the laboratory blank
concentration were evaluated. Exceptions to this include acetone,
methylene chloride, toluene, 2-butanone, and phthalates which were
evaluated if present at concentrations greater than 10 times the
corresponding laboratory blank concentrations. The organic contaminants
of concern for the surficial soil media at the Farm chemicals Area
include: alpha-BHC, beta-BHC, delta-BHC, gamma-BHC, 4,4'-DDD, 4,4'-DDE,
4,4'-DDT, aldrin, dieldrin, delta-chlordane, heptachlor, endrin ketone,
and toxaphene. Metals of concern for this area include: arsenic, lead,
barium, copper, manganese, nickel, and zinc.
/ 'l
N
()
-
0
111
'
"'-'"""' lo.ce\k,t,) 1-..-.-.0, .o f'L w .. 1) :r•.:.:~;-""------J:-,
,s·-te1
10·-,ro
DENSE
TREES
sss-121" • ,_
.. ,,----
0°~
~
~ f) C' u
A (J
0
NORFOLK '"
"'
• J4D <...:.J10 J10
·-11 Jso ·-~ ·-~
N.C.
){-){-..
• FENCING IC • ~ .. ......,,. ){
• m suRnaAJ.. SOII./SU1lSURfAC( SOIL SA1,1Pl( LOc.-.noN
AtmfdLal lnvnllgallon/FHtlbllltJ Study (RIIFS)
. Abttdlen Putldde Dump1 SIie
.r-~ . O£J'nt Of" S.I.MPU: (fl) ., TOT-'L P(STICIO( CONCENTR.-.nON (u9/k9)
~ KNO'M-1 TROIOi AA(A
Aben:teen, Mooni County, NOf1h C.rolll\l
FIGURE 7
-II!!!!! 1!!!111
(2J POT£NT\Al 0A SUSJ'[Cml TRDICtt AAEA
SCALt
Total pesticide concentrations in surficial and subsurface
soils and location of suspected buried trenches -Farm
Chemicals Area. (: -.. --1!111 ...
,oo
--
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5.1.2 subsurface Soils (Farm chemicals Area)
Nineteen subsurface soil samples were collected from the monitoring wells
installed during the field investigation. Samples were collected at three
intervals: one taken above the water table, one from the capillary fringe
zone, and one from the interval where the well screen was installed.
samples collected from boring l-MW-01 were used to evaluate background
conditions. The significant subsurface soil contaminants and their
maximum concentrations are presented in Table 2.
Elevated levels of 4,4'-DDT,-DDD,-DDE (120-1,300 ppb) and toxaphene (4,500
ppb) were found in subsurface soil samples collected at 20 feet below
ground surface. BBC isomers and 4,4'-DDT were identified at a depth of 35
feet. below ground surface at concentrations of 52-160 ppb-and 66 ppb
respectively. The pesticide contamination detected·in the subsurface soil
samples demonstrates downward migration of these contaminants.
Ethyl benzene and total xylenes, which were detected in at least one
sample from four of the five on-site borings, were the only voes found in
significant concentrations. As with the pesticide concentrations, samples
from the boring for l-MW-04 were the most contaminated with voes. The
shallow sample contained ethyl benzene and total xylenes at concentrations
of 1,400 and 10,000 ug/kg, respectively; while the water table sample was
most contaminated with 52,000 and 200,000 ug/kg of these contaminants
detected. Further downward migration of these voes was evident, as trace
levels were detected in the deepest sample (ll and 50 ug/kg,
respectively). Total pesticide concentration for the subsurface soil
samples are shown in Figure 7.
Metals detected in samples from the borings on-site were mainly typical of
those found in the area, and concentrations of most of them were
comparable to background levels. However, elevated concentrations of
several metals were detected in the deepest sample from l-MW-06 at a depth
of 55 feet. Metals present in concentrations greater than 2 times the
Contract Required Detection Limit (CRDL) included: aluminum, calcium,
chromium, iron, lead, vanadium, and zinc. Total organic carbon, cation
exchange capacity, and percent moisture analysis for these samples ranged
from 110-15,000, l.9-4 meq/kg, and 3-21 percent, respectively.
Organic subsurface soil contaminants meeting the minimum concentration
requirements for evaluation under the baseline risk assessment are as
follows: 4,4-DDD, 4,4-DDE, 4,4-DDT, alpha-BBC, beta-BBC, delta-BBC,
gamma-BBC, and toxaphene. Metal contaminants evaluated for this area
include: chromium, barium, cobalt, copper, manganese, vanadium, and zinc.
5.1.3 Tank/Drum/Insulation (Farm chemicals Area)
The Farm Chemicals Area is the only area at the site containing
buildings/structures. There are ll buildings and 3 above ground storage
tanks at this site. Soil samples collected near the foundations of
several of the buildings contained highly elevated levels of pesticides.
Eleven insulation samples were collected from these buildings, consisting
of both blown-on insulation and pipe-wrap types for asbestos analysis.
Three samples taken from pipe-wrap insulation near the warehouse just
south of the mixing vat area were positive for asbestos (20-40%). Three
of nine building samples revealed levels of asbestos up to 40%.
21
Residual material's in drums and containers in sever~l of the on-site
buildings were sampled and analyzed for pesticides, PCBs, voes, and TCL
Metals. On-site drums, 5-gallon buckets and tanks were sampled. PCBs
were not detected in any samples. One liquid sample collected from a tank
contained 490,000 ppm toxaphene. swab samples from a mixing vat and sump
area revealed pesticide residues. Most tank samples revealed elevated
levels of voes. SVOCs were also detected in the liquid tank sample.
Metals were detected in the liquid tank and swab samples.
5.1.4 Air (Farm Chemicals Area)
One air sample collected at the Farm Chemicals Area was analyzed for
pesticides, PCBs, and asbestos. Laboratory results revealed ten pesticide
species ranging from 0.013-2.8 ug/m3 • These pesticides included
alpha-BBC, gamma-BBC, heptachlor, aldrin, dieldrin, gamma-chlordane,
toxaphene, 4,4'-DDD, 4,4'-DDE, and 4,4'-DDT. Asbestos and PCBs were not
detected in the on-site air sample.
5:1.5 Area of contamination (Farm Chemicals Area)
Two known buried trenches and one suspected trench are contained within
the boundaries of this area. one of the known trenches is located in the
southern portion of the area and probably consists of a system of multiple
trenches based on geophysical ~urvey results. The outline of these
trenches is fairly well defined; however, their depths are unknown. For
volume estimation purposes it is assumed that almost the entire southern
portion of the area will have to be excavated/treated. The other known
trench is located in the central area of the site and was confirmed by
surficial and subsurface soil sampling. However, the boundaries of this
trench are not clearly established .. One sample collected in the suspected
trench area in the eastern portion of the area contains a total pesticide
concentration in excess of 3,000 ug/kg at a depth of 5 to 6 feet. Further
sampling should be conducted in this area to verify the presence of a
trench; however, this relatively small area is assumed to require
remediation.
As mentioned above, for volume estimates these trenches (and underlying
contaminated soils) are assumed to extend to a depth of 15 feet below
grade. To reach the target cleanup goals at a 10-• health based level,
the total volume of material to be remediated from the Farm chemicals Area
is estimated to be 1,307,962 cubic feet or 48,443 cubic yards. _Areas
requiring excavation are presented in Figure 8.
5.2 Twin Sites Area
5.2.l Surface Soils (Twin Sites Area)
The TWin Sites Area consists of three disposal areas (Areas "A", "B", and
"C") located on adjacent properties. A total of 32 sampling stations were
selected for the Twin Sites Area. Three background samples were collected
surrounding the perifery of the on-site sampling grid and analyzed for
·pesticides and PCBs. Although no background surface soil samples were
analyzed for metals, background comparison levels were obtained from
subsurface soil sample SUB-201 collected at 15 feet below grade. The
remaining 55,. samples were collected f_rom 29 stations located within the
z.?...
, .. {"
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l,J
-,_
DENSE
TREES
Ill
AEPCO
North
(f)
-----·-------= -----------~ UUTHERN
\
,,----.
0°~
~
' \I:,-c
~ /") 0 u
10 c>
•
Remdll ~wtsdg16M'Ftaslblllty Study (RIIFSJ
,lbffdtt,n it.ttcidt Oumpt Sit,
Abffl!rrn, Moor, County, North Carollna
"'
SAMPl.£ LOCATION
O(Plll OF SAMP1£ (f"l) -TOTAJ.. f'(STICIOE CONCDflRATION (u9j\:9)
AAEA 0:CAVATrtl TO 15 fITT BG\.
AREA O'CAVAllll 1tl 10 FTET Bet.
AA(A D:C"VAlrn TO 5 mT SCl
FIGURE P. Area of contaminated soil requiring remediation at the
Farm chemicals Area.
SSS-107 ,-.1,no :!"•1.ll4
ENSE
rn s
grid area and analyzed'for pesticides and PCBs. These samples ranged in
depth from O -5,:;feet below grade. Six of the on-site samples were also
analyzed for TCL metals, total organic content, cation exchange capability,
and percent moisture. Table 3 lists the samples collected in soil and.air in
addition to the type of analysis performed on these samples. The significant
contaminants and their maximum concentrations for all media at the Twin Sites
Area are presented in Table 4.
TABLE 3
SAMPLE MATRIX FOR THE TWIN SITES AREA
No. of No. of
Sample Depth Samples
Media Location stations (feet) Yieled Analysis
surface Background 3 3 & 5 3 Pesticides, PCBs
Soil
on-site 26 0 -5 49 Pesticides, PCBS
3 0 -5 6 Pesticides, PCBs,
TCL Metals, TOC,
CEC, % Moisture
Sub-Background 1 15-51 3 Pesticides, PCBs,
surface voes, TCL Metals,
Soil TOC (one sample),
% Moisture
on-site 4 3-25 12 Pesticides, PCBs,
-voes, TCL Metals,
TOC, CEC,
% Moisture
Air on-site 1 NA 1 Pesticides, PCBS
Fifty percent of the on-site stations revealed pesticide contamination at
concentrations greater than 2 times the CRDL. The pesticides detected, their
frequency of detection, and concentration ranges are summarized below.
Pesticide Frequency of
Species Detection Concentration tug/kg)
4,4'-DDT 21/55 ND -340,000
alpha-BBC 19/55 ND -440,000
beta-BBC 18/55 ND -35,000
delta-BBC 14/55 ND -160,000
gamma-BBC 13/55 ND -160,000
4,4'-DDD 13/55 ND -11,000
·. toxaphene 4/55 ND -340,000
dieldrin 4/55 ND -1,100
aldrin 3/55 ND -390
2t/
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TABLE L/
SIGNIFICAN: CONTAMINANTS .AND THEIR MAXIMUM CONCENTRATIONS
TWIN 6r1e· s ,I/,?;; rl
CHEMICAL ss (m;/kg) SD (m;/kg) SB (m;/kgl SW (ug/l) GIi (ug/l) AIR (ng/ll FISH (m;/kg)
------------------------------------------·--------------------------------------------------------------------
ANTIMOIIY 430 NA
ARSENIC 3.3 94 4.2 11A
BARIIM 32 69 4.4 40 38 11A 0.91
BERYLLIIM 1 .9 11A
CAl>MIIM 3.4 2.6 11A
CHA~IIM ---15 65 9 11A 0.25
COBALT 4.6 a 6 11A
COPPER 36 120 180 11A 0.71
LEAD 4.7 290 11 51 9 11A
MANGANESE 7.6 24 15 940 210 11A 0.96
MERCURY 0.13 11A 0.71
NICKEL 79 36 NA
SELENIIM NA 0.42
SILVER 22 NA
VANADIIM 24 600 19 42 11A
ZINC 5.8 1,900 800 540 NA 1a
---------------------------------------------------------------------------------------------------------------
CHEMICAL ss (ug/kg) SD (ug/kg) SB (ug/kgl SW (ug/l) GIi (ug/1) AIR (ng/ll flSH (m;/kg)
------------------------------------------·-------------------------------------------····-----------------~---
1,1,1•TAICHLOROETHANE NA 100 11A 11A
1,1·01CHLOROETHENE NA NA NA
1,2·DICHLOROETHANE 11A 520 6 200 NA 11A
BENZENE 11A 11A NA
CARBOII DISULFIDE 11A 11A NA
CARBOII TETRACHLORIDE 11A NA NA
ETHYL BENZENE NA 46,000 4 2100 600 11A NA
TETRACHLOROETHENE 11A 69 1 9 NA NA
TOlUENE 11A 260 98 36 11A 11A
TR I CHLOROETHENE NA 11A NA
XYLENE$ (TOTAL) NA 250,000 19 8,400 2,90D 11A 11A
··------------------------····--···---···-······ ............. -.. --.... ---. ........... --········· -····-·····-
1,2,4·TRICHLOR08ENZENE NA 11A 11A NA 22 11A
2,4·DIMETHYLPHENOl NA 11A 11A 11A 6 11A
2·METHYLNAPHTHALENE 11A 11A 11A 11A 11A
BIS(2·ETNYLHEXYL)PHTHALATE 11A 11A 11A 11A 11A 6.5
NAPHTHALENE 11A NA 11A NA 11A
----····---····-····-·-··· ··········-·····--·-·-····---···· -···--····-----····-----------··· ------------
4.4'·000 11,000 51,000 37'0 1. 7 0.056 0.009
4,4'·DDE 37,000 4,400 480 0.011 0.015
4,4'•0DT 340,000 56,000 5,900 o.n D.045 0.009
ALDRIN 390 3.5
ALPHA·BHC 440,000 6,100 130 11 10 0.440 0.012
BETA·BHC 35,000 1,600 330 6. 1 5 O.D18 D.006
DELTA·BHC 160,000 2,300 9.2 18 O.D15 0.016
DIELDRIN 1,100 150
ENDOSULfAN II (BETA) 160
ENORIN
ENDRIN KETONE 22 a1 2. 1
GAMIIA·BHC 160,000 9.1 4. 1 o.on 0.002
GAMIIA·CHLORDAIIE
HEPTACHLOR 42 0.032
HEPTACHLOR EPOXIDE
TOXAPNENE 340,000
··-·····--···········--··--···--·-····--···---···-·-················--·-----·-··········-------·-·····--·······
SS -Surficial soil; SD • Sedfant; SI -SI.Durfee• soil; SW • Surface water; GW -Grouidwater;
AJA· Air; FISH· Fish tfa1ue; NA· Not ava;lable (analyafa 1111 not perforaed) or not applfcable.
endosulfan I
4,4'-DDE
heptachlor .
2/55
2/55
1/55
ND -160
ND -37,000
ND -42
The sampling stations were located either in or adjacent to suspected
burial areas as identified during the geophysical survey. The BBC isomers
in addition to 4,4'-DDT, and 4,4'-DDD, account for most of the
contamination for this area. station SSS-218, located south of Area c,
was the most contaminated with total pesticide concentrations of 1,162,800
ug/kg at a depth of 3 feet below grade. Sample sss-227, located in Area
A, was the second most contaminated with a total pesticide concentration
of 1,146,000 ug/kg at a depth of 3 feet below grade. Pesticide
contamination in surface soil samples SSS-230 and SSS-224 suggests the
existence of additional buried material southeast of Area A. PCBs were
not detected in any of the surface soil samples. Total pesticide
concentrations for the surface soils are shown in Figure 9.
Several metals were detected in the six on-site samples analyzed for
metals at concentrations greater than 2 times the CRDL. The contaminants
detected in these samples included aluminum, calcium, chromium, copper,
lead, iron, and vanadium in maximum concentrations (mg/kg) of 12,000,
220,000, 15, 36, 4.7, 7,800, and 24, respectively. other·analysis for
these samples included total organic content (ND to 5,900 mg/kg), cation
exchange capacity (1.8 to 16 meq/kg), and percent moisture (4 to 34
percent).
Based on the qualifications required for the baseline risk a~sessment, the
following organic compounds were evaluated as contaminants of concern for
. the surficial soil media at th.e Twin sites Area: alpha-BBC, beta-BBC,
gamma-BBC, delta-BBC, 4,4'-DDD, 4,4'-DDE, 4,4'-DDT, aldrin, dieldrin,
heptachlor, toxaphene, endrin ketone, and endosulfan I. The metal
contaminants. of concern include chromium, barium, coppe_r, mangane-se,
mercury, vanadium and zinc.
5.2.2 Subsurface soils (Twin sites Area)
A total of 15 subsurface soil samples were collected from the 5 borings
labeled 2-MW-01 through 2-MW-05. These samples were analyzed for
pesticides, PCBs, voes, TCL metals, and percent moisture. Eight of these
samples were also analyzed for total organic carbon and three were
analyzed for cation exchange capacity. Station SUB-201, located in the
southwest corner of the area, was used to evaluate background conditions.
The significant subsurface soil contaminants and their maximum
concentrations are presented in Table· 1
Pesticide contamination was detected only in samples collected from
stations SUB-203 and SUB-204. Sample SUB-203, directly downgradient from
Area •A11 , contained the greatest level of tot~l pesticide concentrations
at 6,730 ug/kg from a depth of 3 feet. 4,4'-DDT comprised over 50 percent
of the total pesticide contamination det~cted in this sample. Xylene was
the only voe detected in the subsurface soil samples at concentrations·
greater than 2 times the CRDL. Concentrations for this contaminant ranged
from 11 -19 ug/kg and were detected in the shallow and deep interval at
SUB-202 and in all three intervals in SUB-204. PCBs were not detected in
any of the subsurface soil samples. The t-~-t-al pesticide concentrations
for subsurface soils are shown in Figure
,_.
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---J
AEPCO
Nonh
(f)
----... -----..
-.. ----·-··1
=
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' • '
4)~
¥
0
RemNlel lmestlga11onlf ... lblllty Study (Rl/fS)
AbenlNn PNllc:lda Dumpa stte
AbardNn, Moor. County, Ho,th C.rolln,,
FIGURE '/
1~·-r10
r ,.
ss
SSi226 ,r.
3.,32300 ~-~•-am AREA sss-221e A ss •1146.000 ~ -2~9 ·• ""~ 3" .. ~.120
• EB Surflclal/Subsurface Soll Sample Depth of Sample
3· .. 2.geo Depth of Sample (ft)= Total Pesticide Concentration {ug/kg)
. O Suspected Trench Area
SCALE: Ff .
Total pesticide concentrations in surficial and subsurface
soils and location of suspected buried trenches -Twin sites
Area.
--..
PAGES
LAKE
+
several metals were present in the subsurface soil samples in
concentrations in excess of 2 times the CRDL. These contaminants included
aluminum, arsenic, cadmium, chromium, lead, and manganese. With the
exception of aluminum, all of the metals detected were located in the
eastern portion of the area at stations SUB-202 and SUB-204. The percent
moisture for these samples ranged from 9. to 20 percent. The total organic
carbon (TOC) for the seven on-site samples analyzed for TOC ranged from
170 to 1,000 mg/kg. Cation exchange capacity was analyzed for in three
samples, with values ranging from 2.7 to 3.9 meq/kg.
Organic subsurface soil contaminants meeting the minimum concentration
requirements for evaluation under the baseline risk assessment are as
follows: 4,4'-DDD, 4,4'-DDE, 4,4'-DDT, alpha-BBC, beta-BHC, delta-BBC,
gamma-BBC, dieldrin, endrin ketone, 1,2-dichloroethane, ethyl benzene, and
xylene. Metal contaminants evaluated for this area include arsenic,
cadmium, barium, vanadium, manganese and lead.
5.2.3 Air (Twin Sites Area)
One air sample was collected from the Twin Sites Area and analyzed for
pesticides and PCBs. Laboratory results indicate that this sample
contained alpha-BBC, beta-BBC, delta-BBC, gamma-BBC, heptachlor, 4,4'-DDD,
4,4'-DDE and 4,4'-DDT .. concentrations for these pesticides ranged from
0.011 to 0.44 ug/m'. PCBs were not detected in this sample.
5.2.4 Area of contamination (Twin sites Area)
Area C is a known pesticide disposal area where, unlike Areas A and B, a
removal action has not occured to date. The exact boundaries of this
disposal area are unknown, however, for volumetric estimation the visibly
contaminated area at the ground surface is assumed to extend to a depth of
15 feet. Because Area A has undergone a prior removal action, only 10
feet of material was estimated for remediation. Both the areal and
vertical extent of the contamination is not well defined due to the
limited sampling conducted in these areas.
Residual levels for total pesticide contamination exceeded 1,162,800 ug/kg
for surface soil samples. The areas outlined1 for excavation were
delineated using the surface soil sampling results. To obtain the target
10-• health-based cleanup level for this area, the estimated volume of
material requiring remediation is 718,632 cubic feet or 26,616 cubic
yards. Areas requiring excavation are presented in Figure 10.
5.3 Fairway six Area
5.3.l surface soils (Fairway six Area)
The Fairway six Area consists of a pesticide disposal area located on the
north and south side of fairway number six of "The Pit" Golf Links. A
total of 37 sampling stations were.selected for this area including 4
background stations located around the perifery of the grid area. Two
samples were collected at background station sss-314 at depths of 2-3 feet
and 5-6 feet, while a single sample was collected at 5-6 feet for the
remaining background stations. Two samples were collected from each
station within the on-site grid area at depths ranging from 2-7 feet,
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AEPCO
North
(f)
--
~222
~ f ,-,:;,-,:,__ DENS( +
"' '-.,.
•
sss--m
SSS-220 •l•II
D
Remedlll iwtsllgadONftulbfllty Studi {RI/FS)
Abtrdetn Ptslldde Dump1 S119
Aberdun, Moon County, Horii C.rdlna
o~n
Surflclal,
Oeplh (fl):: Total Pes11clde Concentration (uglkg)
Area Excavated to 5 Feet BGL
Area Excavated to 10 Feet BGL
Area Excavated to 15 Feel BGL SCALE:
FIGURE JO. Area of contaminated soil requiring remediation at the
Twin sites Area.
i l l
PAGES +
LAKE
+
=
except·ifor .:SSS'-339, where only a single sample was collected. All of the
samples collected·· were analyzed for pes'ticides only. Six of these samples
were also analyzed for TCL metals, total organic carbon, cation exchange
capacity, and percent moisture. Table 5 list.s the samples collected in soil
and air in addition to the type of analysis performed on these samples.
Significant contaminants and their maximum concentrations for all media at
the Fairway six Area are presented in Table 6.
TABLE 5
SAMPLE MATRIX FOR THE FAIRWAY SIX AREA
No. of No. of
Sample Depth Samples
Media Location stations (feet) Yieled Analysis
surface Background 4 2-3, 5-6 5 Pesticides
Soils
on-site 25 2-7 57 Pesticides I
on-site 6 2-7 12 Pesticides, CEC
TCL Metals, TOC,
% Moisture
sub-
surface Background l 21-70 3 Pesticides, PCBs,
soils voes, TCL Metals,
TOC, CEC
on-site 6 7-115 14 Pesticides, PCBs,
voes, TCL Metals,
TOC, CEC (one
sample)
Air on-site l NA l Pesticides, PCBs
Of the 33 soil sampling stations at the Fairway Six Area, 23 contained
detectable levels of pesticides. Pesticides were found at both depths
sampled at 20 of the 33 stations. Seven of the 10 stations which contained
no pesticide contamination were 'concentrated in the north and northeastern
200 feet of the grid area. The remaining 3 stations were concentrated in
the southeastern section of the grid area. Thirteen pesticides were
identified within the sampling grid. The types, frequency of detection, and
concentration range are summarized below.
Pesticide Frequency of
Species Detection Concentration lug/kg)
4,4-DDT 43/69 (62%) 18" -210,000
alpha-BBC: 28/69 (41%) 9. 4• -10,000
beta-BHC 26/69 (38%) 8. 4• -4,800
4, 4-DDD , '·: 22/69 ( 32%) 20· 2,300
delta-BBC ''..-. 23/69 (33%) 8. 3· 1,800
30
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TABLE
SIGNIFICANT CONTAMINANTS AND THEIR MAXIMUM CONCENTRATIONS
FAIRWAY SIX 1//c'1~
CHEMICAL SS-(m;/kg) SO (m;/kg) SB (m;/kg) SW (u;/l) GIi (u;/l) AIR (ng/l) FISH (m;/kg)
ANTIMONY 11A
ARSENIC
BAR II.JI 12 56 12
11A
11A ,. 1
BERYL LIi.Ji NA
CADMII.JI 11A
CHROMII.JI 20
COBALT
COPPER 12
LEAD
MANGANESE 23
MERCURY 0.15
NlCKEL
SE LEN II.JI
e. 1
8.4 32
240 11A 0.32
11A
11A 110
11A 4.4
210 11A 0.22
11A 0.67
150 11A 3.2
11A 0.42
SILVER 11A
VANADII.JI 180 16 11A
ZINC 30 11A 61
CHEMICAL SS (u;/kg) SO (u;/kg) SB (u;/kg) SW (UQ/l) GW (u;/l) AIR (ng/l) FISH (1119/kg)
1,1,1·TRICHLOROETHANE NA 2 e 11A 11A
1,1·DICHLOROETHENE NA 5 2 11A 11A
1,2·.DICHLOROETHANE 11A 11A 11A
BENZENE 11A 1 11A 11A
CARBOII DISULFIDE 11A 60 11A 11A
CARBOII TETRACHLORIDE 11A 2 11A 11A
ETHYL BENZENE 11A 11A 11A
TETRACHLOROETHENE 11A 3 11A 11A
TOLUENE 11A 11A 11A
TRICHLOROETHENE NA 11A 11A
XYLENES (TOTAL) 11A 11A 11A
·-·····--------------------------···-.............. ·---------· ---------·· -----······ ----··--·--·-----------1,2,4·TRICHLOROBENZENE 11A NA 11A 11A 21 NA
2,4·DIMETHYLPHENOL 11A 11A 11A 11A 11A
2·METHYLNAPHTHALENE 11A 11A 11A 11A 11A
BIS(2•ETHYLHEXYL)PHTHALATE 11A 11A NA NA 11A 3.3
NAPHTHALENE 11A 11A 11A 11A 11A
--------------------------.. .. .. . .. .. .. ----·------·----------------····· ----------------------...............
4,4'·000 9,300 71 52 0.012 0.018
4,4'•DOE 1,800 150 30 0.006 0.018
4,4' ·DDT 210,D00 1, 100 710 0.035 0.016
ALDRIN 200.0 C 0.07
ALPHA·BHC 10,000 550 0.7 7.8 0.032 0.016
BETA·BHC 4,800 22 260 7 0.006 0.006
DEL TA·BHC . 1,800 130 13 0.022
DIELDRIN 360
ENDOSIJLFAN 11 (BETA)
ENDRIN
ENDRIN ICETOIIE 80
GAMMA·BHC 1,600 120 0.4 0.002
GAMMA-CHLORDANE
HEPTACHLOR 930 0.01
HEPTACHLOR EPOXIDE 10
TOXAPHENE 12,000
-----------------------------------------------------------------------------------------------------······-··· SS • Surffcfal aofl; SD· Sedl11ent; SI• SU:.Urf■ce aotl; SW -Surface water; GW -Grcan::lwater;
AIR· Afr; FISH -Ffsh tissue; NA -Not ava;lable (anelysfa was not perfo,-.,d) or rot applicable.
3/
gamma-BHC 13/69 (19%) 0. 5· -1,600
dieldrin 6/69 (9%) 17• 360
4,4-DDE 6/69 (9%) 10· -1,800
toxaphene 5/69 (7%) 210· -12,000
heptachlor 3/69 (4%) 18 -930
aldrin 3/69 (4%) 16 -200
endrin ketone 3/69 (4%) 16. -80
heptachlor epoxide 1/69 ( 1 % ) 10·
. Indicated concentration below two times the CRDL.
Total pesticide concentrations at the shallow interval (2-3 feet) ranged
from non-detect (ND) to 214,230 ug/kg, while those at the deeper interval
(5-6 feet) ranged from ND to 14,770 ug/kg. Jotal pesticide concentrations
increased with depth only at stations SSS-310, -317, 318, -334, and -338.
Because much of the area has been disturbed during the excavation.of the
buried trenches, it is unknown whether the elevated levels found at depth
are due to downward migration of the contaminants or are residues of
buried material. Total pesticide conentrations in the surface soils are
shown in Figure 11.
several metals were detected in the 6 samples collected for this analysis
in concentrations greater than 2 times the CRDL. These contaminants
included aluminum, chromium, iron, lead, magnesium, manganese, vanadium,
and zinc. Th.e six samples collected for metals analysis were also
analyzed for percent moisture (5 -9 percent), total organic carbon (ND -
2,200 mg/kg), and cation exchange capacity (3.4 -11 meq/kg),
Based on the qualifications required for the baseline risk assessment, the
following organic compounds were evaluated as contaminants of concern for
the surficial soil media at the Fairway Six Area: alpha-BHC, beta-BHC,
gamma-BBC, delta-BBC, 4,4'-DDD, 4,4'-DDE, 4,4'-DDT, aldrin, dieldrin,
delta-chlordane, heptachlor, heptachlor epoxide, toxaphene, and endrin
ketone. The metal contaminants of concern include chromium, barium,
copper, manganese, mercury, vanadium and zinc.
5.3.2 subsurface soils (Fairway six Area)
Three subsurface soil samples were generally collected from each of the
six on-site moni taring wells: one above the water table ("A"), one from
the capillary fringe zone ("B"), and one from the well screen interval
("C"). A total of 18 samples were collected from 7 to 115 feet below
grade and were analyzed for pesticides, PCBs, voes, and TCL Metals. one
sample was analyzed for CEC. samples collected from boring 3-MW-01
(SUB-301) were used to evaluate,background conditions. The significant
subsurface soil contaminants and their maximum concentrations are
presented in Table 6.
Borings for wells 3-MW-02, 3-MW-03, and 3-MW-04 were contaminated with at
least two BHC isomers, 4,4'-DDT and 4,4'-DDD. Sample SUB-303A, collected
at a depth of 13.5 feet, contained the greatest concentration of total
pesticides, 1,702 ug/kg. The total pestide concentrations in subsurface
soils are ·.shown in Figure 11.
.3 '2.. r
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SSS-398 • 5'•NO
AEPCO
North
@
FIGURE //
+
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~ •NO SS-J25
+ ,, .!!,.,--==-
+
~(.6 5 •NO
"'
'
SSS-J18
WW-OJ J •NO
ffiu•-1as2 s--JtJ
Z• •300
SSS-J\4 • Y•HD S'•NO
-j-
""' '--"
+
SUrflclal/Subalrfac. soll MmPI•
Sample dl,pth ■ Total Pfftlc:ldll
Conc:.nt...tlon (~)
SU.,.c:ted tffllch
Prwloualy EzcnetM TNnch
+
SCALE: 1 a • ,.
Total pesticide concentrations in surficial and subsurface
soils and location of suspected buried trenches -Fairway six
Area.
33 r
(
Acetone was found in.both the shallow and mid-level depth samples in
boring 3-MW-02 at concenrtations of 5,400 and 560 ug/kg, respectively.
Acetone was also detected in the deepest sample at 3-MW-03 and 3-MW-04 at
500 and 460 ug/kg, respectively. carbon disulfide was present in sample
3-MW-06 at a concentrations of 60 ug/kg. PCBs were not detected in any of
these samples.
Several metals were detected in the subsurface soil samples at
concentrations greater than 2 times the CRDL. These contaminants include
aluminum, chromium, copper, iron, lead, manganese, and vanadium. Total
organic carbon was detected in 4 of the 5 on-site borings ranging from ND
to 1,700 mg/kg. These levels generally decreased with depth. A cation
exchange capacity of 103 meq/kg was observed for sample SUB-303C.
Subsurface soil contaminants of concern meeting the minimum concentrations
requirements for evaluation under the baseline risk assessment are as
follows: 4,4'-DDD, 4,4'-DDE, 4,4'-DDT, alpha-BHC, beta-BHC, delta-BHC, and
gamma-BHC. Manganese was the only metal contaminant evaluated for this
area.
5.3.3 Air (Fairway Six Area)
One air sample collected at the Fairway six Area was analyzed for
pesticides and PCBs. This sample was contaminated with alpha-BHC,
beta-BBC, heptachlor, 4,4~-DDD, 4,4'-DDE, and 4,4'-DDT. Concentrations
for these contaminants ranged from 0.006 t6 0.035 ug/m'. PCBs were not
detected in this sample.
5.3.4 Area of·contamination (Fairway six Area)
Residual levels for total pesticide contamination exceeded 214,230 ug/kg
for surface ;oil samples. Total pesticide levels up to 1,702 ug/kg were
also detected in the subsurface soil samples. To obtain the target 10-•
health-based cleanup level for this Area, the estimated volume of material
requiring.remediation is 444,220 cubic feet, or 16,453 cubic yards. An
additional 22,000 cubic yards of material stockpiled at this Area during
the emergency removal action conducted in 1988 will also require
remediation. Areas requiring excavation are presented in Figure 12.
5.4 Mciver Area
5.4.l surface soils (Mciver Area)
. ' One background station (SSS-407) was selected for the Mciver Area and was
located 400 feet southwest of Area B. This sample was collected at a
depth of 3-4 feet. A total of 8 stations were sampled within the grid of
Area B. Samples were collected at depths of 3-4 and 5-6 feet at seven of
these stations, two of which also had surficial samples collected.
Station.sss-403 was sampled at 3-4 feet only due to auger refusal. A
single sample (SSS-404) was split and analyzed for TCL metals, TOC, CEC,
and percent moisture. This yielded 19 samples collected for pesticide
analysis (including 1 duplicate). Table 7 lists the samples collected in
soil in addition to the type of analysis performed on these samples.·. The
significant contaminants and their maximum concentrations for all,media at
the Mc Iver .Area· are·, :presented in Table 8.
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SSS-J98 • s·-i,o
AEPCO
North
(i)
I T
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SSS-J14 e
J'•~J
5'•'iC
Remedlll lnvt1tlg1IIM'Fuslblllty Study {RI/FS)
Abffl1ttn Ptslltlde Dumps S111
Aberdeen,~ Coonty, North Carolina
-• u .
J•NO SSS-32~ 5•NO • J •NO
19~ S•NO SS-325 -1
29 '~:::-::: -~~ ,,, SSS-33-4 ~J'•NO -~ J-25"6 5•1'10
,:,5. -1 260
:jJ£1"-..._ ' SSS-JH!
_.; .,
'
Lllilli);
• Swfldll S.lfOlt loettlon
""' SSS-337 -e:-W~ ·-n.eoo ·~E,\00
+sss-,,. •
r.... DI~ (ft)• Total Pfltleldl Cor,e. (ll;,'I:;)
C) Ar• Pm-loualy E.rcavei.d
§ ArM E.rcavmd ID 5 ~I BOL
fS.:SJ Nu [leant.cl ID 1B F.11 SGL
J •NO 5•J\1
SCALE: 1 11 111
+
+
(
-
FIGURE/~. Area of contaminated soil requiring remediation at the
Fairway Six Area.
.1
TABLE 7
SAMPLE MATRIX FOR THE MCIVER AREA
No. of No. of
sample Depth Samples
Media Location stations (feet) Yieled Analysis
surface Background l 3-4 l Pesti'cides
soils
on-site 8 0-6 18 Pesticides
on-site l 3-4 l Pesticides, TCL
(Split) Metals, TOC, CEC,
% Moisture
Sub-Background l 6, 18, 3 Pesticides,
surface 64 PCBs, voes,
soils TCL Metals
on-site l 8, 9, 3 Pesticides,
(split) 44 PCBs, voes,
TCL Metals
TOC, CEC
The background sample (SSS-407) revealed no pesticide contamination. of the
8 soil sampling stations collected at Area B, 6 revealed detectable levels
of pesticides, with all but one containing at least 4 different pesticides.
BBC isomers detected in the surficial soil samples included alpha-BBC,
beta-BBC, gamma-BBC, and delta-BBC in concentrations (ug/kg) up to 430,000,
79,000, 16,000, and 32,000, respectively. other pesticides detected
included 4,4'-DDT; -DDD, -DDE, and toxaphene in concentrations (ug/kg) up to
180,000, 22,000, 7,400, and 160,000, respectively. stations sss-401,
sss-404, and sss-405 contained the highest concentration of total pesticides
at all depth intervals. The total pesticide concentration at both depth
intervals in the surficial soils appears to be associated with proximity to
the exc~vated Area B. It should be noted that samples sss-402 and SSS-406,
collected from the excavation area, contained little or no pesticide
contamination. Figure 13 show the total pesticide concentrations for the
surficial soils.
The pesticides detected, their frequency of detection, and concentration
ranges are summarized below.
Pesticide Frequency of
Species Detection Concentration lug/kg)
4,4'-DDT 10/18 (56%) 85 -180,000
alpha-BBC 10/18 (56%) 20 -430,000
beta-BBC 9/18 (50%) 35 -79,000
delta-BBC 7/18 (39%) 11· -32,000
gamma-BBC (lindane) 6/18 (33%) 10· -16,000
4,4'-DDD 5/18 (28%) 87 -22,000
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TABLE f
SIGNIFICANT CONTAMINANTS AND THEIR MAXIMUM CONCENTRATIONS
McIVER A-<cA
CHENICAL
ANTIMONY
ARSENIC
BARll.04
BERYLLll.04
CADNll.04
CHRCJ41l.04
C06ALT
COPPER
LEAD
MANGANESE
HERCJRY
NICrEL
SELENll.04
SILVER
VANADllJI
ZINC
CHENICAL
1,1 11•TRICHLOROETHANE
1,1·01CHLOROETHENE
1,2•DICHLOROETHANE
BENZENE
CARBON DISULFIDE
CARBON TETRACHLORIDE
ETHYL BENZENE
TETRACHLOROETHENE
TOLUENE
TRICHLOROETHENE
XYLENES (TOTAL)
········------·······--··· 1,2,4·TRICHLORO&l:NZENE
2,4•DIMETHYLPHENOL
2·HETHYLNAPHTHALENE
BIS(2·ETHYLHEXYL)PHTHALATE
NAPHTHALENE
················----------4,4·, ·DOD
4,4'-DDE
4,4'·0DT
ALDRIN
ALPHA·BHC
BETA·BHC
DELTA·BHC
DIELDRIN
ENDOSULFAII II <BETA)
ENORIN
ENORIN KETONE
GA14MA·BHC
GA14MA•CHLORl)ANE
HEPTACHLOR
HEPTACHLOR EPOXIDE
TOXAPHENE
SS (11111/k;l SI> (11111/k;J SB (11111/k;J SIi (ug/l) GW (ug/ll AIR (n;/l) FISH (11111/kgJ
34 8.3 30
10 4.5 12 15
4.4 27 10
54
NA
NA
NA
NA
NA NA-
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
SS (ug/kg) SI> (ug/kg) SB (ug/kg) SIi (ug/l) GW (ug/l) AIR (n;/l) FISH (1111/kg)
NA NA NA
NA NA NA
NA NA NA
NA NA NA
NA NA NA
NA NA NA
NA NA NA
NA NA NA
NA NA NA
NA NA NA
NA 2 NA NA . ----·. --.. ----------- ---------------------· .............. ----------· ·-----------NA NA NA NA NA NA
NA NA NA NA NA NA
NA NA NA NA NA NA
NA NA NA NA NA NA
NA NA NA NA NA NA
------····· ....... ---... .. ....... --.. --------·---------······· ---------·· ·-----------22,000 210 320 NA NA
7,400 83 NA NA
180,000 1,700 0.03 NA NA
NA NA
430,000 83 0.065 D.02 NA NA
79,000 22 74 0.14 0.03 NA NA
32,000 200 0.083 0.02 NA NA
o. 11 NA NA
NA NA
o.11 NA NA
NA NA
16,000 25 0.01 NA NA
25 NA NA
NA NA
NA NA
160,000 2,600 NA NA
-------------------------------------------------------------···················-------------------------------SS • 5urffclal aofl; SO· Sedfaent; SB• Sl.bl:urface soil; SW -Surface water; G\I • Grouidwater;
All• Air; FISH• fl1h tl11ue; NA• Not 1vall1ble (analyol1 ,.., not perfonmd) or not applicable.
37
~NSE IBEES
!.
407
l". Actual Loco11on
,'5()· fl·
AEPCO
MC1-C
•408.86
,;, 0
7SE TREES "
1---No-rt_h_-1 Remedial lrivesllg1Uon/Ft11lblllty Study (RIIFS)
Ablnleen Ptttlclde Dumps SIii . Ci:) Abenleer., Moon County, Nol1h Clrollna
4-IIW-02
e---a•.49z1
9"•J92
44'aJ2
S i40J
J'a142
LEGEND:
eEB
,· .. 147
Surflclal/Subsurrace soll sample
Depth of sample (ftl • Total Pesticide
Concentratlon {ug/kg>
SCALE: I .. 1
___ _,395'-..
'Co~
.....
··· .-, .' ' in surficial and subsurface
FIGURE /J • Total pesticide_concfntr~ti,ops
-. --.. .. -soj .. -Mciver Ar---I.Ill .. -----11!1
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4,4'-DDE
toxaphene
4/18
2/18
(22%)
(11%)
21* -7,400
11,000 -160,000
Indicated concentration below two times the eRDL.
A single on-site station (SSS-404) was analyzed for TeL metals. Because
the background surficial soil station was not analyzed for metals, the
shallow subsurface soil sample for the background well for this area was
used as a comparative background sample. The metals detected in the
on-site surficial soil sample were typical of the Aberdeen area and were
comparable in concentration to the background sample. Metals detected at
2 times the cRDL include aluminum, chromium, and manganese, at
concentration (mg/kg) of 2,100, 4.3, and 10, respectively.
Based on the qualifications ·required for the baseline risk assessment, the
following organic compounds were evaluated as contaminants of concern for
the surficial soil media at the Mciver Area: alpha-BEe, beta-BEe,
gamma-BEe, delta-BEe, 4,4-DDD, 4,4-DDE, 4,4-DDT, and toxaphene. The metal
contaminants of concern include manganese and zinc.
5.4.2 Subsurface Soils (Mciver Area)
Three subsurface soil samples were collected from each boring for the 2
monitoring wells installed for this area. These samples were collected
above the water table (suffix "A"), one from the capillary fringe zone
("B"), and one from the interval where the well screen was installed
("e"). Depths for these samples ranged from 6 to 64 feet below grade.
All samples were analyzed for pesticides, PeBs, voes, and TeL metals (RI
4-130). The significant subsurface soil contaminants and their maximum
concentrations are presented in Table 8.
Background sample SUB-401B contained a trace of alpha-BEe (27 ug/kg) but
is not thought to be site related and may indicate another source of
contamination. No PeBs were detected in any samples collected from this
boring. The on-site borings revealed considerable subsurface
contamination with pesticides. BEe isomers were common to all the on-site
samples with the shallowest interval (SUB-402A) containing several other
pesticides including 4,4'-DDT, 4,4'-DDD, 4,4'-DDE, toxaphene, and total
chlordane in concentrations (ug/kg) of 1,700, 320, 83, 2,600, and 55,
respectively. Figure 13 shows the total pesticide concentrations for the
subsurface soils.
sample SUB-402B contained the only significant levels of voes -acetone
(260 ug/kg) and chlorobenzene (45 ug/kg). Trace levels of xylene and
chlorobenzene were present in samples SUB-402B and SUB-402e,
respectively. Total organic carbon analysis was performed on all samples
collected from station SUB-402 with a range of 230-1,400 mg/kg. A single
sample (SUB-402e) was analyzed for cation exchange capacity which was
detected at 3.4 meq/kg.
several metals were detected from the on-site station for this area. The
following metals were present in concentrations greater than 2 times the
CRDL: aluminum, calcium, chromium, iron, lead, manganese, and vanadium.
Based on the qualifications required for the baseline risk assessment, the
following organic compounds were evaluated as contaminants of concern:
4,4'-DDD, 4,4'-DDE,..".4,4'-DDT, alpha-BBC, beta-BBC, delta-BBC, gamma-BBC,
alpha-chlordane,.: delta-chlordane, toxaphene, chlorobenzene, acetone, and
xylene. The metal·.:contaminants of concern included: barium and manganese.
5.4.3 Area of contamination (Mciver Area)
Total pesticide levels exceeded 926,400 ug/kg for surface soil collected
west of Area "A". A single s~bsurface station (SUB-402).presented a maximum
total pesticide concentration of 4,921 ug/kg at a depth of 8 feet. To
adequately quantify the extent of subsurface soil contamination, additional
samples will be required.
To obtain the target 10-• health-based cleanup level for this area, the
estimated volume of material requiring remediation is 74,000 cubic feet, or
2,740 cubic.yards. An additional 3,200 cubic yards of material currently
stockpiled at this site during the emergency removal action conducted in May
1989 will also require remediation. Areas requiring remediation are
presented in Figure 14. ·
5.5 Route 211 Area
5.5.1 Surface soils (Route 211 Area)
A total of five sampling stations were selected for this area in addition to
a background station located 200 feet northwest of the sand basin and
labeled sss-591. The five on-site surface soil samples were located within
the old sand mining basin were analyzed for pesticides. A total of 10
samples were collected from this area and analyzed for pesticides. surface
soil sample sss-502B was the only sample analyzed for metals at this area.
Table 9 lists the soil samples collected in addition to the type of analysis
performed on these samples. The significant contaminants and their maximum
concentrations for all media at the Route 211 Area are presented in Table
10.
TABLE 9
SAMPLE MATRIX FOR THE ROUTE 211 AREA
No. of No. of
Sample Depth samples
Media Location stations (feet) Yieled Analysis
surface \ Background 1 2 1 Pesticides
Soil.a
on-site 4 2 & 5 8 Pesticides
on-site 1 0 1 Pesti~ides, TCL
Metals
Sub-Background 1 5-32 3 Pesticides, PCBs,
surface voes, TCL Metals
soils
on-site 2 5-32 6 Pesticides, PCBs,
voes, TCL Metals
L(D
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----
AEPCO
North
~
110-C
___.,,,.---.•408.88 ,,,,,-~
0£NSE TREES
R8tll8dlll lnve1Ug1Uon/Featlblll1J Study (RI/FS)
Abfflleen Pesticide Dumps Site
Abenlee11, Moore Count,, North Carolina
S -403 • J'-142
e $ SU!fldll/SublurflOI Sample LOClllan
r... Depth (ft)• Total P9otlcldl
c...www,ballan (ug/llg)
§ Ar• E1Cav■t■d III S Feet BGL
Ar• ERaolllld lo 10 Feel BGl SCALE: I
FIGURE!¥. Area of contaminated soil requiring remediation at the
Mciver Area.
I • X
TABLE 10
SIGNIFICANT CONTAMINANTS AND THEIR MAXIMUM CONCENTRATIONS
;',. ROUTE 211 AeeA
CKEMJCAL SS (IIIG/k;l SD (111G/kg) S8 (IIIG/k;) SIi (u;/1) GIi (u;/1) AIR (ng/1) FISK (11111/t;)
AIITIMOIIY
ARSENIC
v BARILtl
BERYLLILtl
CADMILtl
CKRCIIILtl
, C08ALT
COPPER
•LEAD ·
,,. MANGANESE
·, MERCURY
; NICKEL
SELENILtl
SILVER
VANADILtl
ZINC
8.6
7. 1
1,200
4,800
5.3
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
NA
9.Z
3.4
24
11A
11A
11A
11A
11A
11A
11A
. 11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
20 11A
11A
11A
11A
60 11A
11A
11A
11A
11A
11A
10 ; 11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
CHEMICAL SS (u;/k;l SD (u;/t;) SB (u;/t;l SIi (ug/1) GIi (u;/1) AIR (nail) FISK (11111/k;l
. 1,1,l•TRICKLOROETKANE
1,1•DICKLOROETKENE
1,Z'DICKLOROETKANE
BENZENE
CARBOII DISULFIDE
CARBOII TETRACHLORIDE
ETKYL BENZENE
TETRACKLOROETKENE
v'TOLUENE
TRICKLOROETKENE
XYLENE$ (TOTAL)
1,Z,4·TRICKLOR06ENZENE
Z,4·DIMETKYLPKEN0L
2·NETKYLNAPKTKALENE
BIS(Z·ETKYLKEXYL)PKTKALATE
NAPKTKALENE
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
---·-------11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A 5
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
1
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A ,.IIA
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
11A
-4,4'•D00 60,000 NA KA kA IA
,4,4'·00E 11A 11A 11A 11A
J4,4'-DDT 1,200,000 NA n,ooo KA 0.05 KA KA
ALDRIN 11A 11A 11A 11A
ALPKA·BKC 2,200,000 11A 11A 0.02 11A 11A
. BETA·BKC 120,000 11A 11A 0.04 11A 11A
, DELTA·BKC 18,000 NA 11A 0.03 11A 11A
DIELDRIN NA 11A 11A 11A
ENOOSULfAll IJ (BETA) 11A 11A 11A 11A
ENOR IN 11A 11A 11A 11A
ENDRI N KETONE 11A 11A 11A 11A
· GAMMA·BKC 41,000 11A 11A 0.02 11A 11A
GAMMA·CKLORDAIIE 11A 11A 11A 11A
KEPTACKLOR 11A 11A 11A 11A
NEPTACKLOR EPOXIOE 11A 11A 11A · 11A
v TOXAPHENE 2,300,000 NA 63,000 NA NA NA
···················-························································································---
SS • Surficfel aoll; SO· Sediaent; SB• 51.bsurfece 10il; SW• Surface water; Glil • Grou-dwater;
AIR. Air; FISK. fish tissue; NA. Not available (anelytll VIS not perfonoecl) or not lf'Pllcable.
J/ 2..
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Four of the five surface soil sample stations exhibited contamination with
pesticides. These pesticides include alpha-BBC, beta-BBC, delta-BBC, and
gamma-BBC, 4,4'-DDT, 4,4'-DDD, and toxaphene in concentrations (ug/kg) up to
2,200,000, 120,000, 18,000, 41,000, 60,000, 1,200,000, and 2,300,000,
respectively. station sss-501, located in the center of the basin, was the
most contaminated with total pesticide concentrations of 5,939,000, 36,430,
and 59,650 ug/kg at depths of 0, 2, and 5 feet below grade, respectively.
Sample SSS-505, located on the western side of the basin, was the second
most contaminated surficial soil sample location. Toxaphene comprised over
99% of the total pesticide contamination of 200,360 and 13,075 ug/kg at
depths of 2 and 5 feet below grade, respectively. Figure 15 shows the total
pesticide concentations in the surface soils.
Several metals were detected in the single on-site sample analyzed for
metals in concentrations up to 2 times the CRDL. The contaminants detected
in this sample included magnesium, manganese, and mercury in concentrations
(mg/kg) of 3,800, 1,200, and 4,800, respectively.· The mercury concentration
in this sample far exceeded.the concentrations detected for any other site
area. To qualify the extent of mercury present for this area, additional
sampling will be required.
Based on the qualifications required for the baseline risk a.ssessment, the
following organic compounds were evaluated as contaminants of concern for
the surficial soil media at the Route 211 Area: alpha-BBC, beta-BBC,
gamma-BBC, and delta-BBC, 4,4'-DDD, 4,4'-DDE, 4,4'-DDT, and toxaphene.
Metals of concern for this site include nickel, barium, cobalt, manganese,
mercury, and thallium.
5.5.2 subsurface Soils (Route 211 Area)
Three boring locations adjacent to the sand basin were utilized for the
collection of subsurface soil samples. A total of 9 samples were collected
from 5 to 32 feet below grade and analyzed for pesticides, PCBs, voes, and
TCL metals. station SUB-501 located at boring 5-MW-01 is considered to be
either upgradient or sidegradient of the areas of known contamination based
on groundwater flow direction to the west-northwest or to the southeast.
The significant subsurface soil contaminants and their maximum
concentrations are presented in Table 10.
Both 4,4'-DDT and toxaphene were detected in boring 5-MW-03 at
concentrations (ug/kg) of 33,000 and 63,000, respectively. Trace amounts of
4,4'-DDT were detected in boring 5-MW-02 at 5 and 15 feet below grade.
Total pesticide concentration for the subsurface soils are shown in Figure
15.
Acetone was the primary voe contaminant in the subsurface soil samples. The
highest concentration (3,300 mg/kg) was present in boring 5-MW-03 at 7 feet
below grade. Acetone was also detected in boring 5-MW-02 at 15 and 24 feet
below grade in concentrations of 1,100 and 750 ug/kg, respectively. Trace
amounts of chloroform, bromodichloromethane, trichloroethene, and toluene
were also detected in boring 5-MW-02.
Several metals were detected in samples collected on-site which exceeded 2
times the CRDL. These contaminants include aluminum, chromium, iron, lead,
and manganese.
L/3
-
40 ( ___________ __..•'> J::~({~oooo ~Q~NO
s·~s9,65o~SS-"501..,.. 5'DND 1 ,5-;::-..... ,.... .. \
~s~•
0
·. • •·•••• sJ.~04 s-:;J.: ~{;r~?r~ .. : .. ,JJ:~gY•·~Nb
••"'
.·.~-50,3, .· · ~· ----
46
5-MW-
-

-

-

-

-

-
.... ~ 45------5'$2
-------::::.--" =
+
AEPCO
North
@
-

.

::,...;:: c--.;.:_ _____ .,,,,
Remedial lnvesUgaUon/Feaslblllly Study (RIIFS}
Abenleen Pesticide Dumps Site
Aberdeen, Moor8 County, North Carolina
LEGEND:
9 0 Surf1c1al/SubSurface soll sample
r-1•1 Depth or sample <rt)· Total Pestlc1de
Concentration <ug/kg)
; . I
J5
SCALE: J
etilltrf'IIIIJ
I .. -
., .,
40
,. -
0 NSE TREES
• s
\
DENSE TREE;\
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subsurface soil contaminants meeting the minimum concentration requirements
for evaluation under the baseline risk assessment are: acetone, toluene,
4,4'-DDD, 4,4'-DDE, 4,4'-DDT, alpha-BHC, beta-BHC, gamma-BHC, delta-BHC, and
toxaphene. Metal contaminants evaluated for this site include lead,
manganese, and barium.
5.5.3 Area of Contamination (Route 211 Area)
Residual levels for total pesticide contamination documented in the RI
exceeded 5,000,000 ug/kg in surface soils near the center of the basin.
Total pesticide levels up to 13,075 ug/kg were also detected at depths up to
5 feet for the western section of the basin. A subsurface soil sample
collected 20 feet east of the basin n~~ monitoring well 5-MW-03 contained
96,000 ug/kg of total pesticides (4,4-DDT and toxaphene). This elevated
level may be indicative of additional buried material and may also require
remedial action.
To obtain the target 10-• health-based cleanup level for this area, the
estimated volume of material requiring remediation is 121,000 cubic feet, or
4,481 cubic yards. Figure 16 shows the area of contaminated soil requiring
remediation.
6.0 SUMMARY OF SITE RISKS
The Aberdeen Pesticides Dumps site is releasing contaminants to the
environment. chapter 6 of the RI entitled "Baseline Risk Assessment"
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 risk assessment consists of hazard identification of the contaminants of
concern, an expos~re assessment, identification of toxicological criteria,
and risk characterization. Because the site consists of five separate
areas, each area was treated separately in the risk assessment. Each part
of the risk assessment is discussed below.
6.1 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 (e.g., groundwater, surficial soil), based on screening criteria
including frequency of occurrence in each media, presence at levels
considered to be greater than background, associatiOn with site activities,
either due to Site related concentration gradients or through historical
data on waste disposal, and comparison of levels found in quality control
(QC) samples, if applicable.
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 detects, and the lower of these values was chosen as the estimated
exposure concentration. Table 11 identifies the contaminants of concern
AEPCO
Nor1h
~
Remedial bwesUgadowFeallblllty Study (RIIFS)
Abenleen Pesdelde Dumps SIie
Aberdeen, Moont Coooty. Nor1h Clrollnl
LEGEND ·
-~-591
{150' North)
J'•ND
e fB Surflclll/Subaurflcl Sample L-tton
r• Doplh (II)• Tolll l'Ntlclde
Co,-matlon (~)
ISS] Ar• Emnled ID 10 felt BGI.
,.
SCALE: I
FIGURE /~, Area of contaminated soil requiring remediation at the
Route 211 Area.
D SE TIIEES
t,
\
J5 DENSE TREE\
40 J
• ,L
-------------------
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for each area and the reasonable maximum exposure concentration in each
media sampled which was analyzed in the risk assessment.
6.2 Exposure Assessment
The exposure assessment identified potential pathways and routes for
contaminants of concern to reach receptors and the estimated contaminant
concentration at the points of exposure. Contaminant release mechanisms
from environmental media, based on relevant hydrologic and hydrogeologic
information (fate and transport, and other pertinent site-specific
information, such as local land and water use or demographic information),
were also presented.
Tables 12 and 13 provide~ the estimated exposure frequencies and estimated
time of exposure per event for target populations under current and future
land use conditions at the site. current and future land use conditions for
each area are discussed below.
The Farm chemicals Area is located in a residential/industrial zone. The
property is secured by a chainlink fence. Currently, Farm Chemicals has
closed its operation at the facility, therefore a current on-site worker
scenario was not assumed. Since the area is totally fenced in and locked,
site trespassing is highly unlikely. At the time of the remedial
investigation, an employee of Farm Chemicals was living at the site or at
least spending a few nights a week there. For future land use this area may
be reopened as a pesticide blending/mixing production facility or be
converted into a residential community. Thus, the target populations at the
Farm Chemicals Area under current and future land use are:
0
0
on-site adult and child residents (current & future)
on-site adult workers (future)
The Twin sites Area, located approximately 400 feet north of the Farm
chemicals Area, is in an open area surrounded by woods. The nearest
residents live about .350 • upgradient from the area. This area and its
surroundings are zoned residential. However, the county may change the
zoning to recreational use, since the area is approximately 350 feet from
Pages Lake. Based on these possibilities of future'land use and current
land use conditions, the target populations are:
0
0
0
0
adult and child residents nearby (current)
site trespassers (current)
on-site adult and child resident (future)
recreational adult and child users (future)
The Fairway Six Area is partially located on the sixth fairway of the Pit
Golf Links golf course. The golf course, located in a rural,' sparsely
populated area, is frequently visited by golfers and workers. The southern
half of the site is located on private property which could be developed
into a residential community. Thus, target populations under current and
future land use are:
0
0
0
0
on-site workers (current and future)
residents nearby or site trespassers, adults and children (current
and future)
golfers (current and future)
on-site adult and child resident (future)
'17
-1:::.
""' \
-
-....... --... -... ------.. --
cwrNICAl
··------------------------..,, ...
ua■1c ... , ..
NITl.lll.11 ... , .. ._, ..
<OUI.J ._..
lW
-1(
NlltUIJ
■Ital
RlHl\.111
SILVI■
VAUDU.M
WIC
·------······-··---------· 1.1.1•tl1Clft.mto!t11Alrf
I, l•DICJl'll'.IN'.JfTNfll
1,Z•DIClflOROITIIAJft:
ll■ztlll!
CAlmlDISU."Df
CAIi-tUUClfLmlDf nm. IHZ!llf
flTIACllt.OIUTNfl!
Tot.WIil
tllCJI\.OIO!Tlfllf
ITlUH (TOTAl)
············-········--·--
1,z.,-,11m01101t11r•
Z,4•DINT91lLPlfflDl
Z·•tnLIIAPIITUL(lf(
lll(Z·fTITlllfXTL),Nfltl.Uff --······--··-·-······--·-·--,., .... ,., ... ,., ... ,
MNI■
IOU•lllt
KTA·IIC
Dll.lA·INC
OIII.Dltl
lll90IUI..FU , •.. II (HTA).
1-1■ QT(llf ---URll:.~WLORDAII!
•PllClll.o■
TABLE //
CONTAMINANTS OF CONCERN AND EXPOSURE CONCENTRATIONS
FOR ALL ENVIRONMENTAL MEDIA
FARM CHEMICALS AND TWIN SITES AREAS
---.. ----. ··----------------········ ----------------------------------------------------------····----------·
Tvl11. Sites .AUA .....•....•............•. Farm Chemicals Area ... --. -----. -·--.. --. ---. -. -....... IOlld C...,.;, Ll""ld 1..,11 -~~Hf.111. -~.l3~'-t). All 111 ---------------------------········ ------------.--•··
ss GW (ug/1) II • .... ., ., C..,11
---.. ----.. ----·-····· .. ---. ----. ---········ ------------------------------··· -----------............
uo
J,:,00 J7,'11 Z,'6J,OOO ICIO Z1, 191 n,,., ffl 194.0CIO ,., ,,zo,
l,ffl
ffl 10,IH SJ,119 Z!O • J,ffl , .. • ,,.,, n.2111 se.m 710 ,.
5', 172,000 ' ,.no 91,051 1'.1 • 9,BS4.000 S, 162 7,ffl 16,966 NO '°' 110 78,000 87 no
Z,000 1DJ 11,91111 ,.
420 n
''·"' no,rn, "·' 15,ZM,000 '·'·" ,.,eo 603,017 11,000 "' '4ll
........ ---.. --....... -·········· ·····----------. ------. ---.. -----. --------... .••...••... ··--·· .....
388 ICIO
ZI 161 67.1
,.w
IJ,011 "·"' "' ilOO
no " I ' 1146 • JI ,. ,, ,,.,°' "·"° l,ffl 1,91111
------------...... -... . ----. --... .....••.... ··-········ --········· -·········· ............. -···--····· , .. n
J8 • .. '
" '·'°°
---·-·····-------····· ............. ................ .............. ............ ............ ----······· ··········· ... ••• •--,,.m 0.0, O.CIOCIOJS ,.m ,,.m ••• ••• '·"
, __ ,
645 D.OS O.OCI01' 1.m 1,U7 " 9'S9,500 0.0, 0.-z,, ,a 11.m ,., O.D •••• ··-' O.CIOCIOII ·41 ,., ICIO , .. 10 ··-57,57, " O.DDDD6t n,191 Z,'15 11 , O.DDDDDZS J,IJO 799 6.Z J ' O,CIOCIOII Z9.Z71 ,.z 18 D.CIOCIOIS
37, "'
,., O.CIOOOOZS ,z.u, tilt 16'
Z6D o., D.OOOJ ZIJ o., ZJ
D.Z
11.0 o., II.I o.• o.oaoon 89,475 ID O.OD0014 ,,. 12:J OD ,., ,., ,. , ,.. 0.--,. O.CIOCIOIJ .. , 0.-
IIIPTAC111.C. ~POXID! o.ooa 21,on ,~.,, 296,212 ·······,·:···············-----···························-·-······ ····································-··························-·······
FISIIII :'"_f.flh tlttut; GU• Gr~■ter: SD • SedlMnt; SS • Surffcfal ~o~l; SV • ~face vater -·-.. --

-
------· --
- -----------TABLE //
CONTAMINANTS OF CONCERN AND EXPOSURE CONCENTRATIONS
FOR ALL ENVIRONMENTAL MEDIA
FAIRWAY SIX, MCIVER AND ROUTE 211 AREAS
-
Mciver Area
... liill
-------················ Fairvay _ Six _Are" ......................... . ---·········-·-----·······---------------------
CNfNICAL
u,u •• ,
HAMIC ......
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a.a, a.a,
Cl.DJ
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···································································································· ·················································
FISH• ffsh tfssl.M; C\I • Grouidwater; SD• S.c:tlment; SS • Surfici■l 10ft; SW· 'surface w■ter
--1111
·······················-
Route 211 Area
-~~llkl. -~t,,u,t~ -_. .. ..
7,100
1,200.000
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5,300
10.000
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»4,9M D.OS
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12, 1,a Cl.OZ
TABLE l Z..
ESTIMATED EXPOSURE FREQUENCIES FOR TARGET POPULATIONS
UNDER CURRENT AND FUTURE LAND USE CONDITIONS
TARGET PCIIUUTICll·SPECIFIC [xPOSURE fll:EQUlNCl CdaYI or events/yHr) .. -.. ---... ·-. -----------.. ---·. ---.. ----------------------·-· ---....
Oral Dennal Jrheletion
cFAIOI CHEMICALS SITE>
Current Lal"ld UH Condition:
Onslu ruidenta -Adults
ON.lu ruidenta -Children
Future Land UH Condition:
Onsite tHidenU Adults
Onsfte residents Chlldr.,
Onsi u worker Adul ta
<T'JIN SITE•
Current Land UH Condition:
Near tiU residents • Adult&
Near alu r••fdenta • Children
Site trnpHHtS AOJlta
Site trespasHrs Children
Future Land UH Con:lition:
Crisiu residents AdJlta
Onsit• r"Hidfflu Children
RecrHtfonal users • AO.lits
Rec:rHt IONl l users Children
<FAIRWAY SIX SITE>
Current l Future Land UH Conditions:
Siu trespassers • Ad.Jlta
Site trnpassera • Children
Onsite workers A111lts
<OklYH SITE>
Current L..-d UH Condlttan:
Siu trespasser. • Adults
Site trnpeuers -Childr.,
Future Land UH Condition:
Onslte ruidentl • Ad.llta
Onslta ruldenta · Oii ldren
<ROJTE 211 SITE►
Current Land US• Condition;
SS FISH SW GW
170 365 52 0
170 365 52 0
170 365 52 365
170 365 52 365
250 0 0 250
85
05
42
42
171)
171)
05 ..
42 42
250
17
17
171)
171)
365
365
0
0
365
365
0
0
0
0
365
0
0
l6S
365
52
52
0
0
52
52
52
52
0
0
26
0
0
52
52
0
0
0
0
365
365
0
0
0
0
0
0
0
365
365
Site trH~uer9 • Aa.llts 17 0 0 0
Site trHpuHr9 · Q\fldran 17 0
Fun.ire (and UH Condition;
0 0
Onaite rnident• -AO.llt• 170 365 52 l6S
0'\sit• rnidents • 0\fldren 170 365 52 365
<RECIEATIONAL USE►
Current l Future Land US• Conditions:
GolfiC'ISII at FSS Aa.llts 52 0 0 0
ss so
170 52
170 52
170 52
170 52
25D D
05 ..
42
42
171)
171l
05
85,
42
42
250
17
17
171l
171l
17
17
171)
171l
52
52
52
0
0
52
52
52
"
0
0
26
0
0
52
52
0
0
52
52
0
SW CW
52 0
52 0
52 365
52 365
0 0
52
52
0 -o
52
52
52
52
0
0
26
0
0
52
52
0
0
0
0
365
365
0
0
0
0
0
0
0
365
365
ss cw
365 0
365 0
365 365
365 365
250 0
" 05
42
42
365
365
" "
42
42
250
17
17
365
365
0
0
0
0
365
365
-0
0
0
0
0
0
0
365
365
0 0 17 0
0 0 17 0
52 365 365 365
52 365 365 365
0 O 52 0
SD • Sediment: SS -SUrflclal ao1l; SW Surface water; QI Gr-ou-dwater; fSS • hir-way Six Site
TABLE 13
EXPOSURE TIME OR INGESTION RATE
PER EVENT
------------------------------------------------------------------------
I I I DERMAL I I INHALATION I I ORAL
I MEDIA I I (hours/day•) 11 (hours/day•) I I (grlll or ltr/day) I
I -I I Adult Child I I Adult Child I I Adult Child I
1------------------11---------------11---------------11----------------1
I Surficial soil I I 2 I 4 I I 2 I 4 I I o. l I o. 2 I
I 11 I 11 I 11 I I
I Sediment I I 2 I 4 I I 2 I 4 I I o. l I o. 2 I
I 11 I 11 I 11 I I
!Surface Water I I 2.6 I 2.6 I I N/A I N/A I I 0.13 I 0.13 I
I I I I I I I I I I I
I Groundwater I I o. 2 I o. 2 I I o. 2 I o. 2 I I 2 I l . L
I . 11 I 11 I 11 I I
IF1sh II N/A IN/A 11 N/A IN/A 11 6.5 I 6,5 I
------------------------------------------------------------------------
*or event
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The Mciver Area is in a sparsely populated rural area on land that is partly
wood and partly cleared for agriculture. This area is residentially zoned.
Despite its remote location, residential housing may be built at this site
in the future. Thus, the target populations under current and future land
use are:
0
0
residents nearby or site trespassers, adult and children (current)
on-site adult and child residents (future)
The Route 211 Area, located in a sparsely populated area, is generally
surrounded by pine woods with scattered abandoned sand-mining pits. The
mining may be reactivated in the future. However, the site is also located
in a zoned residential area, which may be developed into a community in the
futllre. Two active "cc>mmercial/industrial facilities are located between
1,000 -2,000 feet of the area. For a conservative risk assessment, the
target populations under current and future land use are:
0
0
residents nearby or site trespasser, adults and children (current)
on-site child and adult residents (future)
The exposure pathways for all areas under current and future land use are
similar or are identical. The risk to future residents at Mciver and Route
211 Areas of ingestion of contaminated fish and dermal contact with or
ingestion of sediments and surface water was estimated by assuming that the
future residents at both sites will use Pages Lake for recreational
purposes. Exposure pathways are:
Dermal contact with or ingestion of surface soil and exposed wastes
Inhalation of suspended particulate generated from contaminated soils
and exposed wastes
Dermal contact with or ingestion of sediments and surface waste
Inhalation during showering with, dermal contact with, and ingestion
of contamiriated groundwater
Ingestion of contaminated biota and food
6.3 summary of Toxicological criteria
Available toxicologic criteria for contaminants of concern are summarized in
Table 14 and are used in estimating risks to site contaminants. This table
contains information on:
Carcinogenicity
Carcinogenic weight of evidence
Tumor sites via oral and inhalation routes
Carcinogenic slope factors (g*) via oral and inhalation routes
Noncarcinogenicity
chronic and subchronic reference doses (RfDs) via oral and
inhalation routes
Chronic and subchronic critical effects via oral and inhalation
routes
Slope (g*) or cancer potency factors (CPF) have been developed by EPA's
Carcinogenic Assessment Group for estimating excess lifetime cancer risks
associated with exposure to potentially carcinogenic chemicals. slope
"' "'
TABLE /II
SUMMARY OF TOXICOLOGICAL CRITERIA
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factors, which are expressed in units of (kg-day/mg), are multiplied by the
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 CPF. 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.
Reference doses (RFDs) have been developed by EPA for indicating the
potential for adverse health effects from exposure to chemicals exhibiting
noncarcinogenic effects. RfDs, which are expressed in units of mg/kg-day,
areestimates-of lifetime daily exposure levels tor humans, including -
sensitive individuals. Estimated intakes of chemicals from environmental
media (e.g., the amount of a chemical ingested from contaminated drinking
water) can be compared to the RfD. RfDs are derived from human
epidemiological studies or animal studies to which uncertainty factors have
been applied (e.g., to account for the use of animal data to predict effects
on humans). These uncertainty factors help ensure that the RfDs will not
underestimate the potential for adverse noncarcinogenic effects to occur.
6.4 Risk characterization
Using the input parameters described above, lifetime excess cancer rates
(LECRs), which estimate the carcinogenic risks posed by the contaminants of
concerns at the Aberdeen Pesticide Dumps Site were calculated. This unit of
risk estimates the number of excess cancer cases caused by exposure to the
site contaminants (e.g., an LECR of 1 x lo-' means that 1 excess case of
cancer per 1,000,000 people could be expected). EPA's target risk range for
aggregated LECR is 1 x lo-• to 1 x 10-•.
In addition, the hazard index (HI), which is a quantitative measure of the
possibility of adverse health effects from exposure to non-carcinogens, was
calculated. A HI value of 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.
Although LECRs and His were calculated for both current and future land use
scenarios at the site, in the interest of conservatism the worst case
scenarios are carried through as being representative of the risks posed by
the Site. Future land use by on-site residents was the worst case scenario
at all of the areas. A portion of the Fairway Six Area, because it is
partially situated on a golf course, was also evaluated under an on-site
adult worker as the worst case scenario.
Considering that no long term remedial action takes place at the Site, the
potential carcinogenic and noncarcinogenic risks to the population under
current and future land use scenarios are discussed below.
6.4.1 Farm Chemicals Area
Tables 15 and 16 summarize the quantitative estimates of risk under the
current and future land use scenario for each target population at the Farm
TABLE ✓~-
CURRENT Land Use Risk Characterization
Farm Chemicals Area
·carCinogenic !Uantitative Exposed Major Routes LECR Major
A=•e•aee.es0s0m0e0n0ts_ _______ :cticsek,·_.sEasetcicmcae.ct,ec._ ____ "PcoeePaucl0actcic·o"-"n~ ___ ;Oefc..,Esx,popoescuereeL ________ VYJla;l0ueec_ ____ _,c,ocnetorcic·beua,tsosrcos
LECR
Noncarcinogenic
Assessment
HI Chronic
HI Subchronic
HI Subchronic
Carcinogenic
Assessment
LECR
LECR
Noncarcinogenic
Assessment
HI Chronic
HI Subchronic
HI Sut;chronic
HI Chronic
HI Subchronic
7. 2
6. 7
109.3
Adult Resident
Adult Resident
Adult Resident
Child Resident
Ingestion of SS
Dermal Contact ss
Dermal Contact SD
Inhalation SS
Ingestion of ss
Dermal Contact ss
Ingestion SS
Dermal con~act SS
Ingestion SS
Dermal Contact SS
TABLE I fo
3 X 10-4
4 X 10-4
5 x 10-5
4 X 10-J
HI
Value
4.2
2.4
4.0
2.2
34.6
73.1
FUTURE Land Use Risk Characterizatic~
Farm Chemicals Area
Quantitative
Risk Estimate
48.9
38.1
236.8
19.6
12.1
Exposed
Population
Adult Resident
Adult Worker
Adult Resident
Adult Resident
Child Resident
Adult Worker
Adult Worker
Major Routes
Of Exposure
Iflgestion ss
Ingestion GW
Dermal contact ss
Inhalation ss
Inhalation GW
Ingestion GW
Inhalation SS
Ingestion GW
Inhalation GW
Ingestion SS
Inhalation GW
Ingestion GW
Ingestion ss
Ingestion SS
Ingestion GW
Dermal contact ss
Inhalation GW
Ingestion SS
Ingestion GW
Dermal Contacts~
Ingestion SS
Ingestion GW
:..,;:;cR
Va:!_i..:e
4 X
4 X
1 X
10-4-
lC-3
10-?.
HI
Value
14.4
27.2
4.2
26.9
4.4
4.D
34.6
9,7
73.1
117. 7
6.2
9.8
3.5
5.9
3.0
alpha-BHC, DDT
toxaphene
alpha-BHC
arsenic
arsenic,
arsenic,
arsenic,
arsenic,
arsenic,
arsenic,
Maj:J!"
Cont.:::-.:._tc.-::.::irs
COpfe=,
OCT
ccppe1:",
DDT
ccpper,
copper,
DDT
DDT
ODT
DDT
alp!:.c1-E!lC, DDT, beta-3r:r:i:
garr~"T,.s-31-:C, Toxaphene
alp:7~-:i;:::, beta-BHC,
gc..-."T.-:.-::i::c
DDT' ,-,.::_,;:-:a-BHC, tox.3.:--:E;';a:>
arser..:._c
chror.o:.i.:.r.:
alpr'.3.-2!'.C
arser,.:._::
ethyl b2~~ene, manga~e2.~
tot.al xj·!.enes
arsenic, 4,4'-DDT
total xylenes, manganese
copper,. :z:i.nc
arsenic, copper, 4,4'-[CT
arsenic, copper, 4,4•-r.=:.r
chr:::mit.:rn, copper, :z:i::c
ar~enic, copper, 4,4•-~~!
total xylenes
arsenic, copper, 4,4'-DDT
chromium, copper, etr.y~
benzene
4,4'-DDT
arsenic, cop?E;r, 4,4'-DDT
arsenic, copper, 4,4'-D~T
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Chemicals Area. The total LECR for current adult residents via all exposure
pathways is 5 x 10·' with inhalation of arsenic as a significant
contributor. While the chronic and subchronic Bis are fairly low for
current adult residents, the subchronic BI for a current child resident is
109.3. The major contaminant contributors are arsenic, copper, and DDT.
At the Farm Chemicals Area the total LECR for future adult on-site residents
via all exposure pathways is 9 x 10·' with arsenic and alpha-BBC
contributing about 45% and 22% of the total carcinogenic risk,
respectively. However, arsenic was detected at a very elevated level in
only one sample in the limited data population (4 detects in seven samples,
3 of which were trace concentrations). If this one sample is an isolated
"'hot spot,• the LECR posed by arsenic may be overestimated.
The chronic and subchronic BIS for adult residents were quite elevated (48.9
and 38.1, respectively), while the subchronic BI for a child resident was
extremely elevated (236.8). Inhalation of groundwater contributes about one
half of the risk for each target population, with ingestion of groundwater
and surficial soil also significant exposure pathways. Dermal contact with
surficial soil contributes about one third of the subchronic risk posed to
future on-site child residents. The contaminants which are major
contributors to the HI are xylene, 4,4'-DDT, and several inorganics
(arsenic, copper, and manganese).
6.4.2 Twin Sites Area
Tables 17 and 18 summarize the quantitative estimates of risk under the
current and future land use scenario for each target population at the Twin
Sites Area. The total LECR for current adult residents near the site and
adult trespassers are 2 x 10·• and 5 x 10·•, respectively. Ingestion of
surficial soil and dermal contact with sediment and surficial soil are major
routes of exposure. Alpha-BBC, toxaphene and 4,4'-DDT are major
contaminants. Except for current child residents near the site, chronic and
subchronic Bis were less than 1.0. The BI subchronic for a current child
resident nearby was 2.7 with ingestion of fish as the primary pathway.
At the Twin Sites Area the total LECR for future adult on-site residents was
2 x 10·', _with ingestion of groundwater as the primary source of risk.
Alpha-BHC, aldrin, and beta-BHC were the contaminants contributing most of
the total carcinogenic risk.
The chronic and subchronic His for future adult residents were elevated
(38.2 and 37.2, respectively), while the subchronic HI for a future child
resident was also very elevated (86.8). Ingestion of groundwater contributes
about 90% of the risk for each target population, while inhalation of
groundwater is also a significant exposure pathway. BI values for dermal
contact with surficial soil and ingestion of fish from Pages Lake exceed 1.0
for subchronic risk to future on-site child residents. The contaminants
which are major contributors to the HI are antimony, aldrin and xylene (and
4,4'-DDT and mercury for children); although the uncertainty factor
associated with antimony is high because it was found at a trace level in
only l of 4 groundwater samples.
ss
Carcinog•nic
A111e■■inent
LECH
IZCR
Noncarcinog■nic
A•■e1111ment
HI chronic
HI Subchronic
HI subchronic
HI ~hronic
HI subchroi:iic
BI subchronic
TABLE L1
CURREii'? Land Ooe Riek Characterization
TWin sites Area
Quantitatiff hp<>■od Na.jar Roat•• LEOI
Ri■k l•tlll.ftt Populat!op Of !p:gpo■ure Yalp•
' • 10-4 Adult Re■ldent Inge■tlon 88 • • 10-S
Near Bite Dermal contact .. 5 • 10-S
Dermal contact SD 5 • 10-S
' • 10-S Adult Tr•■pa■■er :rng•■tion 88 ' • 10-S
Dermal Contact •• ' • 10-S
SI
Yalu■
o., Adult Jte■id■nt Inga■tion Fi■h 0. J
Near Sita Dermal contact SD 0,2
0,6 Adult Ra■ident Inge■tion Fi■ h o. J
Near Site oennal contact SD 0.2
,., Child Re■ident Ingestion l.' Near Site oennal Contact •• 0.'
0, 04 Adult Traapa■■er Ingetion 86 0.02
Dennal contact ., 0.02
0.03 Adult Treepa■■•r Ingeetion •• 0.013
Dermal Contact •• 0.014
0.06 Child Tre ■pa■■er Inge■tion 88 0, l
Dermal contact •• 0, 5
T?.3::_:c: , l
FUTURE Land use :,.:._3:.: c:-: :::.·;;.ct.er::.:·.:.: .:.en
Twir. ~i:.as ;...::.·2,:-~
Najar
contributor■
alpha-BBC
alpha-BBC
alpha-BBC, 4,4•-001'
alph.o.-1:!!!C, t-:::::,phane
alpba-BHC, toxapb■n•
mercury
4,4'-DDT
t11ercury
4,4'-DOT
mercury
4,4'-DOT
4,4'-0DT
4,4'-DDT
4,4•-DOT
4,4'-DDT
4,4•-DOT
4,4'-DDT
Care inogenic Q1.:ant i ':at i ve Ex?osed L"::C~. ~-,;·':::-
ehesasee0se,es0rn0e0c0.t~ _______ 0R0iascSc•sEcsa,t"'"""'•ctcee__ ____ _.p,c0cecs·;l0aot"icccce, ____ sc""___c'c•···--., .. ,.,, _______ \c'•e·c!"•,,.:-c_ _____ ...c··"-~--,._,:_:.:; ~:.:: :· s
LECR Adult ResiC.a:1:::
LECR Recreational
Noncarcinogenic
Assessment
HI Chronic 38.3• Adult Resident
HI Subchronic 37.2* Adult Resident
HI Subchronic 86.8* Child Resident
HI Chronii:: 0.31 Recreational
User (Adult)
HI Subchronic 0.26 Recreatinnal
User (Adult)
HI Subchronic 1.46 Recreational
User (Child)
•Antimony detected in groundwater at a concentratiori of 0.43
moat to the HI for chronic.exposure at the Twin Sites Area.
~e:·:-.?.: Co:--.ta:::::
::::·.,=.:.:i::::..or. GW
::-.:_;c,.=:tic:1 SS
)er::-,al C=ntac::: £5
te:-µ.al Ccr.:::ac-..: s:,
Ingestion GW
Ingestion c;;
Ingestion GW
Dermal Contact SD
Dermal Contact SD
Dermal Contact ss
1 X 1c·:
2 x l~ -.,
4 X 10
1 X 10-•
5 X 10-::
HI
Valt.:e
35.8
37.2
75.9
0.21
0.2
0.9
mg/1 and a detection frequency of 1/4.
The uncertainty of the estimated HI is
a~~.--..:: .. 2;::::, --···-•.. · .. = =~==:=:~~. ~~~=~~-
a:pt-.2.-3?-:•:
4,4•-::r, a:~ta-S~C
a:1:::i::1::r.::, a2.::fri.~
ar.ti.::.c.::,·, aldr :.r:
ar.ti::ior.y, aldrin
4,4'-DDT
4,4'-DDT
4,4'-DDT
_.,
It contributes the
expected to be high.
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6.4.3 Fairway Six Area
Tables 19 and 20 sutnmarize the quantitative estimates of risk under the
current and future land use scenarios for each target population at the
Fairway Six Area. The total LECR for a current and future adult worker was
5 x 10-• with inhalation of surficial soil as a major source of risk.
Arsenic, alpha-BHC, and 4,4'-DDT were the contaminants contributing most of
the total carcinogenic risk. The subchronic and chronic His for all target
population were insignificant (up to 0.67). ()i.,cd J,; (µ.)Jit"'I •• -t.J.,..;
~' -lo ,-,)e ;U.J ;,J,.J,.
6.4.4 Mciver Area
Tables 21 and 22 summarize the quantitative estimates of risk under the.
current a~d future"land use scenario for each target population at the
Mciver Area. The total LECR for current adult trespassers at the Mciver
Area is 4 x 10-•. Inhalation of and dermal contact with surficial are the
major sources of risk with alpha-BBC as the primary contaminant
contributor. The chronic and subchronic His were insignificant for all
target populations.
The total LECR for future adult residents was 4 x 10-•, with ingestion of
and dermal contact with surficial soil driving the risk. Alpha-BBC
contributed most of the carcinogenic risk, with 4,4'-DDT, beta-BBC, and
toxaphene also contributing significantly.
The chronic and subchronic His for adults were less than 1.0 (0.8 and 0.6,
respectively), while the subchronic HI for a future child resident was
slightly elevated (3.9). Dermal contact with surficial soil presents a
significant portion of the site-specific risk, with ingestion of fish from
Pages Lake also contributing to the overall risk (because all the Areas are
reasonably close to Pages Lake, recreational use of this lake was included
in the risk assessment for each Area). The contaminants which are major
contributors to the HI are 4,4'-DDT (surficial soils) and mercury (fish in
Pages Lake) •
6.4.5 Route 211 Area
Tables 23 and 24 summarize the quantitative estimates of risk under the
current and future land use scenario for each target population at the Route
211 Area. At the Route 211 Area the total LECR for future adult residents
was 3 x 10-3 , with surficial soil being the major contributor. Alpha-BHC
provided much of the total carcinogenic risk via the oral and dermal
pathways.
The chronic and subchronic His for adults were elev~ted (15.2 and 14.9,
respectively), while the subchronic HI for children was extremely elevated
(202.8). Ingestion of and dermal contact with surficial soil contribute at
least 95% of the·risk for each target population. In each case, mercury
contributed about 90% of this risk. However, the·uncerta·inty is high
because it was detected at a very elevated level (4,800 mg/kg) in the only
surficial soil sample that was analyzed for inorganics at the Route 211
Area. Additional sampling must be conducted to determine if this
concentration of mercury is representative of surficial soils at the site,
or if it is an isolated "hot spot• (in which case the risk may be
overestimated).
TABLE /?
CURRENT Land Use Risk Characterization
Fairway Six Area
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Carcinogenic Quantitative Exposed .!ajar Major Routes LECR
I rAeses,e.,.sos"mce"-!ln,tc_ ______ _,,Roiaseks__,Eese.staiem"a"tse.__ ____ ___,Psoapau,...1,a,toiaoen,_ ___ --".L-"-'""'-""-""--------_.:'"'"-"-"-------·ontr Of Exposure Value
LECR
LECR
LECR
Noncarcinogenic
Assessment
HI
HI
HI
HI
HI
HI
HI
Chronic
SuCchronic
Subchror.ic
Ch:::cnic
Eubchronic
Ch::o:.ic
Su~,::hrcnic
Ca:::-cicogenic
Azsessment
LECR
HI Chronic
Adult Trespasser Inhalation ss
Dermal Contact ss
5 x l □-S Adult Worker Inhalation ss
Ingestion ss
Ingestion Fish
Dermal Contact ss
Adult Golfer Ingestion SS
Dermal Contact ss
Inhalation ss
0.02 Adult Trespasser Ingestion ss
Dermal contact ss
0.014 Adult Trespasser Ingestion ss
Dermal contact ss
0.26 Child Trespasser Dermal contact ss
0.68 Adult Worker Ingestion Fish
0.65 Adult Worker Ingestion Fish
0.02 Adult Golfer Ingestion ss
Dermal contact ss
0.02 Adult Golfer Ingestion ss
Dermal contact ss
TABLE 2 D
FUTURE Land Use Risk Characterization
Fairway Six Area
Qua:1titative
Risk Estimate
1.1 X 10-3
2.4 X 10-3
.0001
.001
Exposed
Population
Adult Resident
Child Resident
Adult Resident
Child Resident
Major Routes
Of Exposure
Inhalation Oust
Dermal C~ntact cw
Ingestion SS
Ingestion SS
5
1
3
5
7
6
1
l
6
X 10-6
X 10-6
X 1□-5
X 10-6
X 10-6
X 10-6
X 10-6
X 1□-6
X 10-6
HI
Value
0.01
0.01
0.007
0.006
0,2
0.57
o. 56
0.01
0.01
0.01
0.01
LECR
Value
9.9 X 10-4
1.~ X 10-3
HI
Value
.0001
.001
:;hromium
~,4'-DDT, alpha-BHC
chromium
4,4'-DDT, alpha-BHC
bis(2-ethylhexyl)-I·
phthalate, alpha-BHC
4, 4 •-DDT, alpha-BHC I
4,4"-DDT, alpha-BHC
4,4'-DDT, alpha-BHC
chromium
vanadium, 4,4'-DDT
vanadium, 4.4'-DDT
vanadium, 4,4'-DDT
vanadium, 4,4'-DDT
4,4'-DDT
copper, mercury
copper, mercury
vanadium, 4,4'-DDT
vanadium, 4,4'-DDT
vanadi'..lm, 4,4'-DDT
vanadium, 4,4'-DDT
Major
Contributors
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Carcinogenic
Assessment
LECR
Nonca!:"cinogenic
Assessment
HI Chronic
HI Subchronic
H: St:bchronic
TABLE Z. /
CURRENT Land Use Risk Characterization
Mciver Area
Quantitative
Risk E!"timate
--0:01
0.01
a. 2;
Exposed
Population
Adult Trespasser
Adult Trespasser
Adult Trespasser
Child Trespasse::-
TA3L3 Z Z.
Major Routes
Of Exposure
In9'estion ss
Dermal Contact ss
Ingestion ss
Dermal Contact ss
Ingestion ss
Dermal Contact ss
Dermal Contact ss
~']':'Ur,.£ La:-!.C. Use Risk Characterization
Melve~ .h.rea
Ca!.·:; i :--.c:;i-12::ic
Ass;:,_5sr",0"o"t~----=Ri_?:: i:.:otir:-.a::~
Expose,::
Pcpula:.:i.,:,r:
~!ajar P:outes
o: Ex~osure
LECR
Value
Nor.ca~·c .:nogenic
Ai: S<?(l s::-.e1: t
HI Chrcnic
HI Sub::::ronic
H! Subchronic 3.9
Adult Resident
Adt!lt. Re'=i.de:i'.::
Child Rec: i.Cs:-;t:
:r.gest.icn SS 2 X 10-4
::er~al Contact SS 2 X 10-4
HI
Val~e
!ngestian Fish 0.28
Dernal Contact SD 0.22
Ingestion Fish 0.28
De:::-:nal Contact SD
Ir.gestion Fish 1.2
De::~al Contact ss 1.8
LECR
Value
HI
Value
.005
.006
.005
.005
0.18
Major
Contributors
alpha-BBC
alpha-BHC
4,4'-DDT
4.4'-DDT
4,4'-DDT
4,4'-DDT
4,4'-DDT
Major
Contribc:'.::ors
alpha-BHC, toxaphene,
4,4'-DDT
alpha-BHC, toxaphene,
4,4'-DDT
mercury
4,4'-DDT
mercury
4,4'-DDT
mercury
4,4'-DDT
Carcinogenic
Assessment
LECR
r{oncarcinogenic
As~E-ssment
HI Chronic
HI Subchronic
!-!I Subchronic
Quantitative
TABLE 2'.3
CURRENT Land Use Risk Characterization
Route 211 Area
Exposed Major R~utes
Risk Estimate Population Of Exposure
3 X 1□-4 Adult Trespasser Ingestion ss 1
Dennal Contact 5S 2
1.45• Adult Trespasser Ingestion S5
1.43• Adult Trespasser Ingestion S5
20.1• Child Trespasser Ingestion ss
Dermal contact 55
LECR
Value
X 10-4
X 10-4
HI
Value
1.13
1.12
9.7
10.4
Major
Cor.tril "Jtors
4, 4 '-DC,T, alpha-BHC,
·:oxaphene
4,4'-DDT, alpha-BHC,
tox,.1phene
mercury
mercury
merc:.iry
.mercury, 4,4'-DDT
~Mercury contributes more than 90'l of the total HI for chronic effects. However, mercury was detected at a
cc~centration of 4,800 mg/kg in the only surficial soil sample was analyzed for inorganics at the Route 211 Area.
Thus, the uncer~ainty for the c~ronic effects is expected to be significantly high.
1:,.~,.-:arc incgP.:1 :.c
dss-~ ... _-__ _
n: S':Jbchronic
H! S.ibch::-or.:.c
\
TABLE 2.'(
FUTURE Land Use Risk Characterization
Route 211 Ar~a
Q ·.. e Expo5ed Major Routes LECR Major R~: :~ ~;: :,,, ,0'_,-~~,0,,_ _____ PE.Qosos·,,,lca>:tc>L' oQ'ln ____ OQff__!E"xsoeoQ!!eau;rae'------,---V'ieaJlcu"e'-_____ CScEocneterci,· bs,;auataoerc-'s
Adc1lt Res.:.dent
l 5. 2.,. Adult Resident
14.9* Adult Resident
202.5 Child Resident
Ingestion SS
Dermal Contact SS
Ingestion 55
Dermal Contact ss
Ingestion S5
Dermal Contact 55
Ingestion ss
Dermal Contact 55
1 X
2 X
HI
~
11.3
3.14
11.2
3.1
97.0
103.8
alpha-BHC, to!:aphene
alpha-BHC, tcxaphene
mercury
mercury
mercury
mercury
mercury
mercury
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7.0 DESCRIPTION OF ALTERNATIVES
The goal of remedial action at the Aberdeen Pesticide Dumps Site is to
prevent, reduce or mitigate and·minimize potential or current risks to
public health, welfare, and the environment posed by contaminants at the
site. Technically applicable technologies that were judged to be
potentially viable to meet the cleanup objectives for the Site were
identified, screened, and assessed. These technologies were further
evaluated and screened as to their effectiveness, implementability, and
relative cost in comparison with other technologies that accomplish the
same objective for the same media. Technologies surviving the initial
screening were developed and screened further to eliminate those ·
technologies that have adverse impact on human health and the environment,
are not applicabletothe contaminant and media at the Site, or are much
more expensive to implement than other alternatives that provide
essentially the same level of protection.
""d Two cost eatima~ s are provided in the descri tion of alternatives below.
Two cost estimates were calculated in the Feasibility Study The first
cost discussed represents a total cost estimate if the selected remedy
were implemented at one central location. Present worth (base) cost
estimates at each area are also provided. All cost discussed are the. base
cost estimate. One of the reasons for presenting cost information in this
format is to illustrate that a coordinated response action is more cost
effective than independently responding to each area.
seven remedial alternatives were developed for the contaminated soils
which focus on reducing human exposure to contaminated soil as well as
preventing further migration to other media. A comprehensive description
of each alternative evaluated in detail is provided below;
Alternative 1: No Action
The No Action alternative serves as a baseline which other remedial
technolOgies can be measured and is retained for a comparative analysis as
required by the NCP. Under the No Action alternative the Site is left "as
is" and no actions are taken to monitor, control or clean-up the
contamination. This alternative does not reduce the potential for
contaminant migration from the site nor does it minimize or eliminate the
potential exposure to the on-site contaminants or those that have migrated
off-site. The No Action alternative does not meet the remedial objectives
of the FS.
Alternative 2: Environmental Monitoring
The Environmental Monitoring alternative is similar to the No Action
alternative, except that certain actions are taken to better define the
extent of contamination and limit public contact with it. Although this
alternative is not required, it is retained as a modified baseline to aid
in the comparison with other alternatives.
6 I
The Environmental Monitoring alternative calls for the installation of
additional monitoring wells to better define the extent of the
contamination in the groundwate.r by identifying the boundaries of the
contaminated plumes and utilizing institutional controls (fencing and
signs) to reduce public contact with contaminated media.·
on-site areas of soil contamination will be fenced and posted, while
off-site areas where contaminated groundwater discharges will only be
posted. No effort will be made to mitigate the migration of contaminants;
thus continued environmental damage will occur via surface water runoff
(sediment transport) and groundwater migration. Further bioaccumulation
of site contaminants will continue. Environmental monitoring will consist
of collecting soil and groundwater samples annually, conducting laboratory
analysis of these samples, consolidating the laboratory data, inspecting
fences and posted warning signs, and preparing an annual summary report
which includes a comparison with previously collected data and
identification of new areas of concern due to contaminant migration.
TWelve 4-inch stainless steel monitoring wells, averaging 40 feet in
depth, will have to be installed to better define the extent of
groundwater contamination. The number of monitoring wells be to be
installed at each area are listed below. Monitoring well locations are
identified in section 4 of the FS.
~
Farm Chemicals
TWin Sites
Fairway Six
Mciver
Route 211
Number of
wells
5
3
2
1
1
Because this alternative would result in contaminants remaining on-site,
CERCLA requires that the site be reviewed every five years. If justified
by the review, remedial actions would be implemented at that time to
remove or treat the wastes.
This alternative would only take a few weeks to implement at a capital
base cost of $650,000. Capital cost includes construction of the
monitoring wells and fences, sampling and analysis, report preparation,
mobilization and demobilization. operation and maintenance cost are
estimated at $72,000. Estimated base present worth is $1,777,000.
Present worth cost summary by Area is:
~
Farm Chemicals
TWin sites
Fairway Six
Mciver
Route 211
TOTAL
Present Worth Base
$515,000
$584,000
$562,000
$409,000
$412,000
$2,482,000
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Alternative 3: Kultimedia cap
(Alternative 3 -Option Bin FS)
Multimedia capping is a method of source control containment remedy to
prevent the continued contamination of groundwater and direct exposure to
humans.
Under this alternative, an impermeable/low permeable cap would be
constructed over the contaminated wastes/soils, surface runoff would be
diverted by regrading, and site access would be restricted by fencing
contaminated areas. Environmental monitoring would confirm whether
contaminants are migrating off-site, while periodic inspection and repairs
of the cap will be required.
The multimedia cap will consist of, from bottom to top, the following
layers: compacted native soil used to level the area, compacted clay, a
synthetic membrane, granular drainage, a filter fabric, compacted native
soil, and a topsoil layer to support vegetation.
Implementation of this alternative does not provide compliance with
current ARARs since no remedial measures are undertaken and current
conditions exceed Federal and State ARARs.
The approximate area, in acres, covered by the cap at each Area is:
Area
Farm Chemicals
TWin Sites
Fairway Six
Mciver
Route 211
Acres
5
4
4
l
l
On each of the Areas, surface water will be diverted away from the cap to
prevent its erosion and possible exposure of the contaminated soils. The
entire area will be fenced and posted to further prevent human contact
with highly contaminated soils, and to reduce potential vandalism. The
capped areas will be hydro-seeded to help prevent erosion.·
In areas where the groundwater is close to or within the contaminated
material either the water table would have to be lowered via extraction
wells or subsurface_ drains or the contaminated material has to ~e
excavated and moved to a higher elevation prior to capping. Lowering the
water table would require treatment and disposal of contaminated water.
However, moving or consolidating contaminated material within each area of
contamination would not constitute disposal/placement under RCRA.
The proposed cap at the Farm Chemicals Area encompasses almost the entire
area. The on-site buildings probably would have to be demolished prior to
construction of the cap. swab samples from the building material must be
collected and tested for RCRA hazardous characteristics. If it is found
to be hazardous the material must be decontaminated prior to disposal.·
This can be accomplished by using a high pressure steam cleaner, solvents,
or scabbling (i.e., stripping the top layer of concrete). It is assumed
that the building debris will be disposed of in the local municipal
landfill. ~
63
Construction of the cap at the five areas is estimated to take less than
one year at an estimated capital cost of $6,537,000. ·Long-term operation
and maintenance is estimated at $185,000. Present worth cost is
$9,848,000. should capping of the Areas be financed and implemented by
different paying parties, the estimated present worth cost by Area is:
Area
Farm chemicals
Twin sites
Fairway six
Present Worth Base
$3,844,000
$2,715,000
$2,674,000
$1,176,000 Mc Iver
Route 211 $1. 154,000
TOTAL $11,563,000
Alternative 4: on-Site Incineration
(Alternative 5 in FS)
Incineration is a thermal treatment technology which utilizes elevated
temperatures to destroy or detoxify hazardous waste. Under this
alternative, contaminated soil and debris are incinerated on-site.
Residual ash from the incinerator would be buried on-site in a non-RCRA
landfill and covered with clean fill. use of a mobile rotary kiln
incinerator was assumed for cost estimation, due to their relative
abundance and availability. However, other types Of incinerators that
provide equal or better performance should be considered when bidding the
project. Incineration is the Best Demonstrated Available Technology
(BDAT) for halogenated organic compounds, which includes most of the
pesticides found at the site. This alternative consists of the following
remedial activities:
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mobilizing the incinerator in·a centralized area;
excavating pesticide contaminated material;
transporting the material to the centralized area;
homogenizing and sizing the material for incineration;
incinerating the waste;
on-site treatment of process wastewater or scrubber blowdown
sludge by reinjection into the incinerator; and
on-site non-RCRA disposin9 of incinerator ash.
Incineration destroys or detoxifies organic contaminants and generally
converts them to co2 H20 vapor, so2 and NOx off-gases and ash.
since many of the contaminants are chlorinated, hydrochloric acid (HCl)
will be generated as an off-gas •and must be removed with an acid gas
scrubber before discharge to the atmosphere.
Prior to incineration, the material will be passed through a shredder and
power-screens for sizing. The properly sized contaminated material will
then be fed into the incineration unit. In order to maintain a readily.
available feed for the incinerator a "waste pile" must be maintained
on-site. This waste pile will constitute placement of hazardous waste
upder RCRA. Therefore, it will have to comply with RCRA regulations as
specified in CFR 265·,Subpart L, such as a bottom liner, run-off management
system ( leachate collection system), wind dispersion controls·, and
closure. However,-. because this is considered an "on-site" CERCLA response_
action, no permits are necessai:-y.
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Operation of the incineration unit will be in compliance with RCRA
regulations (particularly Subpart o, 40 CFR 264), including performance
standards. The incinerator and air pollution control unit will be
operated so that:
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An operating temperature in the kiln of l,800°F is maintained at
all times to ensure that any volatile and 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°F is
maintained at all times to oxidize and destroy all remaining ' organic substances prior ~o exiting the afterburner and entering
the pollution control system;
The incinerator will be capable of achieving a destruction and
removal efficiency (DRE) of 99.99% for all designated principal
organic hazardous constituents; and
The air pollution control system will achieve performance
standards of (l) hydrogen chloride of less than 4 pounds/hour and
(2) particulate matter of less than 0.08 grains per day ft3 in
the exhaust gas corrected oxygen content.
One localized area of the Farm Chemicals site (area of sss-119) was
contaminated with extremely elevated levels of pesticides and inorganics
(metals such as lead and arsenic) and is believed to be associated with a
spill. This and any other area determined to be contaminated with high
concentrations of inorganics should be isolated from the rest of the
material and treated separately to isolate the ash. Ash from the
incineration of this material will likely contain high levels of
inorganics and may not pass RCRA characteristic testing, and need
additional treatment (stabilization/solidification) and testing prior to
disposal. The amount of highly contaminated material in the area of
sample SSS-119 is unknown; but is believed to be very small. The bulk of
the contaminated soil and debris to be treated is low in inorganics, thus
the ash should pass RCRA characteristic testing and be non-hazardous.
RCRA characteristic testing of ash from the 1986 test burn at the Fairway
six Area was non-hazardous.
For convenience and practicality, the on-site incineration unit will be
mobilized at a centralized location. This procedure will save time and
money by avoiding the necessity of setting-up and breaking-down the unit
at.each Area. The NCP (1990) states that CERCLA has broad discretion to
treat noncontiguous facilities as one site for the purpose of taking
response action. However, wastes transported between sites must be
manifested as required by RCRA.
The areas that require excavation based on the 106 health-based target
cleanup levels are shown in Figures 17 through 21 in section 9.0 of this
document.
During the excavation at Farm Chemicals Area, some of the buildings may
have to be demolished because their foundations will be undermined. These
buildings will be disposed of in a manner similar to the one described in
Alternative 3-Multimedia cap.
Following tre~tment,_the volume of residual ash is dependant on the
composition of the feed.material -the greater the percentage of
incombustible inorganics (i.e., most soil forming minerals), the greater
the residual ash. Volume reduction of material in buried trenches is
expected to be greater than that for the contaminated soils, the volume of
which should o_nly be reduced by a maximum of 10-15·%.
The major cost associated with this alternative are for the excavation and
incineration of the·contaminated material. On-site incineration cost
estimates range from $200 -$350 per ton with $250 per ton used for
.estimating purposes. Excavation cost estimates ranged from $10-$18 per
cubic yard, with $12 per cubic yard being used for estimating purposes.
Under this alternative various on and off-site disposal options
considered depending on the nature of the treatment residuals.
eStimates for incineration and disposal are discussed below.
Option 1 -on-site Non RCRA Ash Disposal
(Alternative 5. -option A-1 in FS)
were
Cost
Under option l, after confirming through sampling and analysis that the
incinerator ash is non-hazardous, the ash would be disposed on-site in the
area where the soil originated. The ash would be covered with clean fill
and revegetated. Capital and present worth costs are estimated at
$48,638,000 and $50,439,000, respectively.
Present worth cost estimates for implementing this remedy at each Area
are:
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Farm chemicals
Twin sites
Fairway six
Mciver
Route 211
TOTAL
Present Worth Base
$24,384,000
$13,439,000
$ 8,792,000
$ 3,515,000
$ 3,084,000.
$53,214,000
Option 2 -on-site Non RCRA Ash Disposal After
solidification/Stabilization
(Alternative 5 -option A-2 in FS)
Under Option 2, if the ash remaining after treatment is hazardous, or the
treatment goals are not achieved, additional treatment through
stabilization/solidification would be required prior to disposing the ash
on-site.
The ash will be mixed with the stabilizing/Solidifying agents and allowed
to cure. The solidified mass must undergo additional RCRA characteristic
testing and be determined non-hazardous level. As mentioned above,
disposal of the material will be transported back to each Area and
disposed back into the excavated area. However, the volume will increase
approximately 20% due 3 to the addition of the solidification agents
(assuming 1 yd3 equ_als 1 ton).
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The addition of the stabilization/solidification costs is $2,977,000.
These costs ranged from $30 -$50 per cubic yard, with $30 per cubic yard
used for cost estimation purposes. Estimated capital and present worth
cost are $53,269,000 and $55,070,000, respectively.
Present worth cost estimates for implementing this remedy at each Area
are:
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Farm Chemicals
TWin Sites
Fairway Six
Mciver
Route 211
TOTAL
Present worth Base
$27,285,000
$15,033,000
$ 9,777,000
$ 3,799,000
$ 3,353,000
$59,247,000
Option 3 -Off-site Municipal Landfill Ash Disposal
(Alternative _5 -Option B in FS)
Under Option 3 the non-hazardous ash is disposed of in an off-site
municipal landfill. The ash will be loaded into trucks and transported to
the local municipal landfill, a distance of less than 5 miles. If the ash
is tested hazardous, secondary treatment, such as stabilization/
solidification, can be performed with the solidified mass being retested
prior to disposal. The excavated areas will be backfilled with clean fill
material and revegetated.
It is estimated to cost $10 per cubic yard or ton to dispose-of the
treated soil in the local municipal landfill. A cost estimate of $15 was
used for the disposal cost estimate, which also includes transportation to
the landfill. Estimated capital and present worth for this option is
$51,026,000, and $52,842,000, respectively.
Present worth cost estimates for implementing this remedy at each Area
are:
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Farm Chemicals
TWin Sites
Fairway Six
Mciver
Route 211
TOTAL
Present Worth Base
$24,958,000
$13,905,000
$ 9,081,000
$ 3,558,000
$ 3,165,000
$54,667,000
Option 4 -Off-site RCRA Landfill Ash Disposal
(Alternative 5 -Option Din FS)
Under Option 4 the ash would be disposed of in an off-site RCRA subtitle c
facility. It is assumed that the hazardous compone~ts are inorganic. The
organics should be destroyed in the incineration process.
Ash from the incinerator would be loaded into trucks and hauled to the
RCRA facility for treatment (stabilization/solidification) and ultimate
61
disposal. The Laidlaw Facility in south Carolina, located approximately
150 miles south of Aberdeen, was used for RCRA disposal cost estimating.
Excavated trenches would be backfilled with clean fill material and
revegetated.
Disposal cost estimates from the Laidlaw Facility with stabilization/
solidification were $250 per ton with an additional $30 per ton charge for
out of state wastes (a total of $280.00 per ton, excluding state tax).
Estimated capital and present worth cost are $91,733,000 and $93,534,000
respectively. Total operation and maintenance cost are $115,000.
Present worth cost for implementing this alternative/option at individual
areas are presented below.
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Twin Sites
Fairway Six
Mciver
Route 211
TOTAL
Present Worth Base
$45,876,000
$25,400,000
$16,186,000
$ 5,944,000
$ 5,098,000
$98,504,000
Alternative 5: Off-site Incineration
(Alternative 6 in FS)
Under this alternative the contaminated material would be excavated and
transported to an off-site incinerator for thermal treatment and
disposal. Contaminated soil and debris will be excavated and transported
to an off-site incinerator where organic contaminants will be thermally
destroyed, with the ash disposed of in a RCRA subtitle c landfill. The
contaminated material would be excavated then transported to an off-site
incineration facility and treated prior to disposal. Due to the type and
volume of material to be treated, only three facilities were considered to
be capable of handling the material. All of these facilities operate
rotary kiln incinerators.
operator
Chemical waste management
Chemical Waste Management
Rollins
Location
Sauget, Illinois
Port Arthur, Texas
Deer Park, Texas
Approx. Miles
from site
800
1000
1300
Selection of the actual off-site incineration facility that would accept
the excavated wastes from the site depends on the availability of
incinerator capacity. Due to the Land Disposal Restriction regulations
incineration capacity is limited, which may hinder the implementation of
this alternative. This shortage in capacity may require the excavation
and transport of material to a facility in stages as capacity becomes
available. This staging could prolong the length of time for the
remediation of the contaminated soils from the site from less than a year
to several years. The incineration facility is responsible for the proper
treatment of the contaminated material in accordance with RCRA incinerator
regulations and final disposal of the residual ash. The Areas requiring
excavation are shown in Figures 17 through 21 in Section 9.0 of this
document.
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Alternative 5, the most costly of the alternatives, has a total present
worth of $207,327,000. The major costs are for the incineration and
transportation of the contaminated material. Although cost is over 1
order of magnitude greater than comparable alternatives, this alternative
was retained to allow for off-site treatment. The incineration cost
estimates ranged from 45 to 90 cents per pound ($900 to $1800 per ton),
and were a factor of the BTU content of the material. For cost
estimation, 60 cents per pound ($1200 per ton) was assumed.
Transportation costs of $4.00 per loaded mile, over a distance of 900
miles were used for the cost estimation.
Capital costs are estimated at $205,549,000 with annual operation and
main~en_ance of $114,000. Present worth cost estimates for implementing
this remedy at each Area are:
Area
Farm Chemical
TWin sites
Fairway six
Mciver
Route 211
TOTAL
Present Worth Base
$99,088,000
$54,490,000
$33,991,000
$24,880,000
$ 9,665,000
$222,114,000
Alternative 6: In-situ vitification
(Alternative 7 in FS)
Under this alternative, the contaminated soil and debris will be vitrified
in place. The resulting mass of glassy material will be tested for
hazardous characteristics and left in place if it is found non-hazardous.
In-situ vitrification (ISV) is an innovative thermal treatment technology
which virtually eliminates handling of the contaminated material. This is
accomplished by inserting electrodes into the soil and flowing an intense
electrical current between them which heats the adjacent soil to 2,900 -
3,600'F, thus causing it to melt. Organic pollutants are thermally
decomposed (pyrolyzed), while non-volatile inorganics are dissolved in
place and incorporated into the melt. Volatile organic and inorganic
off-gases are collected by a negative pressure hood installed above the
treatment area and processing in the off-gas treatment system. The
resulting end product is an inert, extremely stable glass-like solid mass
with a smaller volume (typically 20 -40%) than the original soil/waste.
When the melt has encompassed the entire treatment volume, it is left to
cool (several months) and is then covered with clean fill material and
revegetated. The power source may either be a local utility or, in a
remote area, a diesel gen~rator.
The estimated area of contaminated soil and debris requiring vitrification
is identical to the areas requiring excavation that was shown in Figures
17 through 21 in Section 9.0 of this document. The estimated volume of the
site material to be treated including a 5% overmelt is:
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Area
Farm chemicals
Twin sites
Fairway six
Mciver*
Route 211
Total
volume { ydl .1.
50,865
27,947
17,276
6,237
4 705
107,030
*Volume includes the 3,200 yd3 of contaminated material stockpiled at
the Mciver Area.
Areas estimated to require remediation to a depth of only five feet may
need to be excavated and consolidated in a deeper configuration to
facilitate the ISV process. Similarly, the stockpiled material at the
Mciver Area must be transferred to a trench in order to vitrify it.
In order to monitor the effectiveness of this technology, soil samples are
collected ·adjacent to the outer edge of the melt to be certain that it has
incorporated the desired area/volume. When the melt has cooled and
hardened, samples of the glass are obtained and tested for RCRA toxic
characteristics. All data indicate that the residual glass monolith will
be very.resistant to leaching, and will require no future monitoring or
remediation.
The maximum area which this technology can treat with one setting of the
electrodes .is approximately 30 x 30 ft; the maximum depth is.also 30
'feet. Only 800 to 1,000 tons of material can be treated per setting;
which, for the most soil matrix applications, limits the volume per
treatment to slightly less than the maximum dimensions. The many site-
and application-specific variables of this technology necessitate
treatability and pilot scale studies before full-scale operation:
Cost for the ISV process includes treatability and pilot-scale tests,
mobilization and demobilization of the vitrification unit, and the
estimated cost per ton for the vitrification operations.· costs which are
not included, because a site visit by the contractor has not occurred, are
site characterization, site preparation/construction operations,
permitting/regulatory compliance, dewatering operations (may be required
in the northern areas of the Twin sites Area), site res·toration, delisting
of the remaining vitrified masses (if necessary), and secondary waste
disposal.
Estimated capital and present worth cost are $50,257,000, and $52,101,000,
respectively. Annual operation and maintenance are estimated at
$117,000. Implementation time is estimated to be 3 years. Present worth
costs for implementing this alternative at each Area are:
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Farm Chemicals
Twin sites
Fairway six
Mciver
Route 211
TOTAL
Present Worth Base
$24,648,000
$13,761,000
$ 8,864,000
$ 3,584,000
$ 2,786,000
$53,643,000
70.
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Al.ternative 7: Thermal Desorption/Separation
(Alternative Bin FS)
Under this alternative, contaminated soil and debri~ are excavated and
treated utilizing low temperature thermal technology. Treated soil will
be tested for RCRA characteristics and returned to the excavated area if
found to be non-hazardous. This alternative consists of excavating
contaminated soil and debris and treating it with thermal desorption/
separation. The volume of contaminated soil and debris and the excavation
procedures are identical to those described in section 9.0 of this
document (Figures 17 through 21). Treatment will consist of volatilizing
the organic contaminants at a temperature generally less than .l'000°F with
the off-gases being_treated to prevent the release of contaminants.
off-gas treatment varies depending on"the vendor,-butusually consists of
either, (1) thermal oxidation in a secondary thermal oxidation chamber
similar to incinerators; (2) condensing and concentrating the organics
into a significantly smaller mass for further 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, it was assumed that a smaller concentrated organic mass would
require incineration in an off-site RCRA facility.
The volume or weight of the condensed mass depends on the amount of
organics present in the soil at each area. To approximate a volume or
weight for post treatment, the average total pesticide concentration
(mg/kg) at each area was converted to percent organics and was assumed to
be representative of all the material excavated from that area. The
percent organics was multiplied by the volume/weight of material to be
excavated (assuming 1 yd3 of material weighs 1 ton) to obtain, the
resulting weight of condensate for additional treatment. The volume of
material to be treated at each area and the resulting condensate for post
treatment is estimated to be,
Excavated
Material Percent condensate
~ {tons} Organics* (tons}
Farm Chemicals 48,443 0.056 27 .13
Twin Sites 26,616 0.005 1.33
Fairway Six 16,453 0.0007 0.1
Mciver 5,940 0.006 0.35
Route 211 4,481 0.057 ~
TOTAL 101,933 31.46
* Total pesticides only
The off-gases will pass through an air pollution control system consisting
of cyclonic separators and baghouse and scrubbers to remove particulates
and BCL either prior to or after treatment of the off-gases, depending on
the treatment system. scrubber blowdown water can either be reprocessed
through the system or treated with activated carbon and then used to
quench the treated (hot) soil. Typically, air emitted to the atmosphere
is passed thorough a bed of activated carbon to insure that it is free of
contaminants.
71
Treated soil will be analyzed for RCRA hazardous characteristics and
disposed back into the excavated area if found non-hazardous. If
hazardous due to inorganics, the treated soil must undergo additional
treatment, such as stabilization/solidification, and retesting prior to
disposal. If hazardous due to organics, the soil will be reprocessed to
remove the organics in it to below toxic levels.
Any stockpile of contaminated material must meet RCRA storage requirements
to prevent further contamination of the environment.
·As with Alternative 4 (On-site Incineration), this alternative can be
implemented on each individual area at a central location. The thermal
desorption system would be located in a centralized area. suspected areas
with high inorganic contamination (localized spills) should be isolated
and treated separately to minimize _the potential for secondary treatment
of the soil.
The major costs associated with this alternative are for the excavation of
contaminated soil and debris, treatment of the soil and returning the soil
to the excavated areas. The cost ranges from approximately $50 to $225
per ton, and is dependent on the type of system/vendor. Additionally,
some price estimates included the post treatment costs, s.uch as
regeneration of carbon. The cost variations should-be taken into
consideration if this alternative is chosen for remediation.
For cost estimating purposes, a base cost of $125 per ton was assumed for
treatment of the soil, with a +40% and -30% cost variation for the high
and low cost estimates, respectively. Additionally, the cost for
transporting, treating, and disposing of a residual organic contaminated
ma·ss in a RCRA facility was also included in this estimate. Estimated
capital and present worth cost are $27,314,000 and $29,115,000,
respectively. Should this alternative be financed and implemented by
different parties at each indiyidual area, the estimated present worth •
cost is as follows:
Area
Farm chemicals
TWi~ Sites
Fairway Six
Mciver
Route 211
TOTAL
Present Worth Base
$14,010,000
$ 7,867,000
$ 5,350,000
$ 2,316,000
$ 2,138,000
$31,681,000
The estimated time required to complete the soil/remediation with one
mobile thermal desorption unit is approximately 2.3 years, assuming a
process rate of 5 tons per hour.
8. 0 SUMMARY OF _.COMPARATIVE ,'ANALYSIS OF ALTERNATIVES
The remedial alternatives developed during the Aberdeen Pesticide Dumps
site FS were',evaluated by.· the u.s. EPA and the NCDEHNR using nine!',
criteria.. The>advantages and disadvantages of each alternative were then
compared to identify the·alternative providing the best balance among
these nine.criteria·defined below.
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overall Protection of Buman Health and the Environment addresses whether
a remedy provides adequate protection and describes how risks posed
through each pathway are eliminated, reduced, or controlled through
treatment, engineering controls, or institutional controls.
Compliance with Applicable or Relevant and Appropriate Requirements · A~ts (ARARB) addresses whether a remedy will meet Federal and state~or
justifies a waiver .
Long-term Effectiveness and Permanence refers to expected residual risk
and the ability of a remedy to maintain reliable protection of human
health and the environment over time, once clean-up goals have been met.
Reduction of Toxicity, Kobility or Volume Through Treatment is the
anticipated performance of the treatment technologies a remedy.may employ.
Short-term Effectiveness involves the period of time needed to achieve
protection and any adverse impacts on human health and the environment=
that may be posed during the construction and implementation period, until
cleanup objectives are achieved.
Dnplementability is the technical and administrative feasibility of a
remedy, including the availability of materials and services needed to
implement a particular option.
Cost includes estimated capital and operation and maintenance costs, as
well as present-worth costs.
State Acceptance should be used to indicate the support agencies
comments.
cornrnnnity Acceptance summarizes the public's general response to the
alternatives described in the Proposed Plan and RI/FS Report. The
specific responses to public comments are addressed in the Responsiveness
Summary.
A matrix summarizing the comparative analysis of
criteria ~y criteria basis is presented in Table
discussion expounds on the information provided in
alternatives on a
The following
Table
overall Protection of Buman Health and the Environment: Alternatives 4
through 7 offer the most protection to human health and the environment by
thermally destroying the organic contaminants by eliminating, reducing, or
controlling risk through treatment. The No Action And Environmental
Monitoring alternatives do not protect human health and the environment
and the long-term protection of a multimedia cap is questionable. The
preferred alternative would treat the organic contaminants in the soils to
eliminate unacceptable risks from direct contact. Treatment of
contaminated soils would subsequently eliminate the migration of
contaminants into the underlying groundwater ~quifer.
Compliance with ARARs: All of the alternatives except No Action and
Environmental Monitoring will comply with the existing ARARs. Alternative
6 ISV, treats the contaminated soil and debris in place, thus RCRA Land
Disposal Restrictions (LDRS) should not be applicable. In Alternatives 4
and 5, excavating and stockpiling of contaminated soil and debris are
necessary. This will constitute placement of contaminated material, thus
LDRs will be applicable.
73
summary of the comparative
Analysis of the Alternatives
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,t t•.
'" ..... ....
"·"'° ,_
711,000
""' 100,000
199,000 .... 255,000 ...................................... -· ..... ·········. .. .. ......... ...... .. ·········· ............ ··••········· ·-1.m,aor: Cont .. inatld ar11s f11lly i-.,1-•n.-d
Ult fff"Ctd or
po'tt.d. \Ii I I Should taka • hw rid.Jc• upo<Jur• ..,.,ths to cOl!t)llfla.
thrQO..J9h po.bl le
....
650,000 ,_
5n,ooo .....
Ml,000
.... n,ooo ,_
n.ooo ..... Ol,000
,_
1,691,000 .. ..
z,nz.~
r....-di•l 1c:1lon llkffl. AO.II. ············ ...................................... ·-....................... -··· ..................................................................... -· ............... ········· .. . ....................... ··········-·· aw1r-..<J.
A •inor incruH
in risk can bf'
UP"(tf!'d.
Enlly 1-.,1_.-.tlfd,
Capptl'l9 is ,
....
6,517,000 ,_ ....
185,000 ,_ laH
9,8411,000 ,_ Nut ti.di• , .. fffOfelln In r~ll'l9 \/ill c~ly
1h1t ri,k pond by th• with .OA.lls
•it1t
Long· tffffl 1tfft'Ctivff>t'1s h
quntion■ble ard
1houtd oot bit c~id..r.-d n ,
per1M~t 1olut ion.
Dt>1t't not rrd.c1t 1h11
to•icity, robillty or
volUl'le.of tht'
contlllfllin.ants.
···················· ······················ ················· ····················
0n-,t11
lnclrwntton,
"-On-1\u .... h
Oi1pout,
Oro1nic: c:ont-in.anl1
1r1t d,u1royf!'d, uh
a.st no! bit ICU. huardooa. ,rovidn
~:~~l !:: ~:/lnen
1t<Wit0t'fllent.
lncirwr■tioro
procn, wt 11
C:CffPlY will All
AR.Altl
Oroanlc: conr .. inanh hd.Jul 1o~icily ,rd
are dr<J!royf!'d, nh vol....,.. thrQO..J9h
i't oot 11:Clt.l tr1t1t.....,1.
haurdous.
(>uv•tion will
incruse fugi1iv1t
O.,st ..-d oroenie
v1por,.
En,,i1lons fr011 th1t
incinerator 1hould
bit frH of
ccmrori conHruc:tlon
prac:tlc:1t.
Should t1k1t Ins
than • yur to
eOl!t)lflll.
lllobite lnc!neretor,
lfl avaltabl• fr011
• l'U!Oltr of
vffldors. (nt■-tfd
C:l:lfPl•t tDl"I In
■qvox. 2.n ~ars,
with -trcl,wrator.
5,861,000 .....
8,588,000
1!3,000
""' 210,000
9,on,aoo .. ... 12,J41i1,000
················· ···········•····· ············ ············ ············· lne 48,653,000 ,_
41,799,000 ""' 66,083,000
.....
115,000 ,_
115,000
""' 1Jl,000
.... 50,Ut,OOCI ,_
68, 16',IOO ....
45,5tr,•
...... ·············· ·········. ········· .................................................... ········· ............................ ·-·· ·········· ... ·············· ····-·····-······ ····-···-··· ········-··· -------······ cont•i~u • ....
51,269,000 ,_ . ...
115,000 ,_ ....
55,070,IDO ,_ On-,111
Jnclrwntlon,
o,-,it• Ash
Dl~•l,
s-11 Alt. 5 ·A-1 s-H Alt.
5 A-1
Same H Alt. 5 A·I s-II Alt. 5 A·1
................................................................................................ ····· ... ········ .. ·······• ····-·· ............. ·•······· ·······. ---··············
an-,lt,
Jnclner•tlon,
bh Dhpoul
In fu'llclpel
L~flll
s-11 Alt. 5 ·A·l s-H Alt.
5 A-1
Sanir H Alt. 5 A-1 s-11 Alt. 5 A·1
.. ······-······ ................................. ······· ....................... .
an-,lt•
lnclNntlon,
Off•1lt• ICU
.lth Ol1po11t,
s-H Alt. 5·A s-H Alt. 5·A
...... -·. .. . . . . . . . . . . ............ ·-·...... . ......... ---. . . . . . -...... -. -. . . . . . . . . .................. -. . . . ... -. . .. . . . . . . .. . .. . . .. . . . . . . . . .. . . . . . . . ............. -. . .. ·-....... ···-..
f11lly 19')1-ttd
hc:aHlior, Is • c-c:-truc:tlon
pf' Kt I Cl• D"Pffldl
Ot1 th• avtlllbllhy
of lnr::inrrttlDl"I
c:epec:hy. Should
raq.,lr11 ,bout •
~•r to 1-.,t-t.
Off-sit•
lncl,-r,tlon
I Hh
DI spout
s-11 Alt. 5·A s-II -'lt. 5·A E•c•v•tlon will
incr11H fuoltl"'
0...t erd org•nlc:
vapors.
····-··············• .......... ······· ....... --·· .. ········· .......... -· ..................... ····· ............. ····· ........................ ··-........ ···•··· .. ···········•····· C-r•tn ,..,,.,., D~Otlth•
,,...\t•bltty of th•
ln·•ttu
ln•,ltu
Yltrlflcetior,
Cfntln Siu)
Low t~r•tur,
The.-..t
OHorpt I on with
On•1lt1 Ion·
ICU. Soll
Oi1poul
Oroanle eont•lnanu
an dntro)"t'd .-.rt
lnoroeniu tr•
lncorporattd In th• _, t.
Oro•lnlc: cont•l,-,u
ara th1t.--lly
drstroytd. Solt -t
pan ICIU hHtrdoo.n
ch,ract.rht le t1t'tt Ing
VI trl fleet Ion
prOC:MI will
c~ly 111th AR.Alt, appl lcllble
to lncirwretion
LODT wilt e°""ly
w! th •ti
,ppl I cable AllAR,.
11\ll providlt a
1tffe-ctive long·t1t,..,
■rd P"r.,.r>lt<'lt
rltfflrdi ■tion
Organic cont""i,-.nu
ar• dr11royM. 5oi l
~t not bit RCRA
huardous.
Yltriflc1tlon P,-OC"'"
rffl.JCH the to•lc:lty,
"'<>hi\ity, .--.::l vOIUlllt of
!hit weSIH.
l!ltdo.JCH to•ldty and
volUl'le lhrOV!ih
~~~!~ ~,.
fuoittv• Mt l•wt
n,ch IHI th,n with
ucavnlon.
E•c■vn Ion wl l l incrH11t fugitive
tiu.t and org,nlc
vapor1. E_t,lone fr-thl
LOOI llllt 1hould
bit frtt of
con I .,.1 nant •.
vhrt fic:atlon 1.r1I t.
C~l1ttl01"1 ti•
about :, ~an.
lDOT sys,t-1r1
av•llll.ble fr0111
11tv1r•I wndor1.
htt-tad
c~t•tiOl'I In app,ro•. z.n .,...n.
48,186,000 ., ... n, 116,000
.... ········ ''" 51,026,000 ,_
46,041,000 ""' 69,Zl0,000 ············ ....
91,731,000 ,_
ll,451,000 ""' 12,,,n.000 ··-········· ....
Z0,,'49,000 ,_
11),049,000
""' 269,571,000
··-···-····· ....
50,257,000 ,_
45,221,000
""' 65,791i,OOO . ...........
''" Z7,l14,000 ,_
10,201,000 ""' -11,a.11,000
115,000 ""' 133,000
--·········· ....
116,000 ,_
115,000
""' 131,000 ······· ····-. ...
115,000 ,_
115,000 ....
111,000 ..... ··--·-· . ... 114,000 ,_
114,000 ""' 111,000
-·······-··· ....
117,000 ,_
117,000 ....
1JS,OOO ............ ....
115,000 ,_
115,000 ""' 113,000
49,914,IOO ....
74,llt,IOO
............. ....
52,Ml,D ,_
41,&Jt,IOO .... 11,111,IOO -····· .......
'"' 9l,5k,OOO ,_
14,249,000 .. .. 126,655,000 --··········. .... Z07,J21,000 ,_
1116,IZ4,000 ....
ZTl,621,000
··-·-········ ....
,z. 101,000 ,_
47,061,000 .... 61,920,000 ············· -29,IIS,IOO ,_
4J,9l0,000 ....
22,010,000
•••••••••••••••••••••••••••~H••■n•u , •• ,nu••••••••••••••• •■n■•■:■H■■■•• • •• u•••••••• • eu su•••• •• •••"•n•■■■u•■•• .. ••••••••••••••••••:s••••~~• ••••• .. ••••• .. ••••••••••••••••••••••••••••••••••••••••••••••••••••••!••••••••••
-- ----... ---.. --
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Long-term Effectiveness and Permanence: Alternatives 4 thro~gh 7 offer
long-term effectiveness and permanence for remediation of the site.
However, in Alternatives 4, 5, and 7, inorganic contaminants are not
volatilized or oxidized and remain in the soil, which may require
additional treatment to stabilize them. In Alternative 6, inorganic
contaminants are incorporated into a melt/glassy mass, which is very
resistant to erosion and are considered immobile. Und~r Alternatives 1,
2, and 3 the contaminated material and wastes will remain on-site;
therefore, the long-term effectiveness of these alternatives is
questionable, and they are not considered to be permanent remedial
solutions.
( Reduction of Toxicity,_ Mobility, or Volume of the ContEll!inants Through
Treatment: Alternatives 4 through 7 reduce the toxicity, volume and/or
mobility of the contaminants through treatment and do not require long
term management and monitoring of the wastes. Alternatives 1, 2, and 3
leave contaminated soil and wastes on-site. untreated wastes amy cause
future environmental problems and will require long-term management and
monitoring.
Short-term Effectiveness: All of the alternatives that require some form
of remedialtion will temporarily increase the risks to public health and
the environment during their :implementation. However, these risks can be
minimized by implementing proper dust and vapor control measures, and
on-site workers can be protected by wearing personal protection
equipment. Alternatives 1 and 2 will not significantly increase either
the risk posed by each area above its current level, or the short term
risks.
Implementability: All of the alternatives are implementable.
Implementation of Alternatives 4, 6, and 7 may depend on the availability
of mobile incineration, ISV, and thermal desorption equipment,
respectively. Mobile incineration equipment is available from numerous
companies; however, ISV equipment is only available from a single
company. Thermal desorption equipment is available from several
companies; however, each system differs in the way it treats the
off-gases, which must be considered when choosing a vendor. Alternative 5
Off-site Incineration, may have to be implemented in stages, depending on
off-site incinerator capacity.
Cost: The present worth cost of the various alternatives range from
$1,777,000 for Environmental Monitoring to $203,327,000 for off-site
Incineration. obviously, the alternatives that require treatment and/or
off-site disposal are the most expensive, but are also the most protective
of human health and the environment. Alternative 5 ·off-site Incineration
is 7 times more expensive then other alternatives offering·the same level
of protection. EPA believes that the most cost-effective alternative is
Alternative 8-Excavation, on-site Thermal Desorption, on-site Ash Disposal
at a present worth cost of $29,115,000 which provides the greatest
protection to human health and the environment for the cost.
State Acceptance: The state of North Carolina concurs with this selected
remedy.
Community Acceptance:
9.0 THE SELECTED REMEDY
The selected remedy is Alternative ?-Excavation, On-site Thermal
Desorption, on-site Disposal. Table 26 provides a detailed cost summary
for Alternative 7. Common elements of the sele.cted remedy to each area
are discussed below.
9.1 Common Elements
EXcavation Goals
Excavation of contaminated soil will be required at each Area of the Site.
Areas requiring excavation are identified in Figures 17 through 21 • The
total volume of contaminated soil requiring excavation from the Site is
99,193 cubic yards. The depths at which Areas are to be excavated and the
volume requiring remediation are identified in Table 27. Included in the
volume to be remediated are 3,200 cy of previously excavated and
stockpiled contaminated soil at the Mciver Area. Volume by Area of
contaminated soil requiring excavation and remediation is:
~ Volume to be Excavated Volume to be Remediated
Farm Chemicals 48,443 cubic yards 48,443 cubic yards
TWin sites Area 26,616 cubic yards 26,616 cubic yards
Fairway six Area 16,45~ cubic yards 16,453 cubic yards
Mciver Area 2,740 cubic yards 5,940 cubic yards
Route 211 Area 4,481 cubic yards 4,481 cubic yards
Total 99,193 cubic yards 101,933 cubic yards
The soil cleanup goals or dig up goals are identified in Table 28.
Cleanup goals were developed for the protection of direct contact with
contaminated soil and are at the 10-6 end of the protective risk ·range.
These cleanup goals are further supported bi the summers Model which was
applied to each Area to estimate if the 10-health based levels would
also be protective of groundwater. only contaminants for which there
exists documented physical/chemical data were modeled. In order to meet
North Carolina standards for the protection of groundwater, cleanup levels
must be established at 10-6 health based levels.
Centralized Location for Treatment
CERCLA section 104(d)(4) allows EPA to treat noncontiguous areas as one
site for the purpose of taking response action. The Site is comprised of
five noncontiguous areas which are reasonably close to one another (all
areas are within a 3 mile radius). The wastes are similar or identical,
and are appropriate for like treatment. Moreover, all areas are related
on the basis of the threat, or potential threat to the public health or
welfare or the environment. All areas comprising the Site fall outside of
EPA's protective risk range between 10-4 and 10-6 •
Treatment at a central location is cost-effective, more efficient and is
in the best interests of achieving a sound and expeditious environmental
cleanup at the site.
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I I I I -I I I I I I I I I I I I I I I TABLE 2~ cost summary for Alternative 7 Low Temperature Thermal Desorption ···········••·············•·••··•·· ............................................... -............................. _________ ..................... ___________________________________________ _ ,. u.,!TAL COSTS: COST ELEIIEIT TOTAL IASE COST IIIGM '"" .................. um . ....................... ·························· ························· CIUAITITT UNIT COST '•rc.,,t•• ANO.JIil IS) ,ercfflt•• Aaoo..r,t (I) Pffc..-.t .. Aac:u'lt (I) ·-· ·········· ......... ············ ...... ············································--··· ......... -····· ......... ........ ............ ········· I.I CAPITAL COST ITEMS: A. Acc■11 l~oveamt and Security INd 1-.pr-U 4000 " '" 1160,000 "' 1164,000 ·101 1144,000 ClHrlng 1., AC 15,000 t.8,000 m 19,000 ·101 17,000 fencing 4000 " "' S60,000 "' 169,000 .,. 1'7,000 I. A■botstH ll'IIIIIVII 300 " " 11,080 2,X 11,000 " 11,000 c. lulldh,g o-\ltlon 160,750 " " 1322,000 "' 1403,000 •\01 1290,000 (lnc:ludlng ~on .-.d dllpoul In Jiv,lclpel lardflll) D, Soll/Wlltll hc1v1tton 98,733 CT '12 1,,,as,000 "' 11,422,000 ·101 11,067,000 l. Load Tru.:IU (111 1-heh) 15S of hc...-u Ion 1118,000 m 120S,OOO ... 1169,000 f. tr-porutlon (5 •lln I 14 per •Ill) 6,loa Truc:kl ,20 1126,000 ,.. 1151,000 ·101 1113,000 G. Shrt'd 1nd Stu 111t.rt1\ 113,543 CT " ll41,000 "' 1392,000 .,,. 1171,000 II. On•tltl LDCT TrHtaent Cl1~/ton or CT) 116,743 CT 1125 114,593,000 401 1.20,00,000 •301 rl0,215,000 I. TrHtablllty Tntll'III \ L.li.._1150,000 1150,000 "' 1173,000 ·5l 1143,000 J, LMd' Tr-port to Off·1lt1 ICU '•clllty 2 Tn.clr.• Sl,600 17,000 2111· ---18,000-·101 ... ooo (31.l Tona of Conderaed Cont-lMl'IU) ,. Off•,ttl lnclNrUlon u S0.60 /lb 62.600 " ..... 1:sa,000 ,.. 146,000 •\01 134,000 L heir.fill with lrHted Sot\ (10X rld.ctlon) 102, 1"9 er 110 11,022,000 m 11,17',000 .,. 1971,000 Ill, hckftll 1o1tth ti,., ,Ill 11,]54 CT 110 1114,000 "' 1131,000 .,. 1,oa,000 •· Gro.rdw,t1r Mont torlnQ w,t 1, 12 " Sl,600 143,000 ,.. 152,000 •\01 Sl9,000 O, llydro SNdlng IS AC 11,000 115,000 ,.. 118,000 •\01 114,000 ,. fllonltorl!'III S~llng "' .. "' 123,000 ,.. m,ooo •\01 121,000 Laboratory Analysl, ., " 11,000 ..,_,,. ,.. 198,000 ·IOI 174,000 leport ,r~ratton 100 " '" "·"" 201 110,000 •101 17,000 0, Mobtllutlon/Domblttutton \ , .... 1250,000 1250,000 251 131],000 .... ll00,000 ········ ............ ......... ········•···· ......... ............ 1.2 UTIMATEO WIU.L Cl»T ,,. IHl,n6,000 "' S.ZS,3US,OOO '" 113,1151,000 \ ., UVEL Of 110,LTII/SAft:TT PttlTECTION (1 l It• 1,2) 10:r. C/D 11 ,!73,000 20I 1/C S5 , 064 , 000 10X Cl'O 11,)85,000 1.4 flULTII 'SAffff OtTt:a:UG (I of It.-1.2 and 1.3) n 1412,000 n ..... ooo n SSOS,000 ,., M 01 ITEIIS 1.2, 1.3, ANO 1.4 ,,. 121,011,000 '" 1]0, 990,000 .,. 115,541,000 ,., COIITUGEICT (S of It .. 1.5) ,.. 14,202,000 201 16,198,000 201 Sl, 1011,000 10• ,2,101,000 "' 14,640,000 101 11,554,000 ,., UITITUTIOltAL Alltl UGIIHIIIG (S of It-1.5) ........................................................................................................................................................................... 141,1137,000 120, 201, 000 1.e lOTAL (STJJIIATEO WITAL COl1 CYa\UI ACU"lded Off) (Si..a of It-1.5, 1.6, end 1.7) 121,314,000 '" ,,. "' 153.001 74.001. 1.9 ,uctllf Of TOTAL IJ.st COST (I) ·····-···················· .. ··· .. ·····---·---····· .. ···---· .. ···-.. --.................... ---........ -----····---······-----················ • Jncludlne ov,rhuod, ta.,rcten, and profit .. Perc.nt-,, OV'tr the bllH coat appllcabl• to l~IYIO..l coat It• only. 1/A • lot -wticKII• All valUl'S rou,d,ecl oft to the ntarHt 11,000'•• ·····················--··--····· .. ··· .. ······---·······--····---·---·····-··-·-······--···-··-···-·--·· II. 0' Ill COSTS: II.A Arn.ial llonltortl'III Cost Slbtot■I 11,1 Arn.iat Optr,tlon, Jllalntel'W"IC,, & lntpectlon a. ln■pe,ctlon b, Oper■t ton C, ll■tnt..-..nc:e lASE• .......... 1113,000 ......... 1113,000 "'° " 11,600 IIIGII ....................... Percfflt•• ,._,,., (1,) ......... ·•·········· "' 1110,000 ······--· ............ ,,. 1130,000 "" "" \Ol " 101 11,800 ............ '"' ••··············•··•··· ,,rcent•• -'-U,t (SJ ......... •••·•••·••·· Ol 1113,000 ......... ........... ,,. 1113,000 "' "'" ... " ... 11,500 ......... ............ s..btotat • 12,400 1/A 12,700 tl./A 12,300 ····························--············--·································· .. ······· .. ···································· 11.C TOTAL .I.IOIUAL O ' Ill COST 1115,000 ,,. 1133,000 ,,. 1115,000 11.D PEIICOIC JIIAJoi: ITSllll IEPAll cmr••· Sll,000 tl/A 115,000 I/A 112,000 .................................................................................................................................. • lnc:li.dtr,. ~. l:lur'dtrl, and profit. -Perc-.nt.,. ..,.,. Ute t.H coat • ... lh• coat 1o1llt Incur orca -ry 5 .,..a,. at 5S of th• -of It• l.1·A end •• ti/A • lot appl lubl• All val-. ra.rd■c:I off to tha nnrnt 1100•■: ..:I. •Jor tot ■la rCIU'l:Md off to th• Na,....t 11,000'•• ............................................ ----.. --.. ···-------···--·····-·---·----·-----···-........................ . 11!. SEIISJTl'IITT .uALTSIS AND PlfS(IIT IM:alll: Ill.A SUS1TIYl11' UALTSIS: s-ltivlty factor ........................ 1. w11t,1Soll E•ca••tlon 2. On•,ltl lnc:1,-ratton 3. Tr-porutlon of A•h 4, A•h tllsp:,ul Ill.I COST YUIATIOII: J1.r1ttflcatton for COl'lltderatlon .......................... UncertalntlH In -at• characttrtntc■ llaJor cost lt-Jllajor con I 1• Jllajor cost tt-,.,,,. •25 to ·SS •25 to ·101 •20 10 ·101 •25 to •20X Justification for •ene• . ..................... . Unc,rtalntlH tn tha q.ant\ty of ,,..,ta to t. ellcavated. Uncart1lnttH tn th• duration •rd cnt of lnc:lntratton. Unc•rt1lnttes In th• hauling dtn.-.ca. Uncartatnt\H In off•■itl ICA.I. dlspou\ cost. Capt la\ Cost■ (S) ""' 0 & II Cost 0/YHr) PrHtnt worth (I)• OUCIIPTIClf la■• ,_ .... """ ,_ laH """ ,_ ................................................. TOTAL COST 127,314,000 141,1137,000 120,201,000 1115,000 1113,000 1115,000 129,115,000 143,920,000 122,001,000 SAL YAGE YALU( SO SO SO SO SO SO SO SO SO ............................................................................................................................................. TOTAL 127,31',,000 141,IJ7,000 IZ0,203,000 1115,000 1113,000 1115,000 129,11S,CIOO 14],920,000 122,001,000 --·-··-··-·--·-------------------------• lnc:li.dl,. capital, ...... 1 01.11, W'd perlodlc •Je,r ..,.. •• ,.,.,,. -u. All wl~ ~ off to UHi ,,..rHt ,1,000•1. 17 ,.rcent Varl•tlon frca In• • so.a •24.41 --·----·-·
DENSE
TREES
VUfri[RN
FIGURE 17. Area requiring excavation at the Farm chemicals Area.
_ _,,,.._........., so...,,,,-s, ----....~-----C-..-,.Nen•c..•-. ,
Surflclel tSubwrt,c. S.,,,plo location
O.ptl'I (rt) : To~I PHIICIOII Conconlr,!lon !ugl'kgj
ffl A•-Uc.w .. ..:I to 5 F .. 1 BGL
,.,.,. E.lcawat..:1 lo 10 t=.et BGL
Ar-bc,vatod lo 15 fffl BGL
~~:ll
•·
+
a,. •r:'.: ~ ~~ 1~
-,. m-11•" 111 Ul,-i:,o .....
::: -~~ ' -~ •m
FIGURE if .·Area requiring excavation at the Twin Sites Area.
7f
PAGES
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+ Ir l ----/-J
•
+ ! i(ii)
J cl -.
; :
+ +
,,
// ,,
//
//
II
--(-... ,:,i ';' -~
. :-:-.-f ~ "(
FIGURE /1 . Area requiring excavation at the Fairway Six Area.
AEPCO
-, .. , ....... llfaslbllly SOldy (Rl.fS) ---Site --eount,,llor'II-
OENSC mus
_,_
(ft)■T-P..clddl
m4iskA•~
~■IFMll8CI.
~•11F..t1Gl. SCALE: I • •
FIGURE zc. Area requiring excavation at the Mciver Area.
7'1
-·-
North
@
+
AtlNdlllllmdg I l'ftnfblltySludy(Rl,f'Sl ---Sill AblrdNn, lloor9 C<utty, Nari\ Cnllna
J.EGElll2 e e Wrri"l I 1M,... Loelllon
.... Dlpll(ft)•Tolll~
O...ea:balc.1fl9't;)
IS.'SJ k•~•10Fat IGL SCALE; I •
FIGURE 2/. Area requiring excavation at the Route 211 Area.
TABLE 27
VOLUMES OF MATERlAL REQUIRING REMEDIATION
FOR CLEANUP TO LECR OF u!O~
SOLID MEDIA
foUfl CIIEllltALI IITt
ScuU.,.m lr-1'1
C.,,tr■l Tr...:11
Ent•"',~
10' h-tlcrt
5' l.<.c-tta,i
..... ,,_.
Arn C Trrct,
10' bu.,etlon
5' t:a.c ... •1t0fl
SJ:,toul
fAII\IAT SIX IHI
tr...-r;t! Uoci;pit•
10' hce,,.th1n
5' hcavatlcri
S<&lt~UL
IOJ'II 211 SIU
to• ~tlai,
TOTAL llllTtll.lL to II PCAVAT[ll
576,000 cf :soa,ooo cf
J.6,000 cf
271,000 cf
111,000 cf
t,l01,000 cf
140,625 cf
135,000 cf
lH,SOO cf
17,500 cf
l4l,500 cf
100,1'50 cf
444,ZSO cf
116,400 cf
'6,000 cf
1,000 ci
160,40il cf
1l1,000 cf
121,GO:il cf
ro
11.m cy ,,. ,,, cy ,,mcy
10,296 ey
4,J7'0 cy
5,208 cy 5,000 cy
1l, 167 ,:y
J,16' cy u.,,, Q'
12,m cv l,7J1 cy
],200 cy
l,""4 cy ... "
5,"'4 cy
4,4"1 cy
4,411 cy
101,913 cy
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TABLE J-J_
Lifetime Excess Cancer Risk Target Cleanup
(Excavation) Levels For Soils At Each Area
Farm Chemicals Area
Residual LECR of lxlo-6
lne Line list Tar-get Clean Up Con::rr-:r1tion {ug/11:g)
--·························· Target ············l············I············ ....... ~~: ~~ '. ............... ~:~~;:: ~.:: :~~::: l: ::[ :: l:~:;~::::.;; f:;~~ .: : : : :~~:: :: :1::: ::J: :: : 1::::: ;r:::
L1'£Tll'!E EXCESS
All:SENIC
IIICX:El
' ''·DDO ,·,•-ooe ,:,•-oor
ALDRZ•
AlPHA•BHC
IETA·IHC
01£LDRUI
CAM.I, • I HC
KEPTACHLOII:
TOXAPH(NE
CANCER RA TE:
TOTAL
·•ThHe lewls should bt 250 ug/kg
to Dt-et grOU"Q,jater AR.lits.
2,463,000
2,000
15,97'5
"'' 959,500
100
57,574
29,278
260
89,47'5
94 2M,212
•• ..
1E·06
6E·08
9"·05
5E•07
1E ·04
2E·OS 1£-06
JE-05 1E-07
9E•05
JE·OL
•• ..
1E·06
7E·OS
1E·04
6€·07
1£-04
2£-05
1E·06 4E-05
1e-01
1E·04
4E·04
•• " 1£·05 6£-08
1E·05
2£-06
1E-07 •• 1£·08
1E·05 -----. -. -. 4E·03
1.2£-07 ••
1.2E·07 •• 1.ZE-07 •• 1. 2£-07
1 .2E-O7
1.2E·07
1.2E-07 •• 1.2E-O7 .........
9.6£-07
Fairway Six Area
Residual LECR of lxl0-6
• • • • ,.n,
" 1,217 •• 66
230
26 318 ..
376 --·-··-·····
" "
, ,47'5 •• ~.0,41-•• 56 197
22 2n • • 322 ·····--·····
74 ..
•• ..
-----9,-757-•• ,.,
2,049
2l1 .. ..
3,353 ··········-·
..... --.. -. ---· .. -.... --. -...... ------· ..... ----. ----. --·--. --... -... --.. -. -------.. -. -.. --· -----... -...... ·•· -----y.,.. .. , Cl..., Uc CO"C ... tru\o, (U'i'l/t;) ······--···--·-···············--·-···-·· or,t o.,,--L IM•IUiCl"I ··-·······--------· ----------
lHEilJll.E UCES~ C,.WCER tAiE:
Cill0.11.111 15,0]5.D .. .. .. )(-05 1 .5E·07
" ···: ···· 1···: ···· IS .......... .. " 4,4'·000 563.0 71.0 ..... ,. ... 1E·Oll .. .. •• .. ... .. 4,4'·00E 1]2. 0 150.0 2E·Oll ,. ... 4E·08 .. .. •• ... .. .. 4,4' ·00? 12,a,;].O ,. 100.0 2'·06 ,. ... U-•07 2E-07 1.5E·07 ,ll0I.IN 26.! 2£•07 2E·07 •• ,, ... 1 .5E·07
.. , "'' ... 9,07'0
20 20 .. • • ALPIIA·ll!C 61!.D 5.0 2'·06 2E·06 ]E·08 2E•07 1 .5E·07 .. " ... ...
IETA·IHC l9\.D 22.0 2£-07 lE·07 ]E·Oll 2E·08 1 .5E-07 21' 146 •• ..
01El0111 "·' 4E·07 4E·07 .. 4(-05 1.5E•07 20 20 •• .. ~ -I HC 130.0 , .. ,. ... ..... 5E·09 .. •• •• ... .. ..
tfEPUCHLCII 66.2 1E·07 1E·07 •• lf:•08 •• •• .. ... .. M"EPlACIIU:JR EPOIIOE '5.2 2E·G8 ,. ... •• 21!•09 . , ... ... .. ...
TOUPl!hE 1,]7'0.0 6E·07 SE:·07 ... ,. ... 1.5E•07 '" '" ... ... ··---··············-··-···-·-· ----------------· ...... --···-···· ---···· ... ----------TOU.l 5.7(-06 6.0l-06 4.2'£·07 J.1E·0'5 1.11!•06
Target
ClHn•~
l ... t
(1.11g/lr:g)
74 • •
1,47'5 ..
1,041 ..
56 197
Z2 in• ..
322" -------------
hr11<tt ct .. an Up
L....el, (U'i'l/kg) ... ----.. -----. -. ---
---"·,,·1····"'····
"'' 20 .. , ..
20
%57 . .........
tool P"tidde ccn:tntr,tlan 1,496
I ti
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TABLE J!.L
Lifetime Excess Cancer Riek Target Cleanup
(Excavation) Levels For Soils At Each Area
Mciver Area
Residual·LECR of lxl0-6
Bese Line Risk Target Clean Up Levels (ug/kg)
Oral Dermal lrY'lalation
Che-mi cal ss ss ss
LIFETll'!E EXCESS CAMCER. RATE:
4,41 ·000 ,. 101 3E·07 3E-07 NA 1.SE-07 2,155 1,844 NA
4,4'-00E 1,400 1E-07 2E·07 NA 1.SE-07 1,521 1,301 NA
4,4' ·DOT 34,240 3E-06 4E-06 3E-08 1.SE-07 1,521 l, 301 NA
ALF'HA·BHC 80,158 1£-Qi, 2E·04 1E-Oo 1.SE-07 8, 70 10,716
BETA·BHC 14,-718 8E-06 9E-06 6E-05 1.SE-07 287 246 NA
GAMMA·BHC 2,985 1E-06 1E-06 NA 1.SE-07 398 340 NA
TOXAPHEME 30,265
-------------------------------------------TOTAL 167,867
1.CE-05 1E-05 TE-Ol! 1.SE-07 ------------------------------------1.TE-04 2.0E-04 1.3E-06 1.1E-06
Route 211 Area
Residual LECR of lxlo-6
470 402 NA . --. ------------------------6,435 5,505 10,716
I I .... l,i,w litir. I p.~ ... : ::u ... ~ :.-l ..... ,ti) II
I l·········•··················I T1r9,t l·············•················!I ?11r,.t
I (ace-sun I 0,.•l I O•,-\IJm•l1ti0""1! Cl .. ,,~ I :,I(· I 0~,...,..l jlrT••ta.i,....,!j c:un ~
I IC-=..,.,t,.nionl··· .. ··•JH .. ••··l··········I 1.-l 1··•······[·········1····•·····!1 1,.,....1
I. o.-iul I w,a/lr.9 I ss f ss J u IAll 10t.rt"! s:: \ ss I ss II cwi;nei I
1----------· -·---------·-------------· ---· · · ----· -·-· · -·-· -· ·-· · · -· -· · · -· -· -------·-· I -· · · · · · · · · · · · · · · · · · · -· · · ·--·--·· · ·-· ---· · · i
ILJFETJME o:ass c.ucu UTE: I [11 ,,t tu I
I •ICUL S,)00.D U IA 3E-~ U I u 11A IU. II I
I I
I ,.,•-000 I 17,i!ii'V.o U•06 tt:·06 ..,. 1.n.01 2.~.:.3 2.~? u 11 2.~ I
I "·''·Dllf I a.s u-10 p.Of:·09 1 ,u, 11,1. MA u u I! I
J "·''•COT I 35'-,920.0 3E·05 I U·~ I U:·07 1.7i•07 1.r:?.:. 1,.:.:-; t.:.l-:-:Z II ,.,~
I a.r.•iu-111c I ..,""8,9'lo.o U·03 I n:·Ol f lE-05 1.n:-01 O! ao ,.,~ II ao
I 1EU.•111c I 35,&es.o ;n.05 I 2£·0'5 I '-E·07 1.11.01 3Z!l 2n 1:s, tl11 11 2:"9
..,.__..,.cc t u. ne.o 5E·06 I 5E·06 I u 1.n.01 ,si l.:.e "' 11 l"'6
I t01u11c11E f ,112,,n.o J ZE·O. I JE·04 I 5E·06 I 1.n-01 1 533 '-!lo 2'-,&-42 II ,~o I
I-·-···-·-········-··-··-······ I··--··--····· I········ 1-···-· ··I·········· I··--··-·-· I········· I········· l ·· · ·······II····-····· I
I tOUl I I 1E·Ol I 2t·Ol I 3£-~ I _1.0E·Oo I I I II I ...................................................................................... --....................... ·---............ -.
Tar-get
Clean Up
Level
(ug/lr.g) •
1,841,
1,301
1,301
70
246
340
402
----------5,504
. .,_
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The Fairway six and Mciver Areas were both considered as the central
location for treatment and were subjected to public collllllent. The Fairway
Six Area has been selected as the central location for treatment. The
rational donsidered for selecting this Area include:
The volume of contaminated soil requiring treatment at the Fairway six
Area (a total of 38,453 cy, includes 22,000 cy from OU Two) represents
31% of the total volume requiring treatment versus the volume of
contaminated soil at the Mciver Area (a total of 5,940 cy)
representing 5% of the total volume requiring treatment;
The distance from the Farm Chemicals and Twin Sites Areas to the
Fairway Six Area ~s approximately 1.75 miles while the distance to the
Mciver Area from the Farm Chemicals and Twin sites Areas is
approximately 4.5 miles.
the Farm chemicals, Twin
the total volume of soil
The contaminated soil requiring treatment at
sites and Fairway six Areas represents 92% of
requiring treatment;
Transportation of contaminated soil to the Fairway Six Area is through
a sparsely populated industrial area while transportation to the
Mciver Area would be through a populated residential area increasing
the short-term risks to residents;
Noise pollution would be a nuisance to nearby residence due to the 24
hour a day operations. A resident lives approximately 1000 feet from
the Mciver Area.
Transportation and Storage
The contaminated soil meets EPA's criteria in determining whether a CERCLA
waste is a hazardous waste. The waste is a characteristic waste because
of its toxicity and a listed waste because it contains P and u listed
waste codes. When the waste is excavated and moved out of its Area of
contamination (AOC) for treatment, placement will occur and RCRA's Land
Disposal Restrictions become applicable. Transportation of the Site
hazardous waste from one AOC to another will be subject to RCRA manifest
requirements.
RCRA storage requirements of hazardous waste prior to treatment are
applicable at this Site. Temporary storage·of waste residuals after
treatment will also be required until the waste residuals are delisted as
a RCRA hazardous waste.
Treatment of Contaminated Soil and Off-Gases
The treatment technology selected for remediation of pesticide
contaminated soils is thermal desorption which will be implemented on the
Site at the selected centralized location.
Thermal desorption is an innovative treatment technology which utilizes
indirect heat to volatilize the organic contaminants from the soil. The
contaminants are captured in an off-gas and are further treated to
permanently destroy the toxic contaminants. Off-gas treatment varies
depending on the vendor, but usually consists of either: (l) thermal
oxidation in a secondary thermal oxidation chamber similar to
incinerators; (2) condensing and concentrating the organics into a
significantly smaller mass for further treatment (incineration); or (3)
passing the off gases through activated carbon to adsorb the contaminants
and then regenerating the carbon. This Record of Decision will not select
the off gas treatment so as not to limit vendor competition. However, EPA
will review and approve the secondary treatment prior to implementation.
Treatment Goals
The treatment goals for the site are RCRA Land Disposal Restriction
standards and RCRA delisting requirements. Because the LDR treatment
standards are based on treating less complex matrices of industrial
process wastes, a treatability variance is sought to comply with the
LORs. This variance does not remove the requirement to treat restricted
soil and debris wastes, rather it allows alternate treatment levels based
on data from actual treatment of soil, or best management practices for
debris. These levels become the treatment standard that must be met.
Table -~l identifies alternate treatability variance.levels which must be
attained. A percent reductiori of organic site contaminants must be
reduced to between 90 -99.99. percent depending on the structural/.
functional group or groups applicable to the site. verification testing
using the Toxic Characteristic Leaching Procedure must be performed to
demonstrate that the RCRA listed waste is no longer characteristic for the
organic constituents.
Although.inorganic constituents are not the primary contaminants of
concern at the Site, there are localized hot spots with elevated metal
contamination. These areas will be segregated before and after
treatment. sample collection and analysis will be the same as discussed
above for the inorganic constituents. If the treatment residuals do not
meet the alternate treatability variance levels as identified in Table
_li, further treatment through immobilization will be required in order to
meet treatment goals.·
rsed The best demonstrated available technology used to -set LDR standards at
the Site is incineration. A treatability variance is also sought in order
to not unnecessarily restrict the development and u~e of an alternate and
innovative treatment technology, thermal desorption, for remediating the
Site.
Delisting of RCRA Hazardous Waste
Once a waste is identified as a RCRA hazardous waste and it is moved out
of the AOC for treatment, it must be handled as a hazardous waste even
after treatment based on the derived-from rule [40 CFR 261.3(c)(2)].
Waste to be delisted must be managed as hazardous until it has been
analyzed in accordance with sampling .and analysis requirements.
Delisting of a hazardous,wastec requires a demonstration that a listed RCRA
hazardous waste no.longer meets any of· the criteria under which the waste
was listed. To··demonstrate compliance, verification testing will be
required following."teatment'·of the wastes to confirm that delisting. levels
are attained. Verification'testing will be collection of samples of the
treatment residuals<and analysis of those samples for total and TCLP
leachate concentrations··of inorganic and organic constituents.
{-.
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TABLE Z 'j
Alternate Treatability Variance Levels and
Technologies for Structural/Functional Groups
-Non-Pow 0.5 -10 . 100 ·-. c1o:on11 o.ocm, -o.06 o.5
PCS. 0.1 -10
Herbicides 0.002 -ci.02
Halogenatsd 0.5 -<40
Pheno<•
HaJog8!'\4t8d 0.5 -

2

Aliot'lat!C:3
Halogenated 0.5 -20
Cyci>eo
Nitrated 2.5 -10
Aromatics
HaUN'tlCyClic:8 0.5 -20
Polynuc...,.
A,cma,c,
011181' Polar
Organics
,-:i;~-6-~-G~~ICS
Antimony
Arsenic
8'num
Chromium
Nickel
Sel9l"lium
Vanadium
cacm,um
Mercury
0.5 -20
o.s -,o
0.1 -0.2
0.3 -

1

0.1 -40
0.5-6
0.5 -

l

0.005
0.2 -20
0.2 -2
o., -3
O.oo::2 -

O

008
100
0.2
<CO
"'
200
,a.coo
200
<CO
100
·•.•·
2
10
<CO
120
20
0.05
200
"' 300
0.08
go -"9.9
Sl0 -99.9
SlO -99.9
90-..
96 -99.9
QO -99.9
99.9 -99.99
!ilO -Sl9.!il
90-..
90-..
.· ....• ,<< '"''" 00-..
90 -99.9
90-99
95 -99.9
96 -99.9
90-99
90-99
95 -99.9
99 -~.!ii
90 -99
Tech 0 le QtH tt\at tlChieved
recommended -concentration guidance-
Dec:hlomdon, Soi Wa:stw,g, Th9nnlll DNtruction
~Treatment~ Soil Wastiing,
-Oes,rucoon -~ Biological Treatment. Law Temp. ~. Soil Washing, Thermal DestnJc.1lon .
~~ Low Temp. Stripping, So,i Wa:.r re
~ Tl'MtrT'lent, Soil Washng ,_ D"""'°"""
~.ale:=, Low T.,,-,p, Sb'ipping. Soil Wa.s~r:-1:;
.,,,.-,.-\•;; :',:-.-/:i_..i:t=.':"::··~,-,: .,
lmmo0di%anon
lmmoblliza1X.ln, Sod W1:st11na
Immobilization
lmmot:,dization, Soll Washing
lmmobda.don. Sod Wastung
1mmo01bzabon
lmmo01!1Zlltion
lmt'T'IObllizatlon. Soil Washing
lmmoblliza!lo1"1. Soi! Wash1f"IQ
lmmobll1zatl0r'I
TCLP al.so~~ uud ~fl rvafuotvlg wan,, in ..,/,i,;J, O'JC'l-10 an l'IDl a pnnc'.pal corwuiuru 1.Aat'haw bu" ln'CUd INOUV, .vi i,,v,,c,t,i~ prcxt:u.
O!Mr uCMD~:1 moy ~ wt:d if tnaiahiiily m,d.ia or o/Nr VlformalUNt in.die.au., U1Ql ~ C41'1 ad,ir,,,t 1M MCf:UIJry conul'llrGllDn "' f"'-rr:tru-rtlWctlOn. rwi~.
In addition, once sufficient data are collected on the waste and its
pot.ential fate and transport, models are run to evaluate the dilution and
attenuation of constituents at a hypothetical receptor well. The
calculated concentrations of constituents at the hypothetical receptor
well must at least meet the health-based levels used for delisting
decisions for the waste to be successfully delisted, Table ...l.~ identifies
the maximum allowed concentrations for specific constituents based on the
current health-based levels (l0-6 risk).
Disposal of Treatment Residuals
When the treatment goals are attained, and the listed waste residuals are
delisted, the residuals will be transported and redeposited in the area
from where they originated. The areas will be backfilled with fill
material to grade and then revegetated with native grasses.
Identification of Hazardous Waste Site
All areas of the Site shall have proper warning signs posted in a visible
location in order to provide site control where humans have access to the
release.
9.2 Elements Unique to Each Area
The selected remedy involves elements which are unique to certain areas.of
the Site and are discussed below by Area.
Farm chemicals Area
The Farm chemicals Area has 14 structures/buildings within its boundary.
some of the buildings/structures at the area should be demolished and
removed to facilitate the remediation of contaminated soils. soil samples
collected near the foundations of several of the buildings contained very
elevated levels of pesticides; the foundations may be contaminated. These
foundations probably would be undermined during excavation. In addition,
three pipe insulation samples collected in and around buildings 17 and 19
( see Figure 2 in Section 1. 0 of this report) .contained 40%, 20%, and 37%,
of asbestos. Proper procedures must be followed in removing and disposing
of the asbestos containing pipe insulation before destruction of the
southernmost Warehouse.
The building debris will be subject to RCRA characteristic hazardous waste
testing; if found non-hazardou·s, it may be disposed of in the nearest
municipal landfill. If it is found hazardous because of halogenated
organic compound (HOC) contamination, a treatability variance for this
material may be necessary. The treatment standard required by the LDRs
for the HOC contamination present at the Farm chemicals Area· is
incineration. This is an inappropriate treatment technology for building
debris, thus triggering the need for a treatability variance. In this
case, best management practices, such as decontamination or destruction,
will be employed which lower contamination to the aiternate treatment
levels of the treatability variance. The material will then be suitable
for land disposal.
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. -l!!I l!!!!!I ..
.. - - - - - - -11!1 -I - - - - -
containers consisting of several 55-gallon drums, 1-gallon containers, and
5-gallon buckets are located within several buildings on the area. Any
tank/drums/buckets containing pesticides or volatile or semivolatile
organic compounds must be decontaminated prior to offsite disposal of the
solid waste. The hazardous waste resulting from the decontamination
process will be collected, stored and then treated in the thermal desorber
unit when it is in full scale operation.
A localized, stained area near surficial soil sample 119 contained very
elevated levels of several metals. This area must be further
characterized and segregated during excavation and thermal desoption to
minimize the need for secondary treatment due to metal toxicity in the
treatment residuals. Any area found to contain elevated levels of metals
should be handled and treated in the same manner.
The remedial investigation identified potential or suspected trench areas
at the area. Further sampling is ·needed to confirm the presence of buried
trenches and then to fully characterize the vertical and lateral extent of
contamination.
TWin Sites Area
Geophysical survey results identified six suspected trench areas. several
of these trenches coincide with areas of highly contaminated surficial
soil samples. Additional sampling is needed to confirm the presence of
buried trenches and then.to fully characterize the vertical and lateral
extent of contamination.
Fencing around the site is required to provide area control precautions
where humans or animals have access to the release.
Fairway six Area
The remedial investigation geophysical surveys indicate that as many as
seven additional trenches may be located at the area. Further sampling is
needed to confirm the presence of buried trenches and then to fully
_characterize the vertical and lateral extent of contamination.
HCJ:ver Area
The main area of contamination is located to the northwest of the known
area of con~amination, Area B, and may represent an additional area of
contamination. Further sampling is needed to delineate this area.
Area C was excavated by EPA's Emergency Response Team in 1989. This
material is stockpiled onsite and was included in the volume of soil
requiring treatment at the Mciver Area. Additional sampling is needed to
fully characterize the lateral and vertical extent of residual
contamination in Area C. The cleanup or excavation goals for Mciver Area
B identified in Table 28 will apply to Area c as well. Any residual
contamination exceeding the cleanup goals identified in Table L~ will be
excavated and treated in the thermal desorber unit.
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Route 211 Area
Mercury was detected at a very elevated level in one soil sample.
Additional sampling is needed to confirm and delineate the extent of this
contamination. Areas containing elevated metal contamination must be
segregated during handling and treatment to minimize the potential for
secondary treatment.
9.3 Contingency for soils Remediation
A contingency ROD is appropriate when the performance of an innovative
treatment technology appears to be the most promising option, but
additional testing _will be needed during remedial design to verify the
technology's performance capabilities; in this case, a more "proven
approach" is identified as a contingency remedy.
Should implementation of the thermal desorption method (Alternative 7)
prove ineffective for remediation of soils by not meeting soil treatment
levels, Alternative 4, Option 1 would be the Agency's contingency
alternative. All aspects of Alternative 4, Option 1 are identical to
those of Alternative 7, except that contaminated soils would be remediated
using on-site incineration.
The criteria that EPA will use to decide to implement the contingency
option as opposed to the selected remedy are:
0
0
0
Failure to meet treatability variance levels identified in Table
Failure to meet TCLP requirements; or
Significant cost increase for thermal desorption which would exceed
the cost estimate of on-site incineration.
All components of the contingency remedy, Alternative 4, Option 1 are the
same as the selected remedy, Alternative 7, with the exception of the
treatment technology, incineration. Under Alfernative 4, Option 1,
contaminated soil and debris are incinerated on-site in a centralized
mobile incinerator. For cost estimation, a mobile rotary kiln incinerator
was assumed due to their relative abundance and availability. However,
other types of incinerators that provide equal or better performance
should be considered when bidding the project. This alternative consists
of the following remedial activities:
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mobilizing the incinerator in a centralized area (Fairway six);
excavating pesticide contaminated material from each area of the site;
transporting the material to the centralized area;
homogenizing and sizing the material for incineration;
incinerating the waste;
on-site treating of process wastewater or scrubber blowdown sludge by
reinjection into the incinerator; a" d
demobilization.
Prior to incineration, the material will be passed through a shredder and
power-screens for sizing. The properly sized contaminants will then be
fed into the incineration unit. In order to maintain a readily available
feed for the incinerator a "Waste Pile" must be maintained on-site. This
waste pile will constitute placement under RCRA. Therefore, it will have
to comply with RCRA regulations as specified in CFR 265 Subpart L.
Operation of the incineration unit will be in compliance with RCRA
regulations (particularly Subpart o, 40 CFR 264), including performance
standards. The incinerator and air pollution control unit will be
operated so that:
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An operating temperature in the kiln of l,800°F is maintained at all
tim1;1s tp ensure thi;lt any volatile and semi-volatile / r 5 .,;< C• .. ~•~•"-tf,
IJ.•if< .stvt•"l . .v. J,,v,,, o-.f ,/. f'.., ~,I, ~Al fi,J ~ -/1'1t ci....bo~ t<M..,.0•0J '' 15 /""w4 ~Miit:rJ, an operating temperature in the afterburner of 2,000°F is maintained
at all times to oxidize and destroy all remaining organic substances
prior to exiting the afterburner and entering the pollution control
system;
o the incinerator will be capable of achieving a destruction and removal
efficiency (DRE) of 99.99% for all designated principal organic
hazardous constituents; and
o the air pollution control system will achieve performance standards of
(l) hydrogen chloride of less than 4 pounds/hour and (2) particulate
matter of less than 0.08 grains per dry ft3 in the exhaust gas
corrected to a 7 percent oxygen content.
Excess quenching and scrubber water, if any, will be reinjected into the
incinerator for disposal. Air pollution control wastes or sludges will be
reinjected in the incinerator for further treatment. Incinerator ash will
be collected, tested.for RCRA characteristics, transported back to the
area from where it originated for on-site disposal.
Alternative 4, Option 1, like Alternative 7, utilizes a thermal treatment
to reme'diate contaminated site soils, but Alternative 4 would involve the
use of an on-site incinerator which would destroy the organics present in
site soils rather than cause a physical separation of organics from the
soils by the thermal desorption technology. The use of thermal treatment
of soils will ensure that contaminant levels are permanently reduced, thus
eliminating a current source of ground-water contamination. Table 3 I
provides a cost summary for Alternative 4, Option 1.
10.0 AMENDMENT TO OPERABLE UNIT TWO RECORD OF DECISION
The Fairway six Disposal Site, Operable Unit Two, is located adjacent to
the sixth fairway of the Pit Golf Links golf course in Aberdeen, North
Carolina. The site is currently an enforcement lead site with EPA
providing oversight of site activities. This amendment is being provided
in accordance with CERCLA section 117(c) and the National contingency Plan
(NCP) 40 C.F.R. section 300.435(C)(2)(i). The amendment will become part
of the administrative record file for OU Two and OU One which is located
at the site repository.
The Fairway Six Disposal site was one of four areas used as a disposal
area in Aberdeen, NC. The general area is believed to have served as a
trash dump for many years prior to the construction of the golf course.
After an investigation by EPA's Emergency Response Section in 1985 and
1986, two removal actions were conducted at the site. The first removal
action conducted in 1985 resulted in the excavation and offsite disposal
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TABLE 3 I
Cost summary for the contingency Remedy for
.Alternative 4-on-site Incineration
.................................... ·-·----·-·· ......................................................................... -.... _ .............. _______________ .., ___ _ ,. C..UIT.I.L COSTS: COit (LENUT TOTAL IASl COST "'' "" .................. "'" ························ ......................... ························· QUI.IT\ T1' ''"' "" '•rcW1t•• .uQJIIT (I) ,•rc..,t•• ,.,_,,., (I) ,.,.c.-.t•• -.1(S) ·····································-················ ............ ············ ············ ,. ' WITAL con ITOtS:
A. ACCHI 1.-ov-t Wld S.wrlty
load IIIP!'ft-U 4,000 " '" 1160,000 "' 1114,000 .,,,, 1144,000
tlnrl,. '., " n,ooo "·"' '" '9,000 .,,,, 17,000 ,_1,. '·"" " "' "'·""' "' 169,000 ... '57,000 ,. AlbHlN 1-.,l 300 " ., 11,000 ,,. 11,000 "' '1,000
C. lu\ld("'J OftlCILttlon 160,1'0 " ., n22,ooo ... 1403,000 .,,,, Sl90,000 (lncludl"'II OKon ....:I dhpou\ In ..._.,le!~\ L.-.dftlt) ,. Soll/I/HIit hc•v1tton 98,73:S " "' 11,195,000 '" 11,422,000 ., .. 11,067,000 ,. Load Trucu ( II. r-£ach) 151'. of bCIIV■tlon 1178,000 "' llOS,000 ... IU,9,000 ,. Tr-partnlon c5 •tln ii 14 per •tit> 6,30.!J Truell -szo-.,2,.000 "" 1151,000 . '"' 111:S,OOO ,. Shred I Sl1• 111urhl 113,543 CT ., Sl41,000 "' '392,000 ... 1124,000
M. ~-,ltt lnchwratton (llSO/ton or CY) 116,743 CT IZ50 129,186,000 '" U5,02l,000 ., .. IZ6,Z67,000
I. Truubtllty Tntlr.o ' L .Su■ 1150,COO 1150,000 "' 1171,000 ... 1141,000
J. A ■h 0hpoul.(AIIIIM 151'. 1.0..Ctlon) 99,232 CT "' 1992,000 ... 11,190,000 .,,,, 1891,000
'· hekfill .. tth c1 • .,, Ht\ 11,511 CT '" S1~,000 "' 1201,000 ... 1166,000
L. Groo.rdw■Ur lklnttorlng lil■ l\1 " .. U,600 143,000 ... 152,000 . '"' 139,000
II. "ydro SHdtng ,. " 11,000 115,000 '" 111,000 .,,,, 114,000
'· llonltOrl"'II
S~llna "' " "' 12:S,000 "" 121,000 ., .. 121,000
L ■bornory ._n■lyel ■ .. .. 11,000 112,000 ... 19$,000 ., .. 174,000
hpart Prl'per■tton "' " '" s.e,000 '"' 110,000 ., .. 17,000
o. Motil l tutlon/0.-;,b!\ tut Ion ' L,Su■ 1290,000 1290,000 m ll6J,000 .... 1232,000 ............ . ........... ·•·········· ,.. ESTHUTEO CAPITAL COST .,. 133,3'5,000 ,,. IJ9, 992 , 000 .,. 130,0Zl,OOO ,., UVU Of MEALTN/Uf£TY PROTECTIOII (l A It• 1.2) 101 C/tl S3,3l5,000 lOi 1/C 17,991,000 101'. C/0 U,IXl],000
L4 ~EALTM • unn IICIIITtalNG (I of ,._ 1.2 Wd I.]) '., "'"' ITEIIS 1.2, 1.3, AIIO 1.4 ,., CC:WTIWCENCT (I'. of II• 1.5) ,., IUTITIJTIOIU.L AICI fWCIIIUUIG {I'. of It• 1.5)
t.a TOTAL UTIIUTnl CAPITAL COST (Yalu. IIIU'ldlld Off)
(S,.. of It-1.5, 1.6, ....:I 1.7)
1.9 ,ucoT o, TOTA\. IAR: COST (I'.)
.. .,,
'"' '"
17l4, 000 .. 1960,000 .. 1661,000
137,414,000 .,. 14!,950,000 .,. U:S,692,000
S7,4Sl,000 "" H,190,000 ... u,ne,ooo
U,741,000 "' 11.:su,000 '"' U,369,000
148,638,000 ,,. 166, 0113, 000 .,. 14:S, 1'99, 000
.,. 136,00l 00.001
···--·············--···· .. ······---··-----··--······ .................. -................... -... ■-■ ....... ___ ... ___ ••• _.. .. _ • lncludlno 0¥■f"hHd, bur'doln, ■nd profit •• ,■rcent ... O¥■ r th• b9■■ co■t appl lc■blt to lr&llvlG.al Cllllt 1 t• only.
I/A • lot -.1 lnot■
All ... 1 ..... r ........ ■ff t ■ tN ,-r•t 11,000'••
••--■-■••-----------•----m-•■■--•■--■■•--••-■--■■■--■■••■■ II. 0 I II casts: NICll "" -·--··--IA.SE• Percent .. _,,, '" Ptrcent-_,,, '" ............ ····---· I I.A .,,,_I -lrorll'II to■t 1113,000 "' 1)10,000 " 1113,000 ............ ............
Slbtot■l 1113,000 .,. 1130,000 ,,. 1113,000
II.I .t.rn.,,a\ oi:,.r■tlon, ltlllnt-■, ll'llplCtton
,. Jn1pectlon "" 101 '"' "' "" b. oi:,.rulon
e, ll■lnt-• " '" " ... " 11,600 '" 11,100 ... Sl,500 ............ ............
Sl,400 .,. "·"' .,. '2,100
11.C TOTAL AJIWAL 0 & II COIT 1115,000 .,. 1113,000 .,. 1115,000
11.0 PUICDIC IIUOII ffflfll lfP.1.11 COIT-113,000 I/A 11S,000 II/._ 112,000
·························---···--··---··-··-··---··········---········--•---■•-··--------·--• lncluc:tlne 0¥1rt.■-d, tu-dWI, ■nd profit, •• ,,,.cent.,.. _,. th■ ..._ -,.
••• Th ■ co■t "Ill lror m ~ 5 ,._,.. ■t 5l of tM -of It• 1.1·.I., and l,
If.I. • ■ot lllf:IPI lcabl■ All 'l■l"'" l"Olftlad •ff ti t1N _, 1100'■; ft •Jw totolo """"""off 10 th• rw■r·eu 11,000'•·
·----··---------------------------111. SOSITIVITT .1..U\.TIIS Allt N!Rll'T IISTI;
111.A snSn1v1n .....,LHts1
1 • ._..,1111ott hc...-nton
2. ~-•II• lnclrwrnton :,. lulii:11,-. o-iltlan
111.I COST YAl:1.1.TIC.1
J\atltlc■tlon tor C-ldlrnlon
LW:ffUIMlft It"! -t■ d\erec:torlnln
■..Jor -t It• 11tJor nat tt•
Capital Co■U <I) .,.,
....
•25 to ·5l
•25 to ·101 ■:ro to ·1171
J\atlflntlon for 1.,.. ······················································ uw:,rutntl" '" th• ~tlty 9f -u to N OAc..,•UoCI, \.W:■l'Ult"!tlft It"! tlte l;U'otlon and CNt •f lnc\rwntlon.
unurt■lt"!tln In co■t of dilaolltlon.
O I I Con U/Teorl
,... Nltih low t ... OEKIIPTIC. I•• ············ ............ ............ . .......... . .,.,
161,166,000 TOTAl eon 141,631,000
u.t.YAC.,: VAL.. SO
TOTAL 141,631,000
166, Gal, 000
" SM,Oll,000
14:S,799,000
" 14:S, 799,000
1115,000 1133,000 111,,000 150,4J9,000
U H H U ............ ............ ............ . .......... .
1115,000 11:S:S,000 lt1',000 SS0,43',000 " 161,166,000
14S,591,000
" S4S,5t7,000
•t.61 PercMt vorhtlon f,,. ,-, • :ss.n ··-··-·----------------·-·--------·-----;..;;;;..~;;.;;;..;..;..;;.;;;.;,. ________ , __
• lncluc:ttne c119lul, .-n.l 0111, and periodic •Jw .,.t_ ,.,.u-CNU,
Alt .. ,two r........:I .ff to tM ,..,..., 11,000'••
of 1,420 tons of pesticide contaminated soil and waste. The second
removal conducted in 1988 resulted in the excavation of 29,700 tons of
pesticide laden soil and waste. This material was stockpiled on site and
covered with a top and bottom PVC liner.
on June 30, 1989, the EPA Region IV Administrator signed a Record of
Decision f~r OU Two. The selec~ed remedy involved on-site incineration of
the stockpiled material, confirmatory analysis of incinerator ash and
on-site disposal of incinerator ash.
Following a CERCLA Section 106 enforcement action in March 1990, a
responsible party (Union Carbide corporation) agreed to implement the
remedy at OU TWo. A remedial action work plan was prepared in September
1990 for OU TWo. On September 19, 1990, Union carbide Corporation made a
request that EPA postpone implementation of OU TWO until a remedy was
selected for OU One. The purpose of Union's proposal was to analyze the
viability of combining operable units one and two and subsequently utilize
one treatment technology. After evaluation of·union Carbide's request,
EPA allowed the extension of the implementation schedule for OU TWO for
the following reasons:
0 identification of appropriate cleanup goals not explicitly defined in
the ROD; and
0 potential cost savings if incineration were the selected remedy for OU
One and the operable units were implemented simultaneously;
0 Union Carbi~e's agreement to take measures for the prevention of any
environmental harm resulting from ~he continued existence of the
stockpiled material at the ·Fairway six Disposal site; and
0 Union Carbide's agreement to participate in negotiations for OU One.
Fundamental differences to the ROD for OU TWO are presented below,
followed by a discussion of the basis for those differences.
original Remedy
Incineration of 22,000 cy
of contaminated soil.
Performance standards identified
as elimination of toxic
characteristics (using the EP
Toxicity Test) and conformity
to background levels determined
to be 2.3 ppm total pesticides.
NC ROD concurrence identified
performance standards based on
TCLP to drinking water
standards.
No haz·ardous process residuals
result from the incinerator
technology.
Modified Remedy
Thermal desorption of 22,000 cy of
contaminated soil.
Performarice standards are identified as
elimination of toxic characteristics·
(using the TCLP test) and conformity to
cleanup levels established for the
Fairway six Area identified in this
ROD for ou one.
The waste will be treated to meet RCRA
LOR requirements or other RCRA
requirements, Best Demonstrated
Available Technology (BOAT)
Requirements or obtain a Treatability
Variance.
Hazardous process residuals resulting
from the thermal desorption technology
will require furtlier treatment which
will be vendor specific.
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Estimated present worth cost
for on-site incineration is
is $14.5 million.
Estimated present worth cost for on-site
ex-situ thermal desorption at the site
$4.3 million.
Both technologies, incineration and thermal desorption, utilize thermal
treatment which applies an elevated temperature as the primary means to
change the chemical, physical, or biological character or composition of
the hazardous waste. Incineration is a technology which utilizes
combustion through oxidation to destroy the organic contaminants. Off
gases from the combustion process are emitted into atmosphere following an
air pollution control train. Thermal desorption on the other hand only
volatilizes the·organic contaminants from the soil and the off-gases are
captured for further treatment. Thermal desorption eliminates the off-gas
emissions into the acin6sphere.
The May 1991 Feasibility study for OU one supports the proposal that
remedy implementation should be conducted at one central location. This
is substantiated by the economic impracticability of conducting
remediation at each individual area. Therefore, this rational also
supports combining remediation for OU Two with OU One. The revised remedy
cost of $4.3 million involves treatment of contaminated soil and debris
utilizing thermal desorption.
Considering the new information that has been developed and the changes
that have been made to the selected remedy for OU Two, the EPA and NCDEHNR
believe that the remedy remains protective of human health and the
environment, complies with federal and state requirements that were
identified in the ROD as applicable or relevant and appropriate to this
remedial action (at the time the original ROD was signed), and is
cost-effective. In addition, the amended remedy utilizes permanent
solutions and alternative treatment (or resource recovery) technologies to
the maximum extent practicable for this operable unit.
11.0 THE STATUTORY DETERMINATIONS
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, CERCLA Section 121
established several other statutory requirements which must be attained by
the selected remedy [NCP 40 C.F.R. Sec. 300.430(f)(ii)A-EJ. The statutory
requirements specify that the selected remedial action for this site must
meet all of the applicable or relevant and appropriate requirements
(ARARs) of both Federal and State unless a 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.
ll.l Protection of Human Health and the Environment
The selected remedy and contingency remedy protects human health and the
environment through thermal treatment of pesticide contaminants in soil.
The contaminants will be permanently removed from the soil by thermal
desorption or incineration. The volatilized organic contaminants
resulting from thermal desorption will be captured and permanently
destroyed through secondary treatment. Incineration of the contaminated
soil would destroy the organics by combustion and would not require
secondary treatment. Treated soils must meet RCRA LOR standards
(treatability variance levels), pass RCRA hazardous characteristic testing
and meet RCRA delisting requirements. Thus, implementation of either
alternative, thermal desorption or incineration would provide sufficient
protection to human health and the environment. ·
Thermal treatment of pesticide contaminated soil will eliminate the threat
of exposure to the contaminants from direct contact with or ingestion of
contaminated soil. ·The current risks associated with these exposure
pathways at each Area falls outside of EPA's protective risk range.
Excavation of contaminated soil to cleanup goals established at 10-6
health based levels will provide adequate·protection to human health and
the environment. By excavating and treating the contaminated soil to
stringent RCRA standards, the selected remedy will further provide
protection to the underlying aquifer which is the sole source of drinking
water for the local community.
11.2 Compliance with Applicable or Re'ievant and Appropriate ~eguirements
The selected alternative, as well as the contingency remedy, will be
designed to meet all applicable or relevant and appropriate requirements
(ARARs) of Federal and state laws. The ARARs to be attained by the
thermal desorption technology are presented below.
Action-Specific ARARs:
RCRA Manifest Requirements
RCRA storage Requirements
RCRA Delisting Requirements
RCRA Land Disposal Restriction Requirements
Chemical-specific ARARs: None
Location-specific ARARs: None
11.3 Cost-Effectiveness
Alte.rnative 7 affords a high degree of effectiveness by providing
protection from direct contact with pesticide contaminated soils. Thermal
treatment of contaminated soils will also provide adequate protection to
the underlying sole source aquifer by permanently removing the source of
contamination. Alternative 7, the least costly alternative, is the most
cost-effective alternative which provides the greatest protection to human
health and the environment.
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, 11.4 Utilization of Permanent Solutions and Alternative Treatment
Technologies or Resource Recovery Technologies to the Maximum
Extent Practicable
u.s. EPA and the State of North Carolina believe the selected remedy,
thermal desorption represents the maximum extent to which permanent
solutions and treatment technologies can be utilized in a cost-effective
manner for a source control remedy_of contaminated soils at the A1?erdeen
Pesticide Dumps Site. of those alternatives that are protective of human
health and the environment and comply with ARARs, the State of North
Carolina and EPA have determined that this 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 co~t~-
The selection of treatment of the contaminated soil is consistent with
program expectations that indicate that highly toxic and mobile waste
are a priority for treatment and often necessary to ensure the long-term
effectiveness of a remedy. Options evaluated in detail which do not
require treatment, such as environmental monitoring and capping, obviously
do not meet the statutory requirement for the utilization of permanent
solutions. Alternative 7 meets this statutory requirement by providing a
permanent solution while utilizing an alternative treatment technology.
In the event the contingency remedy will be employed, on-site incineration
will also meet the statutory requirement by providing a permanent solution
to site contamination which utilizes a treatment technology to the maximum
extent practicable.
11.5 Preference for Treatment as a Principal Element
By treating the pesticide contaminated soils in a thermal desorption unit,
and stabilization/solidification of any residuals with metal-
contamination, which may remain hazardous following treatment, the
selected remedy addresses one of the principal threats posed by the Site
through use of treatment technologies. Therefore, the statutory
preference for remedies that employ treatment as a principal element is
satisfied.
This statutory requirement would also be satisfied by the use of the
contingency remedy, on-site incineration.