NCD991278540_20080701_Weyerhaeuser Company_FRBCERCLA SPD_Fact Sheets 2002 - 2008-OCR

SUPERFUND PROPOSED PLAN FACT SHEET
Domtar (Formerly Weyerhaeuser) Site
Lower Roanoke River
Plymouth, North Carolina
JULY 2008
This foct sheet is not to be considered a technical document but has been prepared to provide the gcncrnl public with a better understanding of activities
that have been occurring at the Site. For technical infonnation, please review documents in the Information Repository.
DATES TO REMEMBER
(mark your calendar)
PUBLIC COMMENT PERIOD:
July 12-August 11, 2008
U.S. EPA will accept written comments on this Proposed
Plan during the public comment period.
PUBLIC MEETING:
July 17, 2008, 7:00 pm
U.S. EPA will hold a public meeting to explain this
Proposed Plan and all of the alternatives presented in the
Feasibility Study. Oral and written comments will also be
accepted at the meeting. The meeting will be held at:
First Baptist Church
309 Washington Street
Plymouth, NC
For more information regarding the Site, see the
Administrative Record at the following locations:
U.S. EPA Records
Center
61 Forsyth Street, S.W.
Atlanta, GA 30303
( 404 )562-8946
Hours: M-F
8:30am-4:30pm
Washington County
Public Library
201 East Third St.
Plymouth, NC
27962-0786
[phone]
Hours: Mon-Thur
10am-7pm
Fri 10am-5:30pm
Sat 10 am-1pm
INTRODUCTION
This Proposed Plan identifies the Preferred
Alternative for long term environmental monitoring
in the Lower Roanoke River and provides the
rationale for this preferred alternative. The Lower
Roanoke River is one of several areas (or operable
units) evaluated at the Domtar (formerly
Weyerhaeuser) Site. In addition, this Proposed
Plan includes summaries of other alternatives
evaluated for the Lower Roanoke River. This
document is issued by the U.S. Environmental
Protection Agency (EPA), the lead agency for site
activities, and the North Carolina Department of
Environment and Natural Resources (NC DENR),
the support agency. EPA, in consultation with the
NC DENR, will select a final remedy for the site
after reviewing and considering all information
submitted during the 30-day public comment
period. The final decision will be documented in a
Record of Decision. A Record of Decision is a
public document that explains which cleanup
alternative will be used at a Superfund site and the
reasons for selecting the alternative.
EPA, in consultation with the NC DENR, may
modify the Preferred Alternative or select another
response action presented in this Proposed Plan
based on new information or public comments.
There-fore, the public is encouraged to review and
comment on all the alternatives presented in this
Proposed Plan.
EPA is issuing this Proposed Plan as part of its
public participation responsibilities under Section
300.430(f)(2) of the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP).
The NCP is based on the requirements of the
federal law known as the Comprehensive
Environmental Response, Compensation, and
Liability Act ( commonly referred to as "Superfund").
This Proposed Plan summarizes information that
can be found in greater detail in the Remedial
Investigation (RI) and Feasibility Study (FS)
Reports and other documents contained in the
Administrative Record file
for this Site.
EPA and the NC DENR encourage the public to
review these documents to gain a more
comprehensive understanding of the Site and
Superfund activities that have been conducted at
the Site.
SITE HISTORY
The Domtar (formerly Weyerhaeuser) plant is an
active facility which has been in operation since
1937. Current operations include the production of
fine paper and fluff paper. The plant was owned by
Weyerhaeuser from 1957 until 2007. Recently,
Weyerhaeuser and another paper company,
Domtar Inc., agreed to merge some of their assets
to create a new company. The Plymouth plant and
some other facilities are now owned and operated
by the new company known as Domtar Paper
Company.
The plant property covers about 2,400 acres and is
located about 1.5 miles west of the town of
Plymouth.
Several site studies have been completed at the
Site to address four projects or Operable Units
(OUs): OU1 -the former landfill #1; OU3-the
former Chlorine Plant; OU4-Welch Creek, and
OU2-Lower Roanoke River.
Weyerhaeuser or Domtar conducted the site
studies with oversight and review by EPA and
NCDENR. EPA then selected the remedies for
OU 1 and OU3 as described in Records of Decision
signed in 2002 and 2003, respectively. The
construction of the remedies for OU1 and OU3
were completed in 2005 and 2006, respectively.
• Domtar (Formerly Weyerhaeuser) Site
Proposed Plan Fact Sheet
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A Record of Decision for contaminated sediment in
Welch Creek was signed in September 2007. EPA
is currently negotiating a Consent Decree with
Domtar to perform the design and construction of
the remedy for Welch Creek sediment.
The community has been informed of activities at
the Site through the mailing of fact sheets and
public meetings over the years. An initial public
meeting was held in March 1999 at the start of the
site studies. Additional public meetings were held
in 2002 and 2003 to discuss each of the cleanups
proposed for OU1 and OU3. Fact sheets were
mailed during these times and also in 2005 at the
start of the cleanup for OU1. The most recent
public meeting and public comment period was
held in August 2007 regarding cleanup alternatives
for Welch Creek.
EPA has coordinated with a variety of state and
federal agencies, particularly during the studies for
Welch Creek and the lower Roanoke River. The
FS for OU2 was completed in May 2008. This fact
sheet will focus on OU2, the Lower Roanoke River
(see Figure 1 ).
Wastewater from plant operations was discharged
to the Lower Roanoke River from 1937 to 1957, to
Welch Creek from 1957 until 1988, and again to
the Lower Roanoke River from 1988 to the present.
The discharges to Welch Creek were permitted by
the State of North Carolina in 1969 and a
subsequent federal NPDES permit in 1975. The
mill has a current NPDES permit for its discharge.
The mill modified its paper bleaching methods in
the early 1990's which reduced the levels of dioxin
in its wastewater discharge.
Site Characteristics
The "Lower Roanoke River study area" (designated
as LRR or OU-2) is defined as 14.3 miles of the
river from a point upstream of the Domtar paper
mill to Albemarle Sound. The LRR OU-2 extends
through Martin, Bertie, and Washington Counties,
North Carolina. Along the lower portions of the
Roanoke River, most of the land in the basin is
•
forested (71 percent), and the river and tributaries
are bordered by extensive floodplain forests.
Wetlands dominate the shoreline of the LRR OU-2,
with wetlands present
at over 90 percent of the banks in this 14-mile
reach.
The flow in the Roanoke River is highly regulated
by six dams and associated reservoirs have been
constructed on the river and its tributaries. The
closest dam to the Domtar facility is at Roanoke
Rapids, about 130 miles upstream of the Domtar
facility. This flow control is expected to continue
into the foreseeable future since the dam at Kerr
Lake was re-licensed in 2005 with a forty year
license time span.
The river is about 500 feet wide near the Domtar
mill. The maximum flow in the river in the study
area is about 20,000 cubic feet per second (cfs}.
However, flows are less than or equal to 6,600 cfs
about 53% of the time. The river bed in this area is
considered to be stable with little potential for
erosion.
Sampling Results
Samples were collected from wetland soil,
sediment, surface water, and fish and other biota in
the study area. The collection and testing of these
samples was performed as part of the Remedial
Investigation (RI).
Dioxin can be detected in samples from the
different media tested. However, the levels are
generally below calculated cleanup goals. Dioxin
levels from the LRR tend to be lower than levels in
Welch Creek, particularly in sediment. The
maximum detected level of dioxin in LRR shallow
sediment is about 0.170 ppb. Somewhat higher
concentrations can be found in deeper sediments.
Please see Table 1 for contaminant concentrations
by depth.
The dioxin levels in fish have been dropping over
the last 10-15 years. Fish consumption advisories
due to dioxin were lifted for sport fish in 2001.
Also, dioxin concentrations in catfish have declined
by tenfold or more between 1990 and 2007.
• Domtar (Formerly Weyerhaeuser) Site
Proposed Plan Fact Sheet
3
Fish tissue sampling is performed annually as a
condition of the mill's NPDES permit. In 2007, fish
were collected from 7 locations in the LRR study
area. A total of 22 composite fish samples were
tested. 21 of 22 samples contained dioxin TEQ
that was less than 1.5 ppt. The existing fish
Consumption advisories are based on dioxin levels
in fish of 3 ppt or higher.
The fish consumption advisories for bottom
dwelling fish like catfish and carp remain in effect.
People should continue to follow the fish
consumption advisories issued by the State of
North Carolina. Fish sampling results similar to the
2007 results will need to be achieved for several
years before the dioxin fish consumption advisory
for bottom dwelling fish ( catfish and carp) is
modified.
Mercury can also be detected in some of the
different samples tested. However, the levels are
generally within or below the calculated cleanup
goals for shallow sediment or wetland soil. Higher
levels of mercury can be found in some of the deep
river sediment samples adjacent to the mill. Those
sampling locations are covered by several feet or
more of cleaner sediment. Historic sources of
mercury at the paper mill (like the former chlorine
plant) have been addressed by previous cleanup
actions. However, atmospheric deposition of
mercury from various sources is an ongoing issue.
The State of North Carolina has issued statewide
guidelines to help people limit eating fish that have
higher levels of mercury.
The site studies also considered the potential for
the erosion and mobility of river sediment. Studies
by the USAGE and others indicate that there is little
potential for sediment to erode from the river
bottom. Soil and sediment from upstream areas
tend to settle in this area, leaving cleaner sediment
on top of older sediment containing higher levels of
dioxin or mercury.
SUMMARY OF SITE RISKS
Risk assessments were conducted to determine
the current and future effects of contaminants on
human health and the environment. As discussed
•
further below, the contaminant levels in the LRR
and adjacent wetlands do not present an
unacceptable risk to people based on direct
contact. However, low levels of dioxin in bottom
dwelling fish have resulted in fish consumption
advisories. Mercury in fish is a statewide issue
due to airborne deposition from various sources.
Human Health Risk Assessment
Exposure to contaminants in LRR Creek sediment
or the adjacent wetlands do not pose an
unacceptable risk to people. The risk assessment
considered the ways people could be exposed to
contaminants. The likely exposure pathways
included adult fishermen in contact with surface
water or eating affected fish, and visitors who could
be in contact with wetland soil or water, surface
water.
While the risk assessment calculations did not
indicate an unacceptable risk for people, including
an adult recreational fisherman, please note that
the State of North Carolina has issued notices
advising that people limit their consumption of
some fish from this area. EPA recommends that
people continue to follow the fish consumption
advisories that have been issued by State of North
Carolina. The advisory notes that catfish and carp
from these waters may contain low levels of
dioxins. Women of childbearing age and children
should not eat any catfish or carp from this area
until further notice. All other persons should eat no
more than one meal per month of catfish and carp
from this area.
Ecological Risk Assessment
The Ecological Risk Assessment (ERA) focused on
potential effects on animals due to ingestion or
contact with contaminants in wetland soil, sediment
and surface water.
Dioxin is passed along the food chain as small
insects and fish consume dioxin from shallow
contaminated sediment or surface water. Larger
fish, birds, or mammals then eat the insects or
smaller fish. This process is known as
• Domtar (Fom1crly Weyerhaeuser) Site
Proposed Plan F:ict Sheet
4
bioaccumulation. Dioxin can potentially impact
birds and mammals due to altered development in
embryos or reduced numbers and viability of
offspring.
The risk assessment evaluated the potential risk to
environmental receptors (birds, fish, otters, etc)
using conservative assumptions. The risk
assessment then presented a range of cleanup
goals for contaminants such as dioxin in shallow
sediment. The range of cleanup goals reflects
uncertainties in the risk assessment process that
may over or under estimate the potential for risk.
EPA considered the site specific reference criteria
and the range of site specific cleanup goals to
characterize the levels of dioxin and mercury in
river sediment. Measured dioxin concentrations in
shallow sediment had a maximum value of about
0.178 ppb and an average concentration of 0.037
ppb. These maximum and average dioxin
concentrations in sediment are already below
EPA's general dioxin cleanup value of 1.0 ppb as
well as within the range of calculated cleanup
goals (0.180 to 2.9 ppb}, indicating that an active
cleanup is not necessary.
Measured concentrations of mercury in shallow
sediment had a maximum value of 1.6 ppm and an
average value of 0.24 ppm. These values are
within the range of calculated cleanup values (0.37
to 45.3 ppm), indicating that an active cleanup is
not necessary. However, some additional
monitoring for mercury is included in the
alternatives considered for the LRR.
Measured dioxin concentrations in wetland soil had
a maximum value of about 0.22 ppb and an
average value of 0.058 ppb. These maximum and
average dioxin concentrations in sediment are
already below EPA's general dioxin cleanup value
of 1.0 ppb as well as within the range of calculated
cleanup goals for wetland soil (0.108 to 5.1 ppb),
indicating that an active cleanup is not necessary.
Measured concentrations of mercury in wetland
soil had a maximum value of 0.74 ppm and an
average value of 0.37 ppm. These values are
within the range of calculated cleanup levels (0.37
•
to 45.3 ppm), indicating that an active cleanup Is
not necessary.
The evaluation of potential risk to environmental
receptors focused on the uppermost (shallow)
sediments. Potential receptors have little
opportunity to contact or ingest deeper sediments.
In addition to the results from the RI and risk
assessment, EPA considered other lines of
evidence indicating improvements the LRR study
area over the last 15-20 years:
• Fish dioxin levels have declined since the
early 1990s. In October 2001, the State's
fish consumption advisory for dioxin was
lifted for sport fish. Dioxin levels in catfish
have declined by tenfold or more.
• Dioxin in wood duck eggs has declined by
almost five fold since the mid 1990s. A
recent study by the U.S. Fish and Wildlife
Service noted that there was no definitive
evidence of adverse impacts from dioxin
to wood ducks. Also, mercury levels in
wood duck eggs were well below levels
expected to cause adverse effects.
• Supplemental fine interval sediment
sampling which indicates that about 0.2 to
0.8 feet of cleaner sediment has been
deposited in the study area during the last
15 years.
SCOPE AND ROLE OF PROPOSED REMEDY
The proposed remedy will provide additional
documentation of the ongoing natural recovery in
the LRR. Long term monitoring will be performed
to evaluate the effectiveness of the remedy. In
addition, EPA will perform a review every five years
("five year review") as necessary.
It is the EPA's current judgment that the Preferred
Alternative identified in this Proposed Plan, or one
of the other monitoring programs considered in this
Proposed Plan, is necessary to protect public
health or welfare or the environment from actual or
• Domtar (Fonncrly Weyerhaeuser) Site
Proposed Plan Fact Sheet
5
threatened releases of hazardous substances into
the environment.
REMEDIAL ACTION OBJECTIVES
The Remedial Action Objectives (RAOs) for this
project include:
Reduce the dioxin concentrations in fish tissue
over time
Continue progress towards removal of remaining
fish consumption advisories in the LRR
Compliance with surface water standards minimize
potential adverse effects of remediation activities
on the existing environment/habitat.
REMEDIAL ALTERNATIVES
The following Remedial Alternatives were
developed and documented in the FS for the Site.
The FS focused on monitoring programs because
contaminant levels are already low enough that
active measures are not necessary at this time.
Alternative 1 -No Action
The No Action alternative is included in this FS, as
required by the NCP. This alternative provides the
baseline for evaluation of other alternatives. No
remedial action or additional monitoring is included
for the No Action alternative. The existing fish
consumption advisories would remain in effect.
Alternative 2 -Limited Action with Fish
Tissue Monitoring
Limited Action with Fish Tissue Monitoring includes
the fish monitoring associated with the NPDES
permit plus additional monitoring. This alternative
is based upon a preliminary monitoring plan with
the following components:
For the first 5 years, three species of fish (catfish,
bluegills, and bass) will be collected annually, if
possible. After 5 years, the monitoring may be
reduced to bluegill and bass only on a biannual
basis. Fish samples will be collected in the LRR
•
study area from locations similar to the locations
for the current NPDES fish fillet monitoring, plus a
reference location. Catfish fillet samples will be
analyzed for dioxin to continue the trend analyses
from the NPDES program. Whole bluegills and
bass will be analyzed for dioxin and mercury to
assess concentration trends and confirm the
conceptual model that mercury in fish tissue is not
site related, but likely the result of atmospheric
deposition.
Alternative 3 -Monitored Natural Recovery
Alternative 3 provides a limited response action
with MNR. MNR is a monitored sediment remedy
that relies on natural attenuation processes to
achieve the site-specific remediation objectives, as
compared to more active remedial approaches.
This alternative includes additional monitoring
when compared to Alternative 2. The monitoring for
this alternative includes three rounds of
confirmatory core sampling, annual dioxin sampling
for comparison to the North Carolina surface water
ARAR, fish tissue monitoring as described in
Alternative 2, and annual review of local habitat
conditions from documented sources. The purpose
of the additional data collection activities is to
provide multiple lines of evidence for evaluating the
remedy effectiveness during the first two 5-year
reviews.
These multiple lines of evidence will provide
additional confidence in the evaluation of remedy
effectiveness.
Specific additional sampling, inspection, and
review components include:
• Collect five fine-layer core samples (four
stations in the LRR OU-2 and one upstream
of Warren Neck Creek).
• Analyze approximately nine subsamples in
the top 4 to 6 inches for dioxin.
• Collect samples at years 1, 4, and 9 and
then reassess the need for additional
sampling.
• Sediment sampling for mercury as part of
year 1 monitoring (the need for additional
• Domtar (Fom1crly Weyerhaeuser) Site
Proposed Plan Fact Sheet
6
mercury sediment monitoring to be
determined)
• Collect three 1-liter surface water samples
for dioxin analysis annually (coincident with
fish tissue monitoring locations and
schedule).
• Annually inspect fish advisory signs
( coincident with fish tissue monitoring
locations and schedule).
• Annually review reports on local habitat
conditions such as USAGE summaries of
dam releases, NC DENR water quality
monitoring summaries, and overviews of
severe weather conditions (e.g., hurricanes
or extended droughts) that could adversely
impact biota habitats.
The alternatives described above provide an
estimate of the extent of the sampling programs.
The final sampling program will be subject to
agency review and approval.
As always in Superfund where some residuals
remain in the study area, the performance
monitoring program forms the basis for on-going
remedy evaluation and detailed remedy review at
5-year intervals.
COMPARATIVE ANALYSIS OF ALTERNATIVES
The alternatives were compared to one another
using various criteria and guidelines. The
comparative analysis considered potential positive,
negative, or neutral aspects of the various
alternatives. EPA also considers factors or
principles specifically for sediment sites such as this
project. Consideration of these principles is
generally contained within the following discussion
of the required nine criteria for Superfund projects.
The FS also provides greater detail about the
evaluation process.
The required nine evaluation criteria are discussed
in the following section.
Overall Protection of Human Health and the
Environment determines whether an alternative
eliminates, reduces, or controls threats to public
health and the environment through institutional
• •
Table I: Contaminant Concentrations in Sediment and Wetland Soil
Dioxin Concentrations in LRR sediment (units: u2:/k2: = nnb)
Depth Frequency of Minimum Maximum Average concentration
/inches) detection detected detected
0-6 40/40 0.0028 0.178 0.037
18-36 31/31 0.0047 0.355 0.037
60-72 515 0.0079 0.172 0.0455
Reference criteria /2x background) for dioxin in sediment:0.028 ug/kg
Mercury Concentrations in LRR shallow sediment (units: mg/kg= ppm) includes
sediment adiacent to Plvmouth mill nlus the LRR studv area
Depth Frequency of Minimum Maximum Average concentration
(inches) detection detected detected
0-6 24/51 0.1 1.6 0.24
Reference criteria (2x background) for mercury in sediment:0.68 mg/kg
Note: Onlv 3 of 51 mercurv results exceeded the reference criteria
Mercurv Concentrations in deeoer sediment in LRR studv area (units: m2:/ko1
Depth Frequency of Minimum Maximum Average concentration
/inches) detection detected detected
18-36 11/3 I 0.23 2.3 0.36
60-72 2/5 0.17 1.7 0.42
Mercury Concentrations in deeper LRR sediment adjacent to Plymouth Mill (units:
mi,fk.,)
Depth Frequency of Minimum Maximum Average concentration
(inches) detection detected detected
24-78 919 0.23 5.0 1.23
78-96 6/6 0.29 291 71.5
96-120 4/4 0.41 69.5 22.1
120-144 4/4 0.1 118 29.6
144-192 4/7 0.07 0.23 0.094
Dioxin Concentrations in LRR wetland soil !units: u /ka1
Depth Frequency of Minimum Maximum Average concentration
/inches) detection detected detected
0-6 16/16 0.0033 0.22 0.0586
Reference criteria(2x background\ for dioxin in wetland soil :0.023 u2:/ke
Mercurv Concentrations in LRR wetland soil !units: mr,Jk2:)
Depth Frequency of Minimum Maximum Average concentration
/inches) detection detected detected
0-6 6/14 0.52 0.74 0.37
Reference criteria !2x back2:round) for mercurv in wetland soil: 0.33mg/kg
DOMTAR
MARTIN COUNTY, NORTH CAROLINA
LOWER ROANOKE RIVER • O.U.-2
LOWER ROANOKE RIVER
AND SURROUNDING AREA
•
•
FIGURE 1
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controls, engineering controls, or treatment.
Alternative 1 only provides for the protection of
human health and the environment with
maintenance of the current fish advisories.
Alternative 2 provides some additional information
from the fish tissue monitoring while Alternative 3
provides the most long-and short-term protection
to human health.
Compliance with ARARs evaluates whether the
alternative meets Federal and State environmental
statutes, regulations, and other requirements that
pertain to the site. (ARARs = Applicable or
Relevant and Appropriate Requirements)
There is one chemical-specific applicable
requirement, the North Carolina Surface Water
Quality Standard for 2,3,7,8-TCDD. There have
been no ARAR exceedances based on the
stipulated sampling methods, so all three
alternatives are equal.
Long-term Effectiveness and Permanence
considers the ability of an alternative to maintain
protection of human health and the enJironment
over time.
The value of long-term monitoring to assess
remedy effectiveness is the primary factor
considered in this criterion. Alternative 1 is least
effective because no additional monitoring
information is available. Increasing levels of
monitoring information is available. Increasing
levels of monitoring adds to the overall remedy
effectiveness in Alternative 2. Alternative 3 is most
effective since multiple lines of evidence can be
used to assess the remedy.
Reduction of Toxicity, Mobility, or Volume of
Contaminants through Treatment evaluates an
alternative's use of treatment to reduce the harmful
effects of principal contaminants, their ability to
move in the environment, and the amount of
contamination present.
None of the alternatives have a specific treatment
component, and thus, are all considered
comparable.
• Domtar (Formerly Weyerhaeuser) Site
Proposed Plan Fac1 Sheet
7
Short-term Effectiveness considers the length of
time needed to implement an alternative and the
risks the alternative poses to workers, residents,
and the environment during implementation.
All three alternatives are based upon natural
deposition and have the same short-term
effectiveness.
Implementability considers the technical and
administrative feasibility of implementing the
alternative, including factors such as the relative
availability of goods and services.
No Action is easiest to implement; no adverse
implementation issues were identified for either
Alternatives 2 or 3.
Costs include estimated capital and annual
operations and maintenance (O&M) costs, as well
as present worth cost. Present worth cost is the
total cost of an alternative over time in terms of
today's dollar value. Cost estimates are expected
to be accurate within a range of +50 to -30 percent.
Total capital costs are direct and indirect costs
required to perform a remedial action. Direct costs
include construction costs or expenditures for
equipment, labor, and materials required to
implement the remedial action. Indirect costs
consist of engineering, permitting, supervising, and
other outside services required to implement the
remedial action. Certain contingencies have also
been included in the cost estimates to account for
unknowns, since the FS contains conceptual
designs. Performance monitoring and O&M cost
estimates were converted to present worth values
using a discount rate of 7 percent and a 30-year
post-closure period.
Alternative 1 has no additional costs since any
additional action or monitoring is performed.
Alternative 2 consists of limited monitoring only and
has the next lowest cost, approximately
$1,156,700. Alternative 3 (MNR), with even more
monitoring, has the highest total cost,
approximately $1,959,800.
0
State/Support Agency Acceptance considers
whether the State agrees with the EPA's analyses
and recommendations, as described in the RI/FS
and Proposed Plan.
EPA has consulted with NCDENR (North Carolina
Department of Environment and Natural
Resources) during the RI/FS for this project. State
acceptance of the Preferred Alternative will be
further evaluated after the public comment period
has ended and will be described in the Record of
Decision (ROD) for the Site.
Community Acceptance
Community acceptance of the preferred alternative
will be evaluated after the public comment has
ended and will be described in the ROD for the
Site.
SUMMARY OF THE PREFERRED
ALTERNATIVE
The preferred alternative is Alternative 3:
Monitored Natural Recovery with long term ·
monitoring for the Lower Roanoke River study area.
Domtar will be responsible for the long term
monitoring provided in the remedy; EPA will
continue to provide oversight of the project.
This alternative is recommended because
contaminant concentrations are not high enough to
require active cleanup measures. Also, dioxin
concentrations in fish and wood duck eggs have
been declining over the last 10-15 years. Sediment
in the riverbed is not likely to erode and cleaner
sediment continues to be deposited along the
riverbed.
Based on the information available at this time,
EPA believes the Preferred Alternative provides the
best balance of tradeoffs among the other
alternatives with respect to the balancing and
modifying criteria. EPA expects the Preferred
Alternative to satisfy the following statutory
requirements of CERCLA §121(b), which include
that the alternative would be protective of human
health and the environment, would comply with
ARARs, would be cost-effective, and would utilize
• Domtar (Fonner!y Weyerhaeuser) Site
Proposed Plan Fact Sheet
8
permanent solutions. The Preferred Alternatives
can change in response to public comment or new
information.
EPA provides information regarding the proposed
remedies for the LRR study area to the public
through Fact Sheets, public meetings, and the
Administrative Record file for the site. EPA and
the State encourage the public to gain a more
comprehensive understanding of the Site and the
Superfund activities that have been conducted at
the Site. Information regarding the public comment
period, public meeting and the locations of the
Administrative Record files, are provided on the
front page of this Proposed Plan.
For further information on the LRR project,
please contact:
Randy Bryant
Remedial Project Manager
[phone] or [phone]
e-mail: [e-mail]
or
Angela Miller
Community Involvement Coordinator
[phone] or [phone]
e-mail: [e-mail]
US EPA
61 Forsyth Street, SW
Atlanta, GA 30303-8960
• • Glossary of Terms
Administrative Record: Documents and data used in selecting cleanup remedies at NPL sites. The record is
placed in the information repository to allow public access.
ARARs: Applicable or Relevant and Appropriate Requirements. Refers to Federal and State requirements a
selected remedy must attain which vary from site to site.
Baseline Risk Assessment: A qualitative and quantitative evaluation performed in an effort to define the risk
posed to human health and the environment by the presence or potential presence and use of specific
pollutants.
CERCLA: The Comprehensive Environmental Response, Compensation, and Liability Act, otherwise known
as the Superfund Law.
EPA: U.S. Environmental Protection Agency
Information Repository: Data and documents related to Superjimd site placed near a site for the public.
Monitoring: The periodic or continuous surveillance or testing to determine the level of pollutants in various
media or in numerous plants and animals.
National Contingency Plan (NCP): The federal regulation that guides determination of sites to be corrected
under the Superfund program and the program to prevent or control spills into surface waters or other portions
of the environment.
Proposed Plan: A document that presents the preferred remedial alternative for a site to the public. The
proposed plan briefly summarizes the alternatives studied in the detailed analysis phase of the Rl/FS and
highlights the key factors that led to identifying the preferred alternative.
Record of Decision (ROD): A public document that explains which cleanup alternative will be used at an
NPL site and the reasons for selecting the alternative.
Remedial Investigation/Feasibility Study (RI/FS): Two distinct but related studies, nonnally conducted
together, intended to define the nature and extent of contamination at a site and to evaluate appropriate, site-
specific remedies.
Responsiveness Summary: A summary of oral and written comments received by EPA during a comment
period on a Proposed Plan and EPA's responses to those comments. The Responsiveness Summary is a key
part of the ROD, highlighting community concerns for EPA decision-makers.
Superfimd: Common name used for the CERCLA and for the Trust Fund which funds the program. The
Superfund program was established to oversee the cleanup of hazardous waste sites.
ARARs
CERCLA
coc
eMNR
EPA
FS
NCDENR
NPDES
NCP
PRPs
RAO
RD
RI/FS
ROD
• •
List of Acronyms
Applicable or Relevant and Appropriate Requirements
Comprehensive Environmental Response, Compensation and Liability
Act
Contaminant of Concern
Enhanced Monitored Natural Recovery
United States Environmental Protection Agency
Feasibility Study
North Carolina Department of Environment and Natural Resources
National Pollutant Discharge Elimination System
National Oil and Hazardous Substances Contingency Plan
Potentially Responsible Parties
Remedial Action Objective
Remedial Design
Remedial Investigation/Feasibility Study
Record of Decision
• •
USE THIS SPACE TO WRITE YOUR COMMENTS
Your input on this Proposed Plan for the LRR study area is important to EPA. Comments provided
by the public are valuable in helping EPA select a final cleanup remedy for the site. You may use
the space below to write your comments. Comments must be postmarked by August 11, 2008. If
you have any questions about the comment period, please contact Randy Bryant at (404) 562-
8794 or through EPA's toll-free number at 1-800-435-9233. Those with electronic communications
capabilities may submit their comments to EPA via Internet at the following e-mail address:
bryant.randy @epa.gov.
Comments may also be mailed to:
Randy Bryant
SD-SRSEB
US Environmental Protection Agency
61 Forsyth Street, SW
Atlanta, GA 30303
--.
/
• ·--
Superfund Remedial and Site Evaluation Branch
Angela Miller, Community Involvement Coordinator
Randy Bryant, Remedial Project Manager
U.S. Environmental Protection Agency
61 Forsyth Street, SW
Atlanta, GA 30303-8960
Official Business
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Mr. Nile Testerman, State Project Mgr.
Superfund Federal Remediation Branch
NC DENR
401 Oberlin Rd, Suite 150
Raleigh, NC 27605
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• •
SUPERFUNDFACTSHEET
WEYERHAEUSER WOOD TREATING PLANT
· MARTIN COUNTY, NORTH CAROLINA
INTRODUCTION
This fact sheet notifies you of the
upcoming start of the cleanup for the
Old Landfill # 1 (Operable Unit One) at
the Weyerhaeuser facility in Plymouth,
NC. The fact sheet also describes the
status of other operable units at the
facility . EPA is issuing this fact sheet
as part of its community outreach efforts
under the Comprehensive
Environmental Response,
Compensation, and Liability Act
(CERCLA), also known as Superfund.
The Weyerhaeuser pla!:t is an active
facility which has been in operation
. since 1937, and has been owned by
Weyerhaeuser since 1957. It is one of
the largest paper mills in the ·eastern
United States. Weyerhaeuser has been
working with EPA to evaluate historical
waste management activities and
associated environmental impacts.
CLEANUP FOR OLD LANDFILL #1
The final cleanup for Operable Unit One
(old landfill#!) at the Weyerhaeuser
facility in Plymouth, NC will soon
begin. Weyerhaeuser used this landfill
from the mid-1950s until the early-1980s.
mainly for the disposal of bark, sawdust,
lime grits, and waste paper. In 1981, ·
Weyerhaeuser was permitted to close
and cover the landfill using wastewater
solids from its settling.ponds. During
the more recent sampling studies, the
APRIL2005
cover material was found to contain
dioxin, and metals such as chromium,
lead, mercury, selenium, and vanadium.
The remedy is mainly intended to reduce
the potential risk to animals and birds
from exposure to dioxin and metals.
The old landfill does not pose an
unacceptable risk to people based on
current and expected future use of the
property ..
The cleanup includes the installation of
a geotextile and a one foot layer of soil
or gravel over the entire landfill which is
about 83 acres in size ( instead of 97
acres us wus originally described). This
method of cleanup was selected in
September 2002 after a public meeting
and comment period. Since then,
several events have occurred:
-EPA and Weyerhaeuser negotiated a
Consent Decree
-additional soil sampling was done to
better define the extent of the landfill,
-the remedial de~ign and associated
planning documents we.re completed
The actual construction for Operable
Unit One will begin late April and is
expected to last about six months. The
· first significant task will be grading or
reshaping the surface of the landfill, ·
followed by placement of the geotextile
and finally the soil/gravel cover. The
soil for the cover will be excavated from
a nearby property that is adjacent tci the
Weyerhaeuser property. Dump trucks·
will travel a short distance on the
•
Weyerhaeuser construction entrance
road as they deliver the clean soil to the
Site (see Figure 1 ).
Long-term monitoring of groundwater ·
near the old landfill and soil in the
adjacent wetlands will be performed as
part of the remedy. Deed restrictions
will also be put in place to control future
use of the landfill.
ST A TUS OF OTHER OPERABLE
UNITS AT WEYERHAEUSER
Operable Unit Three {former chlorine
plant): The design for this remedy will
be completed during 2005 and the .
cleanup is scheduled to start in early
2006.
The former chlorine plant operated from
I 951 to I 968 and generated chlorine and
sodium hydroxide from salt brine.
Mercury cells were used in the
production process. The building was
used for storage and equipment
maintenance until 1984. The building
was demolished in 1987. During the
early 1990s, the building foundation,
associated drain pipes, and soil (to a
depth of 4 feet) were removed.
This final cleanup for the former
chlorine plant will focus on the
remaining mercury contamination below
ground and includes the installation of
sheet pile to surrou_nd the contaminated ·
soil. The sheet pile will encircle an area
of a little more than one-half acre and
extend underground to a depth of about
45 feet and rest in a layer of clay. There
will also be some limited excavation and
disposal of subsurface soil in two small .
areas outside of the sheet pile
,. ..... •
containment area. The excavated soil
will be tested to determine if it can be
disposed in the facility's permitted
operating landfill or if it has to be sent
off-site for treatment/disposal. The
areas disturbed by either installation of
the sheet pile or excavation of soil will
be covered with concrete or asphalt to
match existing conditions. Long term
groundwater monitoring and deed
restrictions are also included in this
remedy. The remedy is intended to
prevent the migration of mercury in soil
to groundwater outside of the sheet pile
containment area. The area of the
former chlorine plant does not pose an
unacceptable risk to people based on
current and expected future use of the
property.
This cleanup method was selected in
September 2003 after a public meeting
and comment period. Since then; EPA
has negotiated a separate Consent
· Decree for this operable unit and the
remedial design is in progress.
Operable Unit Two {Lower Roanoke
River): Wastewater from the Site w_as
discharged to the River from. I 93 7 to
I 957 when the Site was operated by
Kieckhefer-Eddy. Weyerhaeuser has
discharged treated wastewater to the
River since I 988 pursuant to a NPDES
permit. Plant improvements completed
around 1992 have reduced the amount of
dioxin in the treated discharge. EPA has
. conducted sampling and a risk
assessment for the lower Roanoke River.
Dioxin is present in river sediments, but·
at lower levels than found in Welch
Creek. The dioxin in sediment does not
pose a threat to people based on current
exposures, but it does contribute to the
dioxin found in some fish.
~ .,,,--✓--✓
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<1000 ---SCALE1 I"• 2000'
•
WEYERHAEUSER PAPER'COMPANV
PL VMOUTH, NORTH CAROLINA .
FORMER LANDFILL No. 1 AREA
FINAL REMEDIAL DESIGN
PROPOSED .BORROW AREA
AND HAUL ROUTE
SOURCE: RMT, INC.
FIGURE 1
•
However, dioxin levels in fish from
Welch Creek and the Lower Roanoke
River have generally been dropping
since the early 1990' s. A fish
consumption advisory regarding sport
fish was lifted in October 200 I by the
NC Department of Health and Human
Services. However, a current fish
advisory regarding catfish and carp is
still in effect. The advisory notes that
wom~n of childbearing age and children
should not eat any catfish or carp from
this area until further notice. All .other
persons should eat no m,ore than one
meal per person per month of catfish
and carp from this area.
Operable Unit Four (Welch Creek): Site
investigations and evaluations continue
for this operable unit. Wastewater (from
bleached paper production) was
discharged to Welch Creek from 1957
~ntil 1988. The dis-::ha~ges to Welch
Creek were permitted by the State of
North Carolina in 1969 and a later
NPDES permit in 1975. Wastewater
solids, which Cilntain varying levels of
dioxin, are pre~ent along the bed of
certain stretche:; of the Creek and in
some of the adjacent wetland soils.
Exposure to sediment or soil does not
pose an unaccept1ble risk to humans.
There may be some risk to birds and
animals if they consume sediment/soil or
fish containing dioxin.
A feasibility study (F:S) is underway that
will evaluate diff:,rcrit possible remedies
such as monitored-n:.ttural recovery,
capping, dredging,;11·, ~ome
combinations of t:10;1,';ilternatives. The
FS will evaluate th~.,i'iJ\ential positive
and negative inpac,f.',,fthe different
alternatives. E.PA wf, continue to
· coordinate witb other 1',!d-~ral and state
' ' I> I
•
agencies to evaluate these alternatives
and will seek public input before making
any cleanup decisions.
Weyerhaeuser has recently completed
the fieldwork for small scale testing of
dredging techniques and different
capping methods for sediment in Welch
Creek. The tests areas had a maximum
size of approximately I 00 feet by I 00
feet and were performed in an area of
the highest dioxin concentrations in
sediment. The results from these tests
will the.n be used in. the FS to evaluate
the potential positive and negative
impacts of the alternatives. The FS may
be completed by mid-2006.
CONT ACT INFORMATION
For further information regarding the
Weyerhaeuser Site, please contact:
R,andy Bryant
Remedial Project Manager
[phone] or [phone]
Angela Miller
Community Involvement Coordinator
[phone] or [phone]
You may also visit the information
repository at two locations: ·
Washington Co~ty Public Library
3,d and Adams Streets
Plymouth, NC 27962
(252)793-2 I 13
EPA Record Center, I J'h Floor
61 Forsyth Street, SW
Atlanta, GA 30303-3104
( 404 )562-8946
11 1 ! \ l l -· • L
MAILING LIST ADDITIONS/CORRECTIONS
If you would like your name and address placed on the mailing list for the Weyerhaeuser Superfund Site, please
complete this form and return to Angela R. Miller, EPA, 61 Forsyth Street, SW, Atlanta, GA 30303.
NAME: ---------------------------'--
ADDRESS: ------~----------~--------
TELEPHONE# (optional): __________ _
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__ There has been a change in my address
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United States
Environmental
Protection Agency
Official Buslnru
Ptnalty ror Privatr Ust
SlOO
SUPERFUND REMEDIAL AND SITE EVALUATION BRANCH
Angela Miller, Community lnvolv~ment Coordinator
MR NILE TESTERMAN, STATE PROJECT MGR.
SUPERFUND FEDERAL REMEDIATION BRANCH
NC DEPT. OF ENVIRONMENT & NATURAL
RESOURCES
1645 MAIL SERVICE CENTER
' RALEIGH NC 27699
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HASLER $0.37
-~-Region 4 APR 07 2005 g6l1f.orsyth Street
At11i~~i,,&'gia 30303 US POSTAGE
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011A0413001152
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RECORD OF D~ISI N FACT SHEET
WEYERHAEUSER WOOD TREATING PLANT
FORMER CHLORINE PLANT AREA
•
. •·
MARTIN COUNTY, N.C.
~eptember 2003
This fact sheet has been prepared to provide the public with more detailed information about the treatment remedies selected in the Record of
Decision for the Weyerhaeuser former chlorine plant area.
BRIEF SITE UPDATE
The Weyerhaeuser facility is an active wood and
paper products manufacturing facility located on
about 2,400 acres, about 1.5 miles west of the town
of Plymouth, in Martin County, NC. Weyerhaeuser
has been the owner/operator of this facility since
1957, after merging with Kieckhefer-Eddy Corp.
which began operation at the site in 1937.
The area of action for this Record of Decision is
the Former Chlorine Plant area which is
approximately 3 acres in size, located adjacent to
the Roanoke River in an active manufacturing area
of the plant. The chlorine plant was built in 1951
and operated until 1968. Operations involved the
production of chlorine and sodium hydroxide from
salt brine. Twelve mercury cells, containing
metallic mercury, were used in the production
process. Process equipment was removed from the
chlorine plant between 1968 and 1978. The
building was then used for storage and equipment
maintenance until 1984. The building was
demolished in 1986/87. In 1992, the building slab,
footings, u-shaped concrete i
drain, tank foundations and surrounding soil down
to the water table were removed. This area was
backfilled with soil and concrete, and paved with
asphalt.
Findings of the Remedial Investigation indicated
mercury was present in subsurface soils beneath the
former building footprint and the central and
eastern u-drain trenches of the former chlorine
plant. In addition, metallic mercury, in its liquid
form, was observed as beads in several soil
samples. Groundwater mercury levels followed a
similar pattern as the soils.
EPA conducted a Proposed Plan public meeting on
July 10, 2003, where various possible actions were
explained that could tie used to address mercury
contamination in the soil and groundwater. The
public comment period ended on August 1, 2003.
After reviewing all public comments and technical
data, a remedy was selected and documented in the
Record of Decision (ROD) which was signed by
the EPA Regional Administrator on September 29,
2003. The following remedy was selected:
Containment with Groundwater Compliance and Trend Monitoring -This remedy provides
for protection of human health and the environment by reducing the migration of mercury from
soils into groundwater and the Roanoke River. In addition, the containment system will reduce
the risk of a sudden release of the large quantity of mercury remaining in site soils. Institutional
controls/deed restrictions limiting the use of the former chlorine plant area and the groundwater,
will limit exposure to mercury contamination on Site. A groundwater monitoring system will be
installed to ·ensure that mercury in groundwater is not causing negative impacts to the river,.or
migrating toward a drinking water source. The Monitoring program will also evaluate the
stability of the groundwater plume, groundwater mercury concentrations and movement, and
evaluate the qroundwater'for evidence of coolinq tower leakaqe.
Page -1-
• This alternative involves the following major
components:
► Land use restrictions
► Surface cap containment system-··
► Cooling tower repair·. , ... ,
► Barrier wall
► Shallow "target area" excavation
► Grouridwatercompliance and trend moni!oring
Land use restrictions -would prohibit the .
placement of potable wells within the source area,
and would be recorded on the property deed.
Surface cap containment system -surface
pavement cover in unpaved areas and pavement
repair in currently paved areas will decrease the
infiltration of precipitation through impacted soil
and thereby reduc_e the movement of aqueous
mercury.
Cooling tower repair -Leaking cooling towers in
the area influence groundwater flow by causing a
mounding which redirects some flo,)'.V to the south-
southeast before the groundwater eventually takes
on the normal flow and discharges.to the Roanoke
River. This situation will be repaired in order to
eliminate the influence on groundwater flow.
Barrier_ Wall -Various types of barrier walls can be
utilized for the containment of mercury
contaminated soils in the Former Chlorine Plant
footprint area. Options range from slurry walls to
geomembranes to driven sheet pile barriers. The
• .enclosed by the barrier. The barrier would almost
eliminate the amount of mercury that could get into
groundwater and move out of the containment area.
"Target area" excavation -There are two areas .
that need to be excavated. These target areas
include excavation of both saturated and
unsaturated soil. The excavations will extend to the
horizontal and vertical limits near the former
hypochlorite tank and along the eastern U-drain.
These excavations will remove surface soil with
mercury concentrations at levels of concern for
direct exposure as well as deeper soil to achieve the
groundwater levels to meet North Carolina and
Federal standards. The areas targeted for
excavation rather than containment are less than two
feet in depth and it would be impracticable to install
a barrier wall. The target areas are located
immediately adjacent to plant operations. These
areas would need to be protected by sheet piling·
being driven between 20-25 feet around Target Area
I and 2. The non-hazardous excavated soil can
either be disposed of in the on-site landfill.or sent to
an off-site non-hazardous landfill. The soil
containing hazardous materia,I will be sent to an off-
site retort facility where it would be processed to
recover and recycle the mercury. Whereas, the soil
within the barrier wall containment area would
remain fixed within the set boundaries. Since some
of the soil to be excavated is below the water table,
fly ash will be added to absorb the water prior to on-
site landfill disposal or off-site management. The
excavated areas will be backfilled with clean fill
exact type of barrier wall will be determined during material.
the Remedial Design phase. The following
description is provided to give you an idea of what Groundwater compliance and trend monitoring
the wall might be like. The wall enclosirig the outside the containment area -To assess the
source area is assumed to consist of a sealed/low mercury concentration trends in groundwater, this
permeability barrier (i.e. metal sheet piling) action would require the implementation of a
installed to approximately 45 feet below the ground groundwater compliance and trend monitoring
surface, tying into a thick clay layer beneath the Site program to evaluate remedial progress, i.e.,
which prevents movement of liquid. The compliance concentrations and containment
conceptual sealed barrier wall has a total length of · · •'effecti vehess. · This program would consist of
610 feet and would enclose an area approximately"' regularly scheduled sampling until clean up goals
23,000 square feet and a volume of approximately , :are achieved. ,Jt is.estimated that samples would be
38,000 cubic yards of soil. It is estimated that collected from 12 existing wells, and that
approximately 7,200 pounds of'mercury will be, monitoring would be conducted annually for 30
Page -2-
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years. This routine would be regularly evaluated to
make needed adjustments as to the number of.wells
sampled and the frequency of sampling. With this
remedy, the·movement of mercury from the•Former
Chlorine Plant area·to the Roanoke River is : ·
estimated to decrease-94%. ' ,
The estimated totaf costs to implement this remedy
are $5,010,000 (capital cost) and $614,000 (O&M
cost), for a total net present value cost (over 30
years) of $5,624,000.
A Five-year review of the remedy will be conducted
in 2008 because contaminants remain on-site.
Where can you obtain more information?
'
Copies of documents developed during the
Remedial Investigation, Feasibility Study and Risk
Assessment have been placed in_ the Information
Repository files located in the:
Washington County Public Library
3•• and Adams Streets
Plymouth, NC 27962
919-793-2113
and
EPA Recore\ Center, ll'h Floor
61 Forsyth Street, SW
. Atlanta, GA 30303,310ft .
. 404-562-8946 .
Who can you contactif you have questions? ~ ·
If you have technical questions about this Site,
please contact:
Jennifer Wendel, EPA Project Manager
Randy Bryant, EPA Project Manager
404-562-8799 or 1-800-435-9233
If you want general information or additional copies
of this fact sheet, please contact:
Diane Barrett, Community Involvement
Coordinator
404-562-8489 or 1-800-435-9233
USEPA, Region 4
61 Forsyth Street, SW
Atlanta, GA 30303-3104
➔➔ANNOUNCEMENT: Jennifer Wendel has taken a new position within EPA and will no
longer be the Project Manager for this Site effective September 30, 2003. The new Project Manager
· is Randy Bryant. He can be reached at the toll free number or 404-562-8794. +-+-
MAILING LIST
If you are not on our mailing list and would like to receive future information on the Weyerhaeuser Site,
or if you have a change of address or.want your na_me removed from the mailing l\st, please complete this
form and return to Diarie Barrett, Community Involvement Coordinator, at the above address.
NAME-------,------,-------,------------------
ADDRESS_~---'-~-,-------:---------------___;___; __
CITY, STATE, ZIP CODE,:.,.·--..,..,..,.-,--'-,-------'---,--------------. . '
PHONE NUMBER--'------~-E-MAIL _____________ _
Change of Address o
Page -3-
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Region4
•
U.S. Environmental Protection Agency
61 Forsyth Street, SW
Atlanta, Georgia 30303-3104
•
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Wastetllanagement Division I:"'""~~ HAs,.s $0.37
Randy Bryant, Site Remedial Project Mana~ • OCT 16 2003
;e, • US POSTAGE
Diane Barrett, Community Involvement Co.
W h S·t FIRST CLASS ■----■-•e_.y:.;e;;;r,;,;;;a.e.u.s.e.,r,_1.,e ... ------------~---------~~~!!"~!!'i,s.~-------■ • l ~
Official Business
Penalty for Private Use $300
S/F
MR. DEXTER MATTHEWS, DIRECTOR
• t DIVISION OF WASTE MANAGEMENT
NC DEPT. OF ENVIRONMENT & NATURAL
RESOURCES
401 OBERLIN ROAD, SUITE 150
RALEIGH NC 27605
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S~RFUND PROPOSED .. AN FACWSHEET
Weyerhaeuser Company Plymouth Wood Treating Plant
Former Chlorine Plant Area
Region 4 Plymouth, Martin County, North Carolina
June 30 2003
This fact sheet is not considered as a technical document, but has been prepared for the general public to provide a better
understanding of the proposed activities at the Weyerhaeuser Company Site. Words appearing in bold print are defined in
a glossary at the end of this publication.
INTRODUCTION
This Proposed Plan identifies the preferred options
for cleaning up contamination associated with the
Former Chlorine Plant Area of the Weyerhaeuser
Company Plymouth Wood Treating Plant Sitenear
Plymouth, Martin County, North Carolina. This
document is being issued by the U.S.
Environmental Protection Agency (EPA), the lead
agency for Site activities,. and the North Carolina
. Department of Environment, and Natural
Resources (NC DENR); the support agency.
Weyerhaeuser Company, in consultation with EPA
and NC DENR, conducted the Remedial
Investigation {RI) and Feasibility Study (FS). A
remedy for the Former Chlorine P!ant A.rea will be
selected only after the public comment period has
ended and all information submitted to EPA during
this time has been reviewed·and considered.
EPA is issuing this Proposed Plan as part of its
public participation responsibilities under Section
117(a) of the Comprehensive Environmental
Response, Compensation and Liability Act
CERCLA), also known as Suoerfund.
This document summarizes information that is
explained in greater detail in the RI/FS reports and
other documents contained in the Information
Repository/Administrative Record for this Site.
EPA and the State encourage the public to review
these documents to better understand the Site and
Superfund activities that have been conducted.
The Administrative Record is available for public
review locally at the Washington County Public
Library.
EPA, in consultation with NC DENR, may modify
the preferred alternative or select another response
action presented in this Plan and the RI/FS reports
based on new information and/or public comments.
Therefore, the public is encouraged to review and
comment on all alternatives identified here.
THIS PROPOSED PLAN:
1. Includes a brief history of the Site and the
principal findings of Site investigations;
2. Presents the alternatives for the Site
considered by EPA;
PUBLIC MEETING
WHEN: July 10, 2003
WHERE: First Baptist Church
309 Washington Street, Plymouth, North Carolina
TIME: 7:00 PM -9:00 PM
PUBLIC COMMENT PERIOD: July 2, 2003-August 1, 2003
1
3. Outlines the criteria u. by . EPA . to
recommend an alternative se at the Site;
4. Provides a . summary of the analysis of
alternatives;
5. Informs the public that the EPA is proposing to
issue a Record of ,Decisio.n (ROD) for the ,
Site; and . · ·
6. · Explains the opportunities for the ·public to
comment on the remedial alternatives.
SITE BACKGROUND
The Weyerhaeuser facility is an active wood and
paper products manufacturing facility located just
outside of the city limits of Plymouth in Martin
County, North Carolina. Current operations include
the production of fluff paper, paper, paperboard
and finished lumber. Weyerhaeuser has been the
owner/operator of this facility since 1957, after
merging with the Kieckhefer-Eddy Corporation,
which began operation at the site in 1937. The
facility is located on about 2,400 acres, about 1.5
miles west of the town of Plymouth. The Former
Chlorine Plant Area is approximately 3 acres in
size, located adjacent to the Roanoke River in an
active manufacturing area of the facility. A steel
sheet pile seawall (bulkhead) forms· the eritire
northern boundary with the River in this part of the
facility. The area is primarily covered with asphalt
and concrete pavement. Figure 1 shows the
approximate location of the Former Chlorine Plant
Area.
The Former Chlorine Plant was built in 1951 and
operated until 1968. Operations involved the
production of chlorine and sodium hydroxide from
salt brine. Twelve mercury cells, containing
metallic mercury, were used in the production
process. Process equipment was removed from
the Former Chlorine Plant building from 1968-1978.
The building was then used for storage and
equipment maintenance until 1984. The building
was demolished in 1986 and 1987. In 1992, the
building slab, footings, a U-shaped concrete drain
(the central U-drain), tank foundations and
surrounding soil down to the water table
(approximately 4 feet) were removed. The
excavation was backfilled with soil and concrete
and paved with asphalt. Soil samples were
collected from the base of the Former Chlorine
2
Plant excava,Aat the completion of the soil
removal. MeWy concentrations in the soil
not excavated ranged from 9,520
milligrams/kilogram (mg/kg) to less than 0.2
mg/kg. An additional U-shaped drain (the
eastern U-drain) was identified during the •
Remedial Investigation planning. ,This area ..
was sampled during the RI and will be
::· dis.cussed below. ·
. The RI for. the For.mer Chlorine Plant Area
was conducted in. response to an
Administrative Order on Consent (AOC)
and the attached Statement of Work
(SOW) issued by the EPA. Individual RI
work a17d reports have been prepared for
each of the three areas identified in the
AOC, Landfill No. 1, the Former Chlorine
Plant Area, and Welch· Creek. These
focused investigations were conducted in
order to streamline the investigation and
remedy selection process. EPA plans to
issue a ROD for each of the three areas of
the site. The Roanoke River is being
investigated by EPA as a Superfund -lead
project. The .results of the Roanoke River
investigation will be published in an RI report
to be issued in July, 2003.
RESULTS OF THE REMEDIAL
INVESTIGATION
The RI involved the installation of 23 soil
borings in the footprint of the Former
Chlorine Plant and the central and eastern
U-drains, and the installation of 32
groundwater monitoring wells at 16 locations
and at . three depths. Samples were
collected and analyzed for total mercury and
methyl-mercury. Forty (40) sediment
samples were collected from 10 locations in
the Roanoke River. The field activities were
conducted in two phases: from February to
May 1999, and in October 1999. The first
Draft of. the RI report was received in
February 2000. After revision, the Final RI
report was approved in February, 2001.
Mercury was detected in subsurface soils
beneath the former building footprint and the
central and eastern U-drain trenches of the
Former Chlorine Plant. Both mercury and
methyl mercury were detected at depths
•
•
i ml m
•
'.l
• •
3
' I
, ... j
•SDI.CNRD'
FIGURE 1
. WEYERHAEUSER COMP.mY
SITT i.UCATOR IIAP
R£11EOIAL INVESTIGATION
w.RTIN COUtllY, NORTH CAROU~
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I
exceeding 40 feet. The highe.tected leve.1 of
mercury was 45,800 mg/kg. ln"lll'dition, metallic
mercury, in its liquid form, was observed as beads
in several soil samples. The occurrence and
concentration of mercury decreases with depth and
distance from the Former Chlorine Plant building
footprint. The total estimate of-the quantity of
m·erc·ury in the soil is approximately 7,490.pounds.
Approximately 95% of the mass of total·mercury is
associated.-with concentrations· above 100 mg/kg,
and approximately 98% of the mercury-containing
soil is located above 26 feet. Methyl mercury was
analyzed for because this form of mercury is more
bioavailable (more available for uptake by
organisms). The highest level of methyl mercury
detected was 0.206 mg/kg. As discussed later in
the risk assessment section of this fact sheet, the
methyl-mercury detected at the site was not found
to contribute to an increased risk at the site.
Outside of the building footprint, with the exception
of the U-drains, mercury levels in the soil were
similar to background.
Groundwater mercury levels followed a similar
pattern as the soils. The highest cc:mcentrations of
mercury in groundwater were present in the shallow
groundwater and co-located with areas of highest
soil concentrations. In the shallow portion of the
groundwater, 6 of 13 wens had mercury levels
which exceeded the North"Carolin·a drinking water
standard of 1.1 micrograms/liter (ug/L). The
highest level of mercury detected in groundwater
was 116 ug/L. Of the 16 wells screened at deeper
intervals, none . had mercury levels . detected
exceeding the North Carolina Standard. Methyl
mercury was also detected in groundwater in the
Former Chlorine Plant Area, and was correlated to
the concentrations of total mercury detected.
Methyl mercury analysis was performed because it
is more readily transported in groundwater and, as
dis.cussed above, is more bioavailable. · The
highest level of methyl mercury detected was 1.68
ug/L.
Groundwater originating beneath the Former
Chlorine Plant travels to the north and west, toward
the bulkhead and the Roanoke River. In addition,
leaky cooling towers in the area influence
groundwater flow by causing a mounding which
redirects some flow tc'l:the south-southeast before
the groundwater eventually takes· on the normal
flow ·and· discharges to the .River.. Groundwater
flowing toward the Roanoke River may enter the
4
river throu~aks in the sheet pile
bulkhead, o7'll!!'Jst of· the bulkhead. The
averages of data from the mercury levels
found in groundwater during the RI were
used to estimate the .total mass of mercury
being released to the Roanoke River
through the groundwater.-The combined
mass of· mercury being· discharged to the
. ;-,-,•,,_River by groundwater.is_ estimated to be.just
,0.012 pounds per year. ·
Within the Roanoke River, sediment core
samples were collected at 1 O locations, with
4 samples taken at each location to an
average of 1 O feet. The sediment samples
were analyzed for both mercury and methyl
mercury. The highest mercury concentration
found was 291 mg/kg; however, this sample
was obtained from a depth of 7 feet, which
indicates it may not be available for
exposure. The actual concentration of
methyl mercury in the sediment was
generally proportional to the concentration of
total mercury and the highest detected level
was 0.055 mg/kg. EPA Region 4 has ·
established screening values for sediments
which are protective of ecological receptors.
The screening value for mercury is 0.13
mg/kg. If this screening value is exceeded,
it usually indicates the need for additional
site specific risk analysis. EPA has
conducted a human health and an ecological
risk assessment for the Roanoke River as a
separate investigation, and these results are
discussed further in this fact sheet.
Mercury was not detected in pore water
samples, water within the sediments.
Methyl mercury was detected, but at very
low levels.
For more information on the results of the
RI, please refer to the RI report available for
review in the Washington County Public
Library.
SUMMARY OF SITE RISKS
,I The RI" report-analyzed and estimated the
. human· health or environmental problems
·.·.·:,';'that could result-if:ccontamination ·at,the
Fo"rmer Chlorine· Plant Area':is -not-cleaned
' · up. This analysis is called a baseline risk
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assessment. In addition, Aparate study was
done by EPA as part of'llll!P!'e Roanoke River
investigation to determine the effects on ecological
receptors. This study is called the baseline
ecological risk assessm,ent (BERA).
·'
Human Health Risk Assessment
·in conducting the human:health risk· assessment,
EPA focused on the human health effects that
could result from incidental ingestion and/or contact
with contaminated soil and groundwater in the
Former Chlorine Plant Area. Given the location of
the Former Chlorine Plant Area, human populations
that may potentially be exposed to contaminants
are limited to construction and industrial workers.
The baseline risk assessment determines the
adverse health effects. that could result from long-
term (30 years) exposure to mercury at the site.
Shallow groundwater in the vicinity of the Former
Chlorine Plant is not currently used for drinking
water. Therefore, risk caused by groundwater
ingestion by human receptors was not evaluated.
However, the State of North Carolina considers all
groundwater to be potentially drinkable. Therefore,
mercury levels in groundwater were compared to
the State drinking water standards.
In calculating risks to ·a population if no remedial
action is taken, EPA evaluates the reasonable
maximum exposure levels to Site contaminants for
current and future exposure scenarios . Scenarios
were developed for the industrial worker and the
construction worker. The pathways of possible
exposure for these workers were assumed to be
ingestion of contaminated soils, dermal contact with
contaminated soils, inhalation of contaminated
soils, and for the construction worker only, dermal
contact with contaminated groundwater.
Mercury and methyl mercury are not known to be
cancer causing chemicals. However, EPA has
established acceptable maximum limits for excess
lifetime non-carcinogenic-risk. The non-
carcinogenic risk of a specific contaminant is
expressed as a Hazard Quotient (HQ). Because
toxicity information .for mercury is not available,
EPA uses mercuric chloride toxicity information
when determining the HQ for mercury. , Hazard
Quotients for indiyidual contaminants are summed,
where. appropriate, to. calc.ulate the Hazard Index
(HI). For the pathways evaluated, the Hi's are
5
added to.er to calculate a total site HI. A
total sit I of greater than 1 (HI> 1)
indicates that there may be a · potential
hazard at the site.
The total Hazard Indices for the industrial
worker under current and hypothetical future
land . use conditions, representing a
re·asonable. maximum exposure,·(RME)
and central tendency (average) exposure
· assumptions were less than 1. , For, the·
construction worker, the . central
tendency/average exposure assumptions
resulted in a Hazard Index less than 1, but
the RME assumptions resulted in a Hazard
Index greater than 1 (2.3).
Due to the heavily industrialized setting of
· the Former Chlorine Plant Area, and given
that the area is predominantly paved, on-site
exposure to ecological receptors in the
Former Chlorine Plant Area is minimal. As
a result, an ecological risk assessment was
not performed for the Former Chlorine Plant
Area. However, potential human and
ecological receptors associated with the
Roanoke River that may be exposed to
mercury in sediment or in the surface water
were assessed by EPA as part of its
Remedial lnvestigaiion of the Roanoke
River. The RI for the Roanoke River
calculated a level of measurable effects to
ecological receptors for mercury
contamination . in sediments. The RI
concluded that the Lowest Observed
Adverse Effects level for exposure to
mercury in sediments ranged from 0.31
mg/kg for the Green Heron to 2.41 mg/kg for
the Wood Duck. Exposure is usually limited
to the very top layers of sediment. Samples
taken in the top 0-6" of the River sediments
adjacent to the Former Chlorine Plant Area
range from 0.11 mg/kg to 0.77 mg/kg. As
detailed earlier, the highest levels of
sediment contamination were found below 6
feet deep.
REMEDIAL ACTION OBJECTIVES
Remedial Action Objectives (RAO) were
developed based on the results of the risk
assessments, and the examination · of
potential -applicable or relevant and
appropriate requirements (ARA!ltl), Chemic!l,1-,
action-, and location-specifi~RARs were
examined.
For the Former Chlorine Plant Area groundwater
the Remedial Action Objective is: .. , .. ;,, \
Total Mercury ., '. 1.1-ug/L . . .
• .-•. : •, .":' '. •, ., • :· ' . • .. ! I . , •; . • • • ~, !, .' .•
Which is the North .. Carqlina, .drinking ,water
standard. . .. • .
For the Former Chlorine Plant Area the surface
water Remedial Action Objective is:
Total Mercury 0.012 ug/L
Which · is the North Carolina surface water
standard.
As discussed earlier, the contaminant mass loading
and concentration of mercury discharge to the
Roanoke River from contaminated groundwater in
the Former Chlorine Plant Area were estimated
based on data obtained during the RI. Taking into
account the flow of the River, a groundwater
mercury level was calculated which would result in
no violation to the North Carolina surface water
standard. This groundwater to surface water
Remedial Action Objective is:
Total Mercury 270 ug/L
This level is well above the North Carolina Drinking
water standard, so the Remedial Action Objective
for groundwater cleanup will be the drinking water
standard of 1.1 ug/L.
There are no chemical-specific cleanup standards
for surface or subsurface soils. However, during
the Remedial Investigation a sub-surface soil level
which would result in no groundwater
contamination with mercury above the North
Carolina drinking water standard was calculated.
The Remedial Objective for sub-surface soil based
on contribution to groundwater contamination at the
Former Chlorine Plant Area is:
Total Mercury 20 mg/kg
.. :, .·. r: · :=,~ .. •.
In summary, the objectives of th!l Remedi9-I Action
for the Former Chlorine Plant Area are:
6
• To ma-·n acceptable levels of
potentia k to h_uman receptors
associated with exposure to mercury in
soil and groundwater at the Former
Chlorine Plant Area, and
.• To li~it the.'r:nigra,iicin ofmer£uryfron,
soil to groundwater •into the adjacent·
,;,;'.'RoanokeRiver.··. :.:·•.·· '· · ..
: : ~-~ .,, ": j -•• "!•1••;
; '· .. ,. . ' ' . ,) . . . :
'· Any cleariup of contaminated sediments
which may be needed within the Roanoke
River will be addressed by EPA as part of
the Roanoke River Investigation work.
SUMMARY OF REMEDIAL
ALTERNATIVES
The following section provides a summary of
the alternatives developed in the FS Report
for the Former Chlorine Plant Area. The
primary objective of the FS was to determine
and evaluate alternatives for the clean-up of
the Former Chlorine Plant Area.
Descriptions of the clean-up alternatives are
summarized below. The FS Report contains
a more detailed evaluation/description of
•
each alternative and is available for review in •
the Information Repository located in the
Washington County Public Library.
The cost information provided below for
each alternative represents estimated capital
cost, annual operation and maintenance
(O&M), and present worth. Capital costs
include construction, engineering and
design, equipment, and Site development.
Operating costs were calculated for activities
that continue after completion of
construction, such as routine operation and
maintenance of treatment equipment and
groundwater monitoring. The present worth
(PW) of an alternative is the amount of
capital required to be deposited at the
present time at a given interest rate to yield
the total amount necessary to pay for initial
construction costs and future expenditures,
, · . , . -including O&M, and future replacement of
;1 :,, ; • . <:apitl¼I equip!Tle,nt . J .. , ·
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ALTERNATIVE 1: No .n
CERCLA requires that the "No Action" alternative
be evaluated at every site to establish a baseline
for comparison. No further activities would be
conducted at the Former Chlorine Plant Area under
this alternative. Because this alternative does not
entail contaminant re'moval, a review of the remedy
would be conducted every'five years in· accordance
with the requirements of CERCLA.. Operating
costs· are based on·this five-year review, which may
include sampling and preparation of a report.
There would be no maintenance costs.
Five-year Review costs:
Total PW Cost:
$100,000
$215,785
ALTERNATIVE 2: Cooling Tower Repair
with Bulkhead Maintenance and
Groundwater Monitoring
Capital Costs:
Annual O&M Costs:
Total PW Costs:
$ 427,000
$ 143,000
$2,420,000
Alternative 2 involves the following major
components:
• Land use restrictions
• · Cooling tower repair
• Surface cover improvements
• Existing River bulkhead inspections/routine
maintenance
• Routine inspection and evaluation of cooling
tower integrity
• Groundwater monitoring
This alternative, in comparison to the no action
alternative, will reduce the.volume of water moving
through the mercury'impacted soil below the
Former Chlorine Plant Area. However, over time,
the absorptive capacity of the soil below the Former
Chlorine Plant Area will be exceeded, and the final
mass of mercury which will eventually be r'eleased
to groundwater would be ttie same as the no action
alternative. . The mercury flushing ti!fle was
estimated in the FS and it exceeds 1 million years .
7.
The·'phyA integrity of the existing river
bulkhead"'ll'i be inspected periodically and
the results of the inspection used to define
additional routine maintenance needs, repair
requirements or a replacement schedule .
The inspections would . be visual
observations performed by divers. A non-
intrusive engineering inspection of the •
bulkhead integrity will also be prepared _as
part of the five yea'r reviews. • . ,.. '' · ''
Under this alternative, groundwater will be
monitored on an annual basis. The
groundwater sampling would be performed
to evaluate the stability of the groundwater
plume, groundwater mercury concentrations
and movement, and to evaluate the ·
groundwater for evidence of cooling tower
leakage. The groundwater monitoring
program will also ensure that mercury in
groundwater is not causing negative impacts
to the river, or migrating toward a drinking
water source.
Increased surface cover over the areas not
currently covered by asphalt and deed
restrictions on the land use are also included
in this alternative. These components serve
to further reduce the movement of mercury
into the groundwater and the River, and to
limit potential future ·human exposure ..
Five-year reviews are required to determine
if contaminants which remain onsite are
causing additional risk to human health or
the environment. As a result of this review,
EPA will determine if additional site
remediation is required. For cost estimating
purposes five-year reviews are assumed to
be conducted for a 30-year period.
However, under this alternative they would
likely be required indefinitely.
ALTERNATIVE 3: Extended Flow
Path and Groundwater Monitoring
Capital Costs: . $ 3,524,000
Annual O&M Costs: $ 52,163.
Total PW Costs: $4,171,000
Alternative 3 involves the following major
components:· · · ·· ' • ' ···
• Land use restrictions • • Surface cover improvements
• Cooling tower repair
•, , Flow path 11JOdification through_ bulkhead wall
extension a_nd improvement -. ,. , : .-.... :
• Groundwater monitoring
;·n: .• . . . -...... , ... ,. ,
This alternative relies on. improving the existing
bulkhead along the Roanoke River to extend the
flow path of mercury contaminated groundwater
prior to reaching the River. The new bulkhead wall
. would be constructed of sealed sheet piling which
would extend approximately 2.5 times longer than
the existing bulkhead, and would tie into the
existing wall through a series of tie backs. The
installation of this barrier wall would lengthen the
flow path from the contaminated soil source area to
the River as the groundwater would have to flow
around the barrier rather than directly to the River
through the existing unsealed and leaky wall.
Impacted groundwater will have a longer contact
period with subsurface soil, possibly enhancing the
ability of naturally occurring process to reduce the
mass movement of mercury to the River overtime.
However, .biochemical breakdown procssses fnr
mercury in groundwater below the site may not be
significant. The degree of mercury absorption to
soil that has not previously been contaminated
would ·be increased, which may initially slow the
migration of contaminated groundwater. However,
because there is a continuing source of mercury in
the soil in the Former Chlorine Plant Area, the
absorptive capacity of the soil will eventually be
exceeded.
This alternative incorporates implementation of a
regular groundwater monitoring program similar to
that described in Alternative 2. The location and
number of the wells, and the monitoring frequency
may differ somewhat based on the final
configuration of the bulkhead wall extension.
This alternative includes the same surface cover
improvements, land use restrictions and five-year
.review requirements describ_ed in.Alternative 2.
8
ALTER.VE 4: Containment and
Ground er Monitoring
Capital Costs:
Annual O&M Costs:
_ .Total PW Costs: -__ , -
$4,709,000
$ _36,465
$ ,5, 16,1,000
'··· • ,: I •• • I ' •
: ~lternative 4_ contains ,,the ,fqll_o~i(lg_ ~.ajor
.. -· compon_ents: _ , ,, 1 , : ;: , -, ,.
.. , ;_ ~ .:: . , ·. . . ~ r , .. , :
, • : Deed Restrictions
• Surface cap containment system
• Barrier wall
• Shallow "target area" excavation
• Groundwater monitoring
This alternative consists of the installation of
a vertical barrier wall around the area of the
footprint of the Former Chlorine Plant
building, as well as two targeted excavations
of high soil contamination outside of the
enclosure. The barrier wall enclosing the
source area under the old building footprint
would contain approximately 90% of the
mass of mercury in the sub-surface soils in
the Former Chlorine Plant Area. The barrier
wall would consist of sealed sheet piling
installed to approximately 45 below ground
surface tying into a thick clay layer beneath
the site.
The two target excavations are near the
former hypochlorite tank an central U-drain
(Area 1) and the eastern U-drain (Area 2).
Excavated soil which has a Toxicity
Characteristic Leaching Potential (TCLP) of
greater than 0.2 mg/L of mercury is
considered a hazardous material. In
addition, if the soil concentrations of mercury
exceed 260 mg/kg the soil must be sent to a
facility which can recover or recycle the
mercury from the soil: It is estimated that
50% of the soil from Area 2 would be
transported as hazardous waste, and that
none .of the soils from Area. 1 ,would be
" -_ hazardous. _ After excavation, the areas
would:·.: be · backfilled with ,clean ... soil.
_ ,-Excavation of these:2 areas would-remove
•
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_: 1 an additional-. 4% __ of-· ',the .:,me(cury _ •
•
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contaminated soils from the .er Chlorine Plant
Area. ·
The containment and excavation of 94% of the total
mass of mercury would reduce the mass
movement of mercury in groundwater leaving the
Former Chlorine Plant Area. Additional and
repaired surface covers would also reduce the
movement of mercury into groundwater. The
containment system would also serve to reduce the
risk of a catastrophic release of the large quantity
of mercury currently in the site soils. A
groundwater monitoring program similar to that .
. described in Alternative 2 would be performed
outside of the containment structure.
The same five-year review requirements that are
described in Alternative 2 are included with this
alternative.
ALTERNATIVE 5: Funnel and Gate
Treatment System
Capital Costs:
Annual O&M Costs:
Total PW Costs:
$6,161,000
$ 58,000
$6,883,000
This engineered treatment barrier alternative
involves the following major components:
• Deed restrictions
• Surface Cap containment system
• Funnel and gate I in situ treatment system
• Shallow ''target area" excavation
• Groundwater monitoring
This alternative would allow contaminated
groundwater to flow through an in situ
(underground) "gate" built into a barrier wall
constructed between the largest area of soil
contamination under the footpririt of the old building
and the Roanoke River. A reactive material in the
· gate would remove mercury dissolved in· the
groundwater prior to discharging to the River. The
treatment media would be activated carbon, which
was evaluated for its effectiveness in removing
mercury from groundwater at the site." · .
The barrier would be· desigried to contain-as much
of the contaminated soil within the footprint of the
9
Former c:Aine Plant building, as described
in Altern-4, as possible, while allowing
groundwater to flow from the upgradient
side. Barriers would be designed to '1unnel"
the groundwater through the reaction "gate".
The targeted excavation of Areas 1 and 2,
described in Alternative 4, is also included in
this alternative.
Groundwater monitoring would be performed
outside of the area of influence of the funnel
and gate system. In addition, the
groundwater monitoring program will
evaluate the effectiveness of the treatment
of the groundwater by the reactive media in
the gate.
The same five-year review requirements that
are described in Alternative 2 are included
with this alternative.
ALTERNATIVE 6: Groundwater
Extraction and Treatment
Capital Costs:
Annual O&M Costs:
Total PW Costs:
. $ 2,644,000
$ 360,000
$7,112,000
Aliernative 5 involves the following major
components: ·
• Deed restrictions
• Surface Cap containment system
• Shallow ''target area" excavation
• Groundwater extraction
• _Groundwater treatment via
flocculation/precipitation, carbon
adsorption, and ion exchange
• Groundwater monitoring outside of the
hydraulic capture area
Mercury impacted groundwater would be
removed from the shallow aquifer below the
Former Chlorine Plant Area through the use
of three groundwater extraction wells, and
conveyed to a treatment system. The wells
would extend approximately 40 feet below
ground surface. The extraction .ystem results
in hydraulic containment of mo ! the dissolved
mercury plume. As a result, this alternative has the
smallest proportion of mercury in groundwater
beyond the source area.
The treatment of the extracted groundwater would
require·. ·a •"pre'treatment step using
flocculation/precipitation:::·, Following ·: the pre-
treatment step, carbon adsorption would be used to
further treat the groundwater. After exiting the
carbon treatment train, the groundwater would be
passed through an ion exchange resin to remove
any remaining mercury.
Groundwater monitoring will be performed outside
the area influenced by the pumping wells. The
groundwater monitoring program will also be used
to evaluate the effectiveness of the extraction
system.
Included in this alternative is a limited target area
exc_avation of Area 2 only. Area 1 is not targeted
for excavation because it is within the area of
·influence of the groundwater extraction system.
The same five-year review requirements that are
described in Alternative 2 are included with this
alternative.
ALTERNATIVE 7: Mass Excavation
Capital Costs:
Annual O&M Costs:
Total PW Costs:
$16,714,000
$ 36,465
$17,166,000
This excavation alternative includes the following
major components:
• Deed restrictions
• Excavation and cover placement
• Groundwater monitoring
This alternative would excavate soil containing
mercury in the Former Chlorine Plant Area to the
remediation goal of 20 mg/kg. The size of the area
and the ongoing manufacturing activity in the area
requires that the excavation be performed in stages
or cells that are stabilized by steel sheet piling
walls. A total of 10 excavation phases ranging from
1 O to 40 feet below ground surface will be
performed. ~ of the deeper excavations
will require -atering the soil and the
recovered water would require treatment by
a mobile carbon adsorption unit.
The excavation area is approximately 24,000 •
·square feet, the, yolume :·o!. soil to. be,-
·.excavated is approximately _16,000 cubic
. yards:,-, The goalwould:be to remove 7,400
:pounds, or approximately . 99% of-the
mercury from the ·. Former Chlorine Plant
Area. Upon cell completion and confirmation
sampling at each excavation, the cell would
be backfilled with clean fill and the entire
area would be paved to match the existing
facility ground surface.
For this alternative a performance/
compliance groundwater monitoring program
would be implemented to monitor the decline
of residual mercury concentrations in the
groundwater outside of the excavation area.
The same Five-Year review requirements
that are described in Alternative 2 are
included with this alternative.
CRITERIA FOR EVALUATING REMEDIAL
ALTERNATIVES
The selection of the preferred alternative for
the Former Chlorine Plant Area, as
described in this Proposed Plan, is the result
of a comprehensive screening and
evaluation process. The Feasibility Study
identified and analyzed appropriate
alternatives for addressing the
contamination at the Site. The Feasibility
Study and other documents describe in
detail the alternatives considered, as well as
the process and criteria EPA used to narrow
the list of the potential remedial alternatives
to address the contamination at the Site. As
stated previously, all of these documents are
available for public review in the Information
Repository/ Administrative Record.
EPA always uses the following nine criteria
to evaluate alternatives ·identified in the
, .. :,. ;-. Feasibility S~udy,_:_ Th_e _remedial alternative
•·:' . , ', ·selected for a Superfund site must .achieve
. , · · · the •two threshold criteria as well as attain
: : . : ; the best balance among· the five evaluation
•
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•
criteria. EPA's Proposed.ernative may be
altered or changed based he two modifying
criteria. The nine criteria are as follows:
THRESHOLD CRITERIA
1. Overall Protection of Human Health
and the Environment: The degree to
which . each .alternative eliminates,
reduces, or controls threats to public
health and the environment through
treatment, engineering methods or
institutional controls.
2. Compliance With Applicable or
Relevant and Appropriate
Requirements (ARARsl: The
alternatives are evaluated for compliance
with all state and federal environmental
and public health laws and requirements
that apply or are relevant and appropriate
to the site conditions.'
EVALUATING CRITERIA
3. Cost: The benefits of implementing a
particular remedial alternative are weighed
against the cost of implementation. Costs
include the capital (up-front) cost. of
implemeniing an alternative over the· iong
term, and the net present worth of both capital
and operation and maintenance costs.
4. Implementability: EPA considers the
technical feasibility (e.g., how difficult the
alternative is to construct and operate)" and
administrative ease (e.g., the amount of
coordination with other government agencies
that is needed) of a remedy, including the
availability of necessary materials and
services. ·
5. Short-term Effectiveness: The length of time
needed to implement each alternative is
considered, and EPA assesses the risks that
may be posed to workers and nearby residents
during construction and implementation.
6. Long-term Effectiveness: The alternatives
are evaluated based ,on their ability to maintain
reliable · protection of public· health and. the
environment over time once the cleanup goals
11
.. . , .hav.m met.
7. Reduction of Contaminant Toxicity.
Mobility, and Volume: EPA evaluaies
each alternative based on how it
reduces (1) the harmful nature of the
contaminants, (2) their ability to move
through the environment, and (3) the
, volume or amount of contamination at
-, . , the site. - · · ·· · -, -· · · , , ··, · .· · . . ', . . ., . . .. . _,
MODIFYING CRITERIA . ··
8. State Acceptance: EPA requests state
comments on the Remedial
Investigation· and Feasibility Study
reports, as well as the Proposed Plan,
and must take into consideration
whether the state concurs with,
opposes, or has no comment on EPA's
preferred alternative.
9. Community Acceptance: To ensure
that the public has an adequate
opportunity to provide input, EPA holds
a public comment period and considers
and responds to all comments received
from the community prior to the final
selection of a remedial action.
'· '
• • EPA'S PREFERRED ALTERNATIVE
As discussed in the introduction, EPA is proposing to issue a Record of Decision. After conducting a
detailed analysis of all the feasible cleanup alternatives based on the criteria described in the previous •
sections, EPA is proposing the following cleanup plan to address contamination at the Former Chlorine
Plant Area. The EPA preferred alternative. is:
••,-? _'. •• •, ,-• 0 T •~' ' • • • •'
ALTERNATIVE 4: Containment and Groundwater Monitoring
Based o"n current information, this alternative appears to provide the best balance of trade-offs with respect ·
to the nine·criteria that EPA uses to evaluate alternatives. Alternative 4 provides for protection of human
health and the environment by reducing the migration of mercury from soils into groundwater and the
Roanoke River. In addition, the containment system will reduce the risk of a catastrophic release of the
large quantity of mercury remaining in site soils. With time, the low levels of mercury contamination in
groundwater outside of the containment wall will be reduced to the North Carolina drinking water standard
through naturally occurring processes. Institutional controls limiting the use of the area and the
groundwater will limit the exposure to contamination left at the site. This alternative is expected to achieve
the Remedial Action Objectives within a reasor:iable amount of time and is cost effective. EPA believes
the preferred alternative will satisfy the statutory requirements of Section 121 (b) of CERCLA, 42 USC
9621 (b), which provides that the selected alternative be protective of human health and the environment,
comply with ARARs, be cost effective, and utilize permanent solutions and treatments to the maximum
extent practicable. The selection of the above alternative is preliminary and could change in response to
public comments.
-!,, '·' . l • .-, . :. ;,,,
12
•
•
•
•
•
COMMUNI_TY PARTICIPATION
EPA has developed a community relations program as mandated by Congress under Superfund to
respond to citizen's concerns and needs for information, and to.enable residents and public officials to
participate in the decision-making process. Public involvement activities undertaken at Superfund sites
consist of interviews with local residents and elected officials, a community relation·s plan for each site, fact
sheets, availability sessions, public meetings, public comment periods,. newspaper advertisements, site
visits, and any other actions needed to keep the community informed and involved.
EPA is conducting a 30-day public comment period from July 2, 2003 to August 1, 2003, to provide
an opportunity for public involvement in selecting the final cleanup method for this Site. Public input on
all alternatives, and on the information that supports the alternatives is an important contribution to the
remedy selection process. During this comment period, the public is invited to attend a public meeting
on July10, at the First Baptist Church, 309 Washington Street in Plymouth, at which EPA will present
the Remedial Investigation/ Feasibility Study and Proposed Plan describing the preferred remedial
alternative for the Former Chlorine Plant Area and to answer any questions. Because this Proposed Plan
Fact Sheet provides only a summary description of the cleanup alternatives being considered, the public
is encouraged to consult the Information Repository for a more detailed explanation.
During this 30-day comment period, the public is invited to review all site-related documents housed at the
Information Repository located at Washington County Public Library, 3"' and Adams streets, Plymouth,
N.C., and offer comments to EPA either orally at the public meeting or in written form during this time
period. The actual remedial action could be .different from the preferred alternative, depending upon new
information or statements EPA may receive as a result of public comments. If you prefer to submit written
comments, please mail them postmarked no later than midnight July 31 to:
Diane Barrett
NC Community Involvement Coordinator
U.S.E.P.A., Region 4
North Site Management Branch
61 Forsyth Street, SW
Atlanta, GA 30303-3014
·All comments will be reviewed and a response prepared in making the final determination of \he most
appropriate alternative for cleanup/treatment of the Site. EPA's final choice of a remedy will be issued in
a Record of Decision (ROD). A document called a Responsiveness Summary summarizing EPA's
response to all public comments will also be issued with the ROD. Once the ROD is signed by the
Regional Administrator it will become part of the Administrative Record (located at the Library) which
contains all documents used by EPA in making a final determination of the best cleanup/treatment for the
Site. Once the ROD has been approved, EPA will begin the design of the selected remedy .
13
_____ ... ________ • _____ _
INFORMATION REPOSITORY LOCATION:
_Washington County Public Library
3"' and Adams streets , . ,
Plymouth, NC 27962
v' ·_:,::. ,.:·. : •. , ··: --:.: '",,.,_;~ •• ,.,!"hone: (9.19)-.793~2H_3_ ,.i ,1:. .. ·
., j f(. ;i~r"•i:.,·.!:.:·,,..,_ .:.:_::_ ·•:, ,·• ,'t. ·)'•·~ •~, ,·,-,·;•;;,_,fl. ~-.. ''• ·,·
FOR MORE INFORMATION ABOUT SITE ACTIVITIES, PLEASE CONTACT:
Ms. Jennifer Wendel, Remedial Project Manager or
Ms. Diane Barrett, NC Community Involvement Coordinator
North Site Management Branch
Waste Management Division
U.S. Environmental Protection Agency, Region IV
61 Forsyth Street, SW
AUanta, Georgia 30303-3104
Toll Free No.: 1-800-435-9233
. .. . . . . ~
MAILING LIST
If you are not already on our mailing list and would like to be placed on the list to receive future information
on the Weyerhaeuser Site, or if you want your name removed from the list, or if you have a change of
address, please complete this form and return to Diane Barrett, Community Involvement Coordinator at
the above address:
NAME:
ADDRESS; ___________________________ _
CITY, STATE, ZIP COu.t:.;__ ________ .:...._ ____________ _
PHONENUMBE.n.;. ________________________ _
Addition. D · Charige of Address □ Deletion □ · ·
•
•
•
•
•
• • GLOSSARY OF TERMS USED IN THIS FACT SHEET
Administrative Order on.Consent (AOC): A.legal agreement entered into by EPA and the Responsible
Party for work to be conducted at a site.
Administrative Record: A file which is•maintained and contains all information used by the lead agency
to make its decision on the selection of a method to be utilized to clean up/treat contamination at a
Superfund site. This file is held in the information repository for public review.
Applicable or Relevant and Appropriate Requirements (ARARs): The federal and state requirements
that a selected remedy must attain. These requirements may vary among sites and various alternatives.
Baseline Risk Assessment: (Human Health and Ecological} A means of estimating the amount of
damage a Superfund site could cause to human heath and the environment. Objectives of a risk assess-
ment are to: help determine the need for action; help determine the levels of chemicals that can remain
on the site after cleanup and still protect health.and the environment; and provide a basis for comparing
different cleanup methods.
Bioavailable: The degree and rate at which a substance is absorbed into a living organism, or is made
available at the site of physiological activity.
Carcinogen: Any substance that can cause or contribute to the production of cancer; cancer-producing.
Comprehensive Environmental Response, Compensation and Liability Act (CERCLA): A federal law
passed in 1980 and modified in 1986 by the Superfund Amendments and Reauthorization Act (SARA).
The Acts created a special tax paid by producers of various chemicals and oil products that goes into a
Trust Fund, commonly known as Superfund. These Acts give EPA the authority to investigate and clean
up abandoned or uncontrolled hazardous waste sites utilizing money from the Superfund Trust or by taking
legal action to.force parties responsible for the contamination to pay for and clean up the site.
Feasibility Study (FSj. Refer to Remedial Investigation/Feasibility Study.
Groundwater: Water found beneath the earth's surface that fills pores between materials such as sand,
soil, or gravel (usually in aquifers) which is often used for supplying wells and springs. Because
groundwater is a major source of drinking water there is growing concern over areas where agricultural
and industrial pollutants or substances are getting into groundwater.
Hydraulic Containment Describes a physical process where the movement of groundwater or
contaminants in groundwater is limited, usually involving the pumping of groundwater wells.
Information Repository/ Administrative Record. A file containing.accurate up-to-date information,
technical reports, reference documents, information about the Technical Assistance Grant, and any other
materials pertinent to the site. This file is usually located in a public building such as a library, city hall or
school, that is accessible for local residents. ·
In situ: In the natural or original position or place, usually used to describe activities at a site happening
in place or underground: ·
NCDENR: An abbreviation for the North Carolina Department of Environment and Natural Resources .
Remedial Action Objectives: These are specific objectives which are identified to protect both human
health and the environment that take into consideration the environmental media contaminated (i.e.,
groundwater, soil, surface water, sediment, or air) and the contaminants present in each medium. The
• • main goal of the objectives is to prevent exposure to contaminants in groundwater, soil, surface water,
sediment, or air in excess of risk0based human health or environmental standards.
Remedial Investigation/Feasibility Study (RVFS): The Remedial Investigation is an in-depth, extensive
sampling and analytical study to gather data necessary to determine the nature and extent of
contamination at a Superfund site; to establish criteria for cleaning up the she; a description and analysis
of the potential cleanup alternatives for remedialactions; and support the technical and cost analyses of
the alternatives. The Feasibility study also usually recommends selection of a cost-effective alternative.
Record of Decision (ROD): A public document that announces and explains which method has been
selected by the Agency to be used at a Superfund site to clean up the contamination.
Reasonable Maximum Exposure (RME) and Central Tendency(CT): RME is designed to be a measure
of "high end" exposure and uses inputs into the calculation which represent maximum reasonable values.
The Central Tendency is meant to measure "average" exposure and uses input values which are more
representative of average individuals exposure.
Responsiveness Summary: A summary of oral and written public comments received by EPA during a
public comment period and EPA's responses to those comments. The responsiveness summary is a key
part of the Record of Decision.
Statement of Work: A document attached to the Administrative Order on Consent which describes in
detail the w_ork to be performed and the timing for completion.
•
•
•
Region 4
•
U.S. Environmental Protection Agency
61 Forsyth Street, SW
Atlanta, Georgia 30303-3014
'
-.. •
·Neo ?,.eC0~ ~ j\l~ ioo?J
~ '{la~e e~\ ~ '11a~aie«1
~
North Site Management E
Diane Barrett, Cofflmunlt
Jennifer Wendel, Remed;
~6l
-~ .....
Official Business
Penalty for Private us·e $300
S/F
DEPUTY DIR.
DIVISION OF WASTE MANAGEMENT
NC DEPT. OF ENVIRONMENT & NATURAL
RESOURCES
401 OBERLIN ROAD, SUITE 150
RALEIGH NC 27605
WEYE 16
• •
HASLER $0.60
JUN 27 2003
US POSTAGE
FIRST CLASS
MAILED FROM 30303
011A0413001152
•• -
-
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• • ,_ ....
3
STAT£ I.OCATIQN
0 ....
FIGURE 1
WEYERHAfUSER COWPANY
Sill cUCATOR UAP
REMEDIAL INVESTIGATION
MARTIN COUNlY, NORTH CAROLINA
., ., ..
SUPERFUND PROPOSED PLAN FACT SHEET
Weyerhaeuser, Martin County Site
Landfill No. 1 Area
Plymouth, Martin County, North Carolina
March 25, 2002
This fact sheet is not conside.red as a technical document, but has been prepared for the general public to provide a better understanding of the proposed activities at the Weyerhaeuser Company Site. Words appearing in bold print are defined in a glossary at the end of this publication.
INTRODUCTION
This Proposed Plan identifies the preferred options
for cleaning up contamination associated with the
Landfill No. 1 Area of the Weyerhaeuser Company
Site, near Plymouth, Martin County,· North
Carolina. This document is being issued by ihe
U.S. Environmental Protection Agency (EPA), the
lead agency for Site activities, and the North
Carolina Department of Environment, and Natural
Resources (NC DENA), the support agency.
Weyerhaeuser Company, in consultation with EPA
and NC DENR, conducted the Remedial
Investigation (RI) and Feasibility Study (FS). A
remedy for the Landfill No. 1 Area will be selected
only after the public comm'ent period has ended
and all information submitted to EPA during this
time has been reviewed and considered.
EPA is issuing this Proposed Plan as part of its
public participation responsibilities under Section
117{a) of the_ Comprehensive Environmental
Response, Compensation and · Liability Act
(CERCLA), also known as Superfund.
This document summarizes information that is
explained in greater detail in the RI/FS reports and
other documents contained in the Information ·
Repository/Administrative Record for this Site.
EPA and the State encourage the public to review
these documents to better understand the Site and
Superfund activities that have been conducted.
The Administrative Record is available for public
review locally at the Washington County Public
Library.
EPA, in consultation with NC DENR, may modify
the preferred alternative or select another
response action presented in this Plan and the
RI/FS reports based on new information and/or
public comments. Therefore, the public is
encouraged to review and comment on all
alternatives identified here.
THIS PROPOSED PLAN:
1. · Includes a brief history of the Site and the
principal findings of Site investigations;·
2. Presents the alternatives for the Site
considered by EPA;
PUBLIC MEETING
WHEN: April 9, 2002
WHERE: First Baptist Church
309 Washington Street, Plymouth, North Carolina
TIME: 7:00 PM -9:00 PM
PUBLIC COMMENT PERIOD: March 27 to April 26, 2002
3. Outlines the criteria used by EPA to
recommend an alternative for use at the Site;
4. Provides . a summary of the analysis of
alternatives;
5. Informs the public that the EPA is proposing to
issue a Record of ·Decision (ROD) for the
Site which includes a contingent alternative; .
and
6. · Explains the opportunities for the public to
comment on the remedial alternatives.
SITE BACKGROUND
The Weyerhaeuser facility is an active wood and
paper products manufacturing facility located just
outside of the city limits of Plymouth, Martin
County, North Carolina. Current operations
include the production. of fluff paper, paper,
paperboard and finished lumber. Weyerhaeuser
has been the owner/operator of this facility since
1957, after merging with the Kieckhefer-Eddy
Corporation, which began operation at the site in
1937. The facility is located on about 2,400 acres,
about 1.5 miles west of the town of Plymouth. The
Landfill No. 1 area is located west of the
manufacturing facility at the site and occupies 97
acres. The area around the landfill is comprised
of dense vegetation and swamps on three sides.
Approximately 41 acres of the landfill is covered
with gravel, and is used as a contractor "lay down"
area, as well as a staging and storage yard.
Figure 1 shows the approximate location of Landfill
No. 1 at the facility, and the size of the study area.
The Landfill No. 1 site became operational in the
mid-1950s, and was closed in the early-1980s.
The area was originally used as a borrow source
for sand, and is unlined and does not have a
leachate collection system. Disposal activities
replaced the borrowed materials throughout much
of the landfill's operating period. Materials
disposed in Landfill No. 1 consisted of
predominately bark, sawdust, lime grits and waste
paper.
When North Carolina prohibited open dumps in
1972, Weyerhaeuser obtained the required siting
and operational permits. In 1981, Weyerhaeuser
sought and received permission from the State of
North Carolina to close Landfill No. 1 using primary
wastewater treatment solids that had collected in
the on-site wastewater settling ponds as cover
material. As part of closure activities, Landfill No.
1 was covered with wastewater treatment solids ·
from the wastewater treatment lagoons. The
materials were placed on the landfill and graded
more-or-less evenly across the landfill area. The
covered landfill was used as a log yard in the mid-
1980s. A portion of the landfill was covered with
gravel in 1994 to facilitate the use of the area for
material storage and plant construction staging. A
ridge of land to the southwest of Landfill No. 1 was
a borrow area that was later used for limited
disposal of paper and wax residue. The area was
abandoned a few years later because of flooding.
The RI for the Landfill No. 1 Area was conducted
in response to an Administrative Order by Consent
(AOC) and the attached Statement of Work (SOW)
issued by the EPA. Individual RI work and reports
have been prepared for each of the three areas
identified in the AOC, Landfill No. 1, the Former
Chlorine Plant, and Welch Creek. These focused
investigations were conducted in order to
streamline the investigation and remedy selection
process. EPA plans to issue a ROD for each of
the three areas of the site.
RESULTS OF THE REMEDIAL
INVESTIGATION
Samples were collected in the surface and
subsurface soils, groundwater, sediments and
surface water. The RI field activities were
conducted· in 1999, and the first Draft of the RI
report was received in December 2000. After
revision, the Final RI report was approved in
February, 2002.
The 97-acre landfill was found to contain mostly
· wood-related waste, with occasional construction
debris and wastewater treatment solids. Up to 12
feet of solid waste was found, and in some
locations, as much as 6 feet of waste were below
the water table. The wastewater treatment solids
cover soils contain dioxins/furans ranging from
0.89 to 1,490 ng/kg 2,3,7,8 TCDD Toxicity
Equivalency Concentration (dioxin TEO). The
landfill cover soi_ls also contain several inorganic
contaminants, collocated with the dioxin TEO
LANDFILL
NO. 1
FORMER. CHLORINE PLANT
FIGURE 1
contaminants, which are also associated with the
wastewater treatment solids. The highest levels of
contaminants were typically found in the southern
half of the landfill. .
The only contaminants detected in groundwater
was dioxin TEO, iron and manganese. The levels
of dioxin TEO are slightly above a standard which
is proposed by the State of North Carolina to be
clarified. The revised North Carolina 2L drinking
water standard sets a limit of 2.3 X 10-'0 mg/L of
dioxin TEO ior groundwater, which is a clarification
over the previous standard which referred only to
the 2,3,7,8 TCDD component. Iron and
manga.Qese exceed their respective North Carolina
2L drinking water standards both upgradient and
downgradient of Landfill No. 1. Naturally elevated
levels of iron and manganese are common in the
region.
Samples of wetland soil and water were collected
from locations adjacent to the landfill and from
locations approximately 150 to 200 feet from the
landfill. The highest dioxin/furan and· metals
concentrations in both surface water and soil were
observed near the southern half of the landfill.
There are no legal standards for wetland soils.
The wetland water samples contained some
measurable concentrations of the same
contaminants. However, there are no quantitative
wetland water standards in North Carolina. The
State has established qualitative requirements
which are related to protection of wetlands use.
Based upon limited potential ecological risk
assessed during the RI, it is concluded that the
qualitative requirement is met.
For more information on the results of the RI,
please refer to the RI report available for review in
the Washington County Public Library.
SUMMARY OF SITE RISKS
The RI report, analyzed and estimated the human
health or environmental problems that could result
if contamination at the Landfill No. 1 Area is not
cleaned up. This analysis is called a baseline risk
assessment. In addition, a separate study was
done to determine the effects on ecological
receptors. This study is called the baseline
ecological risk assessment (BERA).
Human Health Risk Assessment
In conducting the human health risk assessment,
EPA focused on the human health effects that
could result from ingestion and/or contact with
contaminants detected in surface soils, wetland
water and wetland soil. Given the location of the
Landfill No. 1 Area, human populations that may
potentially be exposed to contaminants are limited
to subcontractors using the landfill area and
Weyerhaeuser employees maintaining the landfill
(ie: mowing). However, to maintain conservative
evaluations in the risk assessment, adolescent and
adult trespasser scenarios were also evaluated for
the Landfill No. 1 Area. The baseline risk
assessment determines the adverse health effects
that. could result from long-term (30 years)
exposure to carcinogenic (cancer causing) and
non-carcinogenic chemicals.
Shallow groundwater in the vicinity of the landfill is
not currently used for · drinking water. State of
North Carolina rules limit. drinking water well
locations near landfills, and for this specific site,
the area near Landfill No. 1 is forested wetlands
within the floodplain of the Roanoke River, where
residential development is unlikely to occur.
Therefore, risk caused by groundwater ingestion
by human receptors was not evaluated, for current
land use, in the risk assessment. ·However, the
State of North Carolina considers all groundwater
to be potentially drinkable. As such, the future
residential use of the groundwater was assumed
and. evaluated in the risk assessment.
In calculating risks to a population if no remedial
action is taken, EPA evaluates the reasonable
maximum exposure levels for current and future
exposure scenarios to Site contaminants.
Scenarios were developed for the industrial worker
(subcontractor), the groundskeeper, an on-site
adolescent trespasser, and an on-site adult
trespasser. For the future use of groundwater,
EPA considered a long-terin resident, being
exposed to Site contaminants daily for 30 years.
EPA has established acceptable maximum limits ·
for excess lifetime carcinogenic risks for use in
evaluating risk at sites. EPA has concluded that
the carcinogenic risk to human health at the
Landfill No. 1 Site were greater than the
conservative end of the range, but well below the
maximum levels. The carcinogenic risk would
result mainly from the exposure to surface soils
contaminated with dioxin. In addition, the future
residential use of groundwater estimates resulted
in a risk just above the lower end of the cancer risk
range for ingestion of groundwater containing
dioxin.
The non-carcinogenic risk calculations were below
levels of concern, with the exception of future
ingestion of groundwater containing elevated
levels of arsenic and manganese. However,
arsenic and manganese are not contaminants of
. concern for the site since levels in groundwater
near the Landfill No. 1 area are similar to those in
background.
Baseline Ecological Risk Assessment
The BERA, conducted concurrently with the RI,
documents the biological data gathering and
. ecological risk characterization activities conducted
for the Landfill No. 1 Area. Ecological risk
assessment activities included direct assessment
of the ecological health of organisms living in the
wetlands near the landfill, as well as analysis of
forage materials and prey items which are used in
exposure modeling calculations for higher level
ecological receptors. This dietary exposure
modeling was done on both the upland (on the
landfill itself) and the wetlands.
Assessment endpoints represent the plant and
animal communities and populations, associated
habitats, and any sensitive environments that
compose the ecosystem(s) associated with a site.
Assessment endpoints provide the foundation for
establishing appropriate levels of exposure and
effects related to a site.
Specifically, for the upland portion of the Landfill
No. 1 Area, the assessment endpoints were:
1. Protection of long-term health and
reproductive capacity of insectivorous
mammals, as represented by the short-tailed
shrew.
2. Protection of long-term health and
reproductive capacity of herbivorous birds, as
represented by the Canada goose ..
3. Protection · of long-term health and
reproductive capacity of insectivorous birds,
as represented by the American robin
4. Protection of long-term health and
reproductive capacity of carnivorous birds, a·s
represented by the red-tailed hawk.
For the wetlands immediately adjacent to Landfill
No. 1, the assessment endpoints were:
1. Maintenance of ecological health of the
wetlands macroinvertibrate community, in
terms of structure and function, in support of
upper trophic levels.
2. Protection of long-term health and
reproductive capacity of carnivorous birds, as
represented by the barn owl.
3. Protection of long-term health and
reproductive capacity of insectivorous birds,
as represented by the American woodcock.
4. Protection of long-term health and
reproductive capacity of carnivorous wading
birds, as represented by the green heron.
5. Protection of long-term health and
reproductive capacity of carnivorous
mammals, as represented by the red fox.
For the Landfill No. 1 Area, EPA used two
approaches to estimate potential exposures. The
conservative approach reflects a conservative,
baseline ecological risk evaluation. The alternative
approach used modeling parameters which were
more toward average literature values, and site-
specific· information, where available. The results
of both approaches will be used by EPA when
determining the need for cleanup actions to at the
Landfill No. 1 Area.
For the uplands portion of Landfill No. 1,
contaminants which where identified from dietary
exposure modeling as posing · potentially
unacceptable risk were dioxin TEO, chromium,
lead, mercury, selenium and vanadium.
For the wetlands portion of Landfill No. 1,
contaminants which where identified from dietary
exposure modeling as posing potentially
~ .
unacceptable risk were chromium and mercury.
For more information about the risk posed by the
contamination at the Landfill No. 1 Area, please
refer to the Baseline Risk Assessment Report
contained in the RI report, and the Baseline
Ecological Risk Assessment Report (a separate
document) available for review at the Washington
County Public Library.
REMEDIAL ACTION OBJECTIVES
Remedial Action Objectives (RAO) were
developed based on the results of the risk
assessments, and the examination of potential
applicable or relevant. and appropriate
requirements (ARARs). Chemical-, action-, and
location-specific ARARs were examined. There
are no Chemical-specific ARARs for surface soils
and wetlands soils and wetland water.
For the Landfill No. 1 surface soils, the Remedial
Action Objectives are:
Chemical
dioxin TEO'
dioxin TEO2
Chromium
Lead
Mercury
Selenium
Vanadium
RAO
370 ng/kg*
770 ng/kg
110 mg/kg**
70 mg/kg
0.4 mg/kg
4.0 mg/kg
140 mg/kg
Based on World Health Organization (WHO,
1998) mammalian method
2 Based on WHO 1998 Avian method
• Units expressed as ng/kg=parts per trillion (pp!)
**mg/kg=parts per million (ppm)
For the wetlands soils, the Remedial Action
Objectives are:
Chemical
Mercury
Chromium
RAO
0.4 mg/kg
110 mg/kg
One standard which was considered for
groundwater is the proposed clarification to the
North Carolina groundwater standard for dioxin
TEO. However, there were no exceedences of the
currently published State of North Carolina
Drinking water standard for dioxin (2,3, 7 ,8 TCDD
only) at the Landfill No. 1 Area. In addition, the
Human Health Risk Assessment of the RI
concluded that the level of risk associated with
future residential consumption of groundwater
containing dioxin TEO near the site was within an
acceptable range. Therefore, no .cleanup
standard is needed for dioxin TEO in groundwater.
However, remedial alternatives which prevent
exposure to the groundwater have been evaluated.
Iron and manganese levels in groundwater
exceeded the North Carolina groundwater
standards at both the background and adjacent to
Landfill No. 1 monitoring wells, and are found to
exceed State standards regionally. Iron and
manganese are not retained as contaminants
associated with Landfill No. 1.
In summary, the objective of the Remedial Action
for the Landfill No. 1 Area are:
• To maintain acceptable levels of potential risk
to human receptors associated with exposure
to dioxin TEO in cover soil.
· • To maintain acceptable levels of potential risk
to ecological receptors associated with
exposure to dioxin TEO and inorganic metals
contaminants in cover soil.
• To maintain acceptable levels of potential risk
to ecological receptors associated with
exposure to mercury and chromium in the
wetlands adjacent to Landfill No. 1.
SUMMARY OF REMEDIAL ALTERNATIVES
The following section provides a summary of the
alternatives developed in the FS Report for the
Landfill No. 1 Area. The primary objective of the
FS was to determine and evaluate alternatives for
the clean-up of Landfill No. 1.
Descriptions of the clean-up alternatives are
summarized below. The FS Report contains a
more detailed evaluation/description of each
alternative, and is available for review in the
Information Repository located in the Washington
County Public Library.
The cost information provided below for each
alternative represents estimated capital cost,
annual operation and maintenance (O&M), and
present worth. Capital costs include construction,
engineering and design, equipment, and Site
development. Operating costs were calculated for
activities that continue after completion of
construction, such as routine operation and
maintenance of treatment equipment and
groundwater monitoring. The present worth (PW)
of an alternative is the amount of capital required
to be deposited at the present time at a given
interest rate to yield the total amount necessary to
pay for initial construction costs and future
expenditures, including O&M, and future
replacement of capital equipment.
The alternatives are:
ALTERNATIVE 1: No Action
CERCLA requires that the "No Action" alternative
be evaluated at every site to establish a baseline
for comparison. No further activities would be
conducted at Landfill No. 1 under this alternative.
Because this alternative does not entail
contaminant removal, a review of the remedy
would be conducted every five years in
accordance with the requirements of CERCLA.
Operating costs are based on this five year review,
which may include sampling and preparation of a
report. There would be no maintenance costs.
ALTERNATIVE 2: Cover System for Entire
Landfill, Institutional Controls for
Groundwater Use, and Natural Recovery for
Wetlands
Capital Costs: $ 6,333,000
Annual O&M Costs: $ 80,500
Total PW Costs: $11,935,000
Duration to Finish Construction: 1 d-12 months
A cover system is included in Alternative 2 that
consists of placing a barrier layer of wither gravel
or earthen materials over a geotextile covering the
entire footprint of Landfill No. 1. This cover .
configuration will eliminate direct contact to the
current cover soils. The geotextile separates the
wastewater solids from the supplemental cover
materials and provides a physical barrier to
burrowing animals. The geotextile also serves as
a warning layer to alert personnel of any
compromise in cover integrity and provides
structural reinforcement and stabilization of the
subgrade in traffic areas. Six inches of gravel will
be placed over the geotextile in the contractor lay-
down area, and will continue to be used as a
contractor staging area. Areas outside of the
contractor staging ·area will receive 1 foot of soil,
which will be seeded, mulched and fertilized to
create a vegetated layer that limits erosion. Minor
grading to facilitate runoff will eliminate ponding
and will also protect the cover from overland flow
that could erode the barrier layer and expose the
underlying contaminated soils.
The risk to ecological receptors in the adjacent·
wetlands would be reduced through source control,
covering the landfill, and natural recovery. The
accumulation of clean sediments and organic
material associated with leaf fall and natural
biodegradation of wetland vegetation will continue
to cover the affected wetland soils adjacent to the
landfill.
Institutional controls, including deed restrictions,
will be applied to the Landfill No. 1 Area to prevent
future use of the groundwater as a potable water
source. Periodic groundwater monitoring will be
conducted to assess the effectiveness of this
.remedial alternative for protection of groundwater
quality. A monitoring well network consisting of
existing wells and possibly some additional wells
will be included.
• Five year reviews are required to determine if
contaminants which· remain on site are causing
additional risk to human health or the' environment.
As a result of this review, EPA will determine if
additional site remediation is required. Five-year
reviews are assumed to be conducted for a 30-
year period.
ALTERNATIVE 3: Cover System for Entire
Landfill, Monitored Natural Attenuation for
Groundwater, and Natural Recovery for
Wetlands
Capital Costs: $ 6,333,000
Annual O&M Costs: $ 88,500
Total PW Costs: $12,115,000
Duration to Finish Construction:10-12 months
The barrier system for landfill cover soils chosen
for Alternative 3 is the same as previously
described in Alternative 2.
The risk to ecological receptors in the wetlands will
be reduced through construction of the landfill
cover and natural recovery. The accumulation of
clean sediments and organic material associated
with leaf fall and natural biodegradation of wetland
vegetation will continue to cover the affected soils
in the surrounding wetlands.
Monitored Natural Attenuation, which relies on
naturally occurring physical, chemical, and
biological processes !Q reduce the concentration of
contaminants over time, and periodic monitoring to
assess effectiveness, will be used as the remedy
for groundwater. A groundwater monitoring
network consisting of existing monitoring wells and
additional downgradient monitoring wells will be
included in this alternative to assess the
effectiveness of natural attenuation in
groundwater.
The same Five-Year review requirements that are
de.scribed in Alternative 2 are included with this
alternative.
ALTERNATIVE 4: Cover System for Entire
Landfill, Monitored Natural Attenuation for
Groundwater, and Cover System for
Wetlands
Capital Costs: $7,784,000
Annual O&M Costs: $ 91,000
Total PW Costs: $14,493,000
Duration to Finish Construction: 2 Years
The barrier system for landfill cover soils chosen
for Alternative 4 is the same as previously
described in Alternatives 2 and 3.
Monitored natural Attenuation, as described in
Alternative 3, will also be used as the remdial
alternative for groundwater under Alternative 4.
Under Alternative 4, a barrier system for
approximately 10 acres of wetlands soils
(consisting of a geotextile and a 2-foot thick soil
layer) is also proposed in order to limit the
exposure of ecological receptors to contaminated
sediments. A 2-foot thick layer over the wetlands
area will be needed in order to provide support for
construction equipment during placement of the
clean cover soil. The volume of wetland soil to be
addressed has been estimated as an average
depth of 1-2 feet over an area extending from the
toe of the landfill 200 feet into the adjacent
wetland, along approximately 1,800 feet of the
northwest edge of the landfill from the
westernmost point. An additional triangular
shaped area is located at the eastern end of the
northwest edge of the landfill.
The same Five-Year review requirements that are
described in Alternative 2 are included with this
alternative.
ALTERNATIVE 5-Cover System for Entire
Landfill, ex-situ Treatment of
Groundwater Using Granular Activated
Carbon, and Cover System for Wetlands
Capital Costs: $12,839,000
Annual O&M Costs: $ 434,000
Total PW Costs: $30,256,000
Duration to Finish Construction: 4 Years
The barrier system for landfill cover soils chosen
for Alternative 5 is the same as previously
described in Alternative 2,3, and 4.
The barrier system for wetlands soils chosen for
Alternative 5 is the same as previously described
in Alternative 4.
Groundwater extraction with ex-situ treatment
using granular activated carbon (GAC) will
remediate the groundwater in the vicinity of Landfill
No. 1. The groundwater recovery system will
consist of a series of extraction wells along the
northwest face of the landfill that penetrate the
uppermost aquifer. Pretreatment of the recovered
groundwater would be performed using a chemical
precipitation step and a filtration step to remove
interferences to the adsorption system. Following
pre-treatment, the groundwater will be treated by
passing through GAC. Treated groundwater will
be pumped to the mill's wastewater treatment
plant.
The same Five-Year review requirements that are
described in Alternative 2 are included with this
alternative.
ALTERNATIVE 6-Relocation of Landfill
Cover Soils Under Multi-layer Cap and ex-
situ Treatment System for Groundwater
Using Granular Activated Carbon
Capital Costs: $19,225,000
Annual O&M Costs: $ 434,000
Total PW Costs: $40,475,000
Duration to Finish Construction: 4 Years
The ex-situ treatment system for groundwater
chosen for Alternative 6 is the same qS previously
described in Alternative 5.
Alternative 6 involves removing the Landfill No. 1
cover materials (-97 acres) and affected wetlands
(-10 acres) and consolidating these materials
under a multi-layer cap within 5 to 1 O acres of the
footprint of Landfill No. 1. The proposed multi-
layer cap will consist of a clay or synthetic low-
permeability layer and a vegetative/drainage layer.
The affected soils removed from the top of the
landfill will be replaced by a soil covering. In the
contractor staging area, the surface will be covered
with six inches of gravel overlying a geotextile.
The wetland excavation will be backfilled and left
to naturally recover.
CRITERIA FOR EVALUATING REMEDIAL
ALTERNATIVES
The selection of the preferred alternative for the
Landfill No. 1 Area, as described in this Proposed
Plan, is the result of a comprehensive screening
and evaluation process. The Feasibility Study
identified and analyzed appropriate alternatives for
addressing the contamination at the Site. The
Feasibility Study and other documents describe, in
detail, the alternatives considered, as well as the
process and criteria EPA used to narrow the list of
the potential remedial alternatives to address the
contamination at the Site. As stated previously; all
of these documents are available for public review
in the Information Repository/ Administrative
Record.
EPA always uses the following nine criteria to
evaluate alternatives identified in the Feasibility
Study. The remedial alternative selected for a
Superfund site must achieve the two threshold
criteria as well as attain the best balance among
the five evaluation criteria. EPA's Proposed
Alternative may be altered or changed based on
the two modifying criteria. The nine criteria are as
follows:
THRESHOLD CRITERIA
1. Overall protection of human health and
the environment: The degree to which
each alternative eliminates, reduces, or
controls threats to public health and the
environment through treatment,
engineering methods or institutional
controls.
2. Compliance With Applicable or
Relevant and Appropriate
Requirements (ARARs): The
alternatives are evaluated for compliance
with all state and federal environmental
and public health laws and requirements
that apply or are relevant and appropriate
to the site conditions.
EVALUATING CRITERIA
3. Cost: The benefits of implementing a
particular remedial alternative are weighed
against the cost of implementation. Costs
include the capital (up-front) cost of
implementing an alternative over the long
term, and the net present worth of both capital
and operation and maintenance costs.
4. Implementability: EPA considers the
technical feasibility (e.g., how difficult the
alternative is to construct and operate) and
administrative ease (e.g., the amount of
coordination with other government agencies
that is needed) of a remedy, including the
availability of necessary materials and
services.
5. Short-term effectiveness: The length of time
needed to implement each alternative is
considered, and EPA assesses the risks that
may be posed to workers and nearby
residents during construction and
implementation.
6. Long-term effectiveness: The alternatives
are evaluated based on their ability to
maintain reliable protection of public health
and the environment over time once the
cleanup goals have been met.
7. Reduction of contaminanttoxicity. mobility,
and volume: EPA evaluates each alternative
based on how it reduces (1) the harmful
nature of the contaminants, (2) their ability to
move through the environment, and (3) the
volume or amount of contamination at the site.
MODIFYING CRITERIA
8. State acceptance: EPA requests state
comments on the Remedial Investigation and
Feasjbility Study reports, as well as the
Proposed Plan, and must take into
consideration whether the state concurs with,
opposes, or has no comment on EPA's
preferred alternative.
9. Community acceptance: To ensure that the
public has an adequate opportunity to provide
input, EPA holds a public comment period and
considers and responds to all comments
received from the community prior to the final
selection of a remedial action.
EVALUATION OF ALTERNATIVES
This Table profiles the performance of the alternatives in terms of these evaluation criteria noting how it
compares to the other alternatives under consideration (State and Public Acceptance were not rated).
The numerical ranking is a relative relationship, on a scale of 0-5, of each alternatives performance under
each criteria.
1-No 2-Cover, 3-Cover, 4-Cover 5-Cover 6-Multilayer
Action Institutional Natural landfill and landfill and cap for
Controls; Attenuation wetlands and wetlands landfill and
Natural and Natural Natural and ex-situ wetlands and
Recovery Recovery· Attenuation treatment ex-situ
treatment
Overall 0 3 3 -5 5 5
Protection
Compliance w/ 0 5 5 5 5 ,5
ARARS
Long-Term 0 3 3 4 5 5
Effectiveness
Reduction of 0 3 3 4 5 5
TIMN
Short-Term 5 4 4 3 2 2
Effectiveness
Implementability 5 4 4 3 2 2
Present Worth $11,935,000 $12,115,000 $14,493,000 $30,256,000 $40,475,000
Costs
.,. · .
EPA'S PREFERRED ALTERNATIVE
As discussed in the introduction, EPA is proposing to issue a Record-of Decision. After conducting a
detailed analysis of all the feasible cleanup alternatives based on the criteria described in the previous
sections, EPA is proposing the following cleanup plan to address groundwater contamination at the Site.
The EPA preferred alternative is:
ALTERNATIVE 2-Cover System for Entire Landfill, Institutional Controls for
Groundwater Use, and Natural Recovery for Wetlands
COST: $11,935,000
Based on ·current information, this alternative appears to provide the best balance of trade-offs with
respect to the nine criteria that EPA uses to evaluate alternatives. This alternative is expected to achieve
the Remedial Action Objectives within a reasonable amount of time and is cost effective. EP~ believes
the preferred alternative will satisfy the statutory requirements of Section 121 {b) of CERCLA, 42 USC
9621 (b), which provides that the selected alternative be protective of human health and the environment,
comply with ARARs, be cost effective, and utilize permanent solutions and treatments to the maximum
extent practicable. The selection of the above alternative is preliminary and could change in response
to p"ublic comments. ·
As this alternative relies on monitored natural recovery to clean the wetlands soils, the EPA will be
required to substantiate that natural recovery is occurring, and continue to verify that natural recovery
continues to occur. The frequency of this monitoring will be established in the Remedial _Design.
COMMUNITY PARTICIPATION
EPA has dP.veloped a community relations program as mandated by Congress under Superfund to .
respond to citizen's concerns and needs for information, and to enable residents and public officials to
participate in the decision-making process. Public involvement activities undertaken at Superfund sites
-consist of interviews with local residents and elected officials, a community relations plan for each site,
fact sheets; availability sessions, public meetings, public comment periods, newspaper advertisements,
site visits, and any other actions needed to keep the community informed and involved.
EPA is conducting a 30-day public comment period from March 27, 2002 to April 26, 2002, to provide
an opportunity for public involvement in selecting the final cleanup method for this Site. Public input on
all alternatives, and on the information that. supports the alternatives is an important contribution to the
remedy selection process. During this comment period, the public is invited to attend a public meeting
on April 9, at the First Baptist Church, 309 Washington Street in Plymouth, at which EPA will preserit
the Remedial Investigation/ Feasibility Study and Proposed Plan describing the preferred remedial
alternative for the Landfill No. 1 Area and to answer any questions. Because this Proposed Plan Fact
Sheet provides only a summary description of the cleanup alternatives being considered, the public is
encouraged to consult the Information Repository for a more detailed explanation.
During this 30-day comment period, the public is invited to review all site-related documents housed at
the Information Repository located at Washington County Public Library, 3'd and Adams Streets,
Plymouth, N.C., and offer comments to EPA either orally at the public meeting or in written form during
this time period. The actual remedial action could be different from the preferred alternative, depending
upon new information or statements EPA may receive as a result of public comments. If you prefer to
submit written comments, please mail them postmarked no later than midnight April 26th to:
Diane Barrett
NC Community Involvement Coordinator
U.S.E.P.A., Region 4
North Site Management Branch
61 Forsyth Street, SW
Atlanta, GA 30303-3014
All comments will be reviewed and a response prepared in making the final determination of the most
appropriate alternative for cleanup/treatment of the Site. EPA's final choice of a remedy will be issued
in a Record of Decision (ROD). A document called a Responsiveness Summary summarizing EPA's
response to all public comments will also be issued with the ROD. Once the ROD is signed by the
Regional Administrator it will become part of the Administrative Record (located at the Library) which
contains all documents used by EPA in making a final determination of the best cleanup/treatment for the
Site. Once the ROD has been approved, EPA will begin the design of the selected remedy. ·
•
INFORMATION REPOSITORY LOCATION:
Washington County Public Library
3,a and Adams streets
Plymouth, NC 27962
Phone: [phone]
FOR MORE INFORMATION ABOUT SITE ACTIVITIES, PLEASE CONTACT:
Ms. Jennifer Wendel, Remedial Project Manager or
Ms. Diane Barrett, NC Community Involvement Coordinator
North Site Management Branch
Waste Management Division
U.S. Environmental Protection Agency, Region IV
61 Forsyth Street, SW
Atlanta, Georgia 30303-3104
Toll Free No.: 1-800-435-9233
MAILING UST·
If you are not already on our mailing list and would like to be placed on the list to receive future information on the Weyerhaeuser Site, or if you want your name removed from the list, or if you have a change of address, please complete this form and return to Diane Barrett, Community Involvement Coordinator at the above address:
NAME:
ADDRESS: ____________________________ _
CITY, STATE, ZIP COur:.;__ _____________________ _
PHONENUMBEri....·-----------'---------------
Addition D Change of Address D Deletion D
GLOSSARY OF TERMS USED IN THIS FACT SHEET
Aquifer: An underground geological formation, or group of formations, containing usable amounts of groundwater that can supply wells and springs.
Administrative Order on Consent (AOC): A legal agreement entered into by EPA and the Responsible
Party for work to be conducted at a site.
Administrative Record: A file which is maintained and contains all information used by the lead agency to make its decision on the selection of a met.hod to be utilized to clean up/treat contamination at a Superfund site. This file is held in the information repository for public review. ·
Applicable :,r Relevant and Appropriate Requirements (ARARs): The federal and state requirements that a selected remedy must attain. These requirements may vary among sites and various alternatives.
Baseline Risk Assessment: (Human Health and Eoclogica/) A means of estimating the amount of damage a Superfund site could cause to human heath and the environment. Objectives of a risk assess-ment are to: help determine the need for action; help determine the levels of chemicals that can remain on the site after cleanup and still protect health and the environment; and provide a basis for comparing different cleanup methods.
Carcinogen: Any substance that can cause or contribute to the production of cancer; cancer-producing.
Carnivorous: Defines a class of animals and birds (and even some plants) which subsist on or feed on animal tissue.
Comprehensive Environmental Response, Compensation and Liability Act (CERCLA): A federal law passed in 1980 and modified in 1986 by the Superfund Amendments and Reauthorization Act (SARA). The Acts created a special tax paid ·by producers of various chemicals and oil products that goes into a Trust Fund, commonly known as Superfund. These Acts give EPA the authority to investigate and clean up abandoned or uncontrolled hazardous waste sites utilizing money from the Superfund Trust or by taking legal action to force parties responsible for the contamination to pay for and clean up the site.
Dioxin Toxicity Equiva/ency Concentration (Dioxin TEQ): A process which gives a relative toxicity weight to each separate dioxin congener as compared to, and expresses as, an equivalent toxicity of 2,3,7,8 TCDD.
Ex-situ: Used to describe the process of pumping the groundwater out of the ground for treatment at the surface.
Feasibility Study Refer to Remedial Investigation/Feasibility Study.
Geotextile:
Groundwater: Water found beneath the earth's surface that fills pores between materials such as sand,
soil, or gravel (usually in aquifers) which is often used for supplying wells and springs. Because groundwater is a major source of drinking water there is growing concern over areas wheie agricultural and industrial pollutants or substances are getting into groundwater.
Herbivorous: Subsisting on or feeding on plants .
..
.... ,
Information Repository: A file. containing accurate up-to-date information, technical reports, reference
documents, information about the Technical Assistance Grant, and any other materials pertinent to the
site. This file is usually located in a public building such as a library, city hall or school, that is accessible
for local residents.
Macroinvertebrate: .
•
NCDENR: An abbreviation for the North Carolina Department of Environment and Natural Resources.
Remedial Action Objectives: These are specific objectives which are identified to protect both human
health and the environment that take into consideration the environmental media contaminated (i.e.,
groundwater, soil, surface. water, sediment, or air) and the contaminants present in each medium. The
main goal of the objectives is to prevent exposure to contaminants in groundwater; soil, surface water,
sediment, or air in excess of risk-based human health or environmental standards.
Remedial Investigation/Feasibility Study (RIIFS): The Remedial Investigation is an in-depth, extensive
sampling and analytical study to gather data necessary to determine the nature and extent of
contamination at a Superfund site; to establish criteria for cleaning up the she; a description and analysis
of the potential cleanup alternatives for remedial actions; and support the technical and cost analyses of
the alternatives: The Feasibility study also usually recommends selection of a cost-effective alternative.
Record of Decision (ROD): A public document that announces and explains which method has been
selected by the Agency to be used at a Superfund site to clean up the contamination.
Responsiveness Summary: A summary of oral and written public comments received by EPA during
a public comment period and EPA's responses to those comments. The responsiveness summary is a
key part of the Record of Decision.
Statement of Work: A document attached to the Administrative Order on Consent which describes in
detail the work to be performed and the timing for completion.
Trophic: A term to describe the different levels of organisms in the food chain.
Water Table: The level below which the soil or rock is saturated with water, sometimes referred to as the
upper surface of the saturated zone. The level of groundwater.
U.S. Environmental Protection Agency
61 Forsyth Street, SW f ..,_-., '") ~ ' North Site Management Branch '< -P
Diane Barrett, Commu.nity lnvolvemerWiCC)Ofd.
Jennifer Wendel, Remedial Projec\ Manager Region 4 Atlanta, Georgia 30303-3014
Official Business
Penalty for Private Use $300
S/F WEYE
MR. GROVER NICHOLSON, BRANCH HEAD
SUPERFUND FEDERAL REMEDIATION BR.
NC DEPT. OF ENVIRONMENT & NATURAL
RESOURCES
401 OBERLIN ROAD, SUITE 150
RALEIGH NC 27605
\. ~.
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