NCD991278953_19930917_National Starch & Chemical Corp._FRBCERCLA ROD_Revised Draft Record of Decision for OU-3-OCR

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA 30365
SEP 17 1993 Kt:.Gt\~tU
4WD-NCRS
Mr. Bruce Nicholson
North Carolina Department of Environment,
Health and Natural Resources
401 Oberlin Road
Raleigh, NC 27605
SEP 2 0 1993
SUPERfUNfl SEUION
RE: Request to Review Revised Draft Record of Decision for Operable Unit #3
for the National Starch & Chemical Company Superfund Site
Dear Mr. Nicholson:
Enclosed for the state of North Carolina Department of Environment, Health &
Natural Resources review and distribution are three copies of the draft Record
of Decision (ROD) for Operable Unit #3 (OU #3) at the National Starch & Chemical
Company (NSCC) site. This ROD only addresses contaminated groundwater in the
"Plant" and lagoon areas of the facility and the Northeast Tributary. The
contaminated soils in these areas will be addressed in OU #4 ROD.
As with the previous Operable Units, the work conducted during OU #3 was
performed by the potentially responsible party (PRP), NSCC, and the PRP's
contractor, IT Corporation (IT). This ROD is based on the information provided
in the June 1993 Remedial Investigation (RI) Report, the June 1993 Feasibility
Study (FS) Report, and the July 1993 Proposed Plan Fact Sheet.
The public comment period ended on September 16, 1993.
This draft copy is near final form accept for the following: Table 21 is missing
some of the risk ranges associated with their specified cleanup goals and I am
still working on responses to comments 6-9 in the Responsiveness summary. Other
than these areas, I do not foresee making any other changes. If I do make
additional changes (other than editorial ones), as in the past, I will FAX you
the altered pages with the changes red-lined.
For your information, I am to brief Dick Green on Thursday, September 23 and
brief Pat Tobin on Monday, September 27 for ROD signing.
Thank you in advance for your time and effort.
If you have any questions, I can be reached at [phone].
Sincerely yours,
t:.6:~h::
Remedial Project Manager
enclosure
cc: Michael Kelly, NCDEHNR (w/o encl.)
Printed on Recycled Paper
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DRAFT
RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
OPERABLE UNIT #3
NATIONAL STARCH & CHEMICAL COMPANY SITE
SALISBURY, ROWAN COUNTY
NORTH CAROLINA
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV
ATLANTA, GEORGIA
SEPTEMBER 1993
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DRAFT
DECLARATION FOR THE
RECORD OF DECISION
SITE NAME AND LOCATION
Chemical Starch & Chemical Company
Cedar Springs Road, Salisbury, Rowan County, North Carolina
STATEMENT OF BASIS AND PURPOSE
This decision document presents the Operable Unit Three Remedial Action for the Chemical
Starch & Chemical Company Superfund Site in Salisbury, North Carolina, chosen in accordance
with the Comprehensive Environmental Response, Compensation, and Liability Act of 1980, as
amended by the Superfund Amendments and Reauthorization Act of 1986 and, to the extent
practicable, the National Oil and Hazardous Substances Contingency Plan. This decision is
based on the Administrative Record file for this Site.
The State of North Carolina ccondltlonally cconcurs with the selected remedy for Operable Unit
Three. State comments on this Record of Decision, as well as EPA's responses to those
comments, can be found in Appendix A of this document.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this Site, if not addressed by
implementing the response action selected in this Record of Decision, may present an imminent
and substantial endangerment to public health, welfare, or the environment. Presently, no
unacceptable current risks were identified associated with the National Starch & Chemical
Company Site. The principle threat pertains to the future and potential use of the groundwater
beneath and downgradient of the Site and the potential adverse impact contaminated soils will
have on the quality of the groundwater.
DESCRIPTION OF THE SELECTED REMEDY
This Operable Unit is the third of four Operable Units for this Site. The first two Operable Units
addressed the contamination associated with the Trench Area. This Operable Unit and the fourth
Operable Unit will address the contamination associated with the active production area of the
National Starch & Chemical Company facility and the wastewater treatment lagoon area.
This Operable Unit, Operable Unit #3, will permanently remove contaminants in the groundwater
through groundwater extraction and on-site, above-ground treatment with the discharge of the
treated groundwater to be combined with the facility's effluent to the City of Salisbury publicly
owned treatment works. Operable Unit #4 will address the contaminated soils in this portion of
the Site.
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The major components of Operable1 l)nit #3 Remedial A_ction include:
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Design and implementation of the specified groundwater remediation system. The groundwater remediation alternative includes extraction wells to remove contaminated groundwater, an air stripper to remove the VOCs from the extracted groundwater, control of emissions from the air stripper to the atmosphere through vapor-phase carbon adsorption filters, and discharging treated groundwater to the City of Salisbury POTW system.
Long-term monitoring of the groundwater .
Implementation of institutional controls.
Review and evaluate the existing groundwater monitoring system to insure proper monitoring of both groundwater quality and groundwater flow so that the effectiveness of the groundwater extraction system can be evaluated. Additional monitoring wells and/or piezometers will be added to mitigate any deficiencies.
• Performance of five (5) year CERCLA reviews.
ADDITIONAL SAMPLING AND MONITORING
The installation of additional monitoring wells will be required during the Remedial Design to further delineate the vertical extent of groundwater contamination in the bedrock. Additional aquifer tests may also be needed in order to properly design the selected remedy. And in order to establish a broader database on groundwater quality and groundwater levels, samples and groundwater level readings will be collected and analyzed on a regular basis prior to implementation of the Remedial Action.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the environment, complies with federal and state requirements that are legally applicable or relevant and appropriate to the remedial action, and is cost-effective. This remedy utilizes permanent solutions and alternative treatment technology to the maximum extent practicable, and satisfies the statutory preference for remedies that employ treatment that reduces toxicity, mobility, or volume as a principal element. Since this remedy may result in hazardous substances remaining in the groundwater on-site above the chemical-specific applicable requirements, a review will be conducted within five years after commencement of remedial action to ensure that the remedy continues to provide adequate protection of human health and the environment.
DRAFT
Patrick M. Tobin Date Acting Regional Administrator
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DRAFT
DECISION SUMMARY
RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
OPERABLE UNIT #3
NATIONAL STARCH & CHEMICAL COMPANY SITE
SALISBURY, ROWAN COUNTY
NORTH CAROLINA
PREPARED BY:
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV
ATLANTA, GEORGIA
SEPTEMBER 1993
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TABLE OF CONTENTS
SECTION PAGE No.
1.0 SITE NAME, LOCATION AND DESCRIPTION ...................... :............... 1 .
2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
3.0 _HIGHLIGHTS OF COMMUNITY PARTICIPATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
4.0 SCOPE AND ROLE OF OPERABLE UNIT WITHIN SITE STRATEGY . . . . . . . . . . . . . . . . . . . . 6
5.0 SUMMARY OF SITE CHARACTERISTICS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
5.1 SOILS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
5.2 GROUNDWATER ........................................ : . . . . . . . . . . . . . 11
5.2.1 SAPROLITE GROUNDWATER . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
5.2.2 BEDROCK GROUNDWATER . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
5.3 SURFACE WATER AND SEDIMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
5.4 HYDROGEOLbGICAL SETTING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34
5.5 PATHWAYS AND ROUTES OF EXPOSURE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35
6.0 SUMMARY OF SITE RISKS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45
6.1 CONTAMINANTS OF CONCERN . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45
6.2 EXPOSURE ASSESSMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46
6.3 TOXICITY ASSESSMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47
6.4 RISK CHARACTERIZATION .............................................. · 47
6.5 RISK .UNCERTAINTY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 88
6.6 ECOLOGICAL RISK . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 89
6.7 SUMMARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 89
7.0 REMEDIAL ACTION OBJECTIVES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 89
7.1 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARS) . . . . . . . . 89
7.2 EXTENT OF CONTAMINATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 92
8.0 DESCRIPTION OF ALTERNATIVES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 92
8.1 REMEDIAL ALTERNATIVES TO ADDRESS GROUNDWATER CONTAMINATION....... 93
8.1.1 ALTERNATIVE GWP1/GWL1: No action ................................ 93
8.1.2 ALTERNATIVE GWP2/GWL2: Long Term Monitoring and Fencing
A Portion Of Northeast Tributary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 96
8.1.3 ALTERNATIVE GWP3/GWL3: Institutional Controls, Long Term Monitoring, and
· Fencing A Portion Of Northeast Tributary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 96
8.1.4 ALTERNATIVE GWP4A/GWL4A: Groundwater Extraction Through Wells;
Treatment by Air Stripping with Vapor-Phase Carbon Adsorption;
and Discharge to POTW . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 97
8.1.5 ALTERNATIVE GWP4B/GWL4B: Groundwater Extraction Wells, Treatment by
Air Stripping with Fume Incineration; and Discharge to POTW . . . . . . . . . . . . . . . . . 97
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TABLE OF CONTENTS
SECTION PAGE No.
8.2 REMEDIAL ALTERNATIVES TO ADDRESS SURFACE WATER AND SEDIMENT CONTAMINATION ........................................ ·............. 98 8.2.1 ALTERNATIVE SW/SE-1: No Action . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 98 8.2.2 ALTERNATIVE SW/SE-2: Long-Term Monitoring . . . . . . . . . . . . . . . . . . . . . . . . . . 98
9.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES . . . . . . . . . . . . . . . . . . . . . . . 98 9.1 THRESHOLD CRITERIA . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 98 9.1.1' OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT....... 99 9.1.2 COMPLIANCE WITH APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 99 9.2 PRIMARY BALANCING CRITERIA ......................................... 100 9.2.1 LONG-TERM EFFECTIVENESS AND PERMANENCE ...................... 100 9.2.2 REDUCTION OF TOXICITY, MOBILITY, OR VOLUME ...................... 106 9.2.3 SHORT-TERM EFFECTIVENESS ..................................... 106 9.2.4 IMPLEMENTABILITY ............................................... 106 9.2.5 COST .......................................................... 106 9.3 MODIFYING CRITERIA .......................... : ....................... 107 9.3.1 STATE OF NORTH CAROLINA ACCEPTANCE ........................... 107 9.3.2 COMMUNITY ACCEPTANCE ........................................ 107
10.0 DESCRIPTION OF THE SELECTED REMEDY .... · ............................... 108 10.1 PERFORMANCE STANDARDS TO BE ATTAINED ............................. 108 10.2 GROUNDWATER REMEDIATION ......................................... 109 10.3 NORTHEAST TRIBUTARY SURFACE WATER/SEDIMENT REMEDIATION ........... 112 10.4 MONITOR EXISTING CONDITIONS/ADDITIONAL DATA REQUIREMENTS ........... 112 10.4 COST .............................................................. 113
11.0 STATUTORY DETERMINATION .............................................. 114 11.1 PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT ................... 114 11.2 COMPLIANCE WITH ARARS ............................ ; . . . . . . . . . . . . . . . 114 11.3 COST-EFFECTIVENESS ................................................ 114 11.4 UTILIZATION OF PERMANENT SOLUTIONS AND ALTERNATIVE TREATMENT TECHNOLOGIES OR RESOURCE TECHNOLOGIES TO THE MAXIMUM EXTENT PRACTICABLE ........................................................ 114 11.5 PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT ........... : ....... 114
12.0 SIGNIFICANT CHANGES .................................................... 115
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APPENDICES
APPENDIX A CONCURRENCE LETTER FROM THE STATE OF NORTH CAROLINA AND RESPONSE FROM THE AGENCY
APPENDIX B PROPOSED PLAN FACT SHEET ·
APPENDIX C RESPONSIVENESS SUMMARY
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LIST OF FIGURES
FIGURE TITLE· PAGE No.
FIGURE 1 SITE LOCATION MAP . . • . . . . . . . . . . . . . . . . . . • . . . . . . • . . • . . . . . . . . . . . . . . . . . • . • 2
FIGURE 2 LOCATION OF FACILITIES THAT COMPRISE OPERABLE UNIT #3 . . . . . . . . . . . . . . . . . . . . . . . . 3 FIGURE 3 DISTRIBUTION OF 1,2-DCA IN THE WATER TABLE ZONE OF THE AQUIFER.............. 14 FIGURE 4 DISTRIBUTION OF 1,2-DCA IN THE SAPROLITE ZONE OF THE AQUIFE.R . . . . . . . • . . • • . . . . 15 FIGURE 5 SAMPLING LOCATIONS FOR GROUNDWATER (WATER TABLE) VIA WELLPOINTS AND CONCENTRATIONS OF 1,2-DICHLOROETHANE DETECTED AT EACH WELLPOINT . . . . . . . . . . . . . . . . . . . . . . . • . . . . . . . . • 22 FIGURE 6 SAMPLING LOCATIONS FOR GROUNDWATER (SAPROLITE ZONE) VIA PUSH-POINT SAMPLER, TEMPORARY MONITORING WELLS, AND SCREENED WATER SAMPLER AND CORRESPONDING CONCENTRATIONS OF 1,2-DICHLOROETHANE DETECTED AT EACH LOCATION . . . . . . . . . . . . • . . . . . . . . . . . . . . . . . . . . . . . • . . 23 FIGURE 7 CONCENTRATIONS AND ESTIMATED EXTENT OF 1,2-DICHLOROETHANE CONTAMINATION IN THE BEDROCK ZONE OF THE AQUIFER . . . . . • . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26 FIGURE 8 SURFACE WATER SAMPLING LOCATIONS AND CONCENTRATIONS OF 1,2-DICHLOROETHANE FROM LAST SAMPLING EFFORT ON THE NORTHEAST TRIBUTARY . . . . . . . . . . . . . . . . . . . • . . . . . . . . . . . . . . . . . . 32 FIGURE 9 SEDIMENT SAMPLING LOCATIONS AND CONCENTRATIONS OF 1,2-DICHLOROETHANE FROM LAST SAMPLING EFFORT ON THE NORTHEAST TRIBUTARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . • . . 33 FIGURE 10 ORIENTATION OF CROSS-SECTIONAL A-A' . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37 FIGURE 11 HYDROGEOLOGICAL CROSS-SECTION A-A' . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38
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TABLE 1
TABLE 2
TABLE 3
TABLE 4
TABLE 5
TABLE 6
TABLE 7
TABLE 8
TABLE 9
TABLE 10
TABLE 11
TABLE 12
TABLE 13
TABLE 14
TABLE 15
TABLE 16
TABLE 17
TABLE 18
TABLE 19
TABLE 20
TABLE 21
LIST OF TABLES
TABLE TITLE PAGE No.
RANGE AND FREQUENCY OF DETECTION OF ORGANIC CONTAMINANTS AND INORGANIC CONSTITUENTS FOUND IN THE ENVIRONMENTAL MEDIA SAMPLED ..........................••. ; . . 8 FREQUENCY OF DETECTION AND CONCENTRATIONS OF ORGANIC CONTAMINANTS DETECTED IN GROUNDWATER SAMPLES COLLECTED FROM WELLPOINTS (WATER TABLE) AND PERMANENT MONITORING WELLS NS-13 AND NS-14 . . . . . . • . • . . . . . . . • . . • . . . . . . . . . • . . • . . . . 16 FREQUENCY OF DETECTION AND CONCENTRATIONS OF VOLATILE ORGANICS DATA FOR GROUNDWATER SAMPLES
COLLECTED FROM PUSH-POINT SAMPLER, TEMPORARY MONITORING WELLS, AND SCREENED WATl::R SAMPLER . . . . . . . • . . . • . . . . . . . . . . . . . . . . . . . . . . . • . . . . . . . . . . . . • . . . . . . . . . . 18 FREQUENCY OF DETECTION, CONTAMINANTS DETECTED, AND MOST STRINGENT PROMULGATED STANDARDS FOR CONTAMINANTS DETECTED IN THE SAPROLITE ZONE OF THE AQUIFER . . . • 24 FREQUENCY OF DETECTION, CONCENTRATIONS DETECTED, AND MOST STRINGENT PROMULGATED GROUNDWATER STANDARDS FOR CONTAMINANTS DETECTED IN THE BEDROCK ZONE OF THE AQUIFER . . . . . • . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . • . . . . 27 SUMMARY OF DETECTABLE CONCENTRATIONS OF 1,2-DICHLOROETHANE IN SURFACE WATER, SEDIMENT, AND SOIL SAMPLING OF THE NORTHEAST TRIBUTARY . . • . . • • . . . . . . . 29 CONCENTRATIONS OF ORGANICS AND INORGANICS IN SURFACE WATER AND SEDIMENT FROM LOCATIONS SW/SE-12 AND SW/SE-13 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . • . . . . . . . 31 CHEMICALS OF POTENTIAL CONCERN . . . . . . . . . . . . . . . . . . . • . . • . . . . . . . . . . . . . . . . . 39 POTENTIAL CURRENT AND FUTURE EXPOSURE PATHWAYS OF HUMAN EXPOSURE TO CONTAMINANTS . . . . . . . . . . . . . • . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . • . . . . . . 42 CHEMICALS OF CONCERN POSING RISK . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 48 UPPER CONFIDENCE LIMITS (95%) FOR CHEMICALS AND ASSOCIATED USED TO EVALUATE RISK CONDITIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51 PARAMETERS USED TO DESCRIBE EXPOSURES TO SITE-RELATED CHEMICALS OF CONCERN . 55 ESTIMATED POTENTIAL CURRENT LAND USE RISK FROM CARCINOGENS OUTSIDE PLANT OPERATIONS AREA
(CURRENT CONDITIONS) 69 SUMMARY OF CARCINOGENIC EFFECTS OF CHEMICALS OF POTENTIAL CONCERN . . • . . . . . . . 83 SUMMARY OF CANCER RISK (ILCR) AND NONCANCER HI VALUE" . . . . . . . . . . . . . . . . . . . . 90 REMEDIAL ACTION OBJECTIVES ANO ASSOCIATED GENERAL RESPONSE ACTIONS . . • . . . . . . 91 SECONDARY SCREENING OF TECHNOLOGIES AND PROCESS OPTIONS FOR GROUNDWATER . . 94 SUMMARY OF THE THRESHOLD CRITERIA EVALUATION FOR THE ALTERNATIVES .......... 101 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS ...................... 102 SUMMARY OF PRIMARY BALANCING _CRITERIA EVALUATION OF THE ALTERNATIVES ...•.... 104 PERFORMANCE STANDARDS AND CORRESPONDING RISKS FOR OU #3 ................. 110
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AWQC
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CERCLA
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CRP
CSF
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CWA
. ESD
EPA
I FS
GAC
gpm
I HI
HQ
HRS
LDRs
I MCLs
MCLGs
mg/kg
I mph
MW
NCAC
I NCDEHNR
NCGS
NCP
I NOAA
NPDES
NPL
I O&M
OU
POTW
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ppm
PRP
PW I RA
RCRA
RID
I RD
RI
RME
I ROD
SARA
SOWA
I SVOCs
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LIST OF ACRONYMS
Applicable or Relevant and Appropriate Federal, State or Local Requirements
Ambient Water Quality Criteria
Clean Air Act ·
Comprehensive Environmental Response, Compensation, and Liability Act of 1980
(Superfund)
centimeters per second
Community Relations Plan
Cancer Slope Factor
Clean Water Act
Explanation of Significant Difference
Environmental Protection Agency
Feasibility Study .
.. Granular Activated Carbon
gallons per minute
Hazard Index
Hazard Quotient
Hazardous Ranking System
Land Disposal Restrictions ,,
Maximum Contaminant Levels
Maximum Contaminant Level Goals
milligrams per kilogram
miles per hour
Monitoring Well
North Carolina Administrative Code
North Carolina Department of Environment, Health, and Natural Resources
North Carolina General Statute
National Oil and Hazardous Substances Pollution Contingency Plan
National Oceanic and Atmospheric Administration
National Pollution Discharge Elimination System
National Priority List
Operation and Maintenance
Operable Unit
Publicly Owned Treatment Works
parts per billion
parts per million
Potentially Responsible Party
Present Worth
Remedial Action
Resource Conservation and Recovery Act
Reference Dose
Remedial Design
Remedial Investigation
Reasonable Maximum Exposure
Record of Decision
Superfund Amendments and Reauthorization Act of 1986
Safe Drinking Water Act
Semi-volatile Organic Compounds
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RECORD OF DECISION
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
OPERABLE UNIT THREE
NATIONAL STARCH & CHEMICAL COMPANY SUPERFUND SITE
SALISBURY; ROWAN COUNTY, NORTH CAROLINA
1.0 SITE NAME, LOCATION AND DESCRIPTION
The National Starch & Chemical Company (NSCC Site or the "Site") Site is located on Cedar Springs Road in Salisbury, Rowan County, North Carolina. The Site is approximately 5 miles south of the City of Salisbury at latitude 35°37'49" north and longitude 80°32'03" west. Figure 1 shows the location of the Site with respect to the City of Salisbury. The areas of the Site that compose Operable Unit (OU) #3 are shown in Figure 2. OU #3 includes the following areas of the NSCC facility: Area 2, the parking lot, the Northeast Tributary, and the wastewater treatment lagoons. Area 2 consists of the following operations: Area 2 Reactor Room, the Tank Room, Raw Material Bulk Storage, and the Warehouse. The lagoon area includes three lagoons which were constructed between 1969-1970 as unlined lagoons. Wastewater was pumped into Lagoon 2 from 1970 to 1978. In 1978, Lagoon 1 was put into service and Lagoon 3 was lined with concrete. Lagoons 1 and 2 were originally used as settling and evaporation lagoons. In 1984, Lagoons 1 and 2 were excavated and also lined with concrete. Contaminated soil excavated from beneath the. lagoons was removed and disposed of in an area west of the plant area. The saturated soil was landfarmed and then used as fill material for expanding the facility's parking lot. A fourth lagoon was installed in 1992 as part of the treatment system to treat the contaminated groundwater generated by the OU #1 Remedial Action (RA). In the remainder of this Record of Decision (ROD), the term "Site" refers to the areas investigated as part of OU #3 (i.e., Area 2, the lagoon area, and the Northeast Tributary) unless otherwise specified.
Land use of the areas immediately adjacent to the NSCC property is a mixture of residential and industrial developments. An industrial park is located on the east and south sides of the Site. Another industrial park is located along the southern property line. A mobile home park adjoins the extreme southwestern corner of the NSCC property. Two housing developments lay to the north, one of which is adjacent to the facility property. The location of the nearest private, potable wells is approximately 2,700 feet north of Area #2.
2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES
In September 1968, Proctor Chemical Company purchased the 465,acre tract of land on Cedar Springs Road. Within the next year, Proctor Chemical was acquired by NSCC which operated the facility as a separate subsidiary. Construction of the plant on Cedar Springs Road began in 1970. On January 1, 1983, Proctor Chemical Company was dissolved and its operations merged with NSCC.
The primary products of this facility are textile-finishing chemicals and custom specialty chemicals. Volatile and semi-volatile organic chemicals are used in the production process along with acidic and alkaline solutions. Acidic and alkaline solutions are also used in the cleaning processes. The liquid waste stream from the manufacturing processes include reactor and feed line wash and
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D
KANHAPLOIS
DAVIDSON
COUNTY
CABARRUS COUNTY
SCALE: --
COUNTY
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--0 8 16 MILES
FIGURE 1
LOCATION OF THE NATIONAL STARCH &
CHEMICAL COMPANY SUPERFUND SITE
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GRAPHIC SCALE: 1'=500'
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FIGURE 2
LOCATION OF FEATURES ASSOCIATED
WITH OPERABLE UNIT #3
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NATIONAi. STARCH & CHEMICAL Col.lPANY SUPERRJND SITE
REOORD OF 0ECISKJN FOR OPERABlE UNIT 13
rinse solutions. This wastewater may include a combination of the following chemicals: acrylimide, 1,2-dichloroethane (1,2-DCA), m~thyl isobutyl ketone, methanol, styrene, maleic anhydride, vinyl toluene, sulphonated polystyrene, epichlorohydrin, octyl alcohol, ethyl alcohol, allyl alcohol, allyl chloride, sodium hydroxide, and sulfuric acid.
As the result of finding contaminants in groundwater and in the surface water/sediment of the Northeast Tributary, the original scope· of · work · specified in "the initial 1987 Remedial Investigation/Feasibility Study Work Plan was expanded. The first Remedial Investigation and Feasibility Study .resulted in OU #1 ROD which was issued by the Agency on September 30, 1988. The OU #1 ROD divided the Site into two Operable Units. The ROD for OU #1 required the installation of a groundwater interception, extraction, and treatment system in the western portion of the facility. The contaminants in the groundwater in this area are emanating from the trench area. OU #2 further investigated the contaminated soils in the trench area along with additional monitoring of the surrounding tributaries. OU #2 ROD was signed on September 28, 1990 and required additional work to identify, characterize, and delineate the contamination being continuously detected in the Northeast Tributary. This investigation has resulted in the development of OU #3 and OU #4.
The NSCC Superfund Site was proposed for inclusion on the National Priorities List (NPL) in April 1985, re-proposed in June 1988, and finalized on the list in October 1989 with a Hazardous Ranking System (HRS) score of 46.51. The HRS score was based on the following exposure route score_s: exposure via groundwater pathway -80.46, exposure via surface water pathway -0.00, and exposure via air pathway -0.00. Currently, the Site is cataloged as Number 257 of the 1,249 Superfund sites across the country on the NPL.
National Starch & Chemical Company, the Potentially Responsible Party (PAP), has performed OU #1, OU #2, and OU #3 under the direction and requirements specified in the Administrative Order on Consent (AOC) signed by the Agency and PAP in December 1986. Since there has only been one owner/operator of this property after being developed into an industrial complex, no "Responsible Party Search" was performed. National Chemical Starch & Chemical Company has been and remains the owner/operator of the facility.
A special notice ·ratter was sent on May 30, 1986 to provide NSCC an opportunity to conduct the first RI/FS. A good faith offer was submitted and negotiations were concluded with NSCC signing an AOC on December 1, 1986. The first RI/FS was completed on June 21, 1988 and September 8, 1998, respectively. · The ROD signed on September 30, 1988, divided the Site into two operable units. OU #1 consists of contaminated groundwater and OU #2 consists of trench area soils and surface water/sediment in surrounding tributaries. ·
Following the signing of OU #1 ROD, the Agency sent a special notice letter to the PAP to initiate negotiations on a Consent Decree (CD) for implementing the OU #1 Remedial Design/Remedial . Action (RD/RA). However; negotiations on the CD were not successful resulting in the Agency issuing an Unilateral Administrative Order (UAO) directing NSCC to design and implement the RA specified in the OU #1 ROD. The effective date of the UAO was July 27, 1989.
In support of OU #2, NSCC generated Supplemental RI and FS Reports. These reports were prepared in accordance to the December 1, 1986 AOC. These reports were completed on May 1990 and September 1990, respectively. The Supplemental RI reported continued detections of contaminants in the Northeast Tributary but did not identify the source of this contamination.
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.5.
NATIONAL STARCH & CHEMICAL COMPANY SUPERAJND SITE
RECORD OF DEaSON FOR OPERABLE UNIT #3
Consequently, the OU #2 ROD divided the Site into a third operable unit. Following the sigriing
of the OU #2 ROD, the Agency sent the PRP another special notice letter in March 1991 to
initiate negotiations on a second CD. This CD governed the implementation of the RA required
by OU #2 ROD. The CD was signed in August 1991 and was entered by the Federal Court on
July 20, 1992.
On December 4, 1991, EPA issued written notification to conduct a third RI/FS to determine the
source, nature, and extent of contamination entering the Northeast Tributary. As with the
previous RI/FS efforts, OU #3 RI/FS was conducted in accordance to the December 1, 1986
AOC. The OU #3 RI and FS reports were completed on June 2, 1993 and June 21, 1993,
respectively. NSCC will be provided an opportunity to conduct the OU #3 RD/RA as specified
in this ROD through the issuance of a third RD/RA special notice letter.
3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION
In 1986, community relations activities for this Site were initiated in conjunction with the
development of the RI/FS Work Plan. In developing the August 1986 Community Relations Plan,
the issues and concerns expressed by local citizens from the Site area were compiled and an
overview of these issues and concerns was prepared. A copy of the Community Relations Plan
was placed in the Information Repository located at the Rowan County Public Library. A mailing
list was developed based upon people interviewed, citizens living around the Site, and people
attending the public meetings. The mailing list also includes local, State, and Federal public
servants and elected officials. ·
Several. fact sheets and public meetings were held with respect to OU #1 and OU#2. The
following community relations activities were conducted by the Agency with respect to OU #3.
Two fact sheets and the Proposed Plan Fact Sheet were distributed to the public during the OU
#3 RI/FS. The first fact sheet, disseminated in June 1991, provided the community a status
report of activities associated with all three (3) Operable Units. This Fact Sheet provided a brief
history of the Site, a summary of current activities at the Site, a brief overview of"the Superfund
program, and a list of contacts tor more information. A second Fact Sheet was distributed in June
1993. This fact sheet summarized the findings and conclusions of the OU #3 RI Report which
included the Baseline Risk Assessment, and provided a revised time frame tor future activities
at the Site. A flyer was also distributed in June 1993 informing the public of a change in the
Agency's personnel associated with the management of the Site.
The public was informed through the Proposed Plan Fact Sheet and an ad published on July 19,
1993 in The Salisbury Post and The Charlotte Observer newspapers of the August 3, 1993
Proposed Plan Public Meeting. The Proposed Plan Fact Sheet was mailed to the public on July
15, 1993. The basis of the information presented in the Proposed Plan was the June 21, 1993
FS document. A press release reminding the public of the upcoming public meeting was also
issued on July 30, 1993. The Proposed Plan also informed the public that the public comment
period would run from July 19, 1993 to August 17, 1993.
The goals of the Proposed Plan meeting were to review the remedial alternatives developed,
identify the Agency's preferred alternative, present the Agency's rationale for the selection of this
alternative, encourage the public to voice its own opinion with respect to the remedial alternative
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NAT10NAL STARCH & CHEMICAL CollPANY SUPERRJND SITE
REOORO OF DEaSON FOR OPERABLE UNIT #3
reviewed and the alternative selected by the Agency, and inform the public .that the public comment period on the Proposed Plan would conclude on August 17, 1993. The public was also informed a 30 day extension to the public comment period could be requested and that all comments received during the public comment period would be addressed in the Responsiveness Summary.
On Wednesday, August 11, 1993, the Agency received a request for a 30-day extension to the public comment period which extended the public comment period to midnight September 16, 1993. A notice was mailed on August 18, 1993 to the addressees on the mailing list informing them of this extension. An ad was also published in the August 24, 1993 edition of The Salisbury Post and The Charlotte Observernewspapers informing the public that the public comment period had been extended to September 16, 1993.
Pursuant to Section 113(k)(2)(B)(i-v) and 117 of CERCLA, all documents associated with the development of the Proposed Plan and the selection of the remedial alternative specified in this ROD were made available to the public in the Administrative Record located both in the Information Repository maintained at the EPA Docket Room in Region IV's office and at the Rowan County Public Library in Salisbury, North Carolina.
4.0 SCOPE AND ROLE OF OPERABLE UNIT WITHIN SITE STRATEGY
As with many Superfund sites, the problems at the NSCC Site are complex. As a result, EPA organized the work into four operable units (OUs). These are:
OU #1
OU #2
OU #3
OU #4
Groundwater in western portion of the NSCC property
Trench Area soils and surface water/sediments in the Northeast Tributary
Groundwater under Area 2, the parking lot, and the wastewater treatment lagoons and the surface water/sediments in the Northeast Tributary
Contaminated soils in and around Area 2 and the wastewater treatment lagoons.
This Record of Decision (ROD) has been prepared to summarize the remedial selection process and to present the selected remedial alternative. OU #4 will focus on the contaminated soils in Area 2 and around the treatment lagoons.
EPA has already selected remedies for OU #1 in a ROD signed September 30 1,988, and OU #2 in a ROD signed September 30, 1990 (the contaminated groundwater and contaminated soils associated with the Trench Area, respectively). Construction on the OU #1 remedial action phase began in August 1990. OU #2, a no action ROD for the soils in the Trench Area, was initiated on July 20, 1992, the filing date for the Consent Decree.
The third OU, the subject of this ROD, addresses the contaminated groundwater emanating from Area 2 and treatment lagoon area. Potential ingestion of water extracted from these plumes poses the principal risk to human health because the EPA's acceptable risk range is exceeded and concentrations are greater than maximum contaminant levels (MCLs). The purpose of this
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-7-
NAT10HAI. STARCH & CHEMK:AL COMPANY SuPERRJND SITE
RE<XJRD DF DECOSION FOO OPERABLE UNIT #3
response is to prevent current or future exposure to the contaminated groundwater. OU #3 is the third of four operable units contemplated for th!s Site.
5.0 SUMMARY OF SITE CHARACTERISTICS
The NSCC OU #3 Remedial Investigation and Feasibility Study (RI/FS) is complete. The June 2, 1993 RI Report, conditionally approved by the Agency on July 7, 1993, identified the source, characterized the nature, and defined the probable extent of the uncontrolled hazardous wastes in the soil, groundwater, and surface water/sediment in the area addressed by this Operable Unit. The OU #3 RI Report included a Baseline Risk Assessment. The Baseline Risk Assessment defined the risk posed by the hazardous wastes present in the area investigated as part of OU #3. The Proposed Plan Fact Sheet, based on the June 21, 1993 OU #3 FS document, provided · the public a summary of the detailed analysis of the five (5) remedial alternatives for groundwater remediation and two (2) remedial alternatives for surface water/sediment in the Northeast Tributary.
The overall nature and extent of contamination associated with OU #3 is based upon analytical results of environmental samples collected from surface and subsurface soils, the groundwater, Northeast Tributary surface water and sediment, and the chemical/physical· and geological/hydrogeological characteristics of the area. Environmental samples were collected over a period of time and activities. The majority of the samples collected during the OU #3 RI were screened for volatile organic compounds (VOCs) as the previous Al's conducted at the NSCC facility identified VOCs as the primary contaminants at the Site. A review of the historical use of chemicals in the manufacturing processes at the Site also supports this appraisal. The remainder of the samples were analyzed for the entire target compound list (TCL) and target analyte list (TAL) constituents. The TCL includes voes, semi-volatile organic compounds (SVOCs). pesticides, and polychlorinated biphenyls (PCBs); the TAL includes inorganics such as metals and cyanide.
VOCs, SVOCs, one pesticide, and numerous inorganic analytes were detected in the soils and groundwater and two VOCs and a number of metals were detected in the surface water/sediment samples.
Background/control sampies were collected for groundwater and surface water and sediment. No background surface or subsurface soils samples were collected for OU #3. Therefore, any organic contaminant detected in the soils that could not be attributed to cross contamination, was presumed to be a Site related contaminant. The inorganic analytical data generated for the upgradient sediment sample (SE-12), collected from the Northeast Tributary, was used for comparison for surface and subsurface soils.
Table 1 lists the contaminants detected in each environmental medium sampled as well as the frequency and range of concentrations detected. As can be seen, no PCBs were detected in any of the environmental samples collected. The pesticide detected at the Site was delta-hexachlorocyclohexane (delta-BHC). It was detected once in the soil and once in the groundwater at very low concentrations. Pesticides have never been manufactured at this facility. Cyanide was detected twice in the soil and twice in the groundwater at very low concentrations. The concentrations of both delta-BHC and cyanide are below health base clean up goals. Based on the above information, the following contaminants or group of contaminants will not be
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-8-
NATlONAI. STAR<>< & CHEMICAL COMPANY SUPERFUND SITE
RECOOD OF DECISIOH FOR OPERABtE UNIT '3
discussed in the following sections: PCBs, pesticides.and cyanide. The following sections discuss the results and interpretations of the data collected and generated for each environmental medium investigated as part of OU #3 RI. ·
. Air samples were not collected as part of the OU #3 RI/FS effort. However, the air was monitored during the RI field work as part of the health and safety effort. Based of the information collected, the quality of the air at and around the Site is not currently being adversely impacted by the Site. The PRP also runs routine air sampling in the active portions ·01. the facility as part of their internal, corporate health and safety procedures.
The estimated volume of groundwater impacted is approximately 131 million gallons.
5.1 SOILS
A total of 107 soil samples were collected to identify the source, characterize the contaminants present, and delineate the extent of soil contamination. The soil samples were collected from 59 different locations. These soil samples included 11 surface soil samples (O to 2 feet below the surface) with the rest being collected between 2 feet below surface to either the water table interface or auger refusal.
voes, SVOCs, one pesticide, and inorganics were detected in the soils. To summarize the tabulated analytical results for all the soil samples, a total of 14 different voes, one (1) SVOC, one (1) pesticide, 14 metals, and cyanide was detected. As can be seen in Table 1, the voes detected most frequently and in the highest concentrations are acetone, 2-butanone, chloroform, dibromochloromethane, 1,2-DCA, and toluene (listed alphabetically). A variety of metals were also detected in the soils. Although these metals occur naturally in soil, elevated concentrations of 7 metals were detected. The following metals were either detected in onsite soils but not in the background soil sample or detected onsite at concentrations at least two times greater than the background concentration: barium, chromium, cobalt, copper, manganese, nickel, and vanadium.
In general, the greatest concentrations of organic contaminants were found in two (2) areas. In the soils underneath Area 2 and north-northeast of the lagoon area. The majority of the elevated levels of metals were detected in Area 2. Based on the information generated and collected as part of the OU #3 RI, the following sources of contamination have been identified. In Area 2, the source of contamination has predominantly been the underground terra-cotta piping. The terra-cotta piping was used to transported wastewater from the production area to the lagoons as well as control and direct surface water run-off from the plant area to the embankments of the Northeast Tributary. Currently, NSCC is replacing these buried lines with overhead, stainless steel pipes. NSCC has also controlled surface water runoff from Area 2 through the use of berms and sumps. The berms and the grade of the paved surfaces direct the surface runoff into the sumps. The surface water runoff collected in the sumps is then pumped through above ground pipes to the treatment lagoons. As the underground terra-cotta pipe lines are abandoned, the ends of each section are pressure grouted to ensure that these pipe lines will no longer act as conduits. NSCC projects that the installation of the overhead piping arrangement and abandonment/grouting of the underground terra-cotta pipes will be completed in December 1993.
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NATIONAL STARCH & CHEMICAL CoMPANY SUPERRJND Srre
RECORD Of DEC>SION FOR OPERABI.E UNIT #3
TABLE 1 RANGE AND FREQUENCY OF DETECTION OF ORGANIC CONTAMINANTS AND INORGANIC CONSTITUENTS FOUND IN THE ENVIRONMENTAL MEDIA SAMPLED
COMPOUND SOIL GROUNDWATER SURFACE SEDIMENT
WATER
Acetone 22-4,000 (40) 9-4,200 (15) 18-52 (3) 12-63 (7)
Bis(2-<:hloroethyl)ether 13-32 (2)
Bromodichloromethane 1-220 (7)
2-Butanone 3-42 (30)
Carbon Disulfide 4-8 (3)
Chloroethane 3.35 (6)
Chloroform 2-900 (17) 7-8,900 (2)
Dibromochloromethane 3-31 (5)
1,2-Dichloroethane 2-1,600,000 (42) 1-660,000 (30) 2-3,200 (7) 9-1,000 (5)
1, 1-Dichloroethene 1-14 (3)
1,2-Dichloroethene 1-200 (4)
1,2-Dichloropropane 5
Ethylbenzene 9-36 (2)
Methylene Chloride 1-160 (5)
Tetrachloroethene 2 107 (4)
Toluene 1-3,100 (12) 1-120 (3)
1, 1,2-Trichloroethane
Trichloroethane 11-17 (2) 1-5 (10)
Total Xylenes 2-90 (4)
Vinyl Chloride 32-190 (12) 1-120 (8)
Bis(2-ethylhexyl)phthalate 8
Di-n-butyl Phthalate 2-17 (3)
Di-n-octyl Phthalate
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-10-
NATIONAL STARCH & CHEMICAL COMPANY SUPERRIND SITE
RECORD Of DECISION FOR OPERABLE UNIT #3
TABLE 1 RANGE AND FREQUENCY OF DETECTION OF ORGANIC CONTAMINANTS AND
INORGANIC CONSTITUENTS FOUND IN THE ENVIRONMENTAL MEDIA SAMPLED
COMPOUND SOIL GROUNDWATER SURFACE SEDIMENT
WATER
Antimony 5,100-8,2000 (5) 7.6 (1)
Arsenic 530-2,900 (7) 2.4 1.1-1.9 (2)
Barium 33,300-198,000 (7) 28.2-737 (8) 32.1-38.2 (2) 50.3-88.4 (2)
Beryllium 240-680 (7) 1-2.5 (2) 0.49-0.98 (2)
Chromium 10,000-97,900 (7) 12.9-59.6 (6) 35.1-36.5 (2)
Cobalt 13,700-74,100 (7) 47-66.4 (2) 23.6-28 (2)
Copper 46,700-161,000 (7) 12.4-23. 7 (2) 48.4-90.3 (2)
Cyanide 2,500-21,900 (2) 12-16 (2)
Lead 1,300-9,400 (7) 3.3-3.9 (2) 3-15.1 (2)
Manganese 382,000-2,610,000 (7) 1.5-12,000,000 (14) 60-134 (2) 162-1,020,000 (2)
Mercury 0.05-0.06 (2)
Nickel 4,900-22,900 (7) 23.4-39.6 (3) 10.3-11.6 (2)
Selenium 0.88
Thallium 2,500-2,600 (2) 0.38
Vanadium 71,600-379,000 (7) 10.7-272 (11) 14.8-24.4 (2) 146-176 (2)
Zinc 19,700-50,000 (7) 22-6,410,000 (4) 10.3-11.4 (2) 23.9-48.5 (2)
Concentrations for water samples are reported in micrograms per liter (µgA) or in parts per billion (ppb). Concentrations for soil/sediment samples are reported in milligrams per kilogram (mg/kg) or in parts per billion (ppb). Number appearing in parentheses is the frequency of detection.
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NATIONAL STARCH & CHE•ICAL CO•PANY SUPERF\JND SllE
RECORD OF OECISON FOR OPERABlf UNIT #3
In the lagoon area, the source of contamination was eliminated in 1983 when the PRP lined its lagoons with concrete. The contamination being detected currently in the soils and groundwater in this area is the result of past practices and ihe residual contamination in the soil.
A more detailed discussion of the contaminants detected in the soils will be incorporated into the OU #4 ROD.
5.2 GROUNDWATER
The saprolite and bedrock zones of the aquifer have also been adversely impacted by activities at the Site. Contaminants detected in the groundwater include voes, SVOCs, one pesticide, metals, and cyanide. The pesticide, delta-BHC. was detected in one saprolite groundwater sample (NS-42) at 0.16 micrograms per liter (µg/1). Cyanide was detected twice at concentrations of 16 µg/1 and 12 µg/I at locations NS-13 (a saprolite well) and NS-42, respectively. Table 1 provides a complete list of contaminants detected in the groundwater along with the frequency of detections and the range of concentrations detected. The greatest concentrations of organic contaminants in the groundwater were found underneath and north of Area 2 and north of the lagoon area. In Area 2, contamination can be found throughout the entire aquifer. In the lagoon area, the highest concentrations detected were in the bedrock z_one of the aquifer.
A total of 66 groundwater samples were collected from 52 different locations. All of the groundwater samples were analyzed for VOCs .. Only the groundwater samples collected from the permanent monitoring wells were analyzed for the full analytical analyses. To summarize the analytical results, a total of 16 different VOCs, three (3) semi-volatile organic compound (SVOC), one (1) pesticide, 14 metals, and cyanide was detected in the groundwater. voes detected in concentrations that exceed either Federal MCLs or State groundwater quality standards include (listed alphabetically) acetone, bis(2-chloroethyl)ether, bromodichloromethane, 2-butanone, chloroform, 1,2-dichloroethane, 1, 1-dichloroethene, cis 1,2-dichloroethene, trans 1,2-dichloroethene, 1,2-dichloropropane, ethylbenzene, methylene chloride, tetrachloroethene, toluene, total xylenes, 1,1,2-trichloroethane, trichloroethene, and vinyl chloride. The three SVOCs detected in the groundwater belong to family of organic compounds called phthalates. Numerous metals were also detected in the groundwater. The inorganics that were detected at concentrations exceeding two times the concentration found in the background groundwater samples included: arsenic, barium, beryllium, chromium, cobalt, copper, cyanide, lead, manganese, nickel, vanadium, and zinc.
Groundwater samples from the water table were collected through a variety of methods. Thirteen ( 13) samples were collected through wellpoints, five (5) groundwater samples were collected employing a push-point water sampler, twelve (12) groundwater samples were collected from temporary wells, and nineteen (19) groundwater samples were collected using a screen water sampler. In addition to collecting groundwater samples from the water table, groundwater samples were collected from the six (6) saprolite and six (6) bedrock monitoring wells that were also installed as part of this investigation. The depth of the saprolite wells ranged between 13 to 80 feet. The depth of the bedrock wells ranged in depth of 39 to 135 feet. The depth to the water table ranged from ground surface at the Northeast Tributary to approximately 33 feet below ground surface.
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NATIONAi. STARCH & CHEMICAL C0MPNN SUPERFUND SITE
RECORD OF DECISION FOR OPERABLE UNIT #3
· The RI did not generate sufficient data to completely define the vertical extent of groundwater
contamination. It is estimated that the bedrock is fractured to approximately 200 feet below surface. The deepest bedrock well (NS-41) installed to date in this area of the facility goes to a depth of 135 feet. The groundwater sample collected from this well showed elevated levels of voe contamination. Additional information tci address this data gap will be collected during the remedial design (RD).
5.2.1 SAPROLITE GROUNDWATER
Figures 3 and 4 show the distribution of 1,2-oeA at the water table and in the saprolite zone of the aquifer, respectively. The isopleths shown in Figure 3 are based on the data presented in Tables 2 and 3. Figures 5 and 6 show the sampling locations and analytical results for 1,2-DeA for the data presented in Tables 2 and 3, respectively. The isopleths presented in Figure 4 are
based on the data displayed in Table 3 and 4. F-lgure 4 also shows the locations of the permanent saprolite monitoring wells and the corresponding concentrations of 1,2-DeA detected in each well.
Wellpoints, push-point, temporary wells, and screen water samplers were used to collect
groundwater samples at the water table interface. Table 2 lists the frequency of detection and the concentrations of voes detected at each wellpoint. Table 3 provides the frequency of detection and the concentrations of voes found in the groundwater samples collected by means of the push-point, temporary wells, and screen water samplers. Table 4 provides the frequency of detection, the concentrations of contaminants detected in the permanent wells installed to monitor groundwater quality in the saprolite zone of the aquifer, and the promulgated groundwater· standards. The highest concentration and the greatest variety of voes were found in monitoring well NS-42. voes detected in NS-42 include acetone (31 o µg/1), 2-butanone (240 µg/1), 1,2-DeA (82,000 µg/I), methylene chloride (160 µg/I), and toluene (220 µg/1).
As can be seen in Figure 4, there are two plumes of contamination in the groundwater in the saprolite zone. One is emanating from Area 2 and the other one originates in the lagoon area. Both plumes have migrated approximately 400-500 feet from their source in a northerly direction.
The concentrations detected in the lagoon area are greater in the groundwater than in the unsaturated soils. This indicates that the contaminants are being flus~ed out of the unsaturated soils through the natural processes of precipitation and percolation.
Monitoring well NS-37 had the largest variety of inorganics detected and typically the highest concentrations of inorganic constituents as well. The metals detected in NS-37 which were twice the background concentration were barium (737 µg/I), beryllium (2.5 µg/I), chromium (63.6 µg/I), cobalt (66.4 µg/I), copper (487 µg/I), manganese (1,500 µg/I), nickel (39.6 µg/I), vanadium (272 µg/I) and zinc (220 µg/I). . •
5.2.2 BEDROCK GROUNDWATER
Figure 7 ·shows the distribution of 1,2-DeA in the bedrock zone of the aquifer. This figure also shows the locatioris of the permanent bedrock monitoring wells and the corresponding concentrations of 1,2-DeA detected in each well. Table 5 lists the frequency of detection, the
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NATIONAL STARCH & CHEMICAL CoMPANY SUPERF\JND SITT
RECORD OF OECISIOH FOR 0PERABI.E UNIT #3
concentrations of contaminants detected in each bedrock well, and the promulgated groundwater standards. The highest total concentration of volatiles and the greatest variety of volatiles were found in monitoring well NS-40. voes detected in NS-40 included bis(2-chloroethyl)ether (32 µg/I), 1,2-DCA (99,000 µg/I), 1, 1-dichloroethene (5 µg/I), methylene chloride (66 µg/I), tetrachloroethene (7 µg/I), 1, 1,2-trichloroethane (6 µg/I), total xylenes (11 µg/I), and vinyl chloride (120 µg/I).
Monitoring well NS-38 had the largest variety of inorganics detected and typically the highest concentrations as well. The metals detected in NS-38 which were twice the background concentration were barium (635 µg/1), chromium (13.3 µg/I), cobalt (93.6 µg/I), and manganese (12,000 µg/I).
5.3 SURFACE WATER AND SEDIMENT
A total of 33 surface water and sediment samples have been collected from the Northeast Tributary. The first samples were collected in March 1987 and the most recent samples were collected in January 1993. All the samples collected were analyzed for VOCs. In addition to being analyzed for VOCs, two of the samples (SW/SE-12 and SW/SE-13) were also analyzed for SVOCs and metals. Sampling location SW/SE-12 is the upgradient/background surface water/sediment sampling location. Each sampling event has shown contamination to be present in the surface water and sediment of this tributary. To date, only two (2) voes, acetone and 1,2-DCA, have been detected in this stream. As in the other environmental media samples, metals were also detected but these metals occur naturally. Two metals were detected at concentrations at least two times greater than the background concentration. They are .manganese in the surface water and copper in the sediment. It was the continuous detection of 1,2-DCA in this stream that led to the initiation of OU #3. The objective of OU #3 RI was to identify, characterize, and delineate the source of contamination continually being detected in the Northeast tributary.
The highest concentration of contaminants was detected in the reach of the tributary that is just · east of the production facility. Table 6 lists each sampling event, the sampling locations, and the analytical results for 1,2-DCA in the water column and sediment. Table 7 lists the analytical results for the samples collected at sampling locations SW/SE-12 and SW/SE-13. Figure 8 shows the surface water sampling locations and Figure 9 shows the sediment sampling locations. These figures also present the analytical results for 1.2-DCA for the last samples collected at these sampling locations. The highest concentration of 1,2-DCA detected in the surface water was 3,200 µg/I in May 1992 at sampling location SW-13 and the highest concentration of 1,2-DCA detected in the sediment was 7,400 mg/kg in June 1991 at sampling location SE-14. Sampling location SW/SE-13 is just downgradient SW/SE-14.
As can be seen in Figures 8 and 9, no contamination was detected upgradient of the Site (SW-12, SW-12A, and SE-12). The concentration of contamination increases as the stream flows adjacent to and past Area 2, the production area. The concentrations decrease as the stream flows away from Area 2.
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ABANDONED /,' RAILROAD SPUR _______ / 6
:'/ ND
N 250 -
CHAIN LINK FENCE---~
LEGEND
ND GROUNDWATER SCREENING POINT
C:. SHCMIING 1,2.0CA CONCENTRATION
(ppb)
--·-1.2-DCA CONCENTRA.T10N
10000 _/'. CONTOUR.
FIGURE 3
NOTE: Confirmation data
supplemented by groundWatei
screening data
a ~ a:
"' (!) z a:
Cl, "' a: 13 w u
APPROXJMA TE SCALE (ft)
1 00 200 300 o400 500
CONCENTRATIONS AND ESTIMATED
EXTENT OF 1,2-DICHLOR0ETHANE
CONTAMINATION IN THE GROUNDWATER
AT THE WATER TABLE
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D
I
1050
750 -
450 -
150 -
.750 I
-650
• NS-37
(1 J)
ABANDONED
RAILROAD SPUR~----, -'
□
-350
I f \ \
I I \ \
,,,-,-,'--I I 11 ,,. .... --.._ I
-50 250
• NS-43
(ND)
NS-33
• 1(ND)1
-550
II
LEGEND
1
• NS-13
1 .2-0CA CONCENTRATION
C.ONTOUA (ppb)
(1700) _
1,2-0CA CONCENTRATION
(ppb), GROUNDWATER
SAMPLES
0 <(
0 a:
Cl)
(!) z cc CL
Cl)
a: c§
UJ t)
SCALE (11)
100:a:,o,ooamo
FIGURE 4
CONCENTRATIONS AND
ESTIMATED EXTENT OF
1,2-DICHLOROETHANE
CONTAMINATION IN THE
SAPROLITE ZONE OF
THE AQUIFER
1!!11!1 l!!!!!!!I !!!!I -= == ==· ;;;; liliil --liliil - - - - - - - -NATIONAL STARCH & CI-EMICAL C.OMPANY SUPERRJN0 SITE
RECORD OF DECISION FOR OPERABLE UNIT #3
-16-
TABLE 2 FREQUENCY OF DETECTION AND CONCENTRATIONS OF ORGANIC CONTAMINANTS DETECTED IN
GROUNDWATER SAMPLES COLLECTED FROM WELLPOINTS (WATER TABLE) AND PERMANENT MONITORING
WELLS NS-13 AND NS-14
(Samples were only analyzed for VOCs)
FREQUENCY TWP-1A TWP-2 TWP-3 TWP-4 TWP-5 TWP-6 TWP-7 TWP-8
COMPOUND OF (Background)
DETECTION
VOLATILE ORGANIC CoMP0UNDS
Acetone 10115 10 U
Carbon Disulfide 3115 5U 5U
Chloroethane 3115 10 U 10 U 10 U 10 U 10 U 10 U
1,2-Dichloroethane 7115 10 UJ 5U 5U 5U. SU 5U
1, 1-Dichloroethene 1/15 5U 5U 5U 5U SU SU 5U 5U
1,2-Dichloroethene 2/15 5U 5U 5U 5U SU 5U 5U 10 UJ
1,2-Dichloropropane 1/15 5U 5U 5U 5U 5U 5U 5U 5U
Methylene Chloride 3115 10 U SU 5U 5U 5U 10 U
Tetrachloroethene 2/15 5U 5U 5U 5U 5U 5U 5U
Toluene 3/15 5U 5U 5U 5U 5U 5U 5U
1, 1,2-Trichloroethane 2/15 5U SU 5U 5U 5U 5U 5U 5U
T richloroethene 2/15 5U 5U 5U 5U 5U 5U 5U 5U
Vinyl Chloride 4/15 10 U 10 U 10 U 10 U 10 U 10 U 10 U
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. RECORD OF DECISION FOR OPERABLE UNJT #3
-17-
TABLE 2 FREQUENCY OF DETECTION AND CONCENTRATIONS OF ORGANIC CONTAMINANTS DETECTED IN GROUNDWATER SAMPLES COLLECTED FROM WELLPOINTS (WATER TABLE) AND PERMANENT MONITORING WELLS NS-13 AND NS-14
(Samples were only analyzed for VOCs)
COMPOUND FREQUENCY
OF DETECTION
TWP-9 TWP-10
VOLATILE ORGANIC CoMPOUNDS
Acetone 10/15 10 U
Carbon Disulfide 3/15
Chloroethane 3/15
1,2-Dichloroethane 7/15
1, 1-Dichloroethene 1/15
1,2-Dichloroethene 2/15
1,2-Dichloropropane 1/15 ·
Methylene Chloride 3/15
Tetrachloroethene 2/15
Toluene 3/15
1, 1,2-Trichloroethane 2/1.5
Trichloroethene 2/15
Vinyl Chloride 4/15
Samples were collected in May 1992.
Concentrations are in micrograms per liter (µg/1) or parts per billion (ppb). Shaded area (7 J depicts positive detections.
D -Sample analyzed at secondary dilution.
J · Concentration is estimated.
U -Undetected at the indicated quantitation limit. UJ · Undetected; the associated quantitation limit is an estimated value.
10 U
TWP-11 TWP-12 TWP-13 NS-13 NS-14.
10 U 10 U
5U
10 U 10 U
10 UJ 5U
5U 5U
5U 5U 5 UJ 5U
5U 5U 5 UJ 5U
10 U 10 U 5U 5 UJ
5U 5U 5 UJ 5U
5U 5U 5 UJ 5U
5U 5U 5 UJ 5U
5U 5 UJ 5U
10 U 10 UJ 10 U
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NATIONAL STAACH & C~MICAL COMPANY SUPER~D SITE
RECORD OF DECISION FOR OPERABLE UNIT #3
-18-
TABLE 3 FREQUENCY OF DETECTION AND CONCENTRATIONS OF VOLATILE ORGANICS DATA FOR GROUNDWATER SAMPLES COLLECTED FROM PUSH-POINT SAMPLER, TEMPORARY MONITORING WELLS, AND SCREENED WATER SAMPLER (Samples were only analyzed for VOCs)
FREQUENCY GW-1' . GW-1A GW-1B GW-2' OF DETECTION
SAMPLING DATE 11/20/92 NA 12/4/92 11/20/92
DEPTH TO WATER 8 NA 8 17.8 TABLE (feet)
COMPOUND
VOLATILE ORGANIC COMPOUNDS
Acetone
Carbon Disuttide
Chloroethane
Chloroform
1,2-Dichloroethane
1, 1-Dichloroethene
1,2-Dichloroethene
Ethylbenzene
Methylene Chloride
Tetrachloroethene
Toluene
Total Xylenes
1, 1 ,2-Trichloroethane
Trichloroethene
Vinyl Chloride
4/33
1/33
2/33
1/33
16/33
1/33
1/33
2/33
3/33
2/33
3/33
3/33
4/33
1/33
2/33
25,000 U
12,000 U
25,000 U
12,000 U
12,000 U
12,000 U
12,000 U
12,000 U
12,000 U
12,000 U
12,000 U
12,000 U
25,000 U
10 U 10 UJ 250 U
SU SU 120 U
10 U 10 U 250 U
120 U
SU SU 120 U
SU SU 120 U
SU SU 120 U
SU SU
SU SU
SU SU 120 U
SU SU 120 U
SU SU 120 U
SU SU 120 U
10 U 10 U 250 U
GW-3 GW-5' GW-SA GW-6
11/21/92 11/21/92 11/23/92 11/19/92
9.8 6.45 15 6
10 U 10,000 UJ 10 UJ
SU 5,000 U SU
10 U 10,000 U 10 U
SU SU
SU SU
SU SU
SU 5,000 U SU
SU 5,000 U SU
SU SU
SU SU
5,000 U SU SU
SU 5,000 U SU
SU 5,000 U SU SU
SU 5,000 U SU SU
10,000 U 10 U 10 U 10 U
GW-6RE
12/16/92
6
10 U
SU
SU
SU
SU
SU
SU
SU
SU
10 U
-aa -----.l!!!!!I I!!!!!! . 1111 i;;;:a liliiiil --
-19-
- - - - -
NATIONAL STARCH & CHEMICAL CoMPANY SUPERF~D SITE
RECORD Of DECISION FOR OPERABLE UNIT #3
TABLE 3 FREQUENCY OF DETECTION AND CONCENTRATIONS OF VOLATILE ORGANICS DATA FOR GROUNDWATER SAMPLES
'-. COLLECTED FROM PUSH-POINT SAMPLER, TEMPORARY MONITORING WELLS, AND SCREENED WATER SAMPLER (Samples were only analyzed for VOCs) (continued)
GW-7. GW-7A GW-8 GW-8D GW-8B GW-11A• GW-11B GW-12 GW-12A
SAMPLING DATE 11/23/92 11/24/92 12/4/92 12/5/92 12/5/92 11/24/92 12/3/92 12/6/92 12/2/92
DEPTH TO WATER 9 25 1 1 5 6.5 12.5 16 17 TABLE (feet)
COMPOUND
VOLATILE ORGANIC COMPOUNDS
Acetone . 10 UJ 10 UJ 10 R 10 R 10 UJ 5,000 UJ 10 R 10 UJ 10 R Carbon Disuttide 5U 5U 5U 5U 5U 2,500 UJ 5U 5U 5U Chloroethane -10 U 10 U 10 U 10 U 5,000 UJ 10 U 10 U 10 U Chloroform 5U 5U 5U 5U 5U 2,500 U 5U 5U 5U· 1,2-Dichloroethane -5U 5U 1111:IPlmllII ':! 5U -5U 1, 1-Dichloroethene 5U 5U 5U 5U 2,500 U 2,500 U 5U 5U 1,2-Dichloroethene 5U 5U 5U 5U 2,500 U 5U 5U 5U Ethylbenzene 5U 5U 5U 5U 5U 2,500 U 5U 5U 5U
Methylene Chloride 5U 5U 5U 5U 5U 5U SU SU Tetrachloroethene SU 5U SU SU SU 2,SOO U SU SU SU
Toluene SU -SU SU SU 2,SOO U SU SU SU Total Xylenes 5U SU SU 5U 2,SOO U SU SU SU
1, 1 ,2-Trichloroethane SU SU 5U 5U SU 2,SOO U SU SU SU Trichloroethene 5U SU SU SU SU 2,500 U SU SU SU Vinyl Chloride 10 U 10 U 10 U 10 U 10 U 5,000 U 10 U 10 U 10 U
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RECORD OF DECISION FOR OPERABLE UNIT #3
-20.-
TABLE 3 FREQUENCY OF DETECTION AND CONCENTRATIONS OF VOLATILE ORGANICS DATA FOR GROUNDWATER SAMPLES COLLECTED FROM PUSH-POINT SAMPLER, TEMPORARY MONITORING WELLS, AND SCREENED WATER SAMPLER (Samples were only analyzed for VOCs) (continued)
GW-13 .GW-14 GW-15 GW-16A GW-17 GW-18 GW-18A GW-19
SAMPLING DATE 11/20/92 11/21/92 12/17/92 12/2192 12/1/92 11/23/92 12/18/92 NA DEPTH TO WATER TABLE (feet) 4.5 4.5 3 10 4 7.5 7 NA COMPOUND
'
VOLATILE ORGANIC COMPOUNDS
Acetone 10 UJ 10 U 180 UJ 10 R 10 R 10 UJ --10 U Carbon Disuttide SU SU SU SU SU SU 17 U SU Chloroethane 10 U 10 U 110 U 10 U 10 U 33 U 10 U Chloroform SU SU SU SU SU SU 17 U SU 1,2-Dichloroethane ·SU SU SU ;;,;;;i;~;gllQ;g;;;;;; SU 17 U . 1, 1-Dichloroethene SU SU SU SU SU SU 17 U SU 1,2-Dichloroethene SU SU SU SU SU SU 17 U SU Ethylbenzene SU SU SU SU SU SU 17 U SU Methylene Chloride SU SU 11 U SU SU SU 17 U SU Tetrachloroethene SU SU SU . 5 U SU 17 U SU Toluene SU SU SU SU SU SU 17 U SU Total Xylenes SU SU SU SU SU SU 17 U SU I, 1,2-Trichloroethane SU SU SU SU 17 U SU Trichloroethene SU SU SU SU SU SU 17 U SU Vinyl Chloride 10 U 10 U 10 U 10 U 10 U 33 U 10 U
---------li!!!!!!I l!!!!!!I 1!!!1111 liiiiilil -- - - - -NATIONAL STARCH & CHEMICAL CoMPANY SUPERFLND SITE
RECORD OF DECISION FOR OPERABlE UNIT 13
-21--
TABLE 3 FREQUENCY OF DETECTION AND CONCENTRATIONS OF VOLATILE ORGANICS DATA FOR GROUNDWATER SAMPLES
COLLECTED FROM PUSH-POINT SAMPLER, TEMPORARY MONITORING WELLS, AND SCREENED WATER SAMPLER
(Samples were only analyzed for VOCs) (continued) ·
GW-22 GW-24 GW-25 GW-26 GW-27 NS-13 NS-14
SAMPLING DATE 12/18/92 12/18/92 12/19/92 1/23/93 1/24/93 11/24/92 11/24/92
DEPTH TO WATER TABLE (feet) 7 16 • 11.5 14 19 5.44 5.2
COMPOUND
VOLATILE ORGANIC COMPOUNDS •
Acetone 10 U 10 U 20 U 21 U 14 U 12 UJ
Carbon Disuttide SU SU SU SU SU SU SU
Chloroethane 10U 10U 10U 10U 10U 10UJ 10UJ
Chloroform SU SU SU SU SU SU SUJ
1,2-Dichloroethane SU SU SU SU SU SUJ
.1, 1-Dichloroethene SU SU SU SU SU SU SUJ
1,2-Dichloroethene SU SU SU SU SU SU SU
Ethylbenzene SU. SU SU SU SU SU SUJ
Methylene Chloride SU SU 5 U 16 U 15 U 5 U S UJ
Tetrachloroethene SU SU SU SU SU SU SUJ
Toluene SU SU SU SU SU SU SUJ
Total Xylenes S U . 5 U S U 5 U S U S U 5 UJ
ll-1-,1-.-2--T-'--ri-ch-lo_r_o-et_h_a_ne-----+---s
5
-uu'-----+---'--'s5-UU=----+---'-
5
s-uu=----+----'5S-Uu=-----1If----'-'-----1----~----+l---5
5
-U~J---II
Trichloroethene
Vinyl Chloride 10 U 10 U 10 U 10 U 10 UJ
Concentrations are in micrograms per liter (µg/1) or parts per billion (ppb). · Shaded area (HJ depicts positive detections.
• · Detection limits for VOCs are elevated; prescreening of sample indicated matrix effects required medium or high level analysis.
D · Concentration reported from secondary dilution. J • Concentration is estimated. NA -Not Available A · Unusable results.
RE -Resampled. U · Undetected at the indicated quantitation limit. UJ • Undetected; the associated quantitation limit us an eStimated value.
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NB50 -
NSSO -
N 250 -
-350 -
-650
~ .! ll/ F )
ITWP•13 I ~ l : (2400J) .
Ir
~ ---. ------. § ~ ..
~ ... 'rs-\ ABANDONED ~ RAILROAD SPUR
·-----------------------------, : ' --------------,------:
I I '' '
'' I' I ' ': ' . .
' ' ' '
·---------------, •.••...••...•. TWP•11
'' ''
AREA 2 , (~OOJ)
-: ~
<iJ TWP•1D
(790J)
: : : :
TWP•B
@(4800J)
TWP•7 <el ~
PARKING LOT --(430) -~TWP•6
: ....... TWP•S@ (ND)
NS•13 (ND) TWP-4 r===;-___ (900) -\ (ND)
,~ v I LAG~N ~ TWP•2: @ TWP~
...J L_:_J (ND) (ND)
l~I l:m_J / E250 E .350 E 5
!
! i's
APPROXIMATE SCALE (ft)
0 1 00 200 300 .00 !ICIO
LEGEND·
@ TWP•B
(4800J)
■ NS•14
(ND)
TEMPORARY WEU. POINT
AND 1,2-DCA
CONCENTRATION (ppb)
MONITORING WELL
LOCATION ANO 1.2-0CA
CONCENTRA.Tl(?N (.Ppb)
FIGURE 5
CHAIN LINK FENCE-------...__
SAMPLING LOCATIONS FOR
GROUNDWATER (WATER TABLE)
VIA WELLPOINTS AND
CONCENTRATIONS OF
1,2-DICHLOROETHANE DETECTED
AT EACH WELLPOINT
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N 85-0 -
N 550 -
N250 -
N-350 -
LEGEND
6 GROUNDWATER SCREENING
GW-16 PO<Nr WITH 1.2-0CA
(420) CONCENTAATION jn ppo)
NOTE: Confirmation data
supplemented by grouncrwater
screening data
GW-S 6 c, GW-19
(3J) (4J) .•··:::
ABANDONED RAILROAD SPUR _______ __,
GW-27
(ND) 6
GW-246 GW-236
(ND) (ND)
GW-8B6
(ND)
I· I • I
E-350 E-
' I
CHAIN LINK FENCE __J
-----------. -::--·
GW-18A
(ND) 6GW-18
6 (ND)
c. GW-16A
(ND)
FIGURE 6
APPROXIMATE SCALE l'ft)
0 1 00 200 300 400 500
~ a:
Cl)
C, z a:
Q. Cl)
a: 1§ w u
SAMPLING LOCATIONS FOR GROUNDWATER
(SAPROLITE ZONE) VIA PUSH-POINT
SAMPLER, TEMPORARY MONITORING WELL,
AND SCREENED WATER SAMPLER AND
CORRESPONDING CONCENTRATIONS OF
1,2-DICHLOROETHANE DETECTED AT
. EACH SAMPLING LOCATION
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TABLE 4 FREQUENCY OF DETECTION, CONTAMINANTS DETECTED, AND MOST STRINGENT PROMULGATED STANDARDS FOR CONTAMINANTS DETECTED IN THE SAPROL/_TE ZONE OF THE AQUIFER
COMPOUND PROMULGATED
GROUNDWATER
STANDARDS
VOLATILE ORGANIC CoMPOUNDS
Acetone
Bromodichloromethane 100
2-Butanone
Chloroethane
Chloroform 0.19
1,2-Dichloroethane 0.38
1,2-Dichloroethene 70(cis)/1 00(trans)
Methylene Chloride 5
Tetrachloroethene 5
Toluene 1,000
Total Xylenes 400
1, 1,2-Trichloroethane 5
Vinyl Chloride 0.015
SEMI-VOLATILE ORGANIC COMPOUNDS
Di-n-butyl Phthalate
PESTICIDES
Delta-BHC
FREQUENCY
OF DETECTION
1/8
2/8
1/8
1/8
1/8
5/8
1/8
1/8
1/8
1/8
1/8
3/8
1/8
1/8
1/8
NS-13'
14 U
5 u
10 U
10 UJ
SU
1111l~lfil1Q1P~;;1!t
SU
SU
5 u
SU
SU
10 U
0.05 U
NS-14'
12 UJ
5 UJ
10 UJ
10 UJ
5 UJ
5 UJ
5 UJ
5 UJ
5 UJ
5 UJ
5 UJ
5 UJ
10 UJ
10 U
0.05 U
NS-33
(Background)
10 U
5 u
10 U
10 U
SU
SU
5 u
SU
SU
SU
SU
SU
10 u
10 U
0.05 U
NS-35 NS-37'
10 U
SU SU
SU
SU
10 U 10 U
0.05 U 0.05 U
NATIONAL STARCH & C!EMICAL COMPANY SUPERFUND SITE
RECORD OF DECISION FOR OPERABLE UNIT #3
NS-39 NS-42' NS-431
ll!,111,1§~1!111; 1 o u
1!i!l!J?lli1:; !11 s u
1;i'l:''?4,1j1~r01;;; 10 u
800 UJ 10 U
400UJ 5U
SU
6U SU
SU SU
SU
SU
400 UJ SU
800 UJ 10 U
10 U 10 U
0.05 U 0.05 U
- - - ----------------
-25-
TABLE 4 FREQUENCY OF DETECTION, CONTAMINANTS DETECTED, AND MOST STRINGENT PROMULGATED STANDARDS FOR CONTAMINANTS DETECTED IN THE SAPROLITE ZONE OF THE AQUIFER
COMPOUND
INORGANIC$
.Arsenic
Barium
Beryllium
Chromium
Cobatt
Cyanide
Lead
Manganese
Nickel
Vanadium
Zinc
PROMULGATED
GROUNDWATER
STANDARDS
50
200
4
50
154
15'
50
100
5,000
FREQUENCY
OF DETECTION
1/8
818
2/8
6/8
2/8
2/8
1/8
8/8
3/8
7/8
2/8
NS-131 NS-14' NS-33
(Backgrcund)
NS-35 NS-371
Concentrations are in micrograms per liter (µg/1) or parts per billion (ppb).
Shaded area C D depicts positive detections.
' -Detection iirrilts for VOCs are elevated, due to matrix effects and analyzed under medium or high level. ' -Action Level (EPA, Region IV Established Action Level).
D -Concentration reported from secondary dilution.
J -Concentration is estimated.
NA -Not analyzed.
U -Undetected at the indicated quantitation limit.
UJ -Undetected; the associated quanlitation limit is an estimated value.
NATIONAL STARCH & CHEMICAl. C.OMPANY SUPERFUNO SITE
RECORD OF DECISION FOR OPERABLE UNIT #3
NS-39 NS-421 NS-43'
!l \i1i~~I;!; 1 o u i1':!;!ff![t!Pffw1!s
13.1 u !li;!;lt! i:i; 38.9 u
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1050 -
750 -
•so -
150 -
-150
.750 I
-650
• NS-24
• NS-38
(1J)
(Not Sampled)
ABANDONED RAILROAD SPUR,------,
.350
I
-50
----s '
I
250
NS-34
e (ND)
I I
550
~ a: en Cl z
if a. en a: 13 LU (.)
1 1 .N)CA CONCENTRATION
CONTOUR (ppb)
1.2-0CA CONCENTRATION
(ppb), GROUNDWATER
SAMPLES
APPROXIMATE SCALE (ft)
JOO »o ,00 c,o ,00
FIGURE 7
CONCENTRATIONS AND
ESTIMATED EXTENT OF
1,2-DICHLOROETHANE
CONTAMINATION IN THE
BEDROCK ZONE OF THE
AQUIFER
-------------------NATIONAL STARCH & CHEMICAL COMPANY SUPERFLND SITE
RECORD OF DECISION FOR OP£RABI...E UNIT #3
-27,
TABLE 5 FREQUENCY OF DETECTION, CONCENTRATIONS DETECTED, AND MOST STRINGENT PROMULGATED
GROUNDWATER STANDARDS FOR CONTAMINANTS DETECTED IN THE BEDROCK ZONE OF THE AQUIFER
COMPOUND
VOLATILE ORGANIC CoMPOUNDS
Acetone
Bis(2-chloroethyl)ether
Chloroform
1,2-Dichloroethane
1, 1-Dictiloroethene
Methylene Chloride
Tetrachloroethene
Toluene
Total Xylenes
1, 1,2-Trichloroethane
Trichloroethane
Vinyl Chloride
PROMULGATED
GROUNDWATER
STANDARDS
0.19
0.38
7
5
5
1,000
400
5
2.8
0.015
SEMI-VOLATILE ORGANIC COMPOUNDS
Bis(2-ethylhexyl)phthalate 6
Di-n-butyl Phthalate .
Di-n-octyl Phthalate
FREQUENCY NS-34 NS-36 NS-38' N5-40 N5-41 N5-44'
OF
DETECTION (Backgmund)
2/6 10 U
3/6 10 U
1/6 5U 5U
4/6 5U 5U
1/6 5U 5U 5U
2/6 5U 5U 5U
1/6 5U 5U 5U
1/6 5U 5U 1,200 UD 5U
2/6 5U 1,200 UD 5U
2/6 5U 1,200 UD 5U
2/6 5U 1,200 UD 5U
2/6 10 U 2,500 UD 10 U
1/6 10 U 10 U 10 U 10 U 10 U
1/6 10 U 10 U 10 U 10 U 10 U
1/6 10 U 10 U 10 U 10 U 10 U
-------------------NATIONAL STARCH & CI-EMICAL CoMPAHY SUPERFUND SITE
RECORD OF DECISION FOR OPERABLE UNIT 13
-28-
TABLE 5 FREQUENCY OF DETECTION, CONCENTRATIONS DETECTED, AND MOST STRINGENT PROMULGATED
GROUNDWATER STANDARDS FOR CONTAMINANTS DETECTED IN THE BEDROCK ZONE OF THE AQUIFER
COMPOUND
INORGANICS
Barium
Chromium
Cobalt
Copper
Lead
Manganese
Vanadium
Zinc
PROMULGATED
GROUNDWATER .
STANDARDS
200
50
1,000
1S'
50
5,000
FREQUENCY
OF
DETECTION
5/6
3/6
, 1/6
2/6
1/6
6/6
4/6
2/6
NS-34 NS-36 NS-38'
(Background)
Concentrations are in micrograms per liter (µg/1) or parts per billion (ppb).
Shaded area C t ) depicts positive detections.
• -Detection limits for VOCs are elevated, due to matrix effects and analyzed under medium or high level.
b -Action Level (EPA, Region IV Established Action Level).
D -Concentration reported from secondary dilution. .
J -Concentration is estimated,
U -Undetected at the indicated quantitation limit,
UJ -Undetected; the associated quantitation limit is an estimated value.
N5-40 N5-41 N5-44'
-------------------NATIONAL STARCH & CI-EMICAL COMPANY SUPERFUND SITE
RECORD OF DECISION FOR OPERABLE UNIT #3
-29-
TABLE 6 SUMMARY OF DETECTABLE CONCENTRATIONS OF 1,2-DICHLOROETHANE IN SURFACE
WATER, SEDIMENT, AND SOIL SAMPLING OF THE NORTHEAST TRIBUTARY
Sample Number' March 1987 June 1987 Oct., Nov. 1989 July 1990 June 1991 May 1992 June 1992 January 1993
SW/SE-01 1,400/18b ----------------
NS-W1/S1 ---ND/ND -------------·
NS-W2/S2 ... ND/ND ·-------· ··-. ..
NS-W3/S3 -·· ND/ND ·--·---· -· ... --
NS-W4/S4 ·--4,400 J/3,400 J ·-· -· -· -· -·· ··-
SW/SE-09 -·· ... 350/76 160/980 77/23 150 J/9 J --· --
SW/SE-10 ... ··-1,200/14 1,600/ND 810/310 1,300 J/610 D --· -·
SW/SE-11 ... ... ND/ND ND/ND ND/ND ND/ND ... -·
SW-12A ·-· ·-· ... --------ND ---(Background)
SW/SE-12 -·· ------NS/ND NS/ND 2J/ND ---ND/ND (Background)
SW/SE-13 -·· --· ---880/3,400 1,80017,400 . 3,200 0/290 --200 J/1,200 D
SW/SE-14 --------1, 700/1, 200 1,200/4,200 590 0/1, 000 D -----
SW/SE-15 ··-----· ND/ND ND/ND. -------
SW/SE-16 ·--·----· ----·-1,300 DJ/61 ------
S0-01 -·· ---·-· ND -----------
S0-02 --· ---·--ND --· -----· ---
-------------------
-30-
TABLE 6 SUMMARY OF DETECTABLE CONCENTRATIONS OF 1,2-DICHLOROETHANE IN SURFACE
WATER, SEDIMENT, AND SOIL SAMPLING OF THE NORTHEAST TRIBUTARY
Sample Number' March 1987 June 1987 Oct., Nov. 1989 July 1990 June 1991
SO-03 ---------ND ---
SO-04 ---------ND --
SO-05 ---------650 ---
SO-06 --------57 --
SO-07 ---------ND ---
Concentration for surface water samples are in micrograms per liter (µg/1) or parts per billion (ppb)
Concentration for ·sediment samples are in milligrams per kilogram (mg/kg) or parts per billion (ppb)
• SW/SE: surface water/sediment; NS-W/S: water/sediment (EPA samples); SO: soil
NATIOKM. STARCH & CI-EMICAL COMPANY SUPERFUND SITE
RECORD OF DECISION FOR OPERABLE UNIT #3
May 1992 June 1992 January 1993
-------
--------
--------
-------
---------
° First value represents concentration of 1,2-DCA in surface water/Second value represents concentration of 1,2-DCA in sediment
D Concentration reported from secondary dilution
J -Concentration is estimated
ND -Analyzed for but not detected
NS -Not sampled (no water available)
U -Undetected at the indicated quantitation limit
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-31-
NATIONAL STARCH & CHEMICAL COMPANY SUPERFUND SITE
REOORD Of DECISION FOR OPEAABLE UNIT 13
TABLE 7 CONCENTRATIONS OF ORGANICS AND INORGANIC$ IN SURFACE WATER
AND SEDIMENT FROM LOCATIONS SW/SE-12 AND SW/SE-13
COMPOUND/ANAL YTE
ORGANICS
Acetone
1 ,2-Dichloroethane
IN0RGANICS
Antimony
Arsenic
Barium
Beryllium
Chromium
Cobalt
Copper
Lead
Manganese
Mercury
Nickel
Selenium
Thallium
Vanadium
Zinc
Samples collected in January 1993.
SW-12
(Background)
10 U
5U
30 U
10 U
20 U
10 U
20 U
2U
SW-13
30 U
10 U
20 U
10 U
20 U
2U
SE-12
(Background)
SE-13
Shaded area ( J ) depicts posttive detections. ·
Concentration for surface water samples are in micrograms per ltter (µg/1) or parts per billion (ppb)
Concentration for sediment samples are in milligrams per kilogram (mg/kg) or parts per billion (ppb)
SW -Surface Water Sample ·
SE -Sediment Sample
D -Concentration reported from secondary dilution.
J -Concentration is estimated.
R -Unusable results.
U -Undetected at the indicated quantttation limit.
UJ -Undetected; the associated quantttation limit is an estimated value.
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N850 -
N550 -
N 250
ABANDONED .RAILROAD SPUR' ____ _..,
: :···---------------, :··----, . . . '. . . ' .. .. . . . . : : .. .. ''
PARKING LOT~
AREA2
NS-13
r===;--__ (_900) \
tJ ~G~ 1-'"f°" I •
L .. -50--c::::;--,_s===<--:;;:::1 =~ i
E-350 LiliQLl /
CHAIN LINK FENCE-----------.
SW-12A
(ND)
SW-09
(150J)
... --. --::::.----
SW-10
(1300J)
E 250
SW-16
(1300J)
APPROXIMATE SCALE rf't)
0 100 200 300 ~
.LEGEND
"'
ASW-14
(590)
SURFACE WATER
LOCATION AND 1,2-0CA
CONCENTRATION (ppo)
■ NS-14
E 5 (ND)
FIGURE 8
MONITORING WELL
LOCATION AND 1.2-0CA
CONCENTRATION (ppo)
SURFACE WATER SAMPLING
LOCATIONS ALONG THE
NORTHEAST TRIBUTARY AND
ASSOCIATED CONCENTRATIONS
OF 1,2-DICHLOROETHANE
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NBSO -
N550 -
N250
ABANDONED
RAILROAD SPUR
. '
: .. ;
'' '' : : : :.
''
'' '' '' '' '' '' : :
: : " '' : :
AREA2
.i ...,
' ' ' ' ' : ' ' ' '
' ' ' ' : '
SE·09
(9J)
SE·10
(610)
SE·16
(61)
: : .....•..... : : SE·13
APPROXIMATE SCALE (ft)
1 00 200 300 «lO 500
: : : : ..... : : ....... , .............. , ... ..(?~0) ..... . ~~ :;...1-::: :: ~ -~---_ ------. ------ --------------, ~-: _-:: .· :, ,--------. ------
-650
PAAJ<ING LOT~
'-----------'
LAGOON
1
E .350 E 250
SE·12
SE·14
(1000)
LEGEND
A SE·13
(290)
STREAM SEDIMENT SAMPLE
LOCATION AND 1,2-0CA
CONCENTRATION (ppb)
(ND) FIGURE 9
CHAIN LINK FENCE:------...__ SEDIMENT SAMPLING LOCATIONS
ALONG THE NORTHEAST TRIBUTARY
AND ASSOCIATED CONCENTRATIONS
OF 1,2-DICHLOROETHANE
'/
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-34-
NATIONAL STARCH & CHEMICAL CoMPANY SUPERFUN0 SITT'
RECORD OF DEClSON FOR OPERABLE UNIT 13
Surface water and sediment samples were collected on three occasions from the Northeast Tributary just prior to its leaving the NSCC prqperty. The first samples (sampling location NS-W2/S2) were collected in June 1987, the second set of samples were collected in July 1990 (sampling location SW/SE-15), and the last time in June 1991 (again, at sampling location SW-SW-15). As can be seen in Table 6, no contaminants were detected downstream of the plant prior to the stream leaving NSCC property which indicates that under normal weather conditions, no contamination is leaving the Site via the Northeast Tributary.
Surface water and sediment samples were also collected to perform an ecological assessment on this stream. The results of the ecological assessment are discussed in ssSection 8.6.
The Northeast Tributary is not specifically classified due to the low flow conditions within the stream, however, it is considered as a Class "C" stream under North Carolina Administrative Code, Title 15A, Subchapter 28 (NCAC T1 SA:028) because the receiving stream of the Northeast Tributary, Grants Creek, is classified as a Class C stream. A Class C stream is defined as being suitable for secondary recreation and the "propagation of natural trout and maintenance of trout". Neither sport nor commercial fish species were observed in the surface waters during the RI field work.
5.4 HYDROGEOLOGICAL SETTING
The groundwater beneath the NSCC property is designated as Class GA in accordance with North Carolina's water classification system and Class IIA under USEPA Groundwater Classification Guidelines (December 1986). The Class GA classifications means that the groundwater is an existing or potential source of drinking water supply for humans as specified under North Carolina Administrative Code, Title 15, Subchapter 2L (NCAC T15:02L). EPA classifies the groundwater as Class IIA since the aquifer is currently being used as a source of drinking water in the vicinity of the NSCC facility. Therefore, the groundwater needs to be remediated to a level protective of public health and the environment as specified in Federal and State regulations governing the quality and use of drinking water.
At the NSCC site, a thick mantle of residual soil extends from the ground surface to the bedrock. This mantle, the saprolite, is composed of clay-rich residual soils which range from silty to sandy clays. The saprolite is derived from the intense chemical weathering of the crystalline bedrock and has retained the structural fabric of the parent materials below the oxidation profile. These residual soils exhibit increasing amounts of sand-sized relict mineral grains below the oxidation horizon and closer to the bedrock. There appears to be a complete gradation from saprolite/friable weathered bedrock, to fractured bedrock/sparsely fractured bedrock. The depth to bedrock ranges from 10 to 100 feet below ground surface. The deepest bedrock was encountered was in the vicinity of the Northeast Tributary. Figure 10 shows the orientation of the hydrogeological cross-section of the Site which is displayed in Figure 11.
Soil fissures near the water table are filled with geothite, presumably derived from the weathering of the iron-bearing minerals present in the parent rock. There appears to be no confining layer between the saprolite and bedrock. Therefore these two lithologic units are hydraulically interconnected, and there is little or no impedance between these two zones. ) .
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-35-
NATlONAI. STARCH & CHEMICAL COMPANY SUPERFUNO SITE
RECOOD OF DECISION FOR O!>ERABI.E UNIT t3
The lithology of the soils underlying the Site was determined from drilling logs. The thickness of the soil mantle varies across the Site. It appears that Area 2 occupies a structural high and that the bedrock surface slopes steeply away from this area to the east and more gently to the north. Rock core records show that the upper 10 to 15 feet of bedrock is deeply weathered and friable. Bedrock begins to appear nonfriable and fresh 15 to 25 feet below the bedrock/saprolite interface. However, fractures continue to be frequent and fracture surfaces often exhibit oxidation staining to depths of 40 to 100 feet below the bedrock/saprolite interface. Fracture frequency diminishes downward from the bedrock/saprolite interface. It has been estimated that the bedrock becomes competent approximately 200 feet below ground surface.
Water level measurements from the water table/saprolite zone of the aquifer indicate that hydraulic heads decrease from both the east and west towards the Northeast Tributary and towards the north along the stream. This data indicates that the Northeast Tributary acts as a groundwater divide for the saprolite zone of the aquifer and receives groundwater discharge along its entire reach. This explains the presence of contaminants being detected in the surface water and sediment of this tributary. Additional data needs to be collected during the RD to determine where groundwater in the bedrock zone of the aquifer is discharging.
The hydraulic conductivity of the saprolite materials and the bedrock ranges from 0.72 to 3.35 feet per day (ft/day) and 0.01 to 1.13 ft/day, respectively. Based of the above information, the horizontal flow of groundwater in the saprolite was estimated to have a velocity of 80 feet/year (ft/yr) in the lagoon ar.ea and 27 ft/yr in Area 2. Additional information will be collected during the RD to better define the horizontal flow velocity in the bedrock zone of the aquifer.
5.5 PATHWAYS AND ROUTES OF EXPOSURE
The chemicals of potential concern for each environmental media sampled are listed in Table 8. This list includes VOCs, SVOCs, and metals. These constituents were incorporated into Table 8 because 1) the contaminant detected was above the chemical-specific applicable or relevant and appropriate requirement (ARAR),. 2) the contaminant was not detected in the upgradientlbackground sample(s) for that particular environmental media, or 3) the concentration detected on-site· was twice the upgradientlbackground concentration. The last condition applies particularly to the inorganic constituents.
An exposure pathway is the route or mechanism by which a chemical agent goes from a source to an individual or population (i.e., the receptor). Each exposure pathway must include the following:
A source or mechanism of chemical release to the environment
A transport medium (e.g., soil, groundwater, air, etc.)
• An exposure point (where a receptor will contact the medium) I An exposure route (i.e., ingestion, inhalation, or dermal contact).
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A pathway is considered complete when all of the above elements are present.
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-36-
NA!lONAl STARCH & CHEMICAL COMPANY SUPERRJNO SITE
AEOORO OF DECISION FOR OPERABLE UNIT #3
Based on the information collected during the RI, the four transport mechanisms occurring at the NSCC site are:
• where soils exhibit high levels of contaminant, infiltration of recharge will form leachate, which will transport the dissolved contaminants downward to the water table
• once contaminants have reached the water table, the dissolved contaminants will be transported with groundwater
• where contaminated groundwater discharges to a surface water body, the contaminants will mix with the surface water and be transported downstream
• where contaminants in the water exhibit an affinity for partitioning to organic carbon, some contaminants may become adsorbed to the surface sediment in the receiving stream and ·maybe transported with stream bedload during flooding.
The air pathway was qualitatively evaluated but not quantitatively evaluated as an exposure pathway for volatilized chemicals and particulate emissions from surface soils for the following reasons:
1) Much of the Site is covered with either concrete or asphalt;
2) Five v·ocs were detected in surface soil; and
3) Each of the VOCs detected were at low concentrations, the highest concentration for each contaminant detected in the surface soil are listed below:
Contaminant
acetone
2-butanone
chloroform
1,2-DCA
toluene.
microgram per kilogram (blQ/kg\
3,500
25
2
15
4
Potential current and future exposure pathways under are summarized in Table 9. This table presents potential routes of exposure, potential receptors, an evaluation of pathway completeness, and an assessment of exposure potential. As can be seen, there are no current complete exposure pathways that pose an unacceptable risk to human health or the environment. Since use of the land surrounding the NSCC facility is a mixture of residential and commercial, it is possible that the Site may be used as either residential or commercial area in the future, therefore, both scenarios were evaluated and incorporated into Table 9.
In summary, the following pathways were evaluated in the risk assessment:
Potential current exposure under current land use conditions outside plant operations area to contaminants in surface water and sediment and springs through incidental ingestion and dermal contact, and inhalation.
-I!!!!!!! !!!!!I 11111:1 ------- - - - - - - - -
N 1300 -
NS-32
g
~ 0 z
~
:5 -1-----n. N 300-
N0.00
N -700
E-3200
EX-01
E-2200
A.NS-26
NS-27 ...
AEX-04
PLANT EAST (It)
E -1200
NS-15 ...
E-200
-----------E0.00 \~
CHAIN LINK FENCE \ '---
■
SCALE 1111
/"lil"l""-iiii.l! ~
0 IIIO 200 DI -1iC10
LEGEND
WCATDHS WHERE RHUS.AI.. S8A2-2 SCAHNNOSAMPt.E
WA.SREACHED
NS-14 WJNfTORl'tCl WELL
WHERE REAJSAL WAS MACHED
FIGURE 10
/ llEOAOCk ELEVATDH oo,,mu, 0 ;::
ORIENTATION AND LOCATION OF
HYDROGE0LOGIC CROSS SECTION
SHOWN IN FIGURE 7
liiilllia ________________ _
000.
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1000
A
LEGEND
500
2000
Olst.wlCe(fNQ
•
Vrdcli' E,caggwallon: 4X
NS-15
500
<000
A'
FIGURE 11
HYDROGEOLOGIC CROSS SECTION A-A'
·-------------------
TABLE 8 CHEMICALS OF POTENTIAL CONCERN
CHEMICAUANAL YTE
(Contaminant of
Concern)
Acetone
Bis(2-chloroethyl)ether
Bromodichloromethane
2-Butanone
Carbon Disuttide
Chloroethane
Chloroform
Dibromochloromethane
1,2-Dichloroethane
1, 1-Dichloroethene
1,2-Dichloroethene
1,2-Dichloropropane
Ethylbenzene ·
Methylene Chloride
Phenols
Styrene
SURFACE
SOIL
X
X
X
X
SUBSURFACE
SOIL (to 10
feet)
X
X
X
X
X
X
X
SUBSURFACE
SOIL (to Water
Table)
X
X
X
X
X
X
X
-39-
GROUNDWATER
X
X
X
X
X
X
X
X
X
SURFACE WATER
OUTSIDE PLANT
OPERATIONS
AREA
X
NATIONAL STARCH & Cl'EMICAL COMPANY SUPERFUNO SITE
SURFACE WATER
INSIDE PLANT
OPERATIONS
AREA
X
X
X
REcoRD OF DECISION FOR OPERABLE UNIT #3
SEDIMENT
OUTSIDE PLANT
OPERATIONS
AREA
X
X
X
X
X
X
SEDIMENT
INSIDE PLANT
OPERATIONS
AREA
X
X
X
X
-------------------
TABLE 8 CHEMICALS OF POTENTIAL CONCERN
CHEMICAUANAL YTE SUBSURFACE SUBSURFACE
(Contaminant of SURFACE SOIL (to 10 SOIL (to Water
Concern) SOIL feet) Table)
Tetrachloroethene X X
Toluene X X X
Total Xylenes
1, 1,2-Trichloroethane
T richloroethene
Vinyl Chloride X X
Bis(2-ethylhexyl)phthalate x-X
Di-n-butyl Phthalate
Di-n-octyl Phthalate
Aluminum
Antimony X X
Arsenic
Barium
-40-
SURFACE WATER
GROUNDWATER OUTSIDE PLANT
OPERATIONS
AREA
X
X
X
X
X
X
X
X
X
X
X
X
X
NATIONAL STARCH & Ct-EMICAL COMPANY SUPERFUND SITE
SURFACE WATER
INSIDE PLANT
OPERATIONS
AREA
RECORD OF 0ECtSION FOR OPERABLE UNIT #3
SEDIMENT
OUTSIDE PLANT
OPERATIONS
AREA
X
X
X
SEDIMENT
INSIDE PLANT
·oPERATIONS
AREA
X
X
·-------------------NATIOWil STARCH & CtEMICAL COMPANY SUPERFUND SITE
RECORD OF DECISION FOR OPERABU: UNIT #3
-41-
TABLE 8 CHEMICALS OF POTENTIAL CONCERN
CHEMICAUANAL YTE SUBSURFACE SUBSURFACE SURFACE WATER SURFACE WATER SEDIMENT SEDIMENT (Contaminant of SURFACE SOIL (to 10 SOIL (to Water GROUNDWATER OUTSIDE PLANT INSIDE PLANT OUTSIDE PLANT INSIDE PLANT
Concern) SOIL leet) Table) OPERATIONS OPERATIONS OPERATIONS OPERATIONS
AREA AREA AREA AREA
Beryllium X X X
Cadmium X
Chromium X
Cobalt X X X
Copper X X
Cyanide X X X
Lead X X
Manganese X X X X X
Mercury X .
Nickel X X X
Selenium X
Silver X
Thallium X X X
Vanadium X X X
Zinc X
liiiil liliil ---- - ------------NAnotW. STARCH & CI-EMICAL COMPANY SUPERA.ND SITE
RECORD OF DECISION FOR OPERABlf UNIT #3
-42-
TABLE 9 POTENTIAL CURRENT AND FUTURE EXPOSURE PATHWAYS OF HUMAN EXPOSURE To CONTAMINANTS
RECEPTOR
CHILDREN
ADULTS
MIGRATION/EXPOSURE
PATHWAY.
Incidental ingestion of surface soils
Dermal contact with surface soils
Incidental ingestion of subsurface soils
Dermal contact with subsurface soils
Migration of contaminants from soil to
groundwater, creek, and springs. Exposure via
incidental ingestion, drinking water ingestion,
dermal contact at stream and home, inhalation of
voes at stream and home.
Incidental ingestion of surface soils
Dermal contact with surface soils
Incidental ingestion of subsurface soils
INCLUDED IN RISK
ASSESSMENT?
CURRENT
LAND USE
Yes
Yes
No
No
No
No
No
No
FUTURE
LAND _USE
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
REASON FOR
INCLUSION/EXCLUSION
Surface soil is currently available for contact by on-site
receptors
Surface soil is currently available for contact by on-site
receptors
Subsurface soil is currently unavailable for contact.
. Future development could expose subsurface soil for
future receptors. Children may ingest significantly more
soil than adults .
. Fulure development could expose subsurface soil for
future receptors
Contaminant may migrate from soil to groundwater
Surface soil is currently available for contact by on-site
receptors
Surface soil is currently available for contact by on-stte
receptors
Subsurface soil is currently unavailable for contact.
Future development could expose subsurface soil for
future receptors.
-------------------NATIONAL STARCH & CI-EMICAL CoMPANY 5uPERFUNO SITE
RECORD OF DECISION FOR OPERABLE UNIT #3
-43-
TABLE 9 POTENTIAL CURRENT AND FUTURE EXPOSURE PATHWAYS OF HUMAN EXPOSURE TO CONTAMINANTS
RECEPTOR
CHILDREN
ADULT
MIGRATION/EXPOSURE
PATHWAY·
Dermal contact with subsurface soils
Migration of contaminants from Site to springs;
incidental ingestion of sprtng water
Migration of contaminants from Site to springs;
dermal contact with sprtng water
Use of groundwater as domestic water source:
ingestion of drinking water
Use of groundwater as domestic water source:
dermal contact with water
Use of groundwater as domestic water source:
inhalation of VOCs from household water use
Migration of contaminants from Site to springs;
incidental ingestion of and dermal contact with
sprtng water
Use of groundwater as domestic water source:
ingestion of drinking water
Use of groundwater as domestic water source:
dermal contact with water
INCLUDED IN RISK
ASSESSMENT?
CURRENT FUTURE
LAND USE LAND USE
No Yes
Yes Yes
Yes Yes
No Yes
No Yes
No Yes
No No
No Yes
b
No Yes
REASON FOR
INCLUSION/EXCLUSION
Subsurface soil is currently unavailable for contact
Future development could expose subsurface soil for
future receptors.
Site-related contaminants are present in the creek as a
result of groundwater discharge. Site-related chemicals
area also likely to be present in the springs near the
creek.
Site-related contaminants are present in the creek as a
result of groundwater discharge. Site-related chemicals
area also likely to be present in the sprtngs near the
creek.
Fub.Jre development could result in a production well in
this area
Future development could result in a production well in
this area
Future development could result in a production well in
this area
Adults are not expected to play in sprtngs
Future development could result in a production well in
this area
Future development could result in a production well in
this area
liiiii iiii -----------------NATIONAL STARCH & CI-EMICAL COMPANY SUPEAFUND SITE
RECORD OF DECISION FOR 0PERA8lE UNIT 13
-44-
TABLE 9 POTENTIAL CURRENT AND FUTURE EXPOSURE PATHWAYS OF HUMAN EXPOSURE TO CONTAMINANTS
RECEPTOR
ADULTS
MIGRATION/EXPOSURE
PATHWAY·
Use of groundwater as domestic water source:.
inhalation of voes from household water use
Migration of contaminants from Site to creek;
incidental ingestion of creek sediment
Migration of contaminants from Site to creek;
incidental ingestion of surface water
Migration ol contaminants from Site to creek;
dennal contact with sediment
Migration of contaminants from Site to creek;
dennal contact with surface water
Migration of contaminants from Site to creek;
inhalation of contaminants partitioning to air from
surface water
All pathways identified above
INCLUDED IN RISK
ASSESSMENT?
CURRENT
LAND USE
No
Yes
Yes
Yes
Yes
No
FUTURE
LAND USE
Yes
Yes
Yes
Yes
Yes
No
REASON FOR
INCLUSION/EXCLUSION
Future development could result in a production well in
this area
Site-related contaminants are present in creek water and
sediment Children living in residential area nearby may
play in the creek
Site-related contaminants are present in creek water and
sediment Children living in residential area nearlly may
play in the creek
· Site-related contaminants are present in creek water and
sediment Children living in residential area nearby may
play in the creek
Site-related contaminants are present in creek water and
sediment . Children living in residential area nearby may
play in the creek
Detected chemicals may volatilize into air
Adults are not expected to swim or play in the creek
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NATIONAL STARCH & CHEMICAL COMPANY SUPERRJNO SITE
RECORD OF DECISION FOR OPEAABl.f UNIT 13
• Potential current exposure under current land use conditions inside plant operations area to
contaminants in surface water and sediment, surface soil, and springs through incidental
ingestion and dermal contact, and inhalation.
• Potential future exposure u·nder future land use conditions inside plant operations area to
contaminants in surface water and sediment, surface soil, and springs
• Future exposure of onsite residents to contaminants in the surface water and sediment,
surface soil, subsurface soils, groundwater, and springs through ingestion, inhalation, and
direct contact;
• Future exposure of potential onsite construction workers to contaminants in soil (surface and
subsurface) through incidental ingestion and direct contact; and to contaminants in
groundwater, surface water, and sediment through direct contact.
6.0 SUMMARY OF SITE RISKS
CERCLA directs the Agency to protect human health and the environment from current and future
exposures to hazardous substances at Superfund sites. In order to assess the current and future
risks from the NSCC Site, a baseline risk assessment was conducted in conjunction with the RI.
This section of the ROD summaries the findings concerning the impact to human health and the
environmerit if contaminated media (i.e., groundwater) at the Site were not remediated. The
baseline risk assessment for OU #3 is incorporated into the June 2, 1993 OU #3 RI Report which
can be found in the NSCC OU #3 Administrative Record.
The following sections will concentrate on the risks posed by contaminants in the groundwater
and surface water and sediment. The risks posed by Site soils will be summarized in OU #4.
6.1 CONTAMINANTS OF CONCERN
Table 8 provides a comprehensive list of all the contaminants identified as chemicals of potential
concern for all the environmental media sampled at the Site. Identified in the right hand columns
of Table 10 are those Site contaminants that pose a risk above acceptable levels as identified
during the baseline risk assessment encompass. It is these contaminants that are considered
during the FS process. ·
The extent of the plumes are shown in Figures 3, 4, and 7 and the concentrations of
contaminants detected in the groundwater are presented in Tables 2, 3, 4, and 5.
There are residents within a three-mile radius to the Site who obtain drinking water from private
wells. The nearest private potable wells are approximately 400 feet north of the NSCC property
line. These private potable wells are completed in the bedrock formation.
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6.2 EXPOSURE ASSESSMENT
NATIONAL STARCH & CHEMICAi. CoMPANY SUPERF\/ND SITE
RECORD OF DEClSON FOR OPERABlE UNIT #3
The objective of the exposure assessment is io estimate the type and magnitude of potential exposures to the chemicals of concern that are present at the Site. The results of the exposure assessment are combined with chemical-specific toxicity information to characterize potential risks. The exposure assessment involves the following four (4) major steps:
• characterization of the physical setting and identification of human receptors • identification of potential land-use scenarios
• Identification of potential exposure pathways
• quantification of intakes.
The following pathways were evaluated in the risk assessment for each of the environmental media adversely impacted by Site activities. For soils, they included:
• Incidental ingestion of soil
• Dermal contact with soil.
For groundwater, they included:
• Incidental ingestion of groundwater at springs ( current)
• Dermal contact with groundwater ar springs (current)
• Ingestion of groundwater as drinking water (future)
• Dermal contact with groundwater during domestic water use (future)
• Inhalation of volatile chemicals partitioning to the air from groundwater during domestic water use.
For surface water and sediment, they included:
• Incidental ingestion of creek sediment
• Incidental ingestion of surface water
• Dermal contact with creek sediment
• Dermal contact with surface water
• Inhalation of volatile chemicals partitioning to air from surface water.
Although, the impacted groundwater is not currently being used as a drinking water source, the aquifer itself is being used as a source of drinking water; therefore, this resource should be maintained at drinking water quality.
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NA TlONAI. STARCH & CHEMICAL CouPANY SU PE RAJ NO SITE
REOORD OF DECISION FOR OPERABLE UNIT #3
Table 11 provides the reasonable maximum exposure concentrations which were used in calculating the carcinogenic and noncarcinogeriic risks associated with each chemical of concern. Table 12 lists the specific parameters used to model the site-specific intakes for OU #3. And Table 13 provides the computed chemical intakes values along with the calculated risks.
6.3 TOXICITY ASSESSMENT
The toxicity assessment was conducted to further determine the potential hazard posed by the chemicals of concern for which exposure pathways have been identified. Available evidence is weighed in regards to the potential of particular contaminants to cause adverse effects in exposed individuals and to provide, where possible, an estimate of the relationship between the extent of exposure to a contaminant and the increased likelihood and/or severity of adverse effects.
Cancer slope factors (CSFs) have been developed by EPA's carcinogenic Assessment Group for estimating excess lifetime cancer risks associated" with exposure to potentially carcinogenic chemicals. CSFs, which are expressed in units of milligrams/kilogram/day"' [(mg/kg/day)"'], are multiplied by the estimated intake of a potential carcinogen, in (mg/kg/day), to provide an upper-bound estimate of the excess lifetime cancer risk associated with exposure at that intake level. The term "upper-bound" reflects the conservative estimate of the risks calculated from the CSF. Use of this approach makes underestimation of the actual cancer risk highly unlikely. CSFs are derived from the results of human epidemiological studies or chronic animal bioassays to which animal-to-human extrapolation and uncertainty factors have been applied.
Reference doses (R,Ds) have been developed by EPA for indicating the potential for adverse health effects from exposure to chemicals exhibiting noncarcinogenic (systemic) effects. R,Os, which are expressed in units of mg/kg/day, are estimates of lifetime daily exposure levels for humans, including sensitive individuals, which will result in no adverse health effects. Estimated intakes of chemicals from environmental media (i.e., the amount of chemical ingested from contaminated drinking water) can be compared to the R,O. R,Os are derived from human epidemiological studies or animal studies to which uncertainty factors have been applied (i.e., to account for the use of animal data to predict effects on humans). These uncertainty factors help ensure that the R,Ds will not underestimate the potential for adverse noncarcinogenic effects to occur.
The Agency has derived CSFs and R,Os for the contaminants of concern at the Site for use in determining the upper-bound level of cancer risk and non-cancer hazard from exposure to a given level of contamination. These values are provided in Table 14.
6.4 RISK CHARACTERIZATION
The risk characterization step of the baseline risk assessment process integrates the toxicity and exposure assessments into quantitative and qualitative expressions of risk. The output of this process is a characterization of the site-related potential noncarcinogenic and carcinogenic health effects.
iiiii iiiiil iiiii iliil --- - - - - - - - - - - - -
NATIONAL STARCH & CHEMICAL COMPANY SUPERAMD SITE
RECORD OF DECISION FOR OPERABLE UNIT 13
-48-
TABLE 10 CHEMICALS OF CONCERN POSING RISK
CHEMICALS OF CONCERN CHEMICALS WHICH WILL POSE AS
IN MEDIA A RISK
CHEMICALS OF CONCERN Groundwater Soll Sediment Surface Groundwater I Soll Sediment Surface
Water Water
~ B·c
Acetone X X X X X
Bis(2-Chloroethyl)ether X X
Bromodichloromethane X X X
2-Butanone X X X
Carbon Disulfide X
Chloroethane X
Chloroform X X X
1,2-0ichloroethane X X X X X X X X
1, 1-Dichloroethene X X
1,2-Dichloroethene X X X
1,2-0ichloropropane X X
Ethylbenzene X X
Methylene Chloride X X X X X
Phenols X X X
Styrene X
Tetrachloroethene X X X X
-------------------NATIONAL STARCH & CtEMICAL COMPANY SUPERFlflD SITE
RECORD OF DECISION FOR OPERABLE UNIT #3
-49-
TABLE 10 CHEMICALS OF CONCERN POSING RISK
CHEMICALS OF CONCERN CHEMICALS WHICH WILL POSE AS
IN MEDIA A RISK
CHEMICALS OF CONCERN Groundwater Soll Sediment Surface Groundwater Soll Sediment Surface
Water Water
Toluene X X X X X
Total Xylenes X X
1, 1,2-Trichloroethane X X X
T richloroethene X X X
Vinyl chloride X X X X
Bis(2-Ethylhexyl)phthalate X X X
Di-n-butyl Phthalate X
Di-n-octyl Phthalate X
Aluminum X
Antimony X X X X
Arsenic X X X
Barium X
Beryllium X X X X X
·~------------------NATIONAL STARCH & CHEMICAL COMPANY SUPERFI.MD SITE
RECORD OF DECISION FOR OPERABLE UNIT 13
-50-
TABLE 10 CHEMICALS OF CONCERN POSING RISK
CHEMICALS OF CONCERN CHEMICALS WHICH WILL POSE AS IN MEDIA A RISK
CHEMICALS OF CONCERN Groundwater Soll Sediment Surface Groundwater Soll Sediment Surface Water Water
Cadmium X X X .
Chromium X X
Cobalt X X X
Copper X X X
Cyanide X X X X
Lead X X
Manganese X • X X
Mercury X X
Nickel X X X
Selenium X X
Silver X X X
Thallium X X X X
Vanadium X X
Zinc X
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NATIONAL STARCH & C~MICAL CoMPANY SUPERFLND SITE
RECORD OF DECISION FOR 0P£fW!lE UNIT '3
-51-
TABLE 11 UPPER CONFIDENCE LIMITS (95%) FOR CHEMICALS AND ASSOCIATED USED To EVALUATE RISK CONDITIONS
CHEMICAUANALYTE
(Contaminant of Concern)
Acetone
Bis(2-chloroethyl)ether
2-Butanone
Carbon Disulfide
Chloroethane
Chloroform
1,2-Dichloroethane
1,2-Dichloroethene
Ethylbenzene
Methylene Chloride
Styrene
Tetrachloroethene
Toluene
Total Xylenes
EXPOSURE POINT
CONCENTRATION
FOR GROUNDWATER
(mg/I)
0.04
0.00902
0.00522
0.431
0.0071
0.00603
0.00478
0.0047
EXPOSURE POINT
CONCENTRATION
FOR SURFACE
WATER OUTSIDE
PLANT OPERATIONS
AREA IN NORTHEAST
TRIBUTARY (mg/I)
1.04
0.00258
EXPOSURE POINT ·
CONCENTRATION
FOR SURFACE
WATER INSIDE PLANT
OPERATIONS AREA IN
NORTHEAST
TRIBUTARY (mg/I)
0.001
1.26
0.002
EXPOSURE POINT
CONCENTRATION
FOR SEDIMENT
OUTSIDE PLANT
OPERATIONS AREA
IN NORTHEAST
TRIBUTARY (mg/kg)
0.044
0.00588
0.98
0.0036
0.00276
0.00783
0.002
0.00247
0.00327
EXPOSURE POINT
CONCENTRATION
FOR SEDIMENT
INSIDE PLANT
OPERATIONS AREA
IN NORTHEAST
TRIBUTARY (mg/kg)
0.066
. 0.00842
2.55
0.0283
0.002
~------------------NATIONAL STARCH & CHEMICAL COMPANY SUPERRMD SITE
RECORD OF OECISKJN FOR OPERABLE UNIT #3
-52-
TABLE 11 UPPER CONFIDENCE LIMITS (95%) FOR CHEMICALS AND ASSOCIATED USED To EVALUATE RISK CONDITIONS
CHEMICAUANAL YTE
(Contaminant of Concern)
1, 1,2-Trichloroethane
T richloroethene
Vinyl Chloride
Bis(2-ethylhexyl)phthalate
Di-n-butyl Phthalate
Di-n-octyl Phthalate
Aluminum
Antimony
Arsenic
Barium
Beryllium
EXPOSURE POINT
CONCENTRATION
F.OR GROUNDWATER
(mg/I)
0.00478
0.00446
0.01.1
0.013
0.017
0.002
29.1
0.0185
0.00194
0.257
0.000667
EXPOSURE POINT
CONCENTRATION
FOR SURFACE
WATER OUTSIDE
PLANT OPERATIONS
AREA IN NORTHEAST
TRIBUTARY (mg/I)
EXPOSURE POINT
CONCENTRATION
FOR SURFACE
WATER INSIDE PLANT
OPERATIONS AREA IN
NORTHEAST
TRIBUTARY (mg/I)
EXPOSURE POINT
CONCENTRATION
FOR SEDIMENT
OUTSIDE PLANT
OPERATIONS AREA
IN NORTHEAST
TRIBUTARY (mg/kg)
0.00247
EXPOSURE POINT
CONCENTRATION
FOR SEDIMENT
INSIDE PLANT
OPERATIONS AREA
IN NORTHEAST
TRIBUTARY (mg/kg)
0.003
-1!!!!!!!11 1!m m= == i:m all 11111 --8iil --------NATIONAi. STARCH & C~UICAL COMPANY SUPERFlND SlTE
RECORD OF DECISION FOR OPERABl..E UNIT #3
-53-
TABLE 11 UPPER CONFIDENCE LIMITS (95%) FOR CHEMICALS AND ASSOCIATED USED To EVALUATE RISK CONDITIONS
EXPOSURE POINT EXPOSURE POINT EXPOSURE POINT EXPOSURE POINT CONCENTRATION CONCENTRATION CONCENTRATION CONCENTRATION
EXPOSURE POINT FOR SURFACE FOR SURFACE FOR SEDIMENT FOR SEDIMENT
CHEMICAUANAL YTE CONCENTRATION WATER OUTSIDE WATER INSIDE PLANT OUTSIDE PLANT INSIDE PLANT FOR GROUNDWATER PLANT OPERATIONS OPERATIONS AREA IN OPERATIONS AREA OPERATIONS AREA (Contaminant of Concern) (mg/I) AREA IN NORTHEAST NORTHEAST IN NORTHEAST IN NORTHEAST TRIBUTARY (mg/I) TRIBUTARY (mg/I) TRIBUTARY (mg/kg) TRIBUTARY (mg/kg)
Cadmium 0.00311 --------------
Chromium 0.0414 --------------
Cobalt 0.0191 --------------
Copper 0.301 0.0037 ----------
Cyanide 0.000734 -•e. -----------
Lead 0.00394 0.0021 ---------
Manganese 2.73 0.213 0.134 ---. ---
Mercury · 0.000149 ------------
Nickel 0.0176 ---------------
Selenium 0.00391 --------------
Silver 0.00319 •••m -----------
Thallium 0.00104 --------------' Vanadium 0.0759. --------------
Zinc 1.34 ------------
~------~-----------NATIOHAJ. STARCH & CHEMICAl. COMPANY SUPERR.MD SITE
RECORD OF DECISION FOR OPERABLE UNIT #3
-54-
TABLE 12 PARAMETERS USED To DESCRIBE EXPOSURES To SITE-RELATED CHEMICALS OF CONCERN
Pathway/
Parameter"
Cs
Age
IR
Fl
CF
EF
ED
BW
AT-Noncancer
AT-Cancer
Current Land Use
Current Conditions
Outside Plant Operations
Area
UCLb or maximum
concentration in sediment
7-16 years
100 mg/day
0.25
1 X 10~ kg/mg
143 days/year
1 O years
45 kg
3,650 days
25,550 days
Future Conditions
Inside Plant Operations
Area
UCL or maximum
concentration in sediment
7-16 years
100 mg/day
0.25
1 X 10~ kg/mg
143 days/year
1 O years
45 kg
3,650 days
25,550 days
Future Land Use
Reasonable Maximum
Exposure
UCL or maximum
concentration in sediment
1-12 years
140 mg/day
0.5
1 X 10~ kg/mg
286 days/year
12 years
22.5 kg
4,380 days
25,550 days
Reference(s)/
Justification
Assumption (See text)
Based on ingestion of 200 mg/day to age 6
and 100 mg/day after that (EPA, 1991 b).
Assumption (See text)
See text. Assume 2x current EF for future
Corresponds to age exposed
Average for years exposed EPA (Region IV
Guidance)
365 x ED
365 x 70 yr lifetime
l!!!!!!!I I!!!! l!!I!!!! -= =-=---.. ---- - - - - --NATIONAl STARCH & CJ-EMICAL C.0MPANY SUPERFI..ND SITE
RECORD OF DECISION FOR OPERABLE UNIT #3
-55- ·
TABLE 12 PARAMETERS USED To DESCRIBE EXPOSURES To SITE-RELATED CHEMICALS OF CONCERN
Pathway/
Parameter"
Cs
Age
SA
AF
ABS
CF
EF
ED
BW
AT-Noncancer
AT-Cancer
Current Land Use
Current Conditions
Outside Plant Operations
Area
UCL or maximum
concentration in sediment
7-16years
3,400 cm2/event
0.2 mg/kg
0.01 Organics
0.001 lnorganics
1.0 x 10-6 kg/mg
143 events/year
10 years
45 kg
3.650 days
25,550 days
Future Conditions
Inside Plant Operations
Area
UCL or maximum
concentration in sediment
7-16 years
3,400 cm 2/event
0.2 mg/kg
0.01 Organics
0.001 lnorganics
1.0 x 10-6 kg/mg
143 events/year
1 O years
45 kg
3,650 days
25,550 days
Future Land Use
Reasonable Maximum
· Exposure
UCL or maximum
concentration in sediment
1-12years
2,200 cm 2/event
0.2 mg/kg
0.01 Organics
0.001 lnorganics
1.0 x 10-6 kg/mg
286 events/year
12 years
22.5 kg
4,380 days
25,550 days
Reference(s)/ .
Justification
Assumption (See text)
Average surface area of arms, hands, legs,
and feet for years expos.ed (EPA, 1992a)
EPA Region IV Guidance
EPA Region IV Guidance
See text. Assume 2x current EF for future
Corresponds to age exposed
Average for years exposed (EPA Region IV
Guidance)
365 x ED
365 x 70 yr lifetime
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NATIONAL STARCH & CHEMICAL CoMPAHY SUP~D SITE
AEcoRD Of DECISION FOR ClPERABtE UNIT 13
-56-
TABLE 12 PARAMETERS USED To DESCRIBE EXPOSURES To SITE-RELATED CHEMICALS OF CONCERN
Pathway/
Parameter"
Cw
Age
IR
Fl
ET
EF
ED
BW
AT-Noncancer
AT-Cancer
Current Land Use
Current Conditions
Outside Plant Operations
Area
UCL or maximum
concentration in surface water
7-16years
25 mUhr
1 (unitless)
1 hr/day
143 days/year
10 years
45 kg
3,650 days
25,550 days
Future Conditions
Inside Plant Operations
Area ·
UCL or maximum
concentration in surface water
7-16 years
25 ml/hr
1 {unitless)
1 hr/day
143 days/year
10 years
45 kg
3,650 days
25,550 days
Future Land Use
Reasonable Maximum
Exposure
UCL or maximum
concentration in surface water
1-12years
25 ml/hr
1 {unitless)
1 hr/day
286 days/year
12 years
22.5 kg
4,380 days
25,550 days
Reference(s)/
Justification
Assumption (See text)
50% of swimming ingestion (EPA, 1991 b)
Assumption
50% of swimming time {EPA, 1991b)
See text. Assume 2x current EF for future
Corresponds to age exposed
Average for years exposed {EPA Region IV
Guidance)
365 x ED
365 x 70 yr lifetime
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RECORD OF DECISION FOR OPERABLE UNIT '3
-57-
TABLE 12 PARAMETERS USED To DESCRIBE EXPOSURES To SITE-RELATED CHEMICALS OF CONCERN
Pathway/
Parameter"
Cw
Age
SA
CF
PC
ET
EF
ED
BW
AT-Noncancer
AT-Cancer
Current Land Use
Current Conditions
Outside Plant Operations
Area
UCL or maximum
concentration in surface water
7-16 years
3,400 cm2
0.001 Ucm 3
Chemical specific cm/hr
2 hr/day
t 43 days/year
10 years
45 kg
3,650 days
25,550 days
Future Conditions
Inside Plant Operations
Area
UCL or maximum
concentration in surface water
7-16 years
3,400 cm 2
0.001 Ucm3
Chemical specific cm/hr
2 hr/day
143 days/year
10 years
45 kg
3,650 days
25,550 days
Future Land Use
Reasonable Maximum
Exposure
UCL or maximum
concentration in surface water
1-12 years
2,200 cm2
0.001 Ucm 3
Chemical specific cm/hr
2 hr/day
286 days/year
12 years
22.5 kg
4,380 days
25,550 days
Reference(s)/
Justification
Assumption (See text)
Average arms, hands, legs, feet for years
exposed (EPA, 1992a)
EPA, 1992a
EPA, 1990b
See text. Assume 2x current EF for future
Corresponds to age exposed
Average for years exposed (EPA Region IV
Guidance)
365 x ED
365 x 70 yr lifetime
-58-
_____ ,_ NATIONAL STARCH & Ci-EUICAL CoMPANY SUPERR..ND SITE
RECORD OF DECISION FOR OPERABLE UNIT 13
TABLE 12 PARAMETERS USED To DESCRIBE EXPOSURES To SITE-RELATED CHEMICALS OF CONCERN
Pathway/
Parameter"
Ca
Age
IR
ET
EF
ED
BW
AT-Noncancer
AT-Cancer
Current Land Use
Current Conditions
Outside Plant Operations
Area
Calculated from UCL or
maximum concentration in
surface water
7-16 years
3.2 m3/hr
2 hr/day
143 days/year
10 years
45 kg
3,650 days
25,550 days
Fµture Conditions
Inside Plant Operations
Area
Calculated from UCL or
maximum concentration in
surface water
7-16 years
3.2 m3/hr
2 hr/day
143 days/year
10 years
45 kg
3,650 days
25,550 days
Future Land Use
Reasonable Maximum
Exposure
Calculated from UCL or
maximum concentration in
surface water
1-2 years
3.2 m3/hr
2 hr/day
286 days/year
12 years
22.5 kg
4,380 days
25,550 days
Reference(s)/
Justification
Calculated values in
Assumption (See text)
For moderate activity at-age 1 O (EPA,
1990b)
See text. Assume 2x current EF for future.
Average for years exposed (EPA Region IV
Guidance)
365 x ED
. 365 x 70 yr lifetime
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RECORD OF DECISION FOR OPERABLE UNIT t3
-59-
TABLE 12 PARAMETERS USED To DESCRIBE EXPOSURES To SITE-RELATED CHEMICALS OF CONCERN
Pathway/
Parameter"
Cw
Age
IR
Fl
EF
ED
BW
AT-Noncancer
AT-Cancer
Current Land Use
Current Conditions
Outside Plant Operations
Area
F.uture Conditions
Inside Plant Operations
Area
Future Land Use
Reasonable Maximum
Exposure
UCL or maximum
concentration in groundwater
0-30 years
2 Uday
1 unitless
350 days/year
30 years
70 kg
10,950 days
25,550 days
Reference(s)/
Justification
Assumption (See text)
Upperbound estimates EPA, 1991b
100% of drinking water is assumed to come
from contaminated area (EPA, 1991b)
See text
90% upperbound of time lived in one place
(EPA. 1991 b)
Standard default for adult exposure (EPA,
1991 b)
365 x ED
365 x 70 yr lifetime
-------------------
-60-
NATIONAL STARCH & CIEMJCAL CoMPANY SUPERFUND SITE
RECORD OF DECISION FOR OPERABLE UNIT #3
TABLE 12 PARAMETERS USED To DESCRIBE EXPOSURES To SITE-RELATED CHEMICALS OF CONCERN
Pathway/
· Parameter"
Cw
Age
SA
CF
PC
ET
EF
ED
BW
AT-Noncancer
AT-Cancer
Current Land Use
Current Conditions
Outside Plant Operations
Area
Future Conditions
Inside Plant Operations
Area
Future Land Use
Reasonable Maximum
Exposure
UCL or maximum
concentration in groundwater
0-30 years
21,500 cm2
0.001 Ucm1
Chemical-specific cm/hr
0.2 hour/day
350 days/year
30 years
70 kg
10,950 days
25,550 days
Reference(s)/
Justification
Assumption (See text)
Average of whole body for years exposed
(EPA, 1992a)
EPA, 1992a
EPA, 1991b
See text
Corresponds to age exposed
Standard default for adult exposure (EPA,
1990a)
365 x ED
365 x 70 yr lifetime
-------------------NATIOKAL STARCH & CHEMICAL COMPANY SUPERFUND SITE
RECORD OF DECISION FOR OPERABLE UNIT #3
-61-
TABLE 12 PARAMETERS USED To DESCRIBE EXPOSURES To SITE-RELATED CHEMICALS OF CONCERN
Pathway/
Parameter"
Ca
Age
IR
ET
Shower
Indoors
EF
ED
BW
AT-Noncancer
• AT-Cancer
Current Land Use
Current Conditions
Outside Plant Operations
Area
Future Conditions
Inside Plant Operations
Area
Future Land Use
Reasonable Maximum
Exposure
Calculated from UCL or
maximum concentration in
groundwater
0-30 years
0.63 m3/hr
. 0.2 hour/day
16 hour/day
350 days/year
30 years
70 kg
10,950 days
25,550 days
Reference(s)/
Justification
Calculated values
Assumption (See text)
Average (EPA,.1991b)
Upperbound estimate (EPA, 1991b)
Upperbound estimate (EPA, 1991b)
See text
Upperbound estimate (EPA, 1991b)
Standard default for adult exposures (EPA,
1990a)
365 x ED
365 x 70 yr lifetime
I!!!!!!! l!!!!!!I 1!11!1!1 ---lliil ----

-

-

-- - - - -
NATIONAL STARCH & CHEMICAL CoUPAHY SUPERFUND SITE
RECORD OF DECISION FOR OPERABLE UNIT #3
-62-
TABLE 12 PARAMETERS USED To DESCRIBE EXPOSURES To SITE-RELATED CHEMICALS OF CONCERN
Pathway/
Parameter'
Cw
Age
IR
Fl
EF
ED
BW
AT-Noncancer
AT-Cancer
Current Land Use
Current Conditions
Outside Plant Operations
Area
Future Conditions
Inside Plant Operations
Area
Future Land Use
Reasonable Maximum
Exposure
UCL or maximum
concentration in groundwater
1-12 years
2 Uday
1 Unitless
350 days/year
12 years
22.5 kg
4,380 days
25,550 days
Reference(s)/
Justification
Assumed
Assumed same ingestion rate as adults
100% of drinking water is assumed to come
from contaminated area (EPA, 1991 b)
See text
Corresponds to age exposed
Average years exposed (EPA, 1990b)
ED x 365 days/year
70 year lifetime x 365 days/year
-._ l!!!!!!I !!!!I 11111 == =a 11111111· --liiilil ---· -----
-63-
TABLE 12 PARAMETERS USED TO DESCRIBE EXPOSURES TO SITE-RELATED CHEMICALS OF CONCERN
Current Land Use
Current Conditions
Pathway/ . Outside Plant Operations
Parameter" Area
Cw
Age
SA
CF
PC
ET
EF
ED
BW
AT-Noncancer
AT-Cancer
Future Conditions
Inside Plant Operations
Area
Future Land Use
Reasonable Maximum
Exposure
UCL or maximum
concentration in groundwater
1-12 years
8,900
0.001 Ucm 3
Chemical-specific cm/hr
0.2 hour/day
350 days/year
12 years
22.5 kg
4,380 days
25,550 days
NATIONAL STARCH & CI-EMICAL COMPANY SUPERAM> SIT£
RECORD Of DECISION FOR OPERABLE UNIT #3
Reference(s)/
Justification
Assumed
Average for whole body
(EPA, 1992a)
EPA, 1992a
EPA, 1991b
See text
Corresponds to age exposed
Average for years exposed
(EPA, 1990b)
ED x 365 days/year
70-year lifetime x 365 days/year
- -l!!!!!!!!!!I ~ 1!!!!11 !!!Ill == ------

-- - - - -
NATIOK.\L STARCH & CHEMICAL COMPANY SUPERFLWD SITE
REcoRD OF DECISION FOR OPERABLE UNIT #3
-64-·
TABLE 12 PARAMETERS USED To DESCRIBE EXPOSURES TO SITE-RELATED CHEMICALS OF CONCERN
Pathway/
Parameter"
Ca
Age
IR
ET
Shower
Indoors
EF
ED
BW
AT-Noncancer
AT-Cancer
Current Land Use
Current Conditions
Outside Plant Operations
Area
Future Conditions
Inside Plant Operations·
Area
.
Future Land Use
Reasonable Maximum
Exposure
Calculated from UCL or
maximum concentration in
groundwater
1-12 years
0.63 m3thr
0.2 hour/day
16 hours/day
350 days/year
12 years
22.5 kg .
4,380 days
25,550 days
Reference(s)/
Justification
Calculated value
Assumed
Assumed same inhalatioA rate as adults
Upperbound estimate (EPA, 1991b)
Upperbound estimate (EPA, 1991b)
See text
Corresponds to age exposed
Average for years exposed (EPA, 1990b)
ED x 365 days/year
70-year lifetime x 365 days/year
----

-

-

-
I!!!!!!!! I!!!! -== --------NATIONAL STARCH & Ci-EMICAL COMPANY SUPERFUND SITE
RECORD OF DECISION FOR OPERABLE UNIT '3
-65-
TABLE 12 PARAMETERS USED To DESCRIBE EXPOSURES To SITE-RELATED CHEMICALS OF CONCERN
Pathway/
Parameter"
Cw
Age
IR
Fl
ET
EF
ED
BW
AT-Noncancer
AT-Cancer
Current Land Use
Current Conditions
Outside Plant Operations
Area
UCL or maximum
concentration in surface water
7-16 years
25 mUhr
1 unitless
0.5 hr/day
71 days/year
10 years
45 kg
3,650 days
25,550 days
Future Conditions
Inside Plant Operations
Area
UCL or maximum
concentration in surface water
7-16 years
25 ml/hr
1 unitless
0.5 hr/day
71 days/year
10 years
45 kg
3,650 days
25,550 days
Future Land Use
Reasonable Maximum
Exposure
UCL or maximum
concentration in surface water
1-12 years
25 mUhr
1 unitless
0.5 hr/day
143 days/year
12 years
22.5 kg
4,380 days
25,550 days
Reference(s)/
Justification
Assumption (See text)
50% of swimming ingestion (EPA, 1991 b)
Assumptiori
50"/o of swimming time (EPA, 1991b)
See text. Assume 2x current EF for future
Corresponds to age exposed
Average for years exposed (EPA, 1990a)
365 x ED
365 x 70 yr lifetime
-----

-

-

-
.I!!!!!!!!! 1!!!!!!11 == --------NATIONAL STARCH & CI-EMICAL COMPANY SUPERFUND SITE
RECORD OF DECISION FOR 0P£RABlE UNIT #3
-66-
TABLE 12 PARAMETERS USED To DESCRIBE EXPOSURES To SITE-RELATED CHEMICALS OF CONCERN
Pathway/
Parameter"
Cw
Age
SA
CF
PC
ET
EF
ED
BW
AT-Noncancer
AT-Cancer
Current Land Use
Current Conditions
Outside Plant Operations
Area
UCL or maximum
concentration in surface water
7-16 years
3,400 cm2
0.001 Ucm3
Chemical-specific cm/hr
1 hr/day
71 days/year
10 years
45 kg
3,650 days
25,550 days
Future Conditions
Inside Plant Operations
Area ·
UCL or maximum
concentration in surface water
7-16years
3,400 cm2
0.001 Ucm3
Chemical specific cm/hr
1 hr/day
71 days/year
1 O years
45 kg
3,650 days
25,550 days
Future Land Use
Reasonable Maximum
. Exposure
UCL or maximum
concentration in surface water
1-12 years
2,200 cm 2
0.001 Ucm3
Chemical specific cm/hr
1 hr/day
143 days/year
10 years
22.5 kg
4,380 days
25,550 days
Reference(s)/
Justification
Assumption (See text)
Average arms, hands, legs, feet for years
exposed (EPA, t990a)
EPA, 1992a
EPA, 1991b
See text. Assume 2x current EF for future
Corresponds to age exposed
Average for years exposed (EPA, 1990a)
365 x ED
365 x 70 yr lifetime
-------------------NATIONAL STARCH & CHEMICAL COMPANY SUPERFUNO SITE
RECORD OF DECISION FOR DPERABLE UNIT #3
-67-
TABLE 12 PARAMETERS USED To DESCRIBE EXPOSURES To SITE-RELATED CHEMICALS OF CONCERN
Pathway/
Parameter"
Ca
Age
IR
ET
EF
ED
BW
AT-Noncancer
AT-Cancer
Current Land Use
Current Conditions
Outside Plant Operations
Area
Calculated from UCL or
maximum concentration in
surface water
7-16 years
3.2 m3/hr
1 hr/day
143 days/year
10 years
45 kg
3,650 days
25,550 days
Future Conditions
Inside Plant Operations
Area
Calculated from UCL or
maximum concentration in
surface water
7-16 years
3.2 m3/hr
1 hr/day
143 days/year
10 years
45 kg
3,650 days
25,550 days
Future Land Use
Reasonable Maximum
Exposure
Calculated from UCL or
maximum concentration in
surface water
1-2 years
3.2 m3/hr
1 hr/day
286 days/year
12 years
22.5 kg
4,380 days
25,550 days
Reference(s)/
Justification .
Calculated values
Assumption (See text)
For moderate activity at age 1 O (EPA,
1990b)
Less time in springs than in tributary
See text. Assume 2x current EF for future.
Average for years exposed (U.S. EPA
Region IV Guidance)
365 x ED
365 x 70 yr lifetime
' Parameters are C, = concentration in media "x"; IR= ingestion rate or inhalation rate (with volatiles); Fl= fraction ingested from source; EF = exposure frequency; ED = exposure duration; BW =bodyweight; AT-Noncancer = average time tor noncarcinogens; AT-Cancer= averaging time for carcinogens; SA= surface area exposed; AF= adherence factor; ABS= absorption factor; CF= conversion factor; ET= exposure time; PC= permeability constant. ' UCL-Upper 95% confidence limit
- - - ---

-

-
I!!!!!!!! l!!!!!!I ---------NATIONAL STARCH & CHEMICAL COMPANY SUPERFUN0 SITE
RECORD Of DECISION FOR OPERABLE UNIT #3
-68-
TABLE 13 ESTIMATED POTENTIAL CURRENT LAND USE RISK FROM CARCINOGENS OUTSIDE PLANT OPERATIONS AREA {CURRENT CONDITIONS)
POTENTIALLY
EXPOSED
POPULATION CHEMICAL
Child 1,2-Dichloroethane
Methylene chloride
Tetrachloroethene
Trichloroethene
Total ILCR
Total Media
DERMALLY
ABSORBED
DOSE
(mg/kg/day)
8.29 X 1 ff9
6.62 X 10·11
2.09 X 10·11
2.09 X 10·11
DERMAL
CONTACT
ILCR
8.38 X 10'10
4.97 X 10·13
1.21 X 10·12
2.55 X 10·13
8.40 X 10'10
INGESTED
DOSE
(mg/kg/day)
3.05 X 10-6
2.44 X 10·10
7.68 X 10·11
7.68 X 10·11 .
INGESTION
ILCR
2.77 X 10·9
1.83 X 10·12
3.99 X 10·12
8.44 X 10·13
2.78 X 10·9
INHALED
DOSE
(mg/kg/day)
NA
NA
NA
NA
INHALATION
OF voes
ILCR
NA
NA
NA
NA
NA
3.62 X 10·9
Child 1,2-Dichloroethane 4.27 x 1 ff5 4.32 x 1 o-a 8.05 x 10-a . 7.32 x 10·1 1.67 x 1 0_. 1.52 x 1 ff5 1-----------,l-------+-------+--------,l-------+------+-------ll
Total Media 2.03 x 10~
- - - - - - - --I!!!! ----- - - - -
NATIONAL STARCH & CHEMICAL COMPANY SUPERRJND SITE
REcoAD OF DECISION FOR OPERABLE UNIT #3
-69-
TABLE 13 ESTIMATED POTENTIAL CURRENT LAND USE RISK FROM CARCINOGENS INSIDE PLANT OPERATIONS AREA
(FUTURE CONDITIONS)
POTENTIALLY
EXPOSED
POPULATION
Child
Child
Child
CHEMICAL
1,2-Dichloroethane
Methylene chloride
Total ILCR
Total Media
1, 1,2-Trichloroethane
1,2-Dichloroethane
Methylene chloride
Tetrachloroethene
Total ILCR
Total Media
1,2-Dichloroethane
Methylene chloride
Total ILCR
Total Media
DERMALLY
ABSORBED
DOSE
(mg/kg/day)
2.08 X 10_.
7.61 X 10-a
2.54 X 10'11
2.16x 10.a
2.39 X 10·10
1.69 X 10'11
5.20 X 10·5
1.90 X 10.a
DERMAL
CONTACT
ILCR
INGESTED
DOSE
(mg/kg/day)
INGESTION
ILCR
...... ____ .i...... ____ .i...... ___ ~
2.10 X 10'5 3.92 X 10'5 3.57 X 10-6
5.71 X 10'10 6.22 X 10-a 4.66 X 10'10
2.10x 10'5 3.57 X 10-6
1.61 X 10'12 9.33 X 10'11 5.32 X 10·12
2.18 X 10·9 7.93 X 10-a 7.22 X 10·9
1.79 X 10'12 8.79 X 10'10 6.59 X 10·12
9.77 X 10'13 6.22 X 10·11 3.23 X 10'12
2.19 X 10'9 7.24 X 10·9
5.26 X 10-6. 9.81 X 10-6 8.92 X 10·7
1.43 X 10'10 1.55 X 10.a 1.17 X 10·10
5.26 X 10-6 8.92 X 10·7
INHALED
DOSE
(mg/kg/day)
8.15 X 10'4
1.29 X 10-6
NA
NA
NA
NA
2.04 X 10'4
3.23 X 10·7
INHALATION
OF voes
ILCR
7.42 X 10'5
2.20 X 10·9
7.42 X 10'5
9.88 X 10·5
NA
NA
NA
NA
NA
9.42 X 10'9
1.85 X 10'5
5.49 X 10·10
1.85 X 10'5
2.47 X 10'5
- - - - - - - -1!!!!111 !!!!!I -=-liiilii .. - - - --·
-70-
TABLE 13 ESTIMATED POTENTIAL FUTURE LAND USE RISK FROM CARCINOGENS
POTENTIALLY
EXPOSED
POPULATION CHEMICAL
Child Resident 1,2-Dichloroethane
Methylene chloride
Total ILCR
Total Media
Child Resident 1, 1,2-Trichloroethane
1,2-Dichloroethane
Methylene chloride
Tetrachloroethene
Total ILCR
Total Media
Child Resident 1, 1,2-Trichloroethane
1,2-Dichloroethane
DERMALLY
ABSORBED
DOSE
(mg/kg/day)
6.46x104
2.36 X 10·7
7.88 X 10·11
6.70 X 10-8
7.42 X 10·10
5.25 X 10-11
5.22 X 10-8
1.09 X 104
DERMAL
CONTACT
ILCR
6.53 X 10-5
1.77 X 10·9
6.53 X 10-5
4.99 X 10·12
6.78 X 10·9
5.57 X 10'12
3.04 X 10'12
6.79 X 10·9
3.31 X 10'9
1.10 X 10·5
INGESTED
DOSE
(mg/kg/day)
1.88 X 104
2.98 X 10·7
1.25 X 10·9
1.07 X 10-6
1.18 X 10-8
8.36 X 10·10
6.99 X 10-5
6.29 X 10·3
INGESTION
ILCR
1.71 X 10-5
2.24 X 10·9
1.71 X 10-5
7.15 X 10-11
9.70 X 10-8
8.86 X 10·11
4.35 X 10-11
9.73 X 10-8
3.98 X 10-6
5.72 X 104
NATIONAL STARCH i CI-EMICAL COMPANY SUPERFUNO SITE
RECORD OF DECISION FOR OPERABLE UNIT #3
INHALED
DOSE
(mg/kg/day)
3.91 X 10·3
6.20 X 10-6
NA
NA
NA
NA
9.01 X 10-6
1.52 X 10·3
INHALATION
OF voes
ILCR
3.56 X 104
1.05 X 10-8
3.56 X 104
4.38 X 104
NA
NA
NA
NA
NA
1.04 X 10·7
5.13 X 10·7
1.38 X 104
----------~--------NATIONAL STARCH & CHEMICAL COMPANY SUPERMD SITE
. RECORD OF DECISION FOR OPERABtf UNIT #3
-71-
TABLE 13 ESTIMATED POTENTIAL FUTURE LAND USE RISK FROM CARCINOGENS
POTENTIALLY DERMALLY DERMAL INGESTED INHALED INHALATION
EXPOSED ABSORBED CONTACT DOSE INGESTION DOSE OF voes
POPULATION CHEMICAL DOSE ILCR (mg/kg/day) ILCR (mg/kg/day) ILCR
(mg/kg/day)
Arsenic 2.52 X 10-8 4.50 X 10-8 2.83 X 10-5 4.96 X 10-5 NA NA
Beryllium -8.67 X 10-9 3.73 X 10-5 9.75 X 10-8 4.19x10"5 NA NA
Bis(2-chloroethyl)ether 1.09 X 10-8 1.34 X 10-8 5.84 X 104 6.43 X 104 1.74 X 10-6 2.09 X 10-6
Bis(2-ethylhexyl)phthalate 5.58 X 10-6 8.68 X 10-8 1.90 X 104 2.66 X 1 Q-8 NA NA
Chloroform 6.04 X 10-7 3.68 X 10"9 7.62 X 10-5 4.65 X 10-7 1.36 X 10-5 1.10 X 10-6
Methylene chloride 3.53 X 10-7 2.65 X 10-9 8.82 X 10-5 6.61 X 10-7 1.42 X 10-5 2.41 X 10-8
Tetrachloroethene 2.98 X 10-6 1.72 X 10-7 6.98 X 10 5 3.63 X 10-6 1.62 X 10-5 3.25 X 10-8
Trichloroethene 9.27 X 10-7 1.13 X 10-8 6.51 X 10-5 7.16 X 10-7 1.42 X 10-5 · 8.50 X 10.a
Vinyl chloride 1.20 X 10.7 9.05 X 10-9 1.60 X 104 3.04 x 1 a"' 3.82 X 10-5 1.15 X 10"5
Total ILCR 5.QQ X 10.5 1.62 X 10-3 1.53 X 104
Total Media 1.83 X 10-3
Adult Resident 1, 1,2-T richloroethane 1.01 X 10-7 6.42 X 10-9 5.61 X 10-5 3.20 X 10-6 7.24 X 10-6 4.12 X 10·7
1,2-Dichloroethane 2.12 X 104 2.14x10"5 5.05 X 10-3 4.60 X 104 1.22 X 10-3 1.11x104
Arsenic 4.89 X 10-8 8.74 X 10-8 2.28 X 10-5 3.98 X 10-5 NA NA
Beryllium 1.68 X 10-8 7.24 X 10-5 . 7.83 X 10-6 3.37 X 10-5 NA NA
Bis(2-chloroethyl)ether 2.12x 10-6 2.59 X 10-6 4.70 X 104 5.17x104 1.40x10"6 1.68 X 10-6
-----------~-------NATIONAL STARCH & CHEMICAL CoMPANY SUPERFUNO SITE
RECORD OF DECISION FOR OPERABlf UNIT #3
-72-
TABLE 13 ESTIMATED POTENTIAL FUTURE LAND USE RISK FROM CARCINOGENS
POTENTIALLY DERMALLY DERMAL INGESTED INHALED INHALATION
EXPOSED ABSORBED CONTACT DOSE INGESTION DOSE OF voes
POPULATION CHEMICAL DOSE ILCR (mg/kg/day) ILCR (mg/kg/day) ILCR
(mg/kg/day)
Bis(2-ethylhexyl)phthalate 1.08 X 10·5 1.68 X 10·7 1.53 X 10'4 2.14x10-6 NA NA
Chloroform 1.17x 10-6 7.15 X 10·9 6.12 X 10·5 3.74 X 10·7 1.09x10'' 8.86 X 10·7
Methylene chloride 6.86 X 10·7 5.14 X 10·9 7.09 X 10'5 5.31 X 10'7 1.14x 10'' 1.94 X 10-6
Tetrachloroethene 5.79x 10-6 3.35 X 10·7 5.61 X 10·5 2.92 X 10-6 1.30 X 10'5 2.61 X 10-6
Trichloroethane 1.80 X 10-6 2.20 X 10-6 5.23 X 10·5 5.76 X 10·7 1.14 X 10·5 6.83 X 10-6
Vinyl chloride 2.33 X 10·7 1.76 X 10-6 1.29 X 10'4 2.45 X 10-4 3.07 X 10·5 9.21 X 10-6
Total ILCR 9.71 X 10·5 1.30 X 10·3 1.23 X 10-4
Total Media 1.52 X 10·3
Child Resident 1,2-Dichloroethane 1.62 X 104 1.63 X 10·5 4.71 X 10'5 4.28 X 10-6 9.78 X 10-4 8.90 X 10'5
Methylene chloride 5.91 X 10.a 4.43 X 10·1' 7.46 X 10-8 5.60 X 10·1' 1.55 X 10-6 2.64 X 10·9
Total ILCR 1.63 X 10'5 4.28 X 10-6 8.90 X 10'5
Total Media 1.10 X 10-4
---------l!!!!!!!!!lm!ll!llllla---- - -
NATIONAL STARCH & CI-EMICAL COMPAKV SUPERFUND SITE
RECORD OF DECISION FOR 0PERA81..f UNIT #3
-73-
TABLE 13 ESTIMATED POTENTIAL CURRENT LAND USE HAZARD FROM NONCARCINOGENS OUTSIDE PLANT OPERATIONS AREA
(CURRENT CONDITIONS)
POTENTIALLY
EXPOSED
POPULATION CHEMICAL
Child Manganese (water)
Toluene
Total HQ
Child 1,2-Dichloroethene
2-Butanone
Acetone
Ethylbenzene
Methylene chloride
Styrene
Tetrachloroethene
Toluene
T richloroethene
DERMALLY
ABSORBED
DOSE
(mg/kg/day)
1.26 X 10·5
6.89 X 10-8
2.13x10·10
3.48 X 10'10
2.60 X 10·9
1.63 X 10·10
4.64 X 10·10
1.18 X 10·10
1.46 X 10·10
1.94 X 10·10
1.46 X 10'10
DERMAL
CONTACT
HQ
5.4 X 10·2
3.44 X 10-5
5.5 X 10"2
2.37 X 10-8
7.74 X 10·9
2.89 X 10-8
1.81 X 10"9
7.73 X 10"9
6.58 X 10·10
1.62 X 10-8
9.69 X 10'10
2.71 X 10-8
INGESTED
DOSE
(mg/kg/day)
. 4.64 X 10-5
5.63 X 10·7
7.84 X 10·10
1.28 X 10·9
9.58 X 10'9
6.00 i< 10·10
1.70 X 10'9
4.35 X 10'10
5.37 X 10·10
7.12x10·10
5.37 X 10·10
INHALED
INGESTION DOSE
(mg/kg/day)
9.27 X 10·3 NA
2.81 X 10-8 1.17x 10·5
9.27 X 10·3
7.84 X 10-8 NA
2.56 X 10-8 NA
9.58 X 10-8 NA
6.00 X 10·9 NA
2.84 X 10-8 NA
2.18x10-9 NA
5.37 X 10-8 NA
3.56 X 10'9 NA
8.96 X 10-8 NA
INHALATION
OF voes
HQ
NA
1.17 X 10-4
1.17 X 10-4
NA
NA
NA
NA
NA
NA
NA
NA
NA
-----------~-------NATIONAf. STARCH & CHEMICAL CoMPAHY SUPERFUND SITE
RECORD OF DECISION FOR OPfRABl.f UNIT #3
-74-
TABLE 13 ESTIMATED POTENTIAL CURRENT LAND USE HAZARD FROM NONCARCINClGENS OUTSIDE PLANT OPERATIONS AREA
(CURRENT CONDITIONS)
POTENTIALLY DERMALLY DERMAL INGESTED INHALED INHALATION EXPOSED ABSORBED CONTACT DOSE INGESTION DOSE OF voes POPULATION CHEMICAL DOSE
(mg/kg/day)
HQ (mg/kg/day) (mg/kg/day) HQ
Total HQ 1.1sx10·7 3.83 X 10·7 NA
Total Media HI 4.98 X 10·7
Child Manganese (water) 3.15 X 10-6 1.26 X 10·2 1.16 X 10·5 2.32 X 10·3 NA NA
Toluene 1.72 X 10-6 8.61 X 10-6 1.41 X 10'7 7.3 X 10·7 2.92 X 10-6 2.92 X 10-s
Total HQ 1.26 X 10·2 2.32 X 10·3 2.92 X 10-5
Total Media HI 1.50x 10·2
- - - - - - - - --!!!!I !!!II 1111111 ---- - -NATIOK.\l STARCH & CHElilCAL COMPANY SUPERFUND SITE
RECORD OF DECISION FOR OPERABLE UNIT #3
-75-
TABLE 13 ESTIMATED POTENTIAL CURRENT LAND USE HAZARD FROM NONCARCINOGENS INSIDE PLANT OPERATIONS AREA
(FUTURE CONDITIONS)
POTENTIALLY
EXPOSED
POPULATION
Child
Child
CHEMICAL
Carbon disulfide
Manganese (water)
Methylene chloride
Total HQ
Total Media HI
1, 1,2-T richloroethane
2-Butanone
Acetone
Methylene chloride
Tetrachloroethene
Total HQ
Total Media HI
DERMALLY
ABSORBED
DOSE
(mg/kg/day)
1.42 X 10-6
7.93 X 10-6
5.33 X 10"7
1.78 X 10-10
4.98 X 10"10
3.91 X 10-9
1.67 X 10-9
1.18x 1 □-10
DERMAL
CONTACT
HQ
1.58 X 10-5
3.17x 10·2
3.18 X 10-2
4.93 X 10-8
1.11x10-a
4.34 X 10-8
2.79x 10-a
1.32 X 10-8
1.45 X 10"7
INGESTED
DOSE
(mg/kg/day)
2.18 X 10·7
2.92 X 10·5
-4.35 X 10"7
6.53 X 1 □-10
1.83 X 10·9
1.44 X 10-8
6.15 X 10"9
4.35 X 10-10
INGESTION
HQ
5.83 X 1 □-3
5.84 X 10·3
1.63 X 10"7
3.66 X 10-8
1.44x 10-7
1.03 X 10-7
. 4.35 X 10-8
4.90 X 10-7
INHALED
DOSE
(mg/kg/day)
4.52 X 10-6
NA
9.05 X 10-6
NA
NA
NA
NA
NA
INHALATION
OF voes
HQ
1.51 X 1 □-3
NA
1.01 X 10·5•
1.52 X 10"3
3.91 X 10-2
NA
NA
NA
NA
NA
NA
6.34 X 10·7
-----------~~------NATIONAL STARCH & CHEMICAL COMPANY SUPERFUN0 SITE
RECORD OF 0ECISKJN FOR OPERABLE UNIT #3
-76-
TABLE 13 ESTIMATED POTENTIAL CURRENT LAND USE HAZARD FROM NONCARCINOGENS INSIDE PLANT OPERATIONS AREA
(FUTURE CONDITIONS)
POTENTIALLY
EXPOSED
POPULATION
Child
CHEMICAL
Carbon disulfide
Manganese (water)
Methylene chloride
Total HQ
Total Media HI
DERMALLY
ABSORBED
DOSE
(mg/kg/day)
3.55 X 10·7
1.98 X 10-6
1.33 X 10·7
DERMAL
CONTACT
HQ
3.95 X 10-6
7.93 X 10·3
2.22 X 10-6
7.94 X 10·3
INGESTED
DOSE
(mg/kg/day)
5.44 X 10-8
7.29 X 10-6
1.09 X 10·7
INGESTION
HQ
5.44 X 10·7
1.46 X 10·3
1.81 X 10-6
1.46 X 10·3
INHALED
DOSE
(mg/kg/day)
1.13 X 10-6
NA
2.26 X 10-6
INHALATION
OF voes
HQ
3.77 X 10-4
NA
2.51 X 10-6
3.79 X 10-4
9.78 X 10·3
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TABLE 13 ESTIMATED POTENTIAL FUTURE LAND USE HAZARD ASSOCIATED WITH NONCARCINOGENS
POTENTIALLY -
EXPOSED
POPULATION CHEMICAL
DERMALLY
ABSORBED
DOSE
(mg/kg/day)
DERMAL
CONTACT
HQ
INGESTED
DOSE
(mg/kg/day)
INGESTION
HQ
INHALED
DOSE
(mg/kg/day)
INHALATION
OF voes
HQ
Child Resident Carbon disulfide 3.68 x 10.e 4.09 x 10·5 8.71 x 10·1 8.71 x 10.e 1.81 x 10·5 6.03 x 10·1
l-----------+-------+-----l-------+-----+---------1--------ll
Manganese (water) 2.05 x 10·5 8.21 x 10·2 1.17 x 104 2.33 x 10·2 NA NA
Methylene chloride 1.38 x 10.e 2.30 x 10·5 1.74 x 1 o.e 2.90 x 10·5 3.62 x 10·5 4.02 x 10·5
Total HQ 8.22 x 10·2 2.34 x 10·2 6.07 x 10·3
Total Media HI 1.12 x 10·1
Child Resident 1, 1,2-Trichloroethane 4.60 X 10·1' 1.28 X 10·7 7.31 X 10·9 1.83 X 10-6 NA NA
2-Butanone 1.29 X 10·9 2.87 X 10-a 2.05 X 10-a 4.10 X 10·7 NA NA
Acetone 1.01 X 10-a 1.12x10·1 1.61 X 10·7 1.61 X 10-6 NA NA
Methylene chloride 4.33 X 10·9 7.22 X 10-a 6.89 X 10-a 1.15 X 10-6 NA NA
Tetrachloroethene 3.06 X 10·1' 3.41 X 10-a 4.88 X 10·9 4.88 X 10·7 NA NA
Total HQ 3.75 X 10·7 5.48 X 10-6 NA
Total Media HI 5.86 X 10-6
Child Resident 1, 1,2-Trichloroethane
1,2-Dichloroethene
3.05 X 10·7
1.05 X 10·5
8.46 X 10·5
1.17 X 10·3
4.08 X 104
6.05 X 104
1.02 X 10·1
6.05 X 10·2
NA
NA
NA
NA
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RECORD OF DECISION FOR OPERABLE UNIT #3
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TABLE 13 ESTIMATED POTENTIAL FUTURE LAND USE HAZARD ASSOCIATED WITH NONCARCINOGENS
POTENTIALLY DERMALLY DERMAL INGESTED INHALED INHALATION
EXPOSED ABSORBED CONTACT DOSE INGESTION DOSE OF voes
POPULATION CHEMICAL DOSE HQ (mg/kg/day) HQ (mg/kg/day) HQ
(mg/kg/day)
Aluminum 2.21 X 10·3 1.47 X 10'2 2.48 X 10° 8.27 X 10'1 NA NA
Antimony 1.40 X 10-6 7.00 X 10'2 1.57 X 10'3 3.94x 10° NA NA
Arsenic 1.47 X 10'7 5.00x 104 1.65 X 104 5.51 X 101 NA NA
Barium 1.95 X 10'5 2.79 X 10'3 2.19 X 10'2 3.13 X 101 NA NA
Beryllium 5.06 X 10'8 1.01 X 10·2 5.69 X 10·5 1.14 X 10·2 NA NA
Bis(2-ethylhexyl)phthalate 3.25 X 10·5 1.81 X 10·3 1.11 X 10·3 5.54 X 102 NA NA
Cadmium (water) 1.98 X 10·7 6.60 X 10·3 2.65 X 104 5.30 X 10·1 NA NA
Chloroform 3.52 X 10-6 3.52 X 104 4.45x104 4.45 X 10·2 NA NA
Chromium 3.14x10-6 1.26 X 10·2 3.53 X 10'3 7.05 X 10'1 NA NA
Cobalt 1.45 X 10-6 4.83 X 104 1.63 X 10·3 2.71 X 10·2 NA NA
Cyanide 5.57 X 10.a · 5.57 X 10·5 6.25 X 105 3.13x10·3 NA NA
Di-n-butyl phthalate 4.26 X 10·5 4.73x104 1.45 X 10·3 1.45 X 10'2 NA NA
Di-n-octyl phthalate 5.01 X 10-6 2.78 X 104 1.70x104 8.52 X 10-3 NA NA
Manganese (water) 2.07 X 104 8.29 X 10'1 2.33 X 101 4.66 X 101 NA NA
Mercury 9.49 X 10·9 2.11 X 104 1.27 X 10·5 4.23 X 10'2 NA NA
Methylene chloride 2.06 X 10-6 3.43 X 10·5 5.14 X 104 8.57 X 10·3 6.90 X 10-6 7.67 X 10-6
Nickel 1.34 X 10-6 1.34 X 10·3 1.50 X 10·3 7.52 X 10'2 NA NA
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TABLE13 ESTIMATED .POTENTIAL FUTURE LAND USE HAZARD ASSOCIATED WITH NONCARCINOGENS
POTENTIALLY DERMALLY DERMAL INGESTED INHALED INHALATION
EXPOSED ABSORBED CONTACT DOSE INGESTION DOSE OF voes
POPULATION CHEMICAL DOSE HQ (mg/kg/day) HQ (mg/kg/day) HQ
(mg/kg/day)
Selenium 2.97 X 10·7 9.89 X 10'5 3.33 X 10" 6.67 X 10'2 NA NA
Silver 2.42 X 10·7 9.67 X 104 2.72 X 10" 5.43 X 10'2 NA NA
Tetrachloroethene 1.74x10'5 1.93 X 10'3 4.07 X 10" 4.07x 10·2 NA NA
Thallium 7.91 X 10.a 2.64 X 10'2 8.88 X 10'5 1.48 X 10° NA NA
Total Xylenes 2.85 X 10'5 1.43 X 10'5 4.00 X 10" 2.00 X 10" NA NA
Trichloroethene 5.41x10~ 1.00 X 10·3 3.80x 104 6.33 X 10·2 NA NA
Vanadium 5.76 X 10~ 1.65 X 10·2 6.47 X 10·3 9.24 X 10'1 NA NA
Zinc 1.01 X 104 5.47 X 10·3 1.14x10'1 3.80 X 10'1 NA NA
Total HQ 1.01 X 10° 5.69 X 101 7.67 X 10.a
Total Media HI 5.79 X 101
Adult Resident 1, 1,2-Trichloroethane 2.37 X 10·7 6.57 X 10'5 1.31 X 10" 3.27 X 10'2 NA NA
1,2-Dichloroethene 8.15x10~ 9.06 X 10" 1.94 X 10" 1.94 X 10·2 NA NA
Aluminum 1.71 X 10·3 1.14 X 10·2 7.97 X 10·1 2.66 X 10'1 NA NA
Antimony 1.09 X 10~ 5.44 X 10·2 5.06 X 1 O" 1.26 X 10° NA NA
Arsenic 1.14 X 10·7 3.88 X 104 5.31 X 10'5 1.77 X 10'1 NA NA
Barium 1.51 X 10'5 2.16 X 10·3 7.04 X 10·3 1.01x10'1 NA NA
Beryllium 3.93 X 10.a 7.86 X 10·3 1.83 X 10·5 3.65 X 10·3 NA NA
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TABLE 13 ESTIMATED POTENTIAL FUTURE LAND USE HAZARD ASSOCIATED WITH NONCARCINOGENS
POTENTIALLY DERMALLY DERMAL INGESTED INHALED INHALATION
EXPOSED ABSORBED CONTACT DOSE INGESTION DOSE OF voes
POPULATION CHEMICAL DOSE HQ (mg/kg/day) HQ (mg/kg/day) HQ
(mg/kg/day)
Bis(2-ethylhexyl)phthalate 2.53 X 10'5 1.40 X 10·3 3.56 X 10'4 1.78 X 10·2 NA NA
Cadmium (water) 1.54 X 10·7 5.13 X 10·3 · 8.52 X 10'5 1.70x 10·1 NA NA
Chloroform 2.73 X 10-6 2.73 X 10'4 1.43 X 10'4 1.43 X 10'2 NA NA
Chromium 2.44 X 10-6 9.75 X 10·3 1.13 X 10'3 2.27 X 10'1 NA NA
Cobalt 1.13 X 10 6 3.75 X 104 5.23 X 104 8.72 X 10·3 NA NA
Cyanide 4.32 X 10-8 4.32 X 10·5 2.01 X 10'5 1.00 X 10·3 NA NA
Di-n-butyl phthalate 3.3o'x 10·5 3.67 X 104 4.66 X 104 4.66 X 10·3 NA NA
Di-n-octyl phthalate 3.89 X 10-6 2.16 X 104 5.48 X 10·5 2.74 X 10·3 NA NA
Manganese (water) 1.61 X 104 6.44 X 10'1 7.49 X 10'2 1.50x 101 NA NA
Mercury 7.37 X 10'9 1.64 X 104 4.08 X 10-a 1.36 X 10'2 NA NA
Methylene chloride 1.60 X 10-6 2.67 X 10'5 1.65 X 104 2.76 X 10'3 8.88 X 10'7 9.86 X 10'7
Nickel 1.04 X 10-6 1.04 X 10·3 4.83 X 104 2.42 X 10'2 NA NA
Selenium 2.30 X 10'7 7.68 X 10·5 1.07 X 104 2.14x10·2 NA NA
Silver 1.88 X 10·7 7.51 X 104 8.73 X 10'5 1.75 X 10'2 NA NA
Tetrachloroethene 1.35 X 10·5 1.50 X 10'3 1.31 X 104 1.31 X 10·2 NA NA
Thallium 6.14x 10·9 2.05 X 10'2 2.86 X 10'5 4.76 X 10'1 NA NA
Total Xylenes 2.21 X 10'5 1.11 X 10·5 1.29 X 104 6.44 X 10·5 NA NA
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TABLE 13 ESTIMATED POTENTIAL FUTURE LAND USE HAZARD ASSOCIATED WITH NONCARCINOGENS
POTENTIALLY DERMALLY DERMAL INGESTED. INHALED INHALATION
EXPOSED ABSORBED CONTACT DOSE INGESTION DOSE OF voes
POPULATION CHEMICAL DOSE HQ (mg/kg/day) HQ (mg/kg/day) HQ
(mg/kg/day)
T richloroethene 4.20 X 10.£ 7.78 X 104 1.22 X 104 2.03 X 10-2 NA NA
Vanadium 4.47 X 10.£ 1.28 X 10·2 2.08 X 10·3 2.97 X 10"1 NA NA
Zinc 7.87 X 10·5 4.24 X 10-3 3.66 X 10-2 1.22 X 10·1 NA NA
Total HQ 7.81 X 10·1 1.83 X 10° 9.86 X 10·7
Total Media HI 1.91 X 101
1•.. . .. · .. ··.·.···.··.·.·.·.•.•.· i .·.···.·· .............. · .. ••·•···············•···•·· •.•. E:xposure Medla:.Sprlng yyat~r ti
Child Resident Carbon disulfide 9.19 X 10·7 1.02 X 10·5 2.18 X 10·7 2.18x 10.£ 4.52 X 10.£ 1.51 X 10·3
Manganese (water) 5.13 X 10.£ 2.05 X 10·2 2.92 X 10·5 5.83 X 10·3 NA NA
Methylene chloride 3.45 X 10·7 5.75 X 10.£ 4.35 X 10·7 7.26 X 10.£ 9.05 X 10.£ 1.01 X 10·5
Total HQ 2.05 X 10"2 5.84 X 10·3 1.52 X 10"3 .
Total Media HI 2.79 X 10·2
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I TABLE14 SUMMARY OF CARCINOGENIC EFFECTS OF CHEMICALS OF POTENTIAL CONCERN
INHALATION ORAL CSF EPA GASTROINTESTINAL I CHEMICAL CSF (mg/kg/dayf1 GROUP ABSORPTION
(mg/kg/day)"1 FACTOR a
I Acetone ND ND Db 0.9
I 8is(2-Chloroethyl)ether 1.2X10ob 1.1x10ob 82 b 0.9
8romodichloromethane ND 6.2 X 10'2 b 82 b 0.9
I 2-8utanone ND ND ND 0.9
Carbon Disumde ND ND ND 0.9
I Chloroethane ND ND NA 0.9
Chloroform 8.1 X 10'2 b 6.1 X 10'3 b 82 b 1.0 I Dibromochlorornethane ND 8.4 X 10'2 b Cb 0.9
1,2-Dichloroethane 9.1 X 10·2 b 9.1 X 10'2 b 82 b 0.9 I 1, 1-Dichloroethene 1.75 X 10'1 b 6.1 X 10'1 b Cb 0.93
1,2-Dichloroethene ND C ND ND 0.9 I 1,2-Dichloropropane ND 6.8 X 10·2 d 82 d 0.9
1. Ethylbenzene ND ND Db 0.9
Methylene Chlc,ride 1.7 X 10'3 b 7.5 X 10'3 b 82 b 1.0
I Styrene ND 8 ND 8 ND 0.9
Tetrachloroethene 2.0 X 10'3 8 5.2 X 10'2 8 C -82 • 0.9
I Toluene ND ND Db 1.0
Total Xylenes ND ND Db 1.0
I 1, 1,2-Trichloroethane 5.7 X 10'2 b 5.7 X 10'2 b Cb 0.9
Trichloroethene 6.0 X 10'3 8 1.1 X 10'2 8 C -82 • 0.9
I Vinyl Chloride 3.0X10'1 d 1.9X10'd Ad 0.9
I 8is(2-Ethylhexyl )phthalate ND 1.4 X 10'2 b 82 b 0.9
Di-n-butyl Phthalate Db 0.9 ND ND
I Di-n-octyl Phthalate ND ND NA 0.9
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I TABLE 14 SUMMARY OF CARCINOGENIC EFFECTS OF CHEMICALS OF POTENTIAL CONCERN
INHALATION ORAL CSF EPA GASTROINTESTINAL I CHEMICAL CSF (mg/kg/day)"1 GROUP ABSORPTION
(mg/kg/day)"1 FACTOR a
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Aluminum ND ND NA 0.05 I Antimony ND ND NA 0.05
Arsenic 1.5X 10'1 b 1.75 X 10ob Ab 0.98 I Barium ND ND NA 0.1
Beryllium 8.4X 10° b 4.3x1Qob 82 b 0.001 I Cadmium 6.3x10ob ND 81 b 0.06 .
Chromium VI 1 4.2 X 10'1 b ND Ab 0.05 I Cobalt ND ND NA 0.05
I Copper ND ND NA 0.5
Cyanide ND ND Db 0.05
I Lead ND ND 82 b 0.1
Manganese ND ND Db 0.05
I Mercury ND ND Db 0.15
Nickel 8.4 X 10'' b ND Ab 0.05
I Selenium ND ND Db 0.6.
Silver ND ND Db 0.05
I Thallium ND ND Db 0.05
Vanadium ND ND NA 0.05
I Zinc ND ND NA 0.5
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I, TABLE 14 SUMMARY OF NONCANCER TOXIC EFFECTS OF CHEMICALS OF POTENTIAL CONCERN
I
I CHEMICAL
I ' Acetone
Bis(2-C hloroethyl)ether
I Bromodichloromethane
I 2-Butanone
I Carbon Disuttide
Chloroethane
I Chloroform
I Dibromochloromethane
.1,2-Dichloroethane
I 1, 1-Dichloroethene
1,2-Dichloroethene"
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I 1,2-Dichloropropane
Ethylbenzene
I
I Methylene Chloride
Phenol
I Styrene
Tetrachloroethene
I Toluene
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INHALATION
RfCh
(mg/kg/day)
ND
ND
ND
3x10·1 m
3x10·3d
ND
ND
ND
ND
ND'
ND
1 X 10-om
3 X 10"1m
9 X 10"1 m
ND
3 X 10"1 m
ND
1 X 10·1 m
ORAL RfDh
(mg/kg/day)
1 X 10•1m
ND
2 X 10•2m
5 X 10•2m
10x1ff1m
ND
1 X 1ff2m
2 X 1ff2m
ND
9 X 10•3m
1 X 10'2d
ND
1 X 10'1 m
6 X 10••m
6 X 10·1 m
2 X 10·1 m
1 X 10•2m
2 X 10·1 m
CRITICAL EFFECT
AND
TARGET ORGAN1
(Inhalation; oral)
NA; liver, kidney
damage
NA;NA
NA; renal
cytomegaly
Central nervous
system; fetotoxicity
Fetal toxicity; fetal
toxicity, malformation
NA; NA
NA; fatty cyst on
liver, liver lesions
NA; hepatic lesions
NA; NA
NA q; hepatic lesions
NA; decreased
hematocrtt and
hemoglobin
NA; NA
Developmental
toxicity;
hepatotoxicity and
nephrotoxicity
NA; liver toxictty
NA;NA
NA; RBC and liver
effects
NA; hepatotoxicity
CNS effects, eyes
and nose irrttation;
changes in liver,
kidney weight
UNCERTAINTY
FACTOR1
(Inhalation; oral) .
NA; 1000
NA; NA
NA; 1000
1000; 1000
1000; 100
NA;NA
NA; 1000
NA; 1000
NA; NA
NA; 1000
NA; 3000
NA; NA
300; 1000
100; 100
NA; NA
NA; 1000
NA; 1000
100; 1000
GASTROINTESTINAL
ABSORPTION
FACTOR1
0.9
0.9
0.9
0.9
0.9
0.9
1.0
0.9
0.9
0.93
0.9
0.9
0.9
1.0
0.9
0.9
0.9
1.0
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I TABLE 14 SUMMARY OF NONCANCER TOXIC EFFECTS OF CHEMICALS OF POTENTIAL CONCERN
ORAL RfDh INHALATION CRITICAL EFFECT UNCERTAINTY GASTROINTESTINAL I CHEMICAL Rich (mg/kg/day) AND FACTOR1 ABSORPTION (mg/kg/day) TARGET ORGAN1 (Inhalation; oral) FACTOR1
(Inhalation; oral) I Total Xylenes ND 2 X 10'm NA; hyperactivity, 100; 100 1.0 decreased body
I weight
1, 1,2-Trichloroethane ND 4 X 10•3m NA; clinical NA; 1000 0.9 chemistry alterations I Trichloroethene ND 6 X 10·3P NA;NA NA;NA 0.9 Vinyl Chloride ND ND NA;NA NA;NA 0.9 I
Bis(2-Ethylhexyl)phthalate NA 2 X 10.,m NA; increased liver NA; 1000 0.9 I and kidney weight,
nephrotoxicity
I Di-n-butyl Phthalate ND 1 X 10·1 m NA; whole body NA; 1000 0.9 Di-n-octyl Phthalate ND 2 X 10·2d NA; kidney NA; 1000 0.9
ND 4 X 10' m NA; blood glucose, NA; 1000 0.05 cholesterol
ND 3 X 10,m NA; NA;3 0.98 hyperpigmentation,
keratosis
1 X 10'd 7 X 10•2m Fetotoxicity; 1000;3 0.1 increased blood
pressure
ND 5 X 10'3m NA; ND NA; 100 0.001 Cadmium (water) ND 5 X 10' m NA; proteinuria, NA; 10 0.06 renal damage
Cadmium (food) ND 1 X 10'3 m NA; renal damage NA; 10 0.06 Chromium VI1 ND 5 X 10'3m Nasal mucosa 300;500 0.05 I Cobalt
atrophy; ND
3 X 10'7 p 6 X 10'P Respiratory tract; NA;NA 0.05 blood
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I 1ABLE14 :SUMMARY UF NONCANCER I OXIC t:FFECTS UF GHEMICALS UF t-'OTENTIAL GONCERN
INHALATION ORAL RIDh CRITICAL EFFECT UNCERTAINTY GASTROINTESTINAL I CHEMICAL Rf~ (mg/kg/day) AND FACTOR1 ABSORPTION (mg/kg/day) TARGET ORGAN1 (Inhalation; oral) , . FACTO!¥ -(Inhalation; oral)
I Copper ND ND NA; NA NA;NA 0,5
Cyanide ND 2 X 10•2m NA; reduced weight NA; 100 0,05
gain, thyroid and
myelin effects
Lead ND ND NA;NA NA; NA 0.1
Manganese (water) 1 X 10.,m 5x10•'m Respiratory; CNS 300; 1 0.05
Manganese (food) 1 X 10◄m 1.4 X 10'1m Respiratory; CNS 300; 1 0,05
Mercury 9 X 10-sd 3 X 10-<d Neurotoxictty; kidney 30; 1000 0.15
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Nickel ND .2 X 10•2m NA; decreased body NA;300 0,05
& organ weights
Selenium ND 5x1Q•3m NA; selenosis NA;3 0.6
Silver ND 6 X 10·5m NA; argyria NA; 3 0,05 I Thallium' ND 6x10•5m NA; increased NA; 3000 0,05 SGOT and serum
I LOH levels, alopecia
Vanadium ND 7 X 10'3d NA; none observed NA; 100 0.05
Zinc ND 3 X 10·1 m NA; anemia NA; 10 0,5 I .. The oral CSF Is divided by the gastrointestinal absorption factor (GAF) to estimate a dermal SF, 1.e., a SF based on absorbed, rather than ingested (or
I exposure) dose, see Section 6.4.3 for description of derivation of GAF. IRIS (U.S. EPA. 1993)
ND = Not detennined
d Source: 1992 HEAST, including July 1992 and November 1992 Supplements. I U.S. EPA. 1992, "May 13, 1992 Risk Assessment Teleconference for Superfund Meeting Notes." Value given is for Chromium VI, assuming all chromium found is Chromium VI. 9 Value for nickel refinery dust.
lh The reference concentration or reference dose is the dose below which no adverse effects are likely to be seen (EPA, 1991c and 1992c). Determined by the EPA (1991c, 1992c).
The oral R+D is multiplied by the Gastrointestinal Absorption Factor (GAF). ' NA = Not applicable.
I Source: IRIS. .
Values given are for 1,2-<:is-dichloroethene.
' From the Environmental Criteria and Assessment Office of the U.S. EPA, Cincinnati, Ohio. I By analogy to thallium sulfate, adjusting for differences in molecular weight. NA = Not reported.
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Potential concern for noncarcinogenic effects of a single contaminant in a single medium is expressed as the hazard quotient (HQ) (or the ratio of the estimated intake derived from the contaminant concentration in a given medium to the contaminant's reference dose). By adding the HQs for all contaminants within a medium or across all media to which a given population may be reasonably exposed, the Hazard Index (HI) can be generated. The HI provides a useful reference point for gauging the potential significance of multiple contaminant exposures within a single medium or across media. The HQs and His for the exposure pathways (current and future) identified at the Site are listed in Table 13.
The HQ is calculated as follows:
Non-cancer HQ = CDI/R,D, where:
CDI = Chronic Daily Intake
R,D = reference dose; and
CDI and R,D are expressed in the same units and represent the same
exposure period (i.e., chronic, subchronic, or short-term).
For carcinogens, risk are estimated as the incremental probability of an individual developing cancer over a life-lime as a result of exposure to the carcinogen. Excess life-time cancer risk is calculated from the following equation:
Risk = CDI X SF, where:
· Risk = a unit less probability (e.g., 2 x 1 o·') of an individual developing
cancer;
CDI = chronic daily intake averaged over 70 years (mg/kg-day); and
SF = slope-factor, expressed as (mg/kg-day)"' .
Excess lifetime cancer risks are determined by multiplying the intake level with the cancer potency factor. These risks are probabilities that are generally expressed in scientific notation (i.e., 1 x 10 .. or 1 E-6). An excess lifetime cancer risk of 1 E-6 indicates that, as a plausible upper-bound,
an individual has a one in one million chance of developing cancer as a result of site-related exposure to a carcinogen over a 70-year lifetime under the specific exposure conditions al a site.
EPA has set an acceptable carcinogenic risk range of 1 E-4 to 1 E-6; however, depending upon site factors, a risk of 1 E-4, may be considered protective. If an RA is initiated at a Supertund site, then the Agency strives to achieve a residual cancer risk of no greater than 1 E-6.
The carcinogenic upper-bound risk for each of the exposure pathways (current and future) identified at the Site are summarized in Table 15. The accumulative future risk and hazard index posed by the groundwater at the Site is 2 x 10·3 and 60 for a child, respectively.
6.5 RISK UNCERTAINTY
There is a generally recognized uncertainty in human risk values developed from experimental
data. This is primarily due to the uncertainty of extrapolation in the areas of (1) high to low dose exposure and (2) animal data to values that are protective of human health. The Site specific
uncertainty is mainly in the degree of accuracy of the exposure assumptions.
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The risk assessment is aimed at providing a conservative estimate of risk for the Site. A number of uncertainty and assumptions made throughout the risk assessment are likely to result in an overall overestimation rather than an underestimation of risk. The exposure scenarios also involve a number of uncertainties. Consumption of 2 liters of contaminated drinking water per day for 350 days a year represents the upper bound of potential exposure and has been used because site-specific data were not available. This may be an overestimation of the actual exposure that may occur in the future. The scenario assumes that an adult is consistently being exposed to the same concentrations for 30 years. The daily intake by ingestion is reported as being equal to the daily intake by ingestion; the use of this assumption yields an almost equal risk for the inhalation scenario. Dermal absorption of vapor phase chemicals is considered to be lower than inhalation intakes in many instances and is not considered in this risk assessment. As a result of the uncertainties and assumptions described above, the risk assessment is a conservative analysis intended to indicate the potential for adverse impacts to occur and not an absolute estimate of risk to humans or a specific population.
6.6 ENVIRONMENTAL RISK
Exposure of aquatic and benthic organisms may be exposed via both surface water and sediment. An ecological assessment was conducted during Phase I of the RI for OU #3 to determine if there were any effects of 1,2-DCA on the benthic communities inhabiting the Northeast Tributary. During Phase II of the OU #3 RI, chronic toxicity testing was performed on surface water and sediment samples to further examine ecological impairments noted by the rapid assessment protocol. Chemical, ecological, and toxicological investigations conducted at the Northeast Tributary found ecological impacts in areas of the Northeast Tributary exhibiting elevated levels of 1,2-DCA in surface water or sediments. However, it could not be concluded that 1,2-DCA was the sole cause of this impact in view of the naturally-limiting factors associated with a headwater stream of this type.
6.7 SUMMARY
Actual or threatened releases of hazardous substances from this Site, if not addressed by implementing the response action selected in this Record of Decision, may present an imminent and substantial endangerment to public health, welfare, or the environment. Presently, no unacceptable current risks were identified associated with the NSCC Site. The unacceptable risks connected with the Site are associated with the potential future use of the groundwater as a potable source of water. This is due to the presence of contaminants at concentrations above EPA's MCLs !or drinking water and the State of North Carolina groundwater quality standards. These contaminants will be remediated during the remedial action phase.
Presently, no substantive link can be made between the presence of 1,2-DCA in the Northeast Tributary and limited biodiversity in this stream as the area of the stream impacted by the Site is approximately 1,500 feet from the head-water of this stream.
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7.0 REMEDIAL ACTION OBJECTIVES
NATIONAL STARCH & CHEMICAL COMPANY SUPERFUND SITE
AEOORD OF DECISION FOR 0PERABlE UNIT #3
Section 7 .0 defined the extent and characterized the contamination and the environmental setting of OU #3. Section 8.0 highlighted the human health and environmental risks posed by the Site. This Section specifies the remedial action objectives to protect human health and the environment by preventing exposure to the contaminants in the groundwater and surface water/sediment associated with OU #3.
The specific remedial action objectives and general response actions for the environmental media adversely impacted by the Site addressed in this ROD are listed in Table 16.
7.1 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARS)
Section 121 (d} of CERCLA, as amended by SARA, requires that remedial actions comply with requirements or standards set forth under Federal and State environmental laws. The requirements that must be complied with are those laws that are applicable or relevant and appropriate (ARAR} to the (1} remedial action(s}, (2) location, and (3) media-specific contaminations at the Site.
Applicable requirements defined in 40 C.F.R. § 300.400(9)(1} are those requirements applicable to the release or RA contemplated based upon an objective determination of whether the requirements specifically addresses a hazardous substance, pollutant, contaminant, RA, location, or other circumstance found at a CERCLA site. These requirements would have to be met under any circumstance. Relevant and appropriate requirements defined in 40 C.F.R. § 300:400(g)(2} are those requirements that address problems or situations sufficiently similar to the circumstances of the release or removal action contemplated, and whether the requirement is well suited to the Site. The action-, chemical-, and location-specific ARARs for the selected remedial alternative are listed in Table 19.
7.2 EXTENT OF CONTAMINATION
The extent and volume of contaminated soils will be addressed in OU #4 ROD.
Figures 3, 4, and 7 delineate the estimated periphery of the plumes in the groundwater associated with OU #3. These plume estimates are based on contamination levels detected in the groundwater as well as where there were no detections of contaminants in the groundwater.
Calculations were performed to estimated the volume of groundwater which needs to be remediated. By using an estimated surface area of 748,481 square feet, a saturated aquifer thickness of 26 feet in the saprolite and 100 feet in the bedrock, and an aquifer porosity of 35 percent in the saprolite and 5 percent in the bedrock, the quantity of contaminated groundwater in one pore volume of the aquifer was estimated to be 131 million gallons.
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NATlONAI. STARCI< & CHEM~ COMPANY SUPERF\JND SITE
RECORD OF 0EC>SON RlR 0PERABlf UNIT '3
8.0 DESCRIP.TION OF-ALTERNATIVES
Due to an insufficient evaluation of soil remediation technologies in the June 21, 1993 FS document, this ROD will only address the remediation of groundwater and surface water/sediment. Soil remediation in Area 2 and lagoon area will be addressed in OU #4.
Table 17 inventories those technologies that passed the initial screening for remediating the contaminated groundwater and surface water/sediment at OU #3. In the initial screening, process options and entire technologies were eliminated from consideration if they are difficult to implement due to Site constraints or contaminant characteristics, or if the technology has not been proven to effectively control the contaminants of concern. Table 17 also presents the results of the final screening of the groundwater remediation technologies. Effectiveness, implementability, and relative capital and operation and maintenance costs are the criteria used for evaluating the technologies and process options in the final screening. The process options that were retained for further evaluation are boxed in by a bold line. This table provides the rationale as to why certain technologies were not retained for the detailed comparison.
The five (5) groundwater remediation alternatives retained to address the estimated 131 million gallons of contaminated groundwater and the two (2) surface water/sediment remediation alternatives are described below.
8.1 REMEDIAL ALTERNATIVES TO ADDRESS GROUNDWATER CONTAMINATION
Although the groundwater alternatives for addressing contaminated groundwater for Area 2 and the lagoon area were considered separately in the FS, they were combined in this ROD. Area 2 alternatives are identified by "P" for the "Plant" and the alternatives dealing with the contaminated groundwater associated with the lagoon area are identified by "L" for "Lagoon Area".
Alternative GWP1 /GWL 1:
Alternative GWP2/GWL2:
Alternative GWP3/GWL3:
Alternative GWP4NGWL4A:
Alternative GWP4B/GWL4B:
No action
Long-Term Monitoring with Fencing A Portion of Northeast
Tributary
Institutional Controls with Fencing A Portion of Northeast
Tributary
Groundwater Extraction, Air Stripping, Vapor-Phase Carbon Adsorption, Discharge to Publicly Owned Treatment Works (POTW) (i.e., local sewer system)
Groundwater Extraction, Air Stripping, Fume Incineration,
Discharge to POTW
The point of compliance for all the groundwater alternatives listed above for OU #3 is defined as throughout the entire plume of contamination in accordance to 40 CFR 300.430(a)(1 )(iii)(F) which states "EPA expects to return usable ground waters to their beneficial uses wherever practicable, within a timeframe that is reasonable given the particular circumstances of the site. When restoration of ground water to beneficial uses is not practicable, EPA expects to prevent further migration of the plume, prevent exposure to the contaminated ground water and evaluate further risk reduction."
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NATlONAL STAROi & CHEMICAL COMPANY SUPERRJNO SnE
RECORD OF DEC>SON FOR OPERABI.E UNIT #3
TABLE 15 SUMMARY OF CANCER RISK (ILCR) AND NONCANCER HI VALUEa
Current Land Use
Child/llCR 8 X 10·5 1 X 10_. 4 X 10_.
Child/HI 6 X 10·2 4 X 10·2 1 X 10·1
Adult/lLCR NA NA NA
Adult/HI NA NA NA
Child/lLCR 4 X 10·1 9 X 10·9 1 X 10·7
Child/HI 5 X 10·7 6 X 10·7 6 X 10-6
Adult/lLCR NA NA NA
Adult/HI NA NA NA
Child/lLCR 2 X 10·5 2 X 10·5 1 X 10-4
Child/HI 1 X 10·2 1 X 10·2 3 X 10·2
Adult/lLCR NA NA NA
Adult/HI NA NA NA
Child/lLCR NA NA 2 X 10·3
Child/HI NA NA 6 X 101
Adult/lLCR NA NA 2 X 10·3
Adult/HI NA NA 2 X 101
• Values presented are the sum for all exposure pathways associated with the environmental
medium.
b Outside the plant area; the fence successfully precludes access to the plant area.
c Inside the plant area; the fence around the plant area-is not functional.
d The NSCC property is available for residential use.
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NAOONAI. STARCH & CHEMICAL COMPANY SUPERFUND Sm,
REOORD Of DECl~ON FOR O!>ERABLE UNIT #3
TABLE16 REMEDIAL ACTION OBJECTIVES AND ASSOCIATED GENERAL RESPONSE
ACTIONS
MEDIUM REMEDIAL ACTION OBJECTIVE GENERAL RESPONSE ACTION
-
Groundwater For Human Health: Prevent ingestion of No Action
water having levels of 1,2-DCA resulting in lnstttutional Control
cancer risks exceeding the 1 o~ to 10"6 risk Containment
range. Containment/Treatment
Collection/Discharge
For Environmental Protection: None, Collection/Treatment/Discharge
groundwater concentrations have not
conclusively been found to represent an
environmental hazard.
Surface Water For Human Health: None, surface water is No Action
not a drinking water source. Existing Monitoring
concentrations of 1,2-DCA are below
Ambient Water Qualtty Criteria.
' For Environmental Protection: None,
surface water concentrations have not
conclusively been found to represent an
environmental hazard.
Sediment For Human Health: Prevent direct contact No Action
with sediments having levels of 1,2-DCA Monitoring
resulting in cancer risks exceeding the 104
to 1 O-' risk range.
For Environmental Protection: None.
I
General
Response
Action
NoAcllon
ln9111Utlonal Coolrol
Conlalrmanl
CoolalnnwlVT"'81manl
I
I ColledlocvT -monl/ll
-- -- - - - - - -
Technology Type Process Option
H WA H WA I
H -Re9111dlono H Daad-lono I
H Vortk:al 5utNulaco Flow eoo1ro1H Exlradlonlhjadl Wells
~ Vertical -Flow Coolrol H
In Situ Trellmonl :::::r· :
Coo-nal Elilnldlon Walla I
}-~ Exuacllon
Enhanood -Wallo I
~ SUbalrflloo Crain lnlar,_._ Trwd'I I
-rl lnllllndlon I
~ On-Sft1D--lJ 1n~ I
I
14 POTW I
~ On-SleD-•-
SUrfaoa WIier I
I Coovenllonal Elllracllon Wells I
~ Exlradlon I-
I Enhanood Eldradlon Walla I
~ SUbalrflloo Crain ~ In Trench I
f NI I
1 p,_,,. T-nl • Carbon I
!iloam I
14~
Oxldallon I
-' Chamlcal Troalmonl ---I
14 ~ ~---OU-1 Pralrealment ~am I
~ BlolfVW'A• Treatmanl
~ Aaroblc Bloraaclor I
lnstltutlonal
lmplementeblllty
Eully'"1>1omonl-
Eaoll, h1.-1&1dal>la
in.,.,.,_
ln..,.,a,table
ln .... ,.,lable
No1 '"1>1omo_,., _
'"1>1om•_d_ wllh -Dllllcully
ln.,Ao,1a1blbla
~-Modondo Dllllcully
.....,__ _ lllflbJlly
lr14)kw1.a1table
Nol i..,-od '°' ~
e--. 111.,Ao,1•,1--NI e,, __ -Bo~
Ealy~
~ ....... lablo
ln.,Ao,••·-
lnJ'OV11"'9 Ted•do,w
~ wlh DHllculy
i..,-al>la wlh Dlfflallly
- - - - - -
Effectiveness
In Meeting PRGs
Nol Ellacllva
~lly Elledlve
Not Elled"'9 -Wa!lf -
Tl9almonl lo Moel PROO
E-
Soo • .-Elled"'9
Nol Effod"'9 • Wal« -
Tl9alm0nl lo Moel PRGo
V--, Elledlve
V--,Ellodlve
Nol E-lo,~•~
v--, Ellodlve
V--, Ellodlve
Ellldlvo
Ellodlve
~-Effod-
Modof8!oly Effodlve
Modolately Effodlwl
Cost
Lowlo-•
-lllolyltlgh
~High
Lowlo-•
-aloluHlgh
-ideluHlgh
TABLE 20 SECOND SCREENING OF TECHNOLOGIES AND PROCESS OPTIONS FOR GROUNDWATER
---- - - - - -- -General
Respons-
Actlon
I Colledlon1Trea1
j
Technology Type
Ort-SKo Dlocharge
Off.Site
._ _______ __, • Prooeos Option Relalned
l
l.j
J ~·
lnstltutlonal
PrOC889 Option lmplernenteblllty
l'lllrallon I lrrc>--wllh -Ollllcully
1-1~ I .............
CIIVPOlW I lrrc>.,monl_ wllh -Dlfflcully
SUrface Wat• I "'1>lementable dh llffllrully .
-- - - --Effectiveness
In Meeting PRGe Coat
Ellodlve Low to Modande
Elli>dlve low
Elli>dlve Mudlw"""'lllgh
Ellodlve . .__,
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8.1.1 ALTERNATIVE GWP1/GWL1: No action
NATIONAL STARCH & CHEMICAL COMPANY St!PERRJND SITE
RECORD OF DECISION FOR OPERABLE UNIT 13
The No Action alternative is included, as required by CERCLA, to establish a baseline for
comparing the benefits achieved by the other groundwater remediation alternatives. Under these
alternatives, no cleanup activities would be implemented to remediate the groundwater adversely
impacted by past Site activities (i.e., the Site is left "as is"). Because these alternatives do not
entail contaminant removal or destruction, hazardous materials would remain on Site requiring
a review of the Site remedy every five years in accordance with CERCLA Section 121(c). The
implementation of this remedy could begin immediately and would have no negative impact on
future remedial actions.
A slight reduction in the levels of contamination may occur over lime through natural processes;
however, the levels in the groundwater would remain above the groundwater cleanup goals for
up to 70 years. Although there is no current unacceptable risk associated with the contaminated
groundwater, this situation would change immediately if a potable well was installed near the Site.
The reason there is no current risk is because nobody in the vicinity of the adversely impacted
groundwater is using this groundwater as a source of drinking water. However, if a potable well
was installed in or near the plume, the risk would increase to 2 x 10-3• Since this alternative does
not involve any treatment or other remedial action, the reduction in the toxicity, mobility, or volume
(TMV) of the contaminated groundwater at the Site would result from natural processes.
There are no capital costs associated with this alternative; however, O&M costs would be incurred
for conducti.ng the five year reviews. This review includes monitoring the groundwater under the
Site once every five years as well for a period of 30 years.
Capital Costs:
Annual O&M Costs:
Total PW Costs for 30 Years:
Time to Design:
Construction Time:
Duration to Achieve Clean-up:
$ 0
$ 22,000
$ 227,000
None
None
Over 30 years
8.1.2 ALTERNATIVE GWP2/GWL2: Long Term Monitoring and Fencing
A Portion Of Northeast Tributary
This alternative is analogous to Alternative GWP1/GWL 1, except under Alternative GWP2/GWL2
additional monitoring wells would be installed, groundwater monitoring data would be collected
annually instead of once every five years, and a portion of the Northeast Tributary would be
fenced. Extending the existing fence line to inclose additional portions of the Northeast Tributary
is a precautionary action to reduce the future likelihood of exposing children to unacceptable
levels of contaminants in the Northeast Tributary via dermal absorption, ingestion, and/or
inhalation. As stated in Section 6.0, the current levels of contaminants in the Northeast Tributary
do not pose an unacceptable risk. However, under this alternative, the contaminated groundwater
is not actively remediated which could lead to higher levels of contaminants entering the
Northeast Tributary along with the groundwater. This increase in concentrations of contaminants
entering the stream may result unacceptable exposure concentrations in either water column or ·
sediment or both.
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Capital Costs:
Annual O&M Costs:
Total PW Costs for 30 Years:
Time to Design:
Construction Time:
Duration to Achieve Clean-up:
:96-
$ 178,000
$ 138,000
$1,479,000
None
None
Over 30 years
NATIONAL STARCH & CHEMICAL COMPANY SUPERRJNO SITE
RECORD DF DEOSON FOO 0PERA8l£ UNIT #3
8.1.3 ALTERNATIVE GWP3/GWL3: Institutional Controls. Long Term Monitoring. and
Fencing A Portion Of Northeast Tributary
This alternative is identical to Alternative GWP2/GWL2, except Alterative GWP3/GWL3 includes
institutional controls. No remediation activities would be conducted for groundwater. The
additional costs are associated with preparing and filing deed restriction(s) and implementing the
other institutional controls. The specific institutional controls to be implemented. include: using
deed restrictions to control the installation of new we!ls on both the plant property and adjacent
property; track plume migration; and install fencing around the Northeast Tributary to limit access
to contaminated surface water and sediment.
This alternative provides no reduction in TMV of the contaminants; however, it can reduce or
eliminate direct exposure pathways and the resultant risk to the public. As part of this alternative,
the groundwater would be monitored on a yearly basis. As EPA may not have the authority to
implement these institutional controls, the responsibility rests with the State of North Carolina to
ensure the institutional controls are in place, are reliable, and will remain in place after initiation
of O&M. Therefore, the responsibility for implementing and enforcing institutional controls falls
on the State of North Carolina. Groundwater monitoring and the five year CERCLA review would
be conducted for 30 years.
Capital Costs:
Annual O&M Costs:
Total PW Costs for 30 Years:
Time to Design:
Construction Time:
Duration to Achieve Clean-up:
$ 198,000
$ 138,000
$1,500,000
None
None
Over 30 years
8.1.4 ALTERNATIVE GWP4A/GWL4A: Groundwater Extraction Through Wells;
Treatment by Air Stripping with Vapor-Phase Carbon Adsorption;
and Discharge to POTW
This alternative includes extracting groundwater by means of extraction wells downgradient of
both areas, Area 2 and the lagoon area; volatile organics removal through air stripping; control
of emissions to the atmosphere from the air stripper through vapor-phase carbon adsorption; and
combined discharge with treated groundwater from QlJ-1 to the Salisbury publicly owned
treatment works (POTW). The treated effluent must meet permit limits set by the Salisbury
POTW. Spent activated carbon would be changed out and sent to a commercial
regeneration/recycling facility, destroyed through incineration, or disposed in an appropriately
regulated landfill. The five year review CERCLA requirement would apply to this alternative. ,
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Capital Costs:
Annual O&M Costs:
Total PW Costs •for 30 Years:
Time to Design:
Construction Time:
Duration to Achieve Clean-up:
-97-
$1,437,000
$ 740,000
$5,792,000
1 year
6 months
15 to 30 years
NATIONAL STARCH & CHEMICAL COMPANY SUPERF\JNO Sm;
RECORD OF DEOSON FOA 0PERABlE UNIT #3
8.1.5 ALTERNATIVE GWP4B/GWL4B: Groundwater Extraction Wells, Treatment by
Air Stripping with Fume Incineration; and Discharge to POTW
This alternative is identical to Alternative GWP4A, except that the control of emissions to the
atmosphere from the air stripper would be accomplished through fume incineration.
Capital Costs:
Annual O&M Costs:
Total PW Costs for 30 Years:
Time to Design:
Construction Time:
Duration to Achieve Clean-up:
$1,679,000
$ 659,000
$5,270,000
1 year
6 months
15 to 30 years
8.2 REMEDIAL ALTERNATIVES TO ADDRESS SURFACE WATER AND SEDIMENT
CONTAMINATION
8.2.1 ALTERNATIVE SW/SE-1: No Action
No further activities would be conducted on surface water or the sediment in the Northeast
Tributary. As with Alternative GWP1/GWL 1, this stream would be left "as is". Samples would be
collected and analyzed every five years as part of the five year review CERCLA requirement
which would apply to this alternative.
Capital Costs:
Annual O&M Costs:
Total PW Costs for 30 Years:
Time to Design:
Construction Time:
Duration to Achieve Clean-up:
$ 0
$ 16,000
$151,000
None
None
Over 30 years
8.2.2 ALTERNATIVE SW/SE-2: Long-Term Monitoring
This alternative is similar to Alternative SW/SE-1, except under Alternative SW/SE-2, surface
wate'r and sediment samples would be collected from the Northeast Tributary annually instead
of once every five years.
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Capital Costs:
Annual O&M Costs:
Total PW Costs for 30 Years:
Time to Design:
Construction Time:
Duration to Achieve Clean-up:
-98-
$ 0
$92,000
$867,000
None
None
Over 30 years
NATlONAL STARCH & CHEMICAL COMPANY SUPERRINO SITE
RECORD Df DECISON FOR OPERABtE UNIT #3
9.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
Section 8.0 describes the remedial alternatives that were evaluated in the detailed analysis of
alternatives set forth in the June 21, 1993 OU #3 Feasibility Study Report. This section
summarizes the deiailed evaluation of these remedial alternatives in accordance with the nine (9)
criteria specified in the NCP, 40 CFR Section 300.430(e)(9)(iii). This section summarizes the
comparison of the groundwater and surface water/sediment remedial alternatives; the soils
remedial alternative will be addressed under OU #4.
9.1 THRESHOLD CRITERIA
In order for an alternative to be eligible for selection, it must be protective of both human health
and the environment and comply with ARARs; however, the requirement to comply with ARARs
can be waived in accordance to 40 CFR Section 300.430(f)(1)(ii)(C). Table 18 summarizes the
evaluation of the five (5) groundwater and two (2) surface water/sediment remedial alternatives
with respect to the threshold criteria.
9.1.1 OVERALL-PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
This criterion assesses the alternatives to determine whether they can adequately protect human
health and the environment from unacceptable risks posed by the contamination at the Site. This
assessment considers both the short-term and long-term time frames.
Under current conditions, the groundwater does not pose an unacceptable risk to human health
or the environment. And in contemplating future use scenarios for the Site in the Risk
Assessment, the scenario that typically results in manifesting the greatest risk, using
contaminated groundwater as potable water, the overall risk posed by the Site was 2 x 1 o·'.
Alternatives GWP2/GWL2, GWP3/GWL3, GWP4NGWL4A, and GWP4B/GWL4B, provide
adequate. protection for human health by preventing ingestion of potentially contaminated
groundwater and surface water. Alternatives GWP4NGWL4A and GWP4B/GWL4B would afford
the greatest protection to human health because it would substantially reduce the contamination
in the groundwater and prevent the potential for exposure through use of existing or future off site
wells. Alternatives GWP4NGWL4A and GWP4B/GWL4B would also remediate the surface water
and sediment, which would eliminate the potential for exposure via ingestion of these media.
These alternatives protect the environment by removing contaminants from groundwater,
controlling the extent of groundwater contamination, and reducing the contamination in the
tributary and downstream surface waters. Alternative GWP3/GWL3 would not be as protective
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NATIONAL STARCH & CHEMICAL COMPANY SUPERF\JND SITE
REOORD OF DEOSON FOO OPERABLE UNIT '3
of the environment because contamination would continue to migrate into the tributary through
groundwater discharge. Neither Alternatives GWP1 /GWL 1 nor GWP2/GWL2 would provide
protection for either human health or the environment. Natural degradation/attenuation of
contaminants in the subsurface is not anticipated to prevent the potential migration of
contaminants off site, although such processes may reduce the amount and concentration of
contaminants which would eventually leave the Site.
Under present conditions, both Alternatives SW/SE-1 and SW/SE-2 would be protective of human
health, but may not be protective of the environment. If higher concentrations are discharged into
the stream along witti the groundwater, then both alternatives may not be protective of human or
the environment. ·
9.1.2 COMPLIANCE WITH APPLICABLE OR RELEVANT AND APPROPRIATE
REQUIREMENTS
This criterion assesses the alternatives to determine whether they attain ARARs under federal
and state environmental laws, or provide justification for waiving an ARAR.. Site specific ARARs
are identified in Table 19.
MCLs and State groundwater quality standards are ARARs for Site groundwater. By leaving
contaminants above MCLs in the groundwater, Alternatives GWP1/GWL 1, GWP2/GWL2, and
GWP3/GWL3 would not comply with these ARARs. Therefore, these alternatives would not
achieve the requirements of the NCP. Alternatives GWP4A/GWL4A and GWL4B/GWL4B would
obtain performance standards for groundwater (MCLs and North Carolina Groundwater
Standards), surface water and sediment at the point of compliance. These alternatives would
also comply with action-and location-specific ARARs related to the construction and operation
of the groundwater extraction, treatment, and discharge systems to be installed under these
Alternatives. The discharge to the POTW and air emission associated with Alternatives
GWP4A/GWL4A and GWL4B/GWL4B will also satisfy all appropriate ARARs. The disposal of
any sludge or spent activated carbon created by the groundwater treatment system will also
comply with the appropriate ARARs.
There are no Federal or State ARARs for the contaminants detected in the surface water or
sediment originating from the Site.
.9.2 PRIMARY BALANCING CRITERIA
These criteria are used to evaluate the overall effectiveness of a particular remedial alternative.
This evaluation is summarized in Table 20.
9.2.1 LONG-TERM EFFECTIVENESS AND PERMANENCE
This criterion assesses the long-term effectiveness and permanence an alternative will afford as
well as the degree of certainty to which the alternative will prove successful.
Under Alternatives GWP1/GWL 1, GWP2/GWL2, and GWP3/GWL3 groundwater contamination
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NAOONAL STARCH & CHEMICAL COMPANY SUPERFUNO SITT'
RECORD OF DeasoN FOR OPERABIE UNIT #3
would not be actively remediated; therefore these alternatives cannot be considered to be permanent or effective remedial solutions as these alternatives do not remove, treat, or isolate subsurface contamination. The long-term effectiveness of Alternatives GWP1 /GWL 1 and GWP2/GWL2 is questionable, because of the time it would require for "Nature" to clean "Itself'. These remedies would rely on the natural attenuation and the flowing groundwater to eventually remove all the contaminants that have entered the groundwater at the Site. Alternative GWP3/GWL3 would prevent potential future risk by preventing the installation of drinking wells in any areas exceeding MCLs or North Carolina Groundwater Standards. Alternatives GWP4NGWL4A and GWP4B/GWL4B would provide an effective and permanent solution for groundwater, surface water, and sediment because the chemicals of concern would be removed from the groundwater and destroyed. The reliability of Alternatives GWP4NGWL4A · and GWP4B/GWL4B is high and these alternatives would not pose a human health or environmental risk at the point of compliance and no treatment residuals would be left on Site. Five-year CERCLA mandated reviews will be required for all of the alternatives.
Under current conditions, both Alternatives SW/SE-1 and SW/SE-2 would be protective of human health, but may not be protective of the environment. If higher concentrations of contaminants. begin discharging into the tributary, then neither of these alternatives may be protective of human or the environment.
9.2.2 REDUCTION OF TOXICITY, MOBILITY, OR VOLUME
This criterion assesses the degree to which the alternative employs recycling or treatment to reduce the TMV of the contaminants present at the Site.Alternatives GWP4NGWL4A and GWP4B/GWL4B would reduce the toxicity and volume of contamination in groundwater through removal and treatment. They would also reduce the toxicity and volume of contamination in surface water and sediment. The groundwater treatment processes associated with these two alternatives would completely comply with the statutory preference for alternatives that reduce toxicity of contaminants. Alternatives GWP1/GWL 1, GWP2/GWL2, and GWP3/GWL3 do not directly reduce toxicity, mobility, or volume of groundwater, surface water or sediment contamination.
Alternatives SW/SE-1 and SW/SE-2 could lead to a reduction of VOCs in the tributary; however, neither of these alternatives would result in the destruction of the VOCs. These contaminants would transfer from the tributary to the atmosphere through the process of volatilization.
9.2.3 SHORT-TERM EFFECTIVENESS
This criterion assesses the short-term impact of an alternative to human health and the environment. The impact during the actual implementation of the remedial action is usually centered under this criterion.
All of the alternatives for both groundwater and surface water/sediment can be implemented without significant risk to the community or on-site workers and without adverse environmental impacts.
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NATIONAL STARCH & CHEMICAL COMPANY SUPERF\JNO SITE
RECORD Of DE<>SION FOR 0PERAB1£ UNIT 13
TABLE 18 SUMMARY OF THE THRESHOLD CRITERIA EVALUATION FOR THE
ALTERNATIVES
GWP2/GWL2: Long Term
Monitoring; Fence Portion of
Northeast Tributary
GWP3/GWL3: lnstttutional Controls;
Long Term Monttoring; Fence
Portion of Northeast Tributary
GWP4NGWL4A: Groundwater
Extraction; Treatment Via Air
Stripping and Vapor-Phase
Adsorption; Discharge to POTW
GWP48/GWL4B: Groundwater
Extraction; Treatment Via Air
Stripping and Fume Incineration;
Discharge to POTW
SW/SE-1: No Action
SW/SE-2: Long-Term Monttoring
Does not eliminate any exposure
pathways or reduce the level of risk~
Does not eliminate any exposure
pathways, reduces potential risk of
exposure to contaminated surtace
water/sediment by fencing stream.
Contamination would continue to
discharge into Northeast Tributary.
Potential offstte contaminant migration
would not be eliminated. Institutional
controls would eliminate risk posed by
using contaminated groundwater as
potable water. Contamination would
continue to discharge into Northeast
Tributary.
Offsite contaminant migration would be
eliminated. Eliminates potential risk of
ingestion, inhalation, and dermal
absorption .. Eliminates contamination
entering Northeast Tributary.
Offsite contaminant migration would be
eliminated. Eliminates potential risk of
ingestion, inhalation, and dermal
absorption. Eliminates contamination
entering Northeast Tributary.
Protective of human health but may not
be protective of the environment.
Protective of human health but may not
be protective of the environment.
Not in compliance
Not in compliance
Not in compliance
In compliance
In compliance
No Federal or State
ARARs for contaminants
detected in stream. ·
No Federal or State
ARARs for contaminants
detected in stream.
ilil ----- --
-102-
TABLE 19 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
5T ANDARD REQUIREMEITT,
CRITERIA, OR LIMITATION
GROUNDWATER
Safe Drinking Water Act
Natonal Primary Drinking
Water Standards
Maximum Contaminant Level
Goals
SURFACE WATER
Clean Water Act
Ambient Water Quality Criteria
(AWOC)
National pollutant Dischaige
Elimination System (NPDES)
Nafonal Prelreatment Program
Water Quality Management
Plans (WQMP)
CITATION
42 U.S.C § 300
40 CFR Par1141, Subpart B
40 CFR Par1 141, Subpart F
33 U.S.C. §§ 1311, 1313, 1317
40 CFR Par1131
40 CFR Par1122, Subpar1 C
40 CFR Par1 403
40 CFR Par1 130
DESCRIPTION
Establishes slandards for drinking water
Establishes heahh-based standards for public
water systems maximum contaminant levels
(MCLs)
Establishes drinking water quality goals set at
levels of no known or antici>ated adverse heahh
effects
Defines laws responsible for prolection of the
integriy of the nations waters
Sets criteria for water quality based on toxi~y lo
aquatic organisms and human health
Defines charge lim~ for pollutants; use of best
available technology economically achievable for
toxic pollutants discharged lo surtace waters
Sets limns for discharge to POTWs
Sets criteria for water quality based\n toxi~y to
aquatic organisms and human health; discharge
must comply ~h EPA-approved WQMP
--------·
APPUCABLEIRELEV 00
AND APPROPRIATE
No/Yes
No/Yes
No/Yes
YesNes
No/Yes
Yes,No
Yes,No
No/Yes
NATIOK,\L STARCH & CJ-EMICAL COMPANY SUPERFUND SITE
RECORD Of DECISION FOR OPERABLE UNIT #3
CoMMEITTS
The MCLs for organic and inorganic contaminants
must be addressed as the groundwater is a being
used a sou;ce for drinking water
MCLGs are appropriate at this Stte as i is a source of
drinking water
The AWOC for organic and inorganic contaminants
are relevant and appropriate
Discharge from facilnies must comply ~h NPDES
regulations
Pretrealmenf regulations must be met if wastewater is
discharged to a POTW
Criteria available for water and fish consumption; if
waster water is discharged to a waterway, tt must be
in accord wtth a WQMP
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-103-
TABLE 19 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
STANDARD REQUIREMENT,
CRITERIA, OR LIMITATION
AIR
Clean Air Ad
CITATION
40 U.S.C. §§ 1857, 7409, 7411,
7412
National Primary and 40 CFR Part SO
Secondary Ambient Air Quality
Standards
National Emissions Standards 40 CFR Part 61
for Hazardous Air Pollutants
(NESHAPs)
GROUNDWATER, SURFACE WATER, AIR
North Carolina Drinking Water and
Groundwater Standards
North Carolina Water pollution
Control Regulations
North Carolina Air Pollution Control
Requirements
NCAC Tile 1 SA, Chapter 2,
Subchapter 2L
NCAC Tile 1 SA, Chapter 2,
Subchapter 2H
NCAC Tile 1 SA, Chapter 2,
Subchapter 2D
DISPOSAL -DISCHARGE To SURFACE WATER/POTW
North Carolina_ Drinking Water and
Groundwater Standards
NMh Carolina Water Pollution
Control Regulations
North Carolina Air Pollution Control
Requirements
NCAC Tile 1 SA, Chapter 2,
Subchapter 2B
NCAC Tile 1 SA, Chapter 2,
Subchapter 2H
NCAC Tile 1 SA, Chapter 2,
Subchapter 2D, 2H
DESCRIPTION
Identifies laws responsible for protection of the
nations air qualiy
Sets primary and secondary air standards at
levels to protect public health and public welfare
Provides emissions standard for hazardous air
pollutants for which no ambient air qualiy
standard exists
Establishes groundwater classes and regulates
water qualiy standards
Establishes permi procedures and condiions for
wastewater discharges
Establishes emission limis for air pollutants
Surtace water qualiy standards
Regulates surtace water discharges and
discharges to POTWs
Air pollution control and air quality and emissions
standards
-- - - -- -
APPLICABLE/RELEVANT
AND,APPROPRIATE
Yes,No
Yes,No
Yes,No
Yes,No
Yes,No
Yes,No
Yes,No
Yes,No
Yes,No
NATIONAL SrAflCH & CI-EMICAL CoMPANY SUPERFUND SITE
REcoRo OF DECISION FOR OPERABLE UNIT #3
CoMMENTS
Applicable for on-sie treatment unis having air
emissions
Applicable for on-sie treatment unis wih hazardous
emissions
The guidelines for allowable levels of toxic organic
and inorganic contaminants are applicable as the
groundwater is used as a drinking water source
Must be complied wih n wastewater is discharged to
surtace water
Air regulations must be complied wih if treatment
resufts in air emissions
Standards must be maintained after discharge of
treated water
Must be complied wih if discharged to surtace water
or POTW is necessary
Must be considered if treatment results in air-
emissions
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NATIONAl STARCH & CHEMICAL CoMPANY SUPERFUND SITE
RECORD OF DECISION FOR OPERABLE UNIT #3
TABLE 20 SUMMARY OF PRIMARY BALANCING CRITERIA EVALUATION OF THE ALTERNATIVES
GWP 1 /GWL1 : No
Action
GWP2/GWL2: Long-
Tenn Monitoring;
Fence Portion of
Northeast Tributary
GWP3/GWL3:
Institutional Controls;
Long-Tenn Monitoring;
Fence Portion of
Northeast Tributary
Does not meet ARARs. Length of
service unknown (not permanent).
Ongoing monitoring of groundwater
contaminant levels would be
conducted to assess contaminants
migration. ARARs are not met at
the Site. Length of service ·
unknown (not pennanent). Fence
would reduce potential of exposure
10·contaminated surtace
water/sediment.
Ongoing monitoring of groundwater
contaminant levels would be
conducted to assess contaminants
migration. ARARs are not met at
the Site. Effectiveness is
depended on enforcement of
institutional controls. Length of
service unknown (not permanent).
Fence· would reduce potential of
exposure to contaminated surtace
water/sediment.
None, except natural
attenuation.
None, excep1 natural
attenuation.
None, except natural
attenuation.
None.
None.
None.
---None. 0 227
None. 0 1,479
None. 0 1,500
-------------------NATIONAL STARCH & CHEMICAL CoMPANY SUPERFUND SITE
RECORD OF DECISION FOR OPERABLE UNIT 13
-105-
TABLE 20 SUMMARY OF PRIMARY BALANCING CRITERIA EVALUATION OF THE ALTERNATIVES
GWP4A/GWL4A:
Groundwater
Extraction; Treatment
Via Air Stripping and
Vapor-Phase
Adsorption; Discharge
to POTW
GWP4B/GWL4B:
Groundwater
Extraction; Treatment
Via Air Stripping and
Fume Incineration;
Discharge to POTW
SW/SE-1: No Action
SW/SE-2: Long-Term
Monitoring
Pennanent remedy.
ARARs are met.
Pennanent remedy.
ARARs are met.
Under current conditions human
health may be protected but
possibly not the environment.
Under current conditions human
health may be protected but
. possibly not the environment.
Eliminates TMV of
contaminants and potential
for off-site migration.
Greatest degree of risk
reduction for ingestion,
inhalation, and dennal
absorption.
Eliminates TMV of
contaminants and potential
for off-site migration.
Greatest degree of risk
reduction for ingestion,
inhalation, and dennal
absorption.
Would increase mobility of
contaminants, however,
through volatilization toxicity
and volume of
contaminants in the water
column would be reduced.
Would increase mobility of
contaminants, however,
through volatilization toxicity
and volume of
contaminants in the water
column would be reduced.
Potential release of voes
during extraction well
installation and treatment
system operation. Noise
nuisance due to operation
of drilling equipment.
Potential release of voes
during extraction well
installation and treatment
system operation. Noise .
nuisance due to operation
of drilling equipment.
None.
None.
'IIR
llI!~ i&~li ··11ill1!11i
Design of extraction,
treatment, discharge, and
monitoring systems. Air
stripping of voes to meet
POTW pretreatment
requirements. Treatment of
air stripping off-gases will
be required during start-up.
Design of extraction,
treatment, discharge, and
monitoring systems. Air
stripping of voes to meet
POTW pretreatment
requirements. Treatment of
air stripping off-gases will
be required during start-up.
None.
None.
12 months to design
6 months to oonstruct
12 months to design
6 months to oonstruct
None.
None.
5,792
5,270
151
867
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9.2.4 IMPLEMENTABILITY
NATIONAL STARCH & CHEMICAL COMPANY SUPERFUND SITE
REOORO OF DECISION FOR OPERABLE UNIT '3
This criterion assesses the ease or difficulty of implementing the alternative in terms of technical
and administrative feasibility and the availability of services and materials.
None of the alternatives for both groundwater and surface water/sediment pose significant
concerns regarding implementation. The design of the treatment systems for Alternatives
GWP4A/GWL4A and GWP4B/GWL4B cannot be completed until the discharge requirements are
defined by the Salisbury POTW. This will occur during the RD.
9.2.5 COST
This criterion assesses the cost of an alternative in terms of total present wo.rth cost (PW). Total
PW was calculated by combining the capital cost plus the PW of the annual O&M costs. Capital
cost includes engineering and design, mobilization, Site development, equipment, construction,
demobilization, utilities, and sampling/analyses. 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 PW of a.n 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 t.o pay for initial construction costs and future expenditures, including O&M and future
replacement of capital equipment.
More detailed information on the development of the total present worth costs for each alternative
can be found in Section 8.
Alternative GWP1/GWL 1 No Action $ 227,000
Alternative GWP2/GWL2 Long-Term Monitoring, Fence Portion of
Northeast Tributary: $1,479,000
Alternative GWP3/GWL3 Institutional Controls, Long-Term Monitoring,
Fence Portion of Northeast Tributary: $1,500,000
Alternative GWP4A/GWL4A Groundwater Extraction/Air Stripping/
Vapor-Phase Carbon Adsorption/POTW Discharge: $5,792,000
Alternative GWP4B/GWL4B Groundwater Extraction/Air Stripping/
Fume lncineralion/POTW Discharge : $5,270,000
Alternative SW/SE-1 No Action $ 151,000
Alternative SW/SE-2 Long-Term Monitoring $ 867,000
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9.3 MODIFYING CRITERIA
NAllONAL STARCH & CHEMICAi... CoMPANY SUPERFUND SITE
RECORD OF DECISION FOR OPERABLE UNIT #3
State and community acceptance are modifying-criteria that shall be considered in selecting the
remedial action .
9.3.1 STATE OF NORTH CAROLINA ACCEPTANCE
The State of North Carolina has reviewed and provided EPA with comments on the reports and
data from the RI and the FS. NCDEHNR has also reviewed the Proposed Plan and EPA's
preferred alternative and cccondltlonally concurs with the selected remedy as described in
Section 10.
9.3.2 COMMUNITY ACCEPTANCE
The Proposed Plan Fact Sheet was distributed to interested residents, to local newspapers and
radio and TV stations, and to local, State, and Federal officials on July 15, 1993. The Proposed
Plan public meeting was held in the evening of August 3, 1992. The public comment period on
the Proposed Plan began July 19, 1993 and closed on September 16, 1992.
Written comments were received from the City of Salisbury and the PPRp during the public
comment period. The questions asked during the June 11, 1992 public meeting and the Agency's
response to the written comments are summarized in the Responsiveness Summary, Appendix
A. SSSince no input was received from the community at large, it is infeasible to assess the
ccommunity's aacceptance of the proposed remedy.
10.0 DESCRIPTION OF THE SELECTED REMEDY
As stated previously, the soil remediation alternative will be addressed in OU #4. Alternative
GWP3/GWL3 and GWP4B/GWL4B was selected for groundwater and SW/SE-2 for the surface
water/sediment in the Northeast Tributary. Briefly, the selected remedy for this Site is:
Implement institutional controls to prevent the installation of potable wells that would be
adversely impacted by contaminants migrating from the Site. ·
Long-term monitoring of the groundwater.
• Design and implementation of a groundwater remediation system. The selected groundwater
remediation alternative consists of a ·groundwater extraction system consisting of extraction
wells, an air stripping process to remove the VOCs, control of emissions from the air stripper
to the atmosphere through vapor-phase carbon adsorption filters, and combining the effluent
with the treated groundwater from OU #1 and the facility's operation effluent to be discharged
to the City of Salisbury POTW system.
• Delineate the vertical extent of groundwater contamination in the bedrock.
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NATIONAL STARCH & CHEMICAL CoMPANY SUPERRIND SITE
RECORD OF DECISION FOR OPERABLE UNIT #3
• More accurately evaluate the direction and speed of the flow of groundwater in the bedrock.
• Conduct a review of the existing groundwater monitoring system to insure proper monitoring of both groundwater quality and groundwater flow so that the effectiveness of the groundwater extraction system can be evaluated. Additional monitoring wells and/or piezometers will be added to mitigate any deficiencies ..
• Alternative GWP3/GWL3 also includes fencing a portion of the Northeast Tributary. However, since the groundwater extraction system will reduce and then eliminate contamination migrating into the Northeast Tributary, it will not be necessary to install this fence. This condition will be evaluated in the 5 year CERCLA review.
This remedy will reduce the levels of contamination in the groundwater to below their Federal MCLs and State groundwater quality standards.
10.1 PERFORMANCE STANDARDS TO BE ATTAINED
Table 19 lists the action-specific, chemical-specific, and location-specific Site specific ARARs.
Performance standards include any applicable or relevant and appropriate standards/requirements, cleanup levels, or remediation levels to be achieved by the remedial action. The surface water and groundwater performance standards to be meUattained by the NSCC OU #3 RA are listed in Table 21.
Table 21 provides the remediation goals to be achieved at this Site. This table also lists the risk level associated with each remediation goal. These risks are based on the reasonable maximum exposure (AME) levels and summarizes the information provided in Tables 11, 12, 13, 14, and 15. .
10.2 GROUNDWATER REMEDIATION
The groundwater remediation alternatives selected for the OU #3 at the NSCC Site are GWP3/GWL3 and GWP4B/GWL4B -Institutional Controls, Long-term Monitoring, Groundwater Extraction and Physical Treatment (Air Stripping) with Control of Air Emissions Via Vapor-Phase Carbon Adsorption Filters, and Discharge to POTW. A description of the selected remedial alternative follows.
The contaminated aquifer will be remediated by removal of contaminated groundwater through extraction wells until the performance standards specified in Table 21 are achieved. Figures 3, 4, and 7 delineates the estimated periphery of the plumes emanating from OU #3. The extracted groundwater from Area 2 and the lagoon area will be combined for treatment. Following treatment of the extracted groundwater, the groundwater will be discharged into the sewer system along with the rest of the NSCC influent to the City of Salisbury POTW.
It is anticipated that four (4) extracting wells, two (2) installed in the saprolite and 2 into the bedrock, downgradient of Area 2 and six (6) extraction wells, three (3) installed in the saprolite and 3 into the bedrock, downgradient of the lagoon area will be required. The Area 2 bedrock
I NATlONAL STARCH & CHEMICAL COMPANY SUPERFUND SITE
RECORD OF DEaSION FOR OPERABLE UNIT #3
• _: __________________ -_1_09_-_________________ _
I TABLE 21 PERFORMANCE STANDARDS AND CORRESPONDING RISKS FOR OU #3
PERFORMANCE STANDARDS (CLEANUP GOALS)
I CHEMICAL OF
CONCERN
I GROUNDWATER
I Acetone-
I Bis(2-Chloroethyl)ether
Bromodichloromethane
Chloroform
I 1,2-Dichloroethane
1, 1-Dichloroethene
I cis 1,2-Dichloroethene
trans 1,2-Dichloroethene
I 1,2-Dichloropropane
Ethylbenzene
I Methylene Chloride
Tetrachloroethene
I Toluene
Total Xylenes
I 1, 1,2-Trichloroethane
T richloroethene
I , 1.2-Dichloroethane
I
PERFORMANCE
STANDARD
GIL.
3,500
5
100
7
70
100
29
5
1,000
400
5
2.8
POINT OF
COMPLIANCE
The Entire
Plume of
Contaminated
Groundwater
BASIS OF
STANDARD
DU#1
OU#1
MCL1•
CRQUStateM
CRQUState~1
MCUState
MCUState
State
CRQUState~1
State
State
CRQUState~1
MCUState
Sate
MCL
· State
CRQUState~1
CORRESPONDING RISK LEVELS
CHEMICAL-SPECIFIC RME RISK
CANCER NON-CANCER
NA NA
NA NA
?? .
NA
10• NA
10• NA
NA
10•
NA
10• 10·'
NA
NA
I µgll ··. Micrograms per Liter MCL ·· Maximum Concentration Limit as Specified in the Safe Drinking Water Act
OU #1 ·· Pertormance Standard Developed in September 30, 1988 Operable Unit #1 Record Of Decision
'" •· Based on· MCL for Trihalomethanes CRQL •· Contract Required Quantitation Limit
I State~1 •· Where the Maximum Allowable Concentration Of A Substance Is Less Than The Limit Of Detectability (15 A NCAC 2L.0202(b)(1)
State •· State Groundwater Quality Standards (NCAC 15-2L.0202)
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NATIONAL STARCH & CHEMICAi. CcMPAHY SUPERFUND SITE
RECORD OF DECOSON FOR OPERABLE UNIT #3
and saprolite extraction wells would have an estimated combined flow of 15 gallons per minute
(gpm) and 10 gpm, respectively. The lagoon area bedrock and saprolite extraction wells will have
an estimated combined flow of 6 gpm and 30 !)pm, respectively. At these pumping rates, it is
anticipated that these wells will achieve and maintain a sufficient drawdown in the underlying
aquifer to contain and remove the plumes of contamination. The extraction wells will be located
within and near the sources of contamination. The extracted groundwater will be treated in an
above-ground, on-site air stripper. The actual number, placement, pumping rate of each
extraction well, the size of the air stripping unit, and the size of the vapor-phase activated carbon
adsorption units need will be determined in the RD. The air stripper will be designed to achieve
the pretreatment requirements which will be determined by the City of Salisbury POTW. The only
. anticipated by-product to be generated by the groundwater treatment process described above
is spent activated carbon. The activated carbon may be regenerated, destroyed, or disposed of
in an appropriately regulated landfill. The most cost effective option for dealing with the spent
activated carbon will be implemented.
Groundwater contamination may be especially persistent in the immediate vicinity of the
· contaminants' source where concentrations are relatively high. The ability to achieve cleanup
goals at all points throughout the area of attainment, or plume, cannot be determined until the
extraction system has been implemented, modified as necessary, and plume response monitored
over time. If the selected remedy cannot meet the specified performance standards, at all of the
monitoring points during implementation, the contingency measures and goals described in this
section may replace the selected remedy and goals for these portions of the plume.
The goal of this remedial action is to restore the groundwater to its beneficial use, as defined in
Section 7 .4. Based on information obtained during the RI, and the analysis of all of the remedial
alternatives, EPA and the State of North Carolina believe that the selected remedy may be able
to achieve this goal. ·
Such contingency measures will, at a minimum, prevent further migration of the plume and
include a combination of containment technologies and institutional controls. These measures
are considered to be protective of human health and the environment, and are technically
practicable under the corresponding circumstances.
The selected remedy will include groundwater extraction for an estimated period of 30 years,
during which time the system's performance will be carefully monitored on a regular basis and
adjusted as warranted by the performance data collected during operation. Modifications may
include any or all of the followings:
a) at individual wells where cleanup goals have been attained, pumping may be
discontinued;
b) alternating pumping at wells to eliminate stagnation points
c) pulse pumping to allow aquifer equilibration and encourage adsorbed contaminants to
partition into groundwater;
d) installation of additional extraction wells to facilitate or accelerate cleanup of the
contaminant plume.
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NATIONAL. STARCH & CHEMICAL COMPANY SUPERRJND SnE
RECORD OF DECISION FOR OPERABLE UNIT 13
To ensure that cleanup continues to be maintained, the aquifer will be monitored at those wells
where pumping has ceased on an occurrence of every 2 years following discontinuation of
groundwater extraction.
If it is determined, on the basis of the preceding criteria and the system performance data, that
certain portions of the aquifer cannot be restored to their beneficial use, all of the following
measures involving long-term management may occur, for an indefinite period of lime, as a
modification of the existing system:
a) engineering controls such as physical barriers, or long-term gradient control provided by
low level pumping, as contaminant measure;
b) chemical;specific ARARs may be waived for the cleanup of those portions of the aquifer
based on the technical impracticability of achieving further contaminant reduction;
c) institutional controls may be provided/maintai11ed to restrict access to those portions of the
aquifer which remain above remediation goals;
d) continued monitoring of specified wells; and/or
e) periodic reevaluation of remedial technologies for groundwater restoration.
The decisio'n to invoke any or all of these measures may be made during a periodic review of the
remedial action, which will occur at 5 year intervals in accordance with CERCLA Section 121(c).
The RA shall comply with all ARARs listed in Table 19. The presence of contamination in the
groundwater will require deed restrictions to document their presence and could limit future use
of the area known to be affected by the contaminated groundwater.
10.3 NORTHEAST TRIBUTARY SURFACE WATER/SEDIMENT REMEDIATION
It is anticipated that the groundwater remediation alternative described above will initially reduce
and then eliminate contamination in the Northeast Tributary as the source of this contamination
is the contaminated groundwater discharging into the stream. Alternative SW/SE-2 requires long-
term monitoring o(the water column and sediment to insure that the groundwater remediation is
reducing the levels of contamination in the Northeast Tributary.
Initially, each annual sampling effort will collect a minimum of four (4) surface water and 4
sediment samples collected at the same location. These samples shall be analyzed for TCL
VOCs. After the groundwater extraction system becomes operational and the levels of
contamination in the Northeast Tributary obtain the performance standards specified in Table 21
for two consecutive sampling events, the number of sampling points and the sampling frequency
may be reduced.
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NATIONAi. STARCH & CHEMICAL COuPANY SUPERAJND SITE
RECORD Of DECISION FOR 0PEAABlf UNIT #3
10.4 MONITOR EXISTING CONDITIONS/ADDITIONAL DATA REQUIREMENTS
In addition to the work described above, this ROD and the RD will also have to address a number
of data gaps.
Since the RI was not able to completely delineate the extent of the groundwater contamination
in the bedrock zone of the aquifer, additional monitoring wells will need to be installed during the
RD. It is anticipated that at least two (2) bedrock monitoring wells are needed to better portray
the vertical extent of contamination as well as delineate the depth to which b'edrock is fractured.
To determine to what depth the bedrock is fractured, bedrock cores will need to be collected. The
analytical data generated from the samples collected from these bedrock wells should provide
sufficient information to determine if contaminants have migrated to this depth. The placement
of these and any other additional monitoring wells will be made after a review and evaluation of
the existing groundwater monitoring system. This review is to insure that the groundwater
monitoring system will provide adequate information to assess the long-term quality of the
groundwater and to demonstrate the effectiveness of the groundwater extraction system. This
review effort may also require the need for additional groundwater modeling and aquifer testing.
If a contaminant is found above its groundwater remediation standard specified in Table 21 in the
deeper regions of the bedrock, then the groundwater extraction system shall be extended to
include this lower region of the bedrock zone of the aquifer and all the requirements specified in
Sections 10.0, 10.1 and 10.2 of this ROD will apply.
In order to ·help establish a broader data base on groundwater quality additional groundwater
samples will be collected and analyzed. Below are listed the wells to be sampled, how frequently
these wells are to be sampled, and the chemical analyses to be performed on each sample
groundwater collected. This sampling effort will continue until the groundwater remediation
system is functional and the monitoring procedures specified in the Operation and Maintenance
Manual are implemented.
Analytical
Monitoring Well Sampling Samples Are To Procedure
To Be Sampled Frequency Be Analyzed For To Be Used
S1mroli!e Wells ·
NS-13 Annually voes, TAL metals EPA Methods 8240 + 6010
NS-14 Annually voes EPA Method 8240
NS-33 Annually voes EPA Method 8240
NS-35 Biannually voes, TAL metals EPA Methods 8240 + 6010
NS-37 Annually voes EPA Method 8240
NS-39 Annually voes EPA Method 8240
NS-42 Biannually voes, TAL metals EPA Methods 8240 + 6010
NS-43 Annually voes. EPA Method 8240
Bedrock Wells
NS-34 Annually voes EPA Method 8240
NS-36 Biannually voes, TAL metals EPA Methods 8240 + 6010
NS-38 Annually voes EPA Method 8240
NS-40 Biannually voes, T AL metals EPA Methods 8240 + 6010
NS-41 Annually· voes EPA Method 8240
NS-44 Annually voes EPA Method 8240
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NAT10NAI. STAACH & CHEMICAi. CollPANV SUPERF\JND SITE
RECORD OF DECISON FOIi OPERABIE UNIT #3
-113-
10.5 COST
The total present worth costs for the selected alternatives is
Alternative GWP3/GWL3:
Alternative GWP4A/GWL4A:
Alternative SW/SE-2:
TOTAL PRESENT WORTH COST
The break down of this cost is specified below.
$ 1,500,000
$5,792,000
$ 867,000
$ 8,159,000
The present worth cost components of the institutional controls, long-term monitoring,
groundwater extraction, air stripping, emissions control of off-gas via vapor-phase activated
carbon filtration, and discharging to the local POTW are:
TOTAL CONSTRUCTION COSTS
TOTAL PW O&M COSTS (at annual PW O&M Costs of $878,000)
TOTAL PRESENT WORTH COST
11.0 STATUTORY DETERMINATION
$1,635,000
$6,524,000
$8,159,000
Based on available information, the selected remedy satisfies the requirements of·Section 121
of CERCLA, as amended by SARA, and the NCP. The remedy provides protection of human
health and the environment, is cost-effective, utilizes permanent solutions to the maximum extent
practicable, and satisfies the statutory preference for remedies involving treatment technologies.
11.1 PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
The selected remedy will permanently treat the groundwater. Dermal, ingestion, and inhalation
contact with Site contaminants will be eliminated and risks posed· by continued groundwater
contamination will be abated.
11.2 COMPLIANCE WITH ARARS
The selected remedy will be designed to meet all Federal or more stringent State environmental
laws. A complete list of the ARARs which are to be attained is included in Table 19. No waivers
of Federal or State requirements are anticipated for OU #3.
11.3 COST-EFFECTIVENESS
The selected groundwater remediation technologies are more cost-effective than the other
acceptable alternatives considered. The selected remedy will provide greater benefit for the cost
because it permanently removes the contaminants from the impacted aquifer.
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-114-
NATIONAi. STAR<>< & CHEMICAL COMPANY SUPERFUND SITE
FIEOORO OF OEaSION FOR Of>ERABLE UNIT '3
11.4 UTILIZATION OF PERMANENT SOLUTIONS AND ALTERNATIVE TREATMENT
TECHNOLOGIES OR RESOURCE TECHNOLOGIES TO THE MAXIMUM EXTENT
PRACTICABLE
The selected remedy represents the maximum extent to which permanent solutions and treatment
can be practicably utilized for this action. Of the alternatives that are protective of human health
and the environment and comply with ARARs, EPA and the State have determined that the ·
selected remedy provides the best balance of trade-offs in terms of: long-term effectiveness and
permanence; reduction in mobility, toxicity, or volume achieved through treatment; short-term
effectiveness, implementability, and cost; State and community acceptance; and the statutory
preference for treatment as a principal element.
11.5 PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT
The preference for the treatment of contaminated groundwater is satisfied by the use of the
groundwater extraction system, the air stripper to remove volatile contaminants from the
groundwater, and control of the air stripper off-gas via vapor-phase activated carbon adsorption
at the Site. Further treatment of the discharged groundwater will be achieved at the POTW. The
principal threats at the Site will be eliminated by use of these treatment technologies.
12.0 SIGNIFICANT CHANGES
CERCLA Section 11 ?(b) requires an explanation of any significant changes from the preferred
alternative originally presented in the Proposed Plan (Appendix 8). Below are the specific
changes made in the ROD as well as the supporting rationale for making those changes. The
Proposed Plan was disseminated to the public on June 8, 1992.
Alternative GWP3/GWL3 included installing a fence around a portion of the Northeast Tributary
as it assumed that no remediation of the groundwater would occur. However, the selected
remedy does call for the implementation of an active groundwater extraction system. The
groundwater extraction system will reduce and then eliminate the contaminants entering into the
surface water and sediment of the Northeast Tributary, thereby.eliminating the need for this fence.
This is the reason why the installation of the fence around a portion of the Northeast Tributary has
been excluded from the selected remedy as described in Section 10.
The Proposed Plan reported the total present worth costs for Alternatives GWP4A, GWL4A,
GWP4B, and GWL4B to be $2,222,000, $3,570,000, $2,274,000, and $2,996,000, respectively.
These costs, obtained from the June 21, 1993 OU #3 FS report, were based on obtaining the
cleanup goals at the point of compliance specified in said document. The FS proposed obtaining
a groundwater cleanup goal of 5.0 ug/1 for 1,2-DCA at the periphrey of the plume. However, the
use of 5.0 ug/1 as a cleanup goal for 1,2-DCA and the selection of the periperphy of the plume
at point of compliance are in error. The most stringent promulgated cleanup level for 1,2-DCA
can be found in the State's groundwater quality standards and is described in Section 10.1 as 1.0
ug/1. The point of compliance, as described in Section 8.1, is throughout the entire plume. By
changing these two conditions, the estiamted remediation timeframe is lengthened which results
in a different O&M cost for Alternatives GWP4A, GWL4A, GWP48, and GWL4B. The total
present worth costs for Alternative GWP4A/GWL4A becomes approximatley $107,000 less than
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. -115-
NATlOff.AI. STAR<>< & CHEMICAi. CoMPANY SUPERFUND SITE
RECORD Df Oea~OH FOR 0PERABlE UNIT 13
the total present worth costs for Alternative GWP4B/GWL48. Since both alternatives acheive the same degree of protection and treatment, Alternative GWP4NGWL4A is selected because it is more cost effective. Also, refer to Comment #9 in the Responsiveness· Summary (Appendix C).
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APPENDIX A
CONCURRENCE LETTER FROM THE STATE OF NORTH CAROLINA
AND RESPONSE FROM THE AGENCY
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I APPENDIX B
I PROPOSED PLAN FACT SHEET
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SUPERFUND PROPOSED PLAN FACT SHEET
GROUNDWATER REMEDIATION FOR OPERABLE UNIT #3 FOR THE
NATIONAL STARCH & CHEMICAL COMPANY SUPERFUND SITE
Salisbury, Rowan County, North Carolina
July 1993
·,
INTRODUCTION
This Proposed Plan identifies the preferred options for addressing the contaminated groundwater and surface water/sediment
associated with Operable Unit #3 at the National Starch & Chemical Company Superfund Sita in Salisbury, North Carolina. The
term "Operable Unir is used when individual actions are taken as a part of an overall site cleanup. A number of operable units
can be used in the course of a site cleanup. (Terms in bold lace print are defined in a glossary located at the end of this
publication.) This document has been prepared and is being issued by the U.S. Environmental Protection Agency (EPA), the lead
Agency for Sita activities, and the North Carolina Department of Environmen~ Health and.Natural ReSOUfCllS (NCDEHNR), the
support agency. EPA, in consultation with NCOEHNR, d~ected and oversaw the Remedial lnvestlgatton and Feaslblllty SbJdy,
and will select a remedy for Operable Unit #3 only after the public comment period has endled 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 responsibiities in accordance with Section 117(a) of the
Comprehensive Environmental Response, Compensation, and Llablllty Act (C_ERCLA), also knoWll as Superfund.
This document summarizes information that is explained in greater detail in the Remedial Investigation Repo~ the Feasibility Study
Report, and other documents contained in the lnforrnaUon ReposltorylAdmlnlstraUve Record for this Sita. EPA and the State
encourage the public lo review these documents to better undlerstand the Site and the Superfund activities that have been
conducted. The .Administrative Record is available for public review locally at the Rowan Public Library at 201 West Fisher Street,
Salisbury, North Carolina.
EPA, in consultation with NCDEHNR, may modify the preferred alternative or select another response action presented in this Plan
and the Remedial Investigation and the Feasibility Study Reports based on new information and/or public comments. Therefore,
the public is encouraged to review and comment on all alternatives identified here.
A fourth Operable Unit will be developed to address the contaminated soils and source of contamination at the Site in the near
future.
nus PROPOSED PLAN
1. Includes a brief background of the Site and the principal
findings of Operable Unit #3 Site Remedial
Investigation; ·
2. Presents the remedial (cleanup) alternatives for the Sita
considered by EPA;.
3. Outlines the criteria used by EPA to recommend a
remedial alternative for use at the Sita;
4. Provides a summary of the analysis of the remedial
. alternatives;
5. Presents EPA's rationale for Its preliminary selection of
the preferred remedial alternatives; and
6. Explains the opportunities for the public to comment on
the remedial alternatives.
PUBLIC MEETING:
DATE: August 3, 1993
LOCATION: Agricultural Extension Center
2727 Old Concord Road
Salisbury, North carolina
TIME: 7:00 PM • 9:00 PM
PUBLIC COMMENT PERIOD:
July 19, 1993 • August 17, 1993
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0,,.VIDSON
COUllTY
--c;.;;;;RCs'coullTY
,. ,' ,--.. , -----------------------.-_-_-
' ' ' , _______ -. __ _
0 500 1000
250 750
GRAPHIC SCALE, 1 ''500'
?
N
figure 1
\
COUllTY 7-
/
/ffJ
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SITE BACKGROUND
The National Starch & Chemical Company (NSCC) facility
occupies 465 acres on Cedar Springs Road on the outskirts
of Salisb\xy, Nor1h Caronna (refer to Figure 1). PresenUy,
land use immediately adjacent to the Site.is a mixture of
residential and indusbial developments. East and south of
the Sije are industrial parks consisting primarily of Ught
industrial operations. The west and nor1h sides of the NSCC
property are bordered by residential developments. Refer to
the Figure 2 for Site .location.
A surtace stream, referred to as the Northeast Tributary,
crosses the NSCC property parallel to Cedar Spring Road
and passes within 50 yards of the manufacturing area of the
facility (refer to Figure 2). Surtace water runoff from the
eastern side of the.faciUty discharges into this tributary. The
focus of the Operable Unit #3 Remedial Investigation was to
determine the source, nature, and extent of the
contamination entering this stream.
Primarily, NSCC manufactures textile-finishing chemicals
and custom specialty chemicals. Volatile and semi-volatile
organic chemtcals are used in the production process
along with acidic and alkaline solutions. Acidic and alkaline
solutions are also used in the deaning processes. The
waste stream from the manufacturing process includes wash
and rinse solutions.
Operable Unit #3 focused on the areas of the facility referred
to as "1ea 2 and the wastewater traatrnent lagoons (refer to
Figure 3). Nea 2 consists of the following operations: "1ea
2 Reactor Room, the Tank Room, Raw Material Bulk
Storage, and the Warehouse. The lagoon area includes
three lagoons. A fourth lagoon was flStalled in 1992 for
pretreatment of contaminated groundwaler as part of the
Operable Unit #1 Remedial Action (RA).
As the result of finding contaminants in groundwater and in
the surface water/sediment of the Northeast Tributary, the
original scope of work · specified in the initial Remedial
lnvestigation'FeasibiUty Study Work Plan has been
expanded twice. Tu:. :il'st Remedial Investigation and
Feasibility Study resulled in the first Record of Decision
(ROD) to be issued by the ~yon September 30, 1988
for the NSCC Supellund site. The findings of Operable Unit
#2 Remedial lnvestigatiorvFeasibility Study led to the second
Record of Decision, rendered by the Agency on September
30, 1990. As in Operable Unit #1 and Operable Unit #2, the
wori( pertormed for Operable Unit #3 is being pertormed by
National Starch & Chemical Corporation, the Potentially
Responsibie Party (PAP). The engineering contractor hired
by the PRP to conduct Operabie Unit #3 wori( is IT
Corporation.
The NSCC site was proposed for inclusion on the
National Priorities List in April 1985 and finalized
on the, list in October 1989. The Site had a
Hazardous Ranking System score of 46.5 t. Only
·sites with a Hazardous Ranking System score of
28.5 or higher are eligible to be piaced on the
National Priorities List.
SCOPE AND ROLE OF OPERABLE UNIT
WTTHIN SITE STRATEGY
As 'Mth many Superfund sites, the NSCC site is
complex. ConsequenUy, EPA divided the work into
three manageable components called Operable
Units (OU). These operabie units are:
OU-1 • Groundwater in western portion of the
NSCC property
OU-2 • Trench Area soils and surtace
water/sediments in the Northeast
Tributary
OU-3 • Groundwater/surface water/sediments in
the areas of "1ea 2, the lagoons, and the
Northeast Tributary
SITI DP, f'Ol
0PU.ULI tJIJIT t 3
Ol'DAIILI llllr!' tl
IIU'lQal. 8UJCII •
CIEIIIICAL caaUT
stlPDPUIID SITI
3
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RESULTS OF lHE REMEDIAL INVESTIGATION .
FOR OU-3 .
Three environmental media (soils, groundwater, and SlKface
water/sediment) have . been adversely impacted by
contamination origilaling from Iha NSCC plant and from
past chemical handing and disposal practices of Iha facility.
The primary contaminant at Iha Sile is 1,2-dlclion,ethane
(t,2-DCA). This contaminant is known as a chlorinated
organic compound that volatilizes readily and is classified as
a probable human carcinogen. A carcinogen is any
substance that can cause 01 contribute to Iha development
of cancer. Other Olganic chemicals were also delected.
The chemicals of concsm at the Site are (isled
alphabetically): acetone, bis (2-<:hforoelhyt) elhel, bis (2-
elhyfhexyf) phlhalate, 2-butanone, cadmium, carbon
disulfide, chloroform, chloroelhane, delta-BHC, 1,2·
dichloroelhene, <i-il-butyf phlhalale, ci-n«lyf phlhalate,
ethyl benzene, methylene chloride, styrene,
tetrachloroethene, toluene, 1, 1,2-trichloroethane,
lrichloroelhene, Yilyf chloride and total xylene. The folowing
inorganics were also detected: wnilun, antimony, arsenic,
barun, beryllium, chromium, cobalt, copper, cyaride, lead,
manganese, mercu.')', nickel, selenium, lhaaium, vanadium,
and zinc.
The OU-3 soil investigation has generated ample information
to charactarize Iha contamination, determine Iha source, and
define Iha extent of contamination in Iha Yldos8 soil zone.
The vadose zone is comprised of subslmce soil that is not
saturated with water. The interlace belWeen Iha vadose
zone and Iha saturated zone is commonly referred ID as Iha
water table. FOl.fleen different vofatie Olganic compolllds,
one sem~votatile organic comp()llld, and one pesticide were
detected in Iha vadose soils. The prinary source of
contamination in Area 2 were tuied, leamg terra-cotta
piping used ID ransport waste straams from Iha production
area ID Iha treatment lagoons. The SOIIC8 of Iha
contaminants detected in Iha lagoon area is Iha soi under
and around Iha lagoons YnCh were contaminated prior to
Iha lagoons being ined with concrete.
OU-3 defined Iha nam of groundwater contamination (Iha
contaminants present and lhei' concenrations) but additional
WOik is needed to completely define Iha extent of
groundwater contamination, especialy in the bedrock zone
of Iha aqiitar. The aquter is Slildi-.ided ini> two
interconnected zones, the shallow zone and the bedrock
zone. Both of lhese zones have been adversely impacted
by activities at Iha NSCC plant. Sixteen different volatile
organic compound& and foll' semi-volatile · organic
compounds were detected in Iha groundwater. Groundwater
in Iha shallow zone in Iha vicinity of Iha lagoons is flowing at
an approximate speed of 80 feet per year. This rate slows
to approximately 27 feet per year just east of Iha lagoon
area.
The highest concentrations of contamination detected in the
Northeast Tributary were. found just east of the plant. The
levels of lhese volatie 01ganics decrease downstream as
lhese contaminants vofaliiz.e into lhe atmosphere. Two
samples, one Sll'face water and one sediment, were
collected from the Northeast Tributary just prior to the
stream leavilg the NSCC property and flowing under Airport
Road. No contaminants were detected in these samples
which indicates that Iha iksihood of contamination leaving
the Site via suface water/sediment is minimal. The
apparent SOll'ce of Iha organics in this stream is Iha
discharge of contaminated groundwater into Iha stream.
lnorganics were delected in al tlV8e of the envirorvnentaJ
media sampled (soils, groundwater, and surface water and
sediment). All of the metals detected are nab.laity occurmg
and the variation in concentrations detected does not
indicate Iha Site is releasing inorganic contaminants into Iha
environment.
:::-( (~--T-,..___• -+--'0 ~-> ~
Se.pr-o I It. I
(CI Dy) as·...--:,
~th-.•t
T..-fbuteri,,
Fractured
..,_e.t.~r"'•d
Bedrock
S.dr-oclc
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SUIIIIARY OF Sile RISKS
A task of the Remedial lnvestigatiorvfeasibility Study is ID
analyze and estimate the human health and environmental
problems that could result tt the soil, groundwater, and
surface water/sediment contamination is not cleaned up.
This analysis is call a Baseline Risk Assessment. In
calculating risks ID a population tt no remedial action is
taken, EPA evaluates the reasonable maximum exposure
levels tor current and future exposure scenarios to Sile
contaminants. Scenarios were developed for residents living
on or near to the Site as weU as tor employees working on
the Site. In conducting this assessment EPA focuses on
the adverse human health effects that could result from
long-term daily, direct exposure as a result of ingestion,
inhalation, or dermal contact ID carcinogenic chemicals
(cancer causing) as weU as the adverse health effects that
could resuli from long-tenn exposure to non-carcinogenic
chemicals present at the Site. EPA considers a long-term
resident begiming as a young child being exposed daily for
30 years to be a reasonable maximum exposure scenario for
future exposure ID the NSCC site.
A goal of the Aoerv:.y is to reduce the risk posed by a
Supertund Site to fewer than one person out of 10,000 being
at risk of developing cancer. This is the minimum risk the
Agerv:.y will allow, typically the Agerv:.y aspires ID be even
more protective and strives to lower the risk so that at a
minimum, only · one person out of one million may be
adversely impacted by the contamination found at a
Supertund Site.
EPA has concluded that there are no major current risks ID
human health at the Site. Exposure pathways evaluated in
the Risk Assessment were ingestion, inhalation, and direct
contact to contaminants in the soil, groundwater, and surface
watar/sediment. The only reason groundwater does not
pose a current risk is because the contamination in the
groundwater has not migrated beyond the property boundary
and consequendy, has not impact any private, potable weU.
There are no potable weUs located on Site ..
However, there are dYee unacceptable Mure carcinogenic
risks associated.with the contamination at the Site. The first
scenario resulting in an unacceptable Mure risk is having
residents Uving in homes built on or near the Site and using
the groundwater as potable water. Another unacceptable
future risk is the exposure of a child ID SU/face water,
· sediment, and spring water. The third unacceptable Mure
risk involves exposing individuals to contaminated
subsurface soil. The Mure residential use of the
groundwater would also ·result in an unacceptable future risk
due ID the preserv:.e of noncarcinogenic chemicals in the
groundwater.
A semi-quantitative assessment of the Northeast Tributary
was also conducted as part of the Risk.Assessment This
envirorvnentaf assessment included chemical, ecological,
and toxicological investigations of the surface water and
sediment coUected from the Northeast Tributary. The data
generated by the envirorvnentaf assessment found adverse
ecological impacts in areas of the stream where elevated
levels of 1,2-OCA were detected. However, the assessment
could not conclude that the contaminants originating from
the Site, primarily 1.2-DCA. are the sole cause of this
impact. There is a strong indication that the nalUrafly~imlting
factors of the stream itself results in the diminished numbers
of benthic (bottom-dwelUng) organisms in this section of the
Northeast Tributary.
REIIEDIAL ACTION OBJECTIVES
Remedial action_ objectives (RAOs) were developed based
on the results of the Risk Assessment. an examination of
potential Applicable or Relevant and Appropriate
Requirements (ARARs), and IIYeats to groundwater and
the · Northeast · Tributary. Action-, location-, and
chemical-specific ARARs were examined. Chemical-specific
ARARs for groundwater include maximum concentration
levels (MCLs) as specified in the Safe Drinking Water Act
and Nor1h CaroUna Groundwater Standards. In summary,
the Remedial Action Objectives are:
FOR GROUNDWATER
For Human Health: Prevent ingestion of water
having corv:.entrations of 1,2-DCA resulting in
cancer risks above acceptable limits.
For Enviromientaf Protection: None, groundwater
corv:.entrations have not been found to represent
an env~orvnental hazard.
FOR SURFACE WATER
For Human Health: None, SU/face water is not a
drinking water source.
For Envirorvnentaf Protection: No,.,, surface
water concentrations have not been identified as
the sole cause for the fimitlld benthic populations.
FOR SEDIMENT
For Human Health: Prevent direct contact with
sediments having levels of 1,2-DCA resulting in
cancer risks above acceptable limits.
For Envirorvnentaf Prolection: None.
The objective of a remediation is ID obtain stringent health
risk levels. For groundwater, al chemical-specific ARARs,
which include MCLs and the North Carolina Groundwater
Standards, will be achieved where the -specified
corv:.entration is tecmicaDy detectable. The estimated
volume of contaminated groundwater requiring remediation
is 131 million gallons.
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For more infonnation about the Remedial Action Objectives
and alternatives for the NSCC OU-3 site, please refer to the
June 21, 1993, FeasibiUty Study document and other
documents available for review at the Administrative Record
located at the Rowan P~ic Library. .
SUIIIIARY OF REIIEDIAL Al..lERNATlVES
The following section provides a summary of the alternatives
developed in the Feasibility Study (FS) Report. The primary
objective of the Feasibility Study was to detennine and
evaluate alternatives for cleaning up the Site. Descriptions
of the clean-up alternatives are summarized below. The
Report contains a more detailed evaluatiorvdescription of
each atternative.
The cost information provided below for each atternative
represents estimated total present W0l1l (PW) of each
alternative. Total present W0l1l . was caJculated by
combining the capital _cost plus the present worth of the
amual operating and maintenance (O&M) costs. Capital
cost includes consuuction, engineering and design,
equipment. and site development Operating costs W8l8
calculated for activities that continue after completion of
construction, such as routine operation and maintenance of
treatment equipment. and groundwater moniloling. The
present worth 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 amOl.Wll necessary to pay for
initial construction costs and future expenditures, including
operation and maintenance and~ Jture replacement of capital
equipment.
REMEDIAL ALTERNATIVES TO ADDRESS
GROUNDWATER CONTAMINATION
The groundwater remedial alternatives for addressing
contaminated groundwater -e considered separalely for
Area 2 and the lagoon area. Area 2 allematives are
identified by "P" tor the Plant and the alternatives dealing
wilh the contaminated groundwater associated with the
lagoon area are identified by "l •.
Al TERNATIVES GWP1 AND GWL 1: No AcTloN
Capital Costs:
Amual O&M Costs:
Total PW Costs for 30 Years:
nme to Design:
ConshJctionTlll18:
Duration tD Achieve Clean-up:
$ 0
$ 22,000
$ 227,000
None
None
Over 30 years
CERCLA reqlires that the "No Action" a1tema1ive be
evaluated at every Superfllld Site to estabish a baseline for
comparison. No fll1her activities wo~ be conducted wilh
regard tD the groundwater beneath the Sile lllder ttis
alternative ~.e., lhe Site is left ·as isl. Because lhese
alternatives do not entail contaminant removal or destruclion,
a review of the remedy would be corwcted every ive years
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in accordance wilh CERCLA Section 121(c). Operatilg
costs are based on conducting lhis review every live years
which includes monitoring the grollldwater ll1der the Site
once every five yea,s for a period of 30 years.
ALTERNATIVES GWP2 AND GWL2: LONG TERM
lloNJTORJHG, FENclNG A PoRnoN OF NolnHEMr TllllvrARr
Capital Costs:
Amua1 O&M Costs:
Total PW Costs for 30 Years:
nme to Design:
Consruction nme:
Duration to Achieve Clean-up:
$ 178,000
$ 138.000
$1,479,000
None
None
Over 30 years
These alternatives are similar to Alternatives GWP1 and
GWL 1, except under Alternatives GWP2/GWL2 additional
moniloling wells would be instaled, grw,dwa!ar moritoring
data WOIJd be colected arnialy insblad of once every live
years, and a portion of lhe Northeast Tributary would be
ranced. ·
Al TERNATIVES GWP3 AND GWL3: INS17IVTIONAL
Co#moLS, FEIIC#G A l'ORTIOII OF NoimEAsT TlliBUTARr
Capital Costs:
Amual O&M Costs:
Total PW Costs for 30 Years:
· nme to Design:
ConshJction Tune:
Duration ID Achieve Clean-up:
$ 198,000
$ 138,000
$1,500,000
None
None
Over 30 years
These alternatives tor groundwater contamination in Area 2
and the lagoon area are identical to Alternatives GWP2 and
GWL.2. except Alterative GWP3/GWL3 includes institutional
controls. No remediation activities would be conducted for
groundwater. The additional costs are associated wilh
preparing and fiing deed restriction(s) and inplementing the
other institutional controls. The specific institutional controls
to be implemented include: usilg deed restrictions m control
the installation of new wells on bolh hi plant property and
adjacent property; track plume migration; and install rancing
aro\l1d the Northeast Tributary m limit access tc
contaminated Sl.fface water and seciment. A "pune" is the
discharge of a contaminant from a given point of origin in
water or at, for example, smoke from a smokestack.
These alternatives provide no reduction in volume, mobility
or toxicity of the contaminants, however, they can reduce or
eliminate cwect expo51n pathways and the resutant risk to
the public. As part of these aftematt;es, the groundwater
would be monitored on a yearly basis. As EPA may not
have the authority to inplemenl these insti1utional conlrols,
the responsibility rests with lhe State of North Caroina m
eOSLre the institutional controls are in place, n reliable,
and will remain in place alter iritiation of O&M. Thefefore,
the responsibiity for inplementing and enforcing institutional
controls lalls on the Stale of Norll Carolina. Glolridwater
moritoring and Ive year CERCLA reviews W0lid be
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conducted tor 30 years. The O&M cost is tor both Area 2
and the lagoon area.
ALTERNATIVE GWP4A: GROIJIIJWATER EXTRACTION
THROUGH WEI.LS AND TIIEATIIENI' BY AIR Snil'PtlG WITH
V APOR-PHJ.si CARBON ADsoRPT10N
Capital Costs:;, ,. , .. ,, '· ·i ·
Annual O&M Costs:
Total PW Costs tor 30 Years:
Time to Design:
Construction Time:
Duration ID Achieve Clean-up:
$ 648,000
$ 306.000
$2,222,000
1 year
6 months
15 to 30 years
This alternative includes ex1rae1ing groundwater by means
of extraction wells downgradient of Area 2; volatile organics
. removal through ai stripping; control of' emissions ID the
atmosphere from the ar stripper ttYough vapor-phase
carbon adsorption; and combined discharge with treated
groundwater from OU-1 to the Salisbury publicly owned
treatment works (POTW). The treated effluent must meet
permit limits set by the Salisbury POTW. Spent activated
carbon would be changed out and sent ID a commercial
regeneration/recycling facility. The five year review CERCLA
requirement would apply to this alternative.
ALTERNATIVE GWLAA: GROIMDWATER EXTRACTION
WEI.LS, TREATIIENT BY AIR ST1IIPPING WITH VAPOII-PHAsE
CARBON ADsOR/ITION
Capital Costs:
Annual O&M Costs:
Total PW Costs tor 30 Years:
nme to Design:
Construction Time:
Duration ID Achieve Clean-up:
$ 789,000
$ 434.000
$3,570,000
1 year
6 months
20 years
This alternative is identical to Alternative GWP4A except this
alternative addresses contaminated groundwater associated
with the lagoon area. ·
ALTERNATIVE GWP4B: GR~ATER EXTRACTION
WEI.LS, TIIEATIIENI' BY AIR SnllPPfNG WITH FIJIIE
IICINERATION
Capital Costs:
Annual O&M Costs:
Total PW Costs tor 30 Years:
nme to Design:
Construction nme:
Duration to Achieve Clean-up:
$ 766,000
$ 299.000
$2,274,000
1 year
6 months
15 to 30 years
This alternative is identical to Altemative GWP4A, except
that the control of emissions to the atmosphere from the air
stripper would be accomplished through Ml8 incineration.
ALTERNATIVE GWLAB: GROLWDWATER EXTII.ACTION
WEI.LS, TREATIIENI' BY All SnllPl'ING WITH FIJIIE
IIIC1NEJIA T10II
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Capital Costs:
Annual O&M Costs:
Total PW Costs tor 30 Years:
nme to Design:
Construction Time:
Duration to Achieve Clean-up:
$ 913,000
$ 360.000
$2,996,000
1 year
6 months
20 years
This alternative is identical to Alternative GWP4B except tor
this alternative adcresses contarnimted gtWldwater
associated with the lagoon area.
ALTERNATIVE GWP4C: GROUIIJWATER EXTRACTION
WEI.LS, TREATIIENT BY I.Jour>l'HASE CARBON ADsORPTION
Capital Costs:
Annual O&M Costs:
Total PW Costs for 30 Years:
nme to Design:
Construction nme:
Duration m Achieve Clean-up:
$ 788,000
$ 432.000
$4,305,000
1 year
6 months
15 to 30 years
This alternative includes ex1rae1ing groundwater by means
of extraction wells downgradient of Area 2; volatile organics
removal through iquid-phase carbon adsorption and
combined discharge with treated groundwater from OU-1
discharge to the Salisluy POTW. The treated effluent must
meet permit limits set by the Salisbury POTW. Spent
activated carbon would be regenerated. The five year
review CERCLA requirement would apply to this alternative.
ALTERNATIVE GWLAC: GROIMDWATER EXTRACTION
WELLS, TREATIIENI' BY I.JouD-l'HASE CARBON ADsOR/ITION
Capital Costs:
Annual O&M Costs:
Total PW Costs tor 30 Years:
nme to Design:
Construction nme:
Duration to Achieve Clean-up:
$ 987,000
$ 941.000
$8,375,000
1 year
6 months
20 years
This alternative is identical to Alternative GWP4C except this
alternative addresses contaminated groundwater associated
with the lagoon area.
ALTERNATIVE GWLSA: GROIMDWATER EXTII.ACTION
WEI.LS, TIIEATIENT BY AIR Sr1IIPPwG WITH VAPOII-PIIASE
CARBON Aoso!IF1ION, IN-SiTV Blo!IE.IIEDIATIOII REOIJIRIIG
GROUNDWATER INJECTION OF MITRJENTS
Capital Costs:
Annual O&M Costs:
Total PW Costs tor 30 Years:
nme to Design:
Construction nme:
Duration tD Achieve Clean-lJI):
$1,093,000
$ 798.000
$7,477,000
1 year
6 months
15 to 30 years
This alternative includes extracting 110undwater by means
of extraction wels localed downgradient of the lagoons;
volatile orgarics removal ttYough air stripping; control of
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emissions to the atmosphere from the at stripper ttYough
vapor-phase cartlon adsorption; combining a portion of Ile
discharged groundwater with trealed groundwater from OU-1
for discharging to the Salisbury POTW, polishing the
remaining pol1ion of the grollldwater by at stripping to
cleanup goals belore rjecling the treated grollldwater along
with nu1rients into the comaminated area to promote MIU
biodegradation of Ile contaminants. "In-situ" means to keep
in place ~.e., the treatment is conducted in its original place).
The treated effluent being discharged to the Salisllury
POTW mus! meel pennij imits set by the Salisbury POTW.
Spenl activated carbon would be regeneraled. The five year
review CERCLA requirement would apply ID this allernative.
ALTERNATIVE GWL.58: GROIMDWATER EmlACT/011
WELLS, TliEATIIEHT BY All ST1IIPPING WITH FIAE
INCINERATTON, IN-S/TIJ BIOREMEOIATIOH REQVIRIHG
GROUl«IWATER INJECTION OF MIT1IIENTs
Capital Costs:
Annual O&M Costs:
Total PW Costs for 30 Years:
Time to Design:
Construction Time:
Duration ID Achie-;e C~:
$1,365,000
$ 733.000
$7,000,000
1 year
6 months
1 S ID 30 years
This allernati-;e is sinilar to Allernati-;e GWLSA except
control of emissions of the vapor coming from the first air
stripper would be accomplished IIYough the use of a Ml8
incineration.
ALTERNATIVE GWLSC: GROlMDWATER EmlACTIOH
THROUGH WELLS, TREATIIEHT BY l.Jouu>PHAsE CARBO/I
AOSORl'TIOH, IH-51TU BIOREIIEOIATTOII REQUIRING
GROUl«!WATER INJECTION OF MIT1IIENTs
Capital Costs:
Annual O&M Costs:
Total PW Costs for 30 Years:
Time 10 Design:
Conslruction Tune:.
Duration ID Achie-;e Clean-up:
$1,216,000
$ 1,631.000
$13,853,000
1 year
6 months
1 s to 30 years
This alll!rnati-;e inciudes extading l)IOlll(t,vater by means
of extraction wels localed downgradient of Ile lagoons; .
volatile organics remowl IIYough iquid-phase cartlon
adsorption; combimg a pol1ion of the discharge with teated
groundwalar from OU-1 for cischarging ID the Salisbury
POTW; the remaining portion of the trealed grollldwaler
would be re~ along with rlArients, back 111D the
contaminaled area to promote in-silU biodegradalion ot the
contaminants. The trealed effulnt being cischalged to the
Salisbury POTW Ylill meet penn~ linits set by the POTW.
Spent activated catbon would be changed out and sent to a
commercial regeneration faciity. The IMI year review
CERCLA requirement would apply. The teated effluent
must meet pennlt linits set by lhe POTW. The 1M1 year
review CERCLA req,.irement would w-i to lhis aHemati-;e.
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REIIEDIAI. ALTERNA11VES TO ADDRESS
SURFACE WATER AND SEDIIIENT
CONTAIIINATION
ALTERNATIVE SW11SD1: No Acno#
Capital Costs:
Annual O&M Costs:
Total PW Costs for 30 Years:
Time to Design:
Conslruction Time:
Duration ID Achieve Clean-up:
$ 0
S 16,000
$151,000
None
None
Over 30 years
No further activities would be conducted on Sl.riace water or
the sediment in the Nc~~asl Tributary. As with Alternative
GWP1/GWL1, this stream would be left ·as is". Samples
would be collected and analyzed every five years as part of
the five year review CERCLA reqlirement fflch awlY ID
this alternative.
ALTERNATIVE SW21SD2: LoHG-TERII UOWTORIIG
Capital Costs:
Annual O&M Costs:
Total PW Costs for 30 Years:
Time to Design:
Construction Time:
Dllation ID Achieve ~:
$ 0
S 92.000
$867,000
None
None
Over 30 years
This alternative is sinilar to Alternative SW1/S01, except
l6lder Allemati-;e SW2/SD2, Sl.riace water and sedimenl
samples would be collected from the Northeast Tributaly
amually nstsad of once every fi-;e years.
CRITERIA FOR EVALUATING REIIEDIAI.
ALTERNA11VES
EPA's selection of the preferred cleanup alternati-;e for the
NSCC OU-3 site, as desaibed in this Proposed Plan, is lhe
result of a comprehensr;e evaluation and screening process.
The Feasibility Study for Ile Site was conduc1ed to identity
and analyze the alternati-;es considered for addressing
contamination al the Site. The Feasibiity Study and other
documents for the NSCC OU-3 site desaibe, in detal, the
alll!rnatives considered, as wel as the process and crileria
EPA used to narrow lhe list ID polential remedial alternatives
to address the Site contamination. As slated previously, all
of these documents are avaiable for public review in the
information repository/adminiSlrati-;e record.
Allernati-;es GWP4C, . GWL4C, GWLSA, . GWL.58, and
GWLSC were nol retained for Ile delailed analysis because
the other altemali-;es would aclieve 118 same_ degree of
prol9clion for tunan healtl and tie envinlnment but at a
substantially lower cost
EPA always uses the foflowing nine criteria to evaluate
alternati-;es identified in lhe Feasiliity Study. The remedial
al1Brnati-;e seleded for a Supemrd site must achieve the
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two threshold criteria as well as attain the best balance
among the five evaluation 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
ttvough 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 envirorvnental and public health
laws and requirements that apply or are relevant
and appropriate ID the site conditions.
EVALUATING CRITERIA
3. Cost:· The benefits of implementing a particular
remedial alternative ai:e 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 .~ operation and main~nance 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
goverrvnent agencies that is needed) of a remedy.
including the availabiUty of necessary materials and
services.
5. Shon-term effectiveness: The length of time
needed ID implement each alternative is
considered, and EPA assesses the risks that may
be posed ID worl<ers and nearby residents during
construction and implementation.
6. Long-term effecttveness: The alternatives are
evaluated based on their ability to maintain reliable
protection of public health and the envirorvnent
over time once· the cleanup goals have been met.
7. Reduction of contaminant toxicity, mobility,
and volume: EPA evaluates each alternative
based on how it reduces (t) the harmful nab.Jre of
the contaminants, (2) their ability to move ttvough
the envvonment, and (3) the volume or amount ot
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
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state concurs with, opposes, or has no comment
on EPA's preferred alternative.
9. Community acceptance: To ensura that the
public has an adequate oppol11Jnity ID provide
input, EPA holds a public comment period and
considers and responds to all comments received
from the comm~ty prior ID the final selection ot a
remedial action.
EVALUATlON OF ALTERNATlVES
The following summary profiles the performance of the
preferred alternatives in terms of the nine evaluation criteria
noting how it compares ID the other alternatives under
consideration. The comparative analysis tor the
groundwater remediation alternatives is as follows:
GROUNDWATER REMEDIATION
The following alternatives were su_bjected to detailed
analysis for migration corrtrol:
Alternative GWP1 : No action with regard to the
groundwater in Area 2
Alternative GWP2: Long-Term Groundwater Monitoring of
in Area 2 with Fencing A Portion of Northeast Tributary
Alternative GWP3: Institutional Controls with regard to the
groundwater in Area 2 with Fencing A Portion of
Northeast Tributary
Alternative GWP4A: Groundwater Extraction Through
Wells Downgradient of Area 2 and Treatment By f,Jr
Stripping with Vapor.Phase Carbon Adsorption with
Combined Discharge to the Salisbury POTW
Alternative GWP4B: Groundwater Extraction Tlrough
Wells Downgradient of Area 2 and Treatment By f,Jr
Stripping With Fume Incineration with Combined
Discharge to the Salisbury POTW
Alternative GWL 1 : No Action with regard to the
groundwater in the lagoon area
Alternative GWL2: Long-Term Groundwater Monitoring of
in the lagoon area with Fencing A Portion of Northeast
Tributary
Alternative GWL3: Institutional Controls with regard to the
groundwater in the lagoon area with Fencing A Portion
of Northeast Tributary
Alternative GWL4A: Groundwater Extraction Through
Wells Downgradient of the Lagoon Area and
Treatment By /vi Stripping with Vapor.Phase Carbon
Adsorption with Combined Discharge to the Salisbury
POTW
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AJtemaUve GWlAB: Groundwater Extraction Tlv'ough Wells
Downgradient of the Lagoon Area and Treatment By
f,,jr StriWing Wilh Furne Incineration with Combined
Discharge to the Saistuy POTW
Overall Protection: Allemali'IIIS GWP2, GWl2, GWP3,
GWL3, GWP4A, GWUA, GWP4B, and GWL4B provide
adequate protection tor tunan heallh by preventing
ingestion of polentialy contaminated groundwater and
surface water. Alternatives GWP4A, GWP4B, GWL4A, and
GWL4B would afford the grealest protection ID human heallh
because n would substantially reduce Ille contamination in
Ille groundwater and prevent the potential for exposure
ttvough use of existing or future rff site weas. Alternatives
GWP4A, GWP4B, GWL4A, and GWL4B would also
remediale Ille surface water and sediment. which would
eliminate Ille potential for exposure via ingestion of lhese
media. These alternatives prolect Ille environment by
removing contamnants from groundwater, controGing the
extent of groundwater contamination, and reducing Ille
contamination in the tribulary and downslream surface
waters. Neilher Alternatives GWP3 nor GWL3 would protect
Ille envirorvnent because contamination would continue to
migrate into Ille tribulary 1tvough groundwater discharge.
None of Ille Alternatives GWP1, GWL1, GWP2, or GWL2
wil provide protection for eilher tunan health or Ille
environment Natural degradation/attenuation of
contaminants in the subsurface is not anticipated to prevent
the potential migration of contaminants off site, allhough
such processes may reduce the amooot and concentration
of contaminants.
Compliance with ARARs: Altematives GWP4A, GWP4B,
GWL4A, and GWL4B would obtain pelformance standalds
for groundwater (MCLs and North Carolina Groundwater
Standards), surface waler and sediment at the point of
compliance. These allBrnatives would also comply wilh
location-and action-specific ARARs related ID the discharge
to the POTW and ai' emission controls. Alternatives GWP 1,
GWL 1, GWP2, GWL2, GWP3, and GWL3 are not expected
to meet performance slandards at the point of compliance,
however, Alternatives GWP3 and GWL3 would comply wilh
Ille location-specific ARAR related ID operations at a
hazardous waste site.
Long-lBrm Effectiveness and Permanence: Alternatives
GWP4A, GWP4B, GWL4A, and GWL4B would provide an
effective and permanent sokJtion for groundwaler, surface
waler, and sediment because the chemicals ol concern
would be removed from the pnjwaler and destroyed.
The reliabiity of these alternatives is tigh. These
alternatives would not pose a lunan health or
envirormental risk at the point of compiance and no
treatment residuals would be left on Site. Alternatives
GWP3 and GWL3 would prevent potential future risk by
preY8nting the installation of mriing wells in any nas
exceeding MCLs or North Carolina Grouldwaler Standards.
AIIBrnatives GWP1, GWL 1, GWP2. and GWL2 wil not be
prolective of tunan health and the envirorvnent in the long
IBrm because lhese altamatives do not remove, teat, or
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isolate subsl.rface contamnation. Five-year CERCLA
mandated reviews will be required for al of !he allBrnatives.
Reduction of Toxicity. Mobility or Voune: Alternatives
GWP4A, GWP4B, GWL4A, and GWL4B would l'9(l.T(:8 Ille
toxicity and YOll.me ol conlamination in pn!walBr tlr'ougll
removal and treatment. They would also recu:e the tDxicity
and vollJ!l8 of contamnation in Sl6face water and sediment.
AIIBrnatives GWP1, GWL 1, GWP2, GWL2, GWP3, and
GWL3 do not din!ctly r&(l.T(;8 IDxicity, mobiity, or voune of
groundwater, surface waler or sedinent contamination.
Short-term Effectiveness: All of the alternatives can be
implemented withOut significant risk to Ille commlrity or
on-site WOlkers and without adverse environmen1al impacts.
Implementability: None of the allernatives pose significant
concerns regarding implementation.
Cost Total present worth costs (based on 30 years) tor Ille
groundwater alternatives are presented below:
AftemaUves GWP1/GWL 1 -No action: $227,000
AftemaUves GWP2/GWL2 • Long-Tenn Monitoring wilh
Fencing A Portion of Northeast Tributary:
$1,479,000
AftemaUves GWP3/GWL3 -Institutional Controls with
Fencing A Portion of Northeast Tributary:
$1,500,000
AftemaUve GWP4A · Grollldwater ExtractiorvAa-
StrWirJWVapor-f'hase Carbon AdsorptionlPOTW
Discharge: $2,222,000
AftemaUve GWP4B · Grooodwater ExlractiorV A,
StriWinwf'lllle lncineraliorvPOTW Discharge :
$2,274,000
AJtemaUve GWL4A · Groundwater ExtractiorV A,
StrWirJWVapor-f'hase Carbon AdsorpliorvPOTW
Discharge: $3,570,000
AJtemaUve GWL4B -Groundwater ExlractiorVAa-
Stripping/Fume lncineration/POTW Discharge:
$2,996,000
SURFACE WATER/SEDIMENT
The following allBmatives were SliJjeclBd to detailed
analysis for IUface waler and sediment remeciation:
AftemaUve SW1/SD1: No Action
AftemaUve SW2/S02: Long-Tenn Monitoring
Overall Protection: lhler present conditions, bolh
Alternatives SW1/SD1 and SW2/SD2 would be proteCtive of
lunan health, but may not be protect,e of Ille envilOrment. .
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If higher concentrations of contaminants are discharged ini>
the stream from lhe groundwaler, then neither alternative
may be protective of human heallh nor the environment.
Compliance wilh ARARs: There are no Federal or Stale
ARARs for the conlaminants detected in the surface water
or sediment
Long-1erm Effectiveness-and Permanence:. Under current
conditions, Allernatives SW1/SD1 and SW2/SD2, would be
prolective of human health but possibly not the envirorvnent
If higher concentrations of contaminants begin discharging
into the tributary, none of lhese alternatives may be
protective of human heallh.
Reduction ofToxicity. Mobility or Volume: Bolh Alternatives
SW1/SD1 and SW2/SD2 could lead to a reduction of volatile
contaminants in lhe tributary, however, neither of lhese
alternatives would result in lhe c.lestruction of lhe -.olatile
contaminants. These contaminants would be transferred
from the tributary to the atmosphere tlvough the process of
volatilization.
· Short-term Effectiveness: All of the alternatives can be
implemented wilhou1 significant risk to the community or
on-site workers and withou1 adverse environmental impacts.
Implementability: None of the allernatives pose significant
concerns regarding implementation.
Cost Total present worlh costs (based on 30 years) for the
sur1ace water/sediment alternatives are presented below:
'' AfteinaUve SW1/S01 · No Action: $151,000
AJtemaUve SW2/SD2 -Long-Term Monitoring: $867,000 . ., '.".. ,,.'':".
State Acceptance:. Toe NCDEHNR has reviewed and
provided EPA wilh comments on the reports and data from
the RI and the FS. The NCDEHNR has also reviewed this
proposed plan and EPA's preferred alternative and presentiy
concurs with EPA's selection.
Community Acceptance: Community acceptance of the
preferred allemative wil be evaluallid after the public
comment period ends and a response to each comment wil
be included in a ResponslVeness Sunrna,y which will be
a part of the Record of Decisfon (ROD) for the Site.
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EPA'S PREFERRED ALTERNATIVE
After conducting a detailed analysis of all the feasible cleanup alternatives based on the criteria described in the previous sections, EPA is proposing a cleanup plan to address groundwater, surface water, and sediment contamination at the Site. The EPA preferred alternatives are:
GROUNDWATER REMEDIATION
ALTERNATIVES GWP3B AND GWL3B: Long-Term Monitori~stiMional Controls; ALTERNATIVE GWP4B: Groundwater Extraction Through Wells and Treatment By Air Stripping with Fume Incineration; and ALTERNATIVE GWL4B: Groundwater Extraction Through Wells and Treatment By Air Stripping with Fume Incineration and Combine Treated Groundwater with Groundwater from OU-1 for Discharge to the Salisbury POTW
At a cost of $1,500,000, $2,279,000, and $2,996,000.
SURFACE WATER/SEDIMENT
ALTERNATIVE SW2/SD2: Long-Term Monitoring Cost: $867,000
· An active groundwater remediation al1ernative would reduce the levels of contamination in both the surface water and sediment as the source of this contamination is the discharge of contaminated groundwater along the section of the Northeast Tributary.
OVERALL TOTAL PRESENT WORTH COST OF $7,637,000
Based on current information, these alternatives appear to provide the best balance of trade-offs with respect to the nine criteria that EPA uses to evaluate alternatives. EPA believes the preferred alternative will satisfy the statutory requirement 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 alternatives is preliminary and cou!d change in response to public comments.
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COIIIIUNITY PARTIQPATION
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 ID participate in the decision-making process. Public
involvement activities IJ1dertaksn at Superfund sites consist of interviews with local residents and elected officials, a community
relations plan tor each site, tact sheets, availabiUty sessions, public.meetings, public comment periods, newspaper advertisements,
site visits, and Tecmcal AssiSlance Grants, and any other actions needed to keep the community informed and involved.
EPA is conducting a 30-day publlc conment period from July 19, 1993 to August 17, 1993, ID provide an opportunity for public
involvement in selecting the final cleariup method for this Site. Pubric input on all alte~tives, and on the information that supports
the alternatives is an important contribution ID the remedy selection process. DUiing lhis comment period, the public is invited ID
attend a public meeting on August 3, 1993, at the Agricultural Extension Center Auditorium, 2727 Old Concord Road, Salisbury,
North Carolina begiming at 7:00 p.m. at which EPA will present the Remedial Investigation' FeasibiUty Study and Proposed Plan
describing the prefenred alternative for lrealment of the ~inated groundwater at the National Starch & Chemical Company
Superfund Site and ID answer any questions. Because this Proposed Plan Fact Sheet provides only a summary description of the
cleanup alternatives being considered, the public is encouraged ID consult the information repository for a more detailed
explanation. ·
During !his 30-<!ay period, the public is invited ID review all site-related documents housed at the information repository located
at the Rowan County Public Library, 201 West Front Street. Salistuy. North Carolina and offer comments ID EPA either orally at
the public meeting which will be recorded by a court reporler or in written form during lhis lime period. The actual remedial action
could be different from the prefenred alternative, depending upon new information or statements EPA may receive as a result of
public comments. tt you prefer ID submit written comments, please mail them postmarked no later than midnight August 17, 1993
to:
Dlati. Barrett
NC Comroonlty Relations coordJnaior
U.S.E.P.A., R11glon 4
Norlh Remedial SUperfund Branch
345 Countand Street, NE
Atlanta, GA 30365
All comments wil be reviewed and a response prepared in making the final detennination of the most appropriate alternative for
cleanup,watment of the Site. EPA's final choice of a remedy will be issued in a Record of Decision (ROD). A document called
a Responsiveness Sunwnary SLmmarizing EPA's response ID al public comments wil also be issued with the ROD. Once the
ROD is signed by the Regional Administrator It wiU become part of the Administrative Record (located at the Library) which contains
all documents used by EPA in making a final determination ol the best cleanup,walment for the Site. Once the ROD has been
approved, EPA will begin negotiations with the Potentially Rasponslble Parties (PRPs) ID allow lhern the opportunity ID design,
implement and absolb al costs ol the remedy delerm~ in the ROD in accordance with EPA guidance and prolDCOI. If
negotiations do not result in a settlement, EPA may conduct the remedial activity using Superfund Trust monies, and sue for
reimbursement ol Its costs with the assistance of the Department of Justice. Or EPA may issue a unilaleral administrative order
Of directly file suit to force the PRPs ID conduct the remedial activity. Once an agreement has been reached, the design of the
selected remedy wil be developed and implementation ol the remedy can begin. The preceding actions are the standard
procedures utilized during the Supemm process.
As part ol the SuperUld program, EPA provides affected communities by a Superfund site wilh the opportunity ID apply tor a
Technical Assistance Grant (TAG). This grant of up ID $50,000 enables the group ID hire a technical advisor or consultant ID assist
them in inlerpreting or commentir,g on site findings and proposed remedial action plans.
For more information concerning lhis grant program, please contact:
11s. Hosemsty Patton, Coordinator
NC T«hn/CBI Asslstancs Grants
Waste llsnsQement DMslon
U.S.E.P .A., Region 4
345 Courtlsnd Street, NE
Atlanta, GA 30365
(404) 347-ZZ:U
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INFORIIATJON REPOSITORY LOCATION:
Rowan County Publlc Library
201 Wesl Fisher Slreet
Sallsluy, North Clrollna 28144
Phone: {704) 633-55711
Hours: llonday • Fr1day 8:00 IIJII. • 9:00 p.m.
Sllbrday 9:00 am. • 5:00 p.m.
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FOR IIORE INFORMATION ABOUT SITE ACTIVITIES, PLEASE CONTACT:
a. Jon Bomhobn, Remedial Project ll■mger or
11s. Diane Barrell, NC Comnullly Relallons CoordlnalDr
North SUpa'fund Remedial Elnn:b
WBSIII ll■iagemat Division
U.S. EnmlllllNlillll Piuhidb1 Agcn:y, Region IV
345 Courtland Slnlet, NE
Allanla, Ga 30365
ToU Free No.: 1-800-435-9233
GLOSSARY OF TERIIS USED IN THIS FACT SHEET
Aquffer: An undergroLfld geological follnation, or group of formations, containing usable am01111s of grOllldwatsr that can supply weUs and springs.
AdmlnJstnllve Rscard: A fie which is maintained and contains all infonnation used by lhe lead agency ID make its decision on lhe selection of a meflod ID be utiized ID dean upr1reat contamination at a SupefUld site. This fie is held in the information reposit01y for public review.
Appl/cab/II or RM1'Nlt and Ap,,,.,,,,,,_ Raqulf8mllflts (ARARs): The federal and state r&qlilemenls flat a select8d remedy must attain. These requirements may vary among siles and various aJIBmatives.
Basel/111 Risk $55 us 111Mit A means of estimating lhe amouit of damage a Supem.nd site could cause to tunan heath and lhe environment. Objectles of a risk assessment are ID: help detsrmine the need for action; ~ defemline lhe levels of chemicals Iha! can remain.on Ile sile after clearup ~ stil proled heallh and lhe enwom1ent; and provide a basis for comparing different clearup melhoda.
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Carcinogen: Ally substance that can cause or COn1ribute ID the production of cancer; cancer-producing.
Comprehensive Environmental Responsa, CompensalJon BIid Uab/1/ty Act (CERCLA): A federal law passed in 1980 and
modified in 1986 by the Super1und Amendments and Reauthorization l<d. (SARA). The l<d.s CIBated a special tax paid by
producers of various chemicals and oi products that goes into a Trust Fund, commonly known as Superfl.m. These l<d.s give
EPA the autholity to investigate and clean up abandoned or uncon1rolled hazaldous wasts sites utiw,g money lrom the SuperMd
Trust or by taking legal action ID forte parties responsible for the contamination ID pay for and clean up hi sile.
Groundwater: Waler found beneath the earth's surtace that fills pores belWeen materials such as sand, soi, or gravel (usually
in aquifers) which is often used for supplying wells and springs. Because groundwater is a major source of drinking watsr there
is growing concern over areas where agricultural and indusb'ial pollutants or substances are getting into groundwatsr.
Hazardous Ranlclng System (HRSt The principle SCl98ning IDOi used by EPA to evaluate risks ID public heallh and the
environment associated wilh hazardous waste sitss. The HRS calculates a score based on the potential of hazardous substances
spreading from the sits tlvough the air, surface water. or groundwater and on other factors such as nearby population. This score
is the primary factor in deciding tt the sits should be on the National Priorities List and, tt so, what ranking ij should have compared
to other sites on the 1st
lnfonnatlon Repository: A file containing accurate up-to-oate information, teclvlical 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 buUding
such as a library, city hall or school, that is accessible for local residents.
Maximum ContJ/mlnant Lsvels (MCLs): The maximum permissible level of a contaminant in water delivered to any user of a
public water system. MCLs are enforceable standards.
National PoltutJJnt Discharge Elimination Systsm (NPOES): A provision of the Clean Waler l<d. which prohibits the discharge
of pollutants into waters of the inked Statss unless a special permit is issued by EPA, a state or (where delegated) a bibal
government on an Indian reservation allowing a controlled discharge of liquid after it has l.lldergone treatment.
National Prtontles LJst (NPL): EPA's list of the most serious uncontrolled or abandoned hazardous waste sites identified for
possible long-tsrm remedial action under Superfund. A site must be on the NPL to receive money from the Trust Fund for remedial
action. The list is based primarily on the score a sits receives from the Hazard Ranking System (HRS). EPA is required to updats
the NPL at least once a y8ll/.
PolBntlally Respons/ble Plrlles (PRPs): Any individual or company • including owners, operators, transporters, or generators
• potsntially responsible for, or contributing to, the contamination problems at a Superlund site. Whenever possible, EPA requires
PRPS, lhrough administrative and legal actions, to clean up hazardous waste sitss PRPs have contaminated.
Remedial lnvesttgatlOfllFBBSJb/Uty Study (RIIFS): The Remedial Investigation is an in-deplh, extensive sampling and analytical
study to gather data necessary to determine the nalure and ex1ent of contamination at a Super1und sits; ID establish criteria for
cleaning up the she; a de~tion and analysis of the potantiaJ cleanup altsmatives for remedial actions; and support the technical
and cost analyses of the altarnatives. The FeasibiUty study also usually recommends selection of a cost-effective alternative.
· Record ot DBCJs/on (ROD): A public document that amounces and explains which method has been selected by the Agency to
be used at a SuperMd sits 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 ID those comments. The responsiveness summary is a key part of the Record of Decision.
Sem-VoJat/le Organic Compolllds (SVOCsi-Carbon-<:0ntaining chemical compoims thal at a relatively low tsmperature,
fluctuate between a vapor state (a gas) and a liquid stats.
Vo/aUle Organic Compounds (VOCS): Ally organic compound that evaporates readily into the ai' at room temperature.
Water Tab/8: The level below which the soil or rock is saturated wilh' water, somlimes referred ID as the upper surface f lhe
saturated zone. The level of groundwater.
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MAILING UST ADDmONS
If you are not aJraac1Y on OIi' rnalD~ 11st and would IDie to be placed on the 11st to ncalve tutin lnlonnlllon on the Nltlonal Stan:11 I Ctanlcal COll!plllf !qlerfllld Sita, please complete Ila IOml and lllum to Diani Bam1I, Conrnunlty Ralallons COorcfJnatgr at the above lllldrNa: .
NAME•;_------'-----------------,----------
ADDRESS_· -----------------------------
CITY, STATE, ZIP CODE: ______ ,,_ __________________ _
PHONE NUMBER•;_---------------------------
U.S.-IUIP_..,,,
S4.! CoMlllnd S1i-ool, N.E.
Alllllll,Goo,p-
____ J
-~--Diano-. Comnamlly-~ .Ion Bo. b olm, ..,_ Pn,joct lllmgor
1111,lka-
ly for Priv,.. UN POO
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RESPONSIVENESS SUMMARY
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RESPONSIVENESS SUMMARY
FOR THE
PROPOSED REMEDIAL ACTION
FOR OPERABLE UNIT #3
NATIONAL STARCH & CHEMICAL COMPANY SUPERFUND SITE
SALISBURY, ROWAN COUNTY, NORTH CAROLINA
Based on Public Comment Period
July 19 through September 16, 1993
Which Includes August 3, 1993 Public Meeting Held In
Agricultural Extension Center, Salisbury, North Carolina
Prepared by:
U.S. Environmental Protection Agency, Region IV
September 1993
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RESPONSIVENESS SUMMARY
OPERABLE UNIT #3 PROPOSED PLAN
NATIONAL STARCH & CHEMICAL COMPANY SUPERFUND SITE
TABLE OF CONTENTS
SECTION PAGE No.
1.0 OVERVIEW . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
2.0 BACKGROUND . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
3.0 SUMMARY OF MAJOR ISSUES/CONCERNS/QUESTIONS/STATEMENTS VOICED
DURING PROPOSED PLAN PUBLIC MEETING AND RESPONSES . . . . . . . . . . . . 3
3.1 SOIL REMEDIATION ALTERNATIVES............................... 3
3.2 AREA OF SOIL CONTAMINATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
3.3 MIGRATION OF CONTAMINATION................................. 4
4.0 SUMMARY OF MAJOR ISSUES/CONCERNS/QUESTIONS/STATEMENTS VOICED
DURING PUBLIC COMMENT PERIOD . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
4.1 CONCERN ABOUT DISCHARGING INTO THE CITY OF SALISBURY SEWER
SYSTEM ............................................... : . . . . 5
4.2 ESTABLISHMENT OF A FOURTH OPERABLE UNIT . . . . . . . . . . . . . . . . . . . . 5
4.3 ESTABLISHMENT OF A POINT OF COMPLIANCE WITH ENFORCEABLE
INSTITUTIONAL CONTROLS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
4.4 ESTABLISHMENT OF A SITE CLEANUP LEVEL FOR 1,2-DICHLOROETHANE 8
4.4 SELECTION OF THE MOST COST EFFECTIVE REMEDIAL ALTERNATIVE... 9
ATTACHMENTS
Attachment A -Transcript of Public Meeting
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RESPONSIVENESS SUMMARY
OPERABLE UNIT #3 PROPOSED PLAN
NATIONAL STARCH & CHEMICAL COMPANY SUPERFUND SITE
1.0 OVERVIEW
A development of this Responsiveness Summary is in accordance to the requirement set forth
in 40 CFR 300.430(f)(3)(i)(F). This community relations Responsiveness Summary is divided into
the following sections:
Section 2.0 BACKGROUND
This section discusses the Environmental Protection Agency's preferred
alternative for remedial action, provides a brief history of community interest, and
highlights the concerns raised during the remedial planning for Operable Unit #3
(OU #3) at the National Starch & Chemical Company (NSCC or NSC) Superfund ·
Site.
Section 3.0 SUMMARY OF MAJOR ISSUES/CONCERNS/QUESTIONS/STATEMENTS
VOICED DURING PROPOSED PLAN PUBLIC MEETING
This section provides a summary of issues/concerns and questions/comments
voiced by the local community and responded to by the Agency during the
Proposed Plan public meeting. "Local community" may include local
homeowners, businesses, the municipality, and not infrequently, potentially
responsible parties.
Section 4.0 SUMMARY OF MAJOR ISSUES/CONCERNS/QUESTIONS/STATEMENTS
VOICED DURING PUBLIC COMMENT PERIOD
This section provides a comprehensive response to all significant written
comments received by the Agency and is comprised primarily of the specific legal
and technical questions raised during the public comment period.
2.0 BACKGROUND
EPA conveyed its preferred remedial alternative tor OU #3 NSCC Superfund Site, located in
Salisbury, North Carolina in the Proposed Plan Fact Sheet mailed to the public on July 15, 1993,
and through an ad in The Salisbury Post and The Charlotte 0bservernewspapers. The ads were
published in the July 19, 1993 edition of these two newspapers. A press release reminding the
public of the forthcoming meeting was issued on July 30, 1993. The public meeting was held on
August 3, 1993 at the Agricultural Extension Center in Salisbury, North Carolina. The purpose
of the meeting was to present and discuss the findings of the OU #3 Remedial
Investigation/Feasibility Study (RI/FS), to apprise meeting participants of EPA's preferred remedial
alternative for OU #3, and to respond to any questions or adcjress any concerns expressed during
the public meeting. The Proposed Plan Fact Sheet, the newspaper ad, and the press release all
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OU #3 National Starch & Chemical Company
Responsiveness Summary
informed the public that the 30-day public comment period would run from July 19 to August 17,
1993. However, a request was made for a 3tl-day extension to the public comment period.
Consequently, the public comment period was extended to September 16, 1993.
No remedial alternative was presented for soils as this environmental medium will be addressed
in the forthcoming Operable Unit #4.
The alternative presented for addressing the contaminated groundwater included Alternatives
GWP3B/GWL3B and GWP4B/GWL4B: This alternative permanently removes the contaminants
in the groundwater through groundwater extraction and on-site treatment through an air stripper
with controls on air emissions. The treated groundwater will be discharged into the City of
Salisbury's sewer system. The following activities are involved in this alternative:
o Contaminated grouridwater will be extracted from within and at the periphery of the plumes
emanating from the Area 2 and the treatment lagoon area via extraction wells and piped
to an on-site, above-ground treatment process;
o Treatment will consist of air stripping to achieve concentrations to meet discharge
requirements set forth by the City of Salisbury wastewater treatment system;
o Long-term monitoring of the underlying aquifer; and
o Implementation of a deed restriction on the NSCC property as an institutional control.
The alternative presented for addressing the contamination detected in the surface water and
sediment of the Northeast Tributary was SW/SE-2. This alternative requires long-term monitoring
· of the stream as the proposed groundwater remediation system will reduce and eventually
eliminate the contamination discharging into the stream along with the groundwater.
The Risk Assessment indicates that neither the soils nor groundwater pose an unacceptable risk
to either human health or the environment under present conditions; however, these contaminated
environmental media could pose as an unacceptable future risk to both human health or the
environment. In addition, the remediation of the groundwater is warranted as the levels of 1,2-
dichloroethane and a number of other chemicals are above applicable or relevant and appropriate
requirements (ARARs) established for these contaminants in the groundwater. For these
contaminants, the cleanup goals selected were Safe Drinking Water Maximum Concentration
Levels, State of North Carolina groundwater quality standards, and risk based concentrations.
Community interest and concern about the NSCC Site has fluctuated from moderate to high over
the past two decades. Awareness of and concern about the NSCC "Plant", not the Superfund
related hazardous wastes, were very high in the communities which are adjacent to and nearby
the "Plant". NSCC received considerable local news media attention when it's Lumber Street
Plant, which is also located in Salisbury, North Carolina, experienced an explosion which
destroyed a section of the plant. In 1984, at the NSCC Cedar Springs Road Plant where the
Superfund Site is located, a production process reportedly boiled over releasing a vapor cloud
containing acetic acid. The vapor cloud reportedly injured vegetation for up to 1.5 miles from the
plant.
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OU #3 National Starch & Chemical Company
. Responsiveness Summary
A 1985 newspaper article indicated there are mixed feelings in the communities surrounding the
plant. Some of the residents believe that NSCC is a responsible company with an excellent
record and that NSCC will work with EPA and cleanup the dump as other residents were
concerned about the effects on their health and believe their community has borne the brunt of
living near to NSCC. As stated above, the community has maintained a high level of awareness
and concern regarding NSCC as a result of the incidents reported in the media.
The following provides details on the accumulative community relations efforts conducted by the
Agency. A Community Relations Plan identifying a positive public outreach strategy was
completed in September 1986. As part of this initiative, Information Repositories including the
Administrative Record, were established at the Rowan County Public Library and in EPA, Region
IV Information Center in Atlanta, Georgia to house the Administrative Record for the Site. The
Information Repository and Administrative Record are available for public review during normal
working hours.
Fact sheets and public meetings were the primary vehicles for disseminating information to the
public. EPA sponsored a number of public meetings and released several fact sheets to keep
the public apprised of current activities, to help the community understand the Superfund program
and the public's role in the process, and to share information regarding the direction and technical
objectives of data collection activities at the Site. Only a few individuals from the community
attended the Proposed Plan public meeting. In addition to these individuals, one representative
from the news media, representatives from NSCC, and representatives from various government
agencies also attended the meeting.
3.0 SUMMARY OF MAJOR ISSUES/CONCERNS/QUESTIONS/STATEMENTS VOICED
DURING PROPOSED PLAN PUBLIC MEETING AND RESPONSES
This section summarizes the major issues and concerns expressed during the Proposed Plan
public meeting. Only four questions were asked during the public meeting. They related to:
Why was ·soil remediation alternatives left out of the Proposed Plan?
In what direction is the contamination migrating and has the contamination migrated off the
NSCC property?
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A recount of the questions summarized above and the Agency's response can be found on pages
32-36 of the transcript of the Proposed Plan public meeting (Attachment A).
Summarized below are significant questions asked during the Proposed Plan public meeting:
3.1 SOIL REMEDIATION ALTERNATIVES
Q: What's wrong with the soil that you have to go back to the operation?
A: It's not what's wrong. NSCC needs to perform a more thorough evaluation of the soil
alternatives.
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3.2 AREA OF SOIL CONTAMINATION
Q: Where's the soil now?
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OU #3 National Starch & Chemical Company
Responsiveness Summary
A: An overhead was used to show the extent of soil contamination.
3.3 MIGRATION OF CONTAMINATION
Q: Does any of the contamination left the soil yet? Left the property?
A: To the best of our knowledge, no.
Q: Something in the paper about it traveling north; is that true?
A: Its tending to follow the stream which flow in a northerly direction.
4.0 SUMMARY OF MAJOR ISSUES/CONCERNS/QUESTIONS/STATEMENTS VOICED
DURING PUBLIC COMMENT PERIOD
This section summarizes the major issues and concerns expressed during the Proposed Plan
public comment period. The major issues and concerns on the proposed remedy for OU #3
NSCC Site can be grouped into five areas:
• Discharge into the City of Salisbury sewer system;
• Establishment of a Fourth Operable Unit;
Establishment of a Point of Compliance with Enforceable Institutional Controls;
• Establishment of a Site Cleanup Level for 1,2-Dichloroethane; and
• Selection of the Most Cost Effective Remedial Alternative.
Below is each written comment received and the Agency's corresponding response in italicized
print. The comments below have been transcribed verbatim from the written set of
comments the Agericy received.
4.1 CONCERN ABOUT DISCHARGING INTO THE CITY OF SALISBURY SEWER SYSTEM
COMMENT #1: This industrial user is subject to categorical OCPSF organics limits, and is
usually in compliance with our local limits for those compounds. However,
the application of supplementary limits to the discharge -fume toxicity,
explosivity, and human health criteria -could result in some limits being so
restrictive that this discharger may be unable to consistently meet those
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RESPONSE:
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OU #3 National Starch & Chemical Company
Responsiveness Summary
limits. If this occurs, the potential exists that the remediation project could
be halted until the system· is redesigned to meet the more stringent limits.
The City requests that the EPA Superfund Branch work and communicate
with the N_PDES Permit Branch in an effort to develop and implement limits
based on more practical, alternative ways of assuring both worker safety ·
and collection system integrity. We feel that the existing methods may
produce limits which are unrealistic when compared to OCPSF limits or
local limits derived by traditional headwo_rks methods. We request your
assistance in resolving this compliance issue.
Currently, the PRP's contractor, IT Corporation, does not believe it will be
necessary to revise NSCC's existing discharge permit. However, in the
event after closer examination of all the data, it becomes apparent that the
discharge permit to the City of Salisbury sewer system will need to be
revised due to the additional loading created by the groundwater extraction
system for Operable Unit (OU) #3, then all entities involved, the Agency,
North Carolina Department of Environment, Health & Natural Resources
(NCDEHNR), the City of Salisbury, the PRP, and the PRP's contractor will
need to work together to develop and implement limits based on practical,
alternative ways of assuring both worker safety and collection system
integrity. A determination on whether or not the existing discharge permit
will need to be revised cannot be made until the Remedial Design stage
at which time the actual loading rates and volumes can be calculated.
4.2 ESTABLISHMENT OF A FOURTH OPERABLE UNIT
COMMENT#2:
RESPONSE:
For the reasons expressed in the enclosed comments of IT, we do not
believe that it is necessary to establish a Fourth Operable Unit. NSC has
agreed to perform the DNAPL test suggested by EPA and the-State. We
are prepared to perform this test immediately following EPA's approval so
that the results will be available prior to issuance of the ROD. Thus, if the
tests do not show the presence of DNAPLS, we do not think a Fourth
Operable Unit to address soils should be required.
At a minimum, we think it is premature to establish a Fourth Operable Unit
unless and until such time as continued groundwater monitoring results
indicate that concentrations of contaminants do not significantly decrease.
We suggest that the ROD be written so as to require a Fourth Operable
Unit at a later date, only if necessary, following the analyses of sufficient
groundwater monitoring results that would allow a determination of the
effectiveness of a no action soil alternative.
The need for a fourth operable unit was a mutually agreed upon decision
between the Agency and NCDEHNR. The decision was based upon the
fact that the June 21, 1993 Feasibility Study (FS) did not provide sufficient
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OU #3 National Starch & Chemical Company
Responsiveness Summary
supporting and defendable technical rationale for the elimination of soil
remediation technologies that could permanently remove the residual
contamination from the soil. Therefore, OU #4 FS will need to more
thoroughly evaluate soil remediation technologies providing sufficient
rationale for the elimination and/or retention of appropriate technologies
that can address the soil contamination at the Site.
Another concern, the presence of either a free-phase or residual-phase
. dense non-aqueous phase liquid (DNAPL) in the soil in Area 2 was
highlighted during the review of the draft Proposed Plan. The primary
contaminant at the NSCC site is 1,2-dichloroethane (1,2-DCA) which is a
chemical that can exist as a DNAPL. The presence of a DNAPL in either
the soils or aquifer can control the ultimate success or failure of
remediation at a hazardous waste site. The testing procedures and
findings of the hydrophobic dye test conducted on September 22-23, 1993
shall be-incorporated in the OU #4 FS. Currently, the Agency does not
foresee the need for any additional field work to be conducted as part of
OU #4; hence, the June 2, 1993 RI report should suffice as the OU #4 RI
report.
We disagree with the EPA for the need of another Operable Unit. Based
on the investigative data that has been collected the source of
contamination of the subsurface soils is well defined. In tact, the EPA has
stated in.the Proposed Plan that "The OU3 soil.investigation has generated
ample information to characterize the contamination, determine the source,
and define the extent of contamination in the vadose soil zone."
The EPA and the NCDEHNR have both expressed their concerns about
the presence of dense nonaqueous phase liquid (DNAPL), which they have
used as the basis tor the establishment of OU4. The agencies want the
OU3 FS expanded to include more active remedial actions tor the soil
because they suspect that DNAPL may be present in the soil and it the
DNAPL continues to release from the soil to the groundwater the
groundwater remediation will not succeed in cleaning up the aqui_ter. The
data that has been collected to date does not indicate that DNAPLs are
present, but direct testing has not been performed to refute their concern.
The NCDEHNR has recommended a field screening test using hydrophobic
dye to make the determination of the presence or absence of DNAPLS,
which NSCC has agreed to perform. The testing procedure along with the
proposed borehole location is provided as Attachment A. (This attachment
has not been incorporated into the Responsiveness Summary.) We feel
that if the test results show an absence of DNAPL there truly is no need
for another operable unit. We continue to recommend long-term mo_nitoring
of the groundwater to determine if no action is sufficient for the subsurface
soils. If increased concentrations of contaminants or no substantial
decrease in concentrations of contaminants are noted after 5 years of
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RESPONSE:
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OU #3 National Starch & Chemical Company
Responsiveness Summary
active groundwater remediation then other remedial options may have to
be considered.
As denoted in the Response to Comment # 2 above, it is the lack of
supporting technical rationale in the June 21, 1993 FS report for the
elimination/retention of the soil remediation technologies that is actually
driving the need for revising this document in OU #4. If a DNAPL is found
to exist on-site, the Agency has found through experience that it is more
advantageous to remove the DNAPL directly rather than rely on a pump
and treat technology to remove the DNAPL.
4.3 ESTABLISHMENT OF A POINT OF COMPLIANCE WITH ENFORCEABLE
INSTITUTIONAL CONTROLS
COMMENT#4: EPA should establish a point of compliance for remediation of the
contaminated plume that is, at a minimum, at the plume periphery rather
than throughout the plume. That the NCP permits a remedy to incorporate
a point of compliance that is a distance away from the source of
groundwater contamination is not disputed by EPA. This issue was raised
recently in a lawsuit brought by various states against EPA challenging
EPA's use of the NCP in CERCLA. Ohio v. EPA, 39 ERG 2065, US Ct
App, DC (1993). There, the Plaintiff states argued that in the preamble to
the NCP EPA acknowledges that, while ·remediation levels should
generally be attained throughout the contaminated plume, or at and beyond
the edge of the waste management area ... an alternative point of
compliance may also be protective of public health and the environment
under site-specific circumstances." (underlines added) 40 C.F.R.
300.430(f)(5)(iii)(A). EPA did not challenge the states' interpretation of the
NCP in this regard. Rather, EPA's response was that " ... alternatives
must in any case be protective of public health and the environment." Ohio
v. EPA, supra at p. 2080. It is thus clear from the language of the NCP,
and from EPA's interpretation of the NCP in the Ohio case, that it is
permissible to set a point of compliance at the property boundary, the
plume periphery, or any other alternate point so long as it is protective of
public health and the environment.
The NCP threshold criteria-of overall protection of public health and the
environment is met at this site by setting such alternative point of
compliance at the plume periphery, especially when combined with
institutional controls. NSC is certainly agreeable to having a deed
restriction recorded against the site indicating that the plume of
contaminated groundwater is not suitable for drinking and prohibiting such
use in perpetuity. Such deed restriction would run with the land and would
thus legally prevent drinking water wells from being established in or near
the plume. Moreover, NSC is willing to support the adoption by the City of
Salisbury of an ordinance that would also prohibit such use of the
groundwater unless it is demonstrated to meet drinking water standards.
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COMMENT#S
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OU #3 National Starch & Chemical Company
Responsiveness Summary
Such undertakings on the part of NSC could be incorporated into an
enforceable Consent Decree in which NSC would agree to notify EPA and
the State of North Carolina in the event it ever sold the site to a third party.
Stipulated penalties could also be incorporated into the Consent Decree to
ensure the enforceability of such institutional controls.
It is doubtful that a site cleanup level of 5 ppb (and certainly of 1 ppb) for
1,2-dichloroethane ("DCA") throughout the entire plume could ever be met.
Establishing an alternate point of compliance of the plume periphery, along
with the institutional controls mentioned above, or other institutional
controls which NSC would be willing to consider, meets the threshold NCP
requirement of overall protection of the environment and is consistent with
EPA's interpretation of the NCP as articulated most recently in Ohio v.
EPA, supra.
40 CFR 300.430(a)(1 )(iii)(F) states "EPA expects to return usable ground
waters to their beneficial uses wherever practicable, within a timeframe that
is reasonable given the particular circumstances of the site. When
restoration of ground water to beneficial uses is not practicable, EPA
expects to prevent further migration of the plume, prevent exposure to the
contaminated .ground water and evaluate further risk reduction." And in
accordance to Section 5.2.1 of EPA's Guidance on Remedial Actions for
Contaminated Ground Water at Superfund Sites (EPA/540/G-88/003), "The
area of attainment defines the area over which cleanup levels will be
achieved in the ground water. It encompasses the area outside the
boundary of any waste remaining in place and up to the boundary of the
contaminant plume." Furthermore, it states that " .. .if the source is
removed, the entire plume is within the area of attainment. " Based on the
above assertions, the Agency elected that the entire plume be the point of
compliance.
In addition, there is no guarantee that NSCC will sign a Consent Decree
and in the event the Agency issues an Unilateral Administrative Order to
NSCC, the UAO cannot compel NSCC to implement a deed restriction on
the property.
The proposed plan did not discuss a compliance point nor do the agencies
accept the concept of a compliance point for CERCLA, when it is
commonly used under RCRA. However, the agencies have no problem
associating various laws, acts, regulations to determine cleanup standards
(i.e. ARARS). The final rule, 40 CFR 300.430 (f)(S)(iii)(A), provides the
following statement "performance shall be measured at appropriate
locations in the groundwater ... ". The groundwater plume is considered the
waste management area, therefore the point of compliance should be at
the edge of the plume.
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OU #3 National Starch & Chemical Company
Responsiveness Summary
The groundwater plume boundary has been well defined as depicted i[l
figures in the RI/FS documents. The area of groundwater contamination.
is well within the property boundaries, which offers the agency with a large
buffer zone between the compliance point and the nearest receptors. An
integral part of the establishment of compliance points is the
implementation of institutional controls. Institutional controls are required
at this site in order prevent future human exposure to contaminants
remaining within the waste management area (i.e. groundwater plume
upgradient of the compliance points).
The agencies have expressed concern over their inability to enforce
institutional controls. There are many options available to the agencies
such as: deed restrictions, local ordinances, fencing, etc. The enforcement
terms of for these controls can be identified as part of a consentdecree,
administrative order, contract. etc. National Starch should make a
recommendation to the agency.
For the rationale stated in response to Comment #4, the Agency maintains
that the point. of compliance will be throughout the entire plume of
contamination.
4.4 ESTABLISHMENT OF A SITE CLEANUP LEVEL FOR 1,2-DICHLOROETHANE
COMMENT#6: As discussed in the enclosed comments of IT, the site cleanup level for
DCA should be set at 5 ppb (at the point of compliance, as discussed
above) which is the federal primary drinking water standard. Such level
satisfies the NCP criteria of overall protection of public health and the
environment. The State of North Carolina drinking water standard of .38
ppb, while relevant, is not appropriate based on problems with the
accuracy of detecting concentrations of DCA at that level and it is not
applicable to the contaminated groundwater plume here since such
groundwater is not the source of drinking water supplies.
EPA has proposed a level of 1 ppb for Operable Unit Three in recognition
of the problem of accurately detecting DCA at levels of .38 ppb. However,
EPA has previously determined that the practical quantitative limit ("PQL ")
(defined as the lowest level that can be reliably achieved within specified
limits of precision and accuracy) is 5 ppb for all volatile organic compounds
except vinyl chloride. Federal Register, Vol. 52, No. 130, July 6, 1987.
We do not believe there is any basis for establishing a level of 1 ppb for
DCA as an ARAR at this site. To the extent that any level other than the
federal drinking water standard is deemed by EPA to be an ARAR, we
believe such ARAR should be waived and we accordingly request such a
waiver. We do not believe that a level of 1 ppb of DCA can be
demonstrated by EPA to be applicable to the conditions at this site, nor is
it technically achievable since it is below the PQL as determined by EPA.
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COMMENT#7:
RESPONSE:
A -10
to be Addressed
OU #3 National Starch & Chemical Company
Responsiveness Summary
The federal MCL tor 1,2-DCA is 5 ppb. The NCDEHNR groundwater
standard tor 1,2-DCA is 0.38 ppb. IT has presented arguments in the past
against using the state standard based on the impracticability of accurately
measuring the concentration of 1,2-DCA at that leveL Based on this
argument, EPA has now proposed a cleanup standard of 1.0 ppb.
However, this is in conflict with the evaluation that was conducted by the
EPA tor the establishment of the MCL.
For the establishment of MCLs·the EPA assesses a range of factors such
as: the availability and performance of Best Available Technology (BAT),
the cost of these technologies, the availability and reliability of analy1ical
results, and the resulting health risk (for carcinogens 10-4 to 10-6 is the
acceptable range). As part of the assessment for proposing the MCL tor
1,2-DCA, the EPA determined that "the costs associated with the additional
removals, i.e., from 0.005 mg/I to 0.001 mg/I, are not warranted", therefore,
the MCL was established at 5 ppb (Federal Register, Vol. 52, No. 130,
July 6, 1987).
The EPA proposed cleanup standards are established tor drinking water
supplies. National Starch plans to implement deed restrictions and
possibly have the City of Salisbury establish an ordinance so that the
installation of drinking water wells within the plume area will not be allowed.
Based on the arguments presented, we feel that the cleanup level tor
1,2-DCA should be 5 ppb.
to be addressed
4.4 SELECTION OF THE MOST COST EFFECTIVE REMEDIAL ALTERNATIVE
COMMENT#8:
RESPONSE:
For the reasons discussed by IT, we believe that vapor-phase carbon
adsorption should be selected by EPA as the preferred remedial alternative
based on cost-effectiveness.
to be Addressed
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RESPONSE:
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OU #3 National Starch & Chemical Company
Responsiveness Summary
Upon further review of the cost estimates provided in the FS it became
apparent that the O&M costs for vapor-phase carbon adsorption did not
take into account the reduction in groundwater concentrations over time.
Using the results of the contaminant fate and transport model (FS
Appendix D) the depletion rates for 1,2-DCA were estimated. Using the
depletion rates and starting with an assumed average concentration of
55,000 ppb of 1,2-DCA in groundwater, the estimated vapor-phase carbon
usage was calculated. The cost was then estimated based on the total
amount of carbon required for 15 years of treatment. Therefore, the
revised estimate for Alterative GWL3A Lagoon Area Groundwater
(Extraction, Air Stripping, Vapor-Phase Carbon) is $2,612,000 and the
revised estimate for Alterative GWP3A Plant Area Groundwater (Extraction,
Air Stripping, Vapor-Phase Carbon) is $1,814,000. The combined total is
approximately $480,000 less than was reported in the FS cost estimate for
the same Alternatives and is approximately $107,000 less than the
combined total for the same alternatives using fume incineration.
Therefore, we recommend that the agency select vapor-phase carbon
adsorption over fume incineration.
to be Addressed
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OU #3 National Starch & Chemical Company
Responsiveness Summary
~N•p,Ml•-----olN/IJOW•-"'•• --~olP,.-_n ___ .__..,.«,QFF'a,UO(aJ(l}f/lll(DJ•--n.-o1 M-.l ____ not,_ILe/0/_,,,.,._,... ____ ,__, _____ ,. ____ IIOIIDllol,.~ .. •.
ATTACHMENT A
TRANSCRIPT OF PUBLIC MEETING·
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NATIONAL STARCH AND CHEMICAL COMPANY
SUPERFUND SITE
GROUNDWATER REMEDIATION FOR
OPERABLE UNIT NUMBER 3
7:00 P.M.
August 3, 1993
Salisbury, North Carolina
PROPOSED PLAN PUBLIC MEETING
0.::harlottc O.::ourt 3Rcµortrng. Jlnr.
flost ©fficc iBox llli29
<Cliorlott,. 'Xonh <Carolin, 28220
(70--!) 373-03--17
(!:all Jm (SOD) --156-9--!2-l
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Ms. Diane Barrett
Community Relations Coordinator
United States Environmental Protection Agency
Region IV
345 Courtland Street, Northeast
Atlanta, Georgia 30365
Mr. Jon Bornholm
Remedial Project Manager
Superfund Remedial Branch
Mr. Winston Smith
Groundwater Expert
* * * * * * * *
Comments by Ms. Barrett
Comments by Mr. Bornholm
Public comments
* * * * * * * *
Pages
4 - 9
9 -32
32 -33
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This is the proposed plan public meeting for
the National Starch and Chemical Company Superfund Site in
Salisbury, North Carolina, conducted before Shannon s.
McGilberry, Certified Verbatim Reporter and Notary Public,
at the Agricultural Extension Center, 2727 Old Concord Road,
Salisbury, North Carolina, on August 3, 1993, beginning at
7:00 P. M.
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MS. BARRETT: Well,, I want to welcome you tonight.
My name is D{ane Barrett; I'm the Community
Relations Coordinator for the State of North
Carolina for our Superfund sites in this State.
Tonight's meeting is to present to the public the
proposed alternatives for treating groundwater at
this site, at the National Starch and Chemical
Company Superfund Site. I'd like to introduce to
you our other people from Atlanta. Mr. Jon
Bornholm, .Jon please stand. He is the remedial
project manager for this site and then Mr. Winston
Smith; he is our groundwater expert. I hope each
of you have availed yourselves of the literature
out front as you came in as well as signing up.
This literature will give you a lot of information
about what we're talking about tonight, so that
will help y'all make a well informed decision on
what we're doing here. The public comment period
.for this particular proposed plan began on July
the 19th and will end at midnight August· the 17th.
This is also a required meeting by our circle of
law and we have a court reporter here and she will
be taking the transcript from this meeting. So
when it comes to our public comment period, if you
would please .stand and give your name so that she
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can get it for the record, we would appreciate it.
I wanted-to give you just a brief run down of
the community relations ·activities that have
happe .. ad so far at this-site. First.of all, let
me ask how many of you have 0een to one of these
meetings before regarding this particular site and
are familiar with Superfund? Are y'all familiar
with Superfund? Okay.
First of all, at any site after it's first
discovered, and this site was investigated and the
proposed in the national priorities list and then
finalized in October of 1989, _and the national
priorities list made this site eligible to be
funded for remedial design work through our
Superfund money. The Superfund money is a tax
that is levied against chemical and oil producing
companies and the monies there are put in a fund,
and as the Superfund work progresses and we get
into the remedial design and action stages of a
process, the monies are used to conduct the
activities if there are not viable people to pay
for the work.
When we first began, after the site was first
listed on the national priorities list, the agency
conducted interviews here in the community to find
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out what the community concerns were and then we
prepared what we call our --a community relations
plan that addressed the concerns of the
communities and how we would endeavor to keep them
informed. Now, we do that through such things as
fact sheets, news articles, telephone calls, we
have a one-eight-hundred number, for your
convenience, to call us. It is listed in the fact
sheet. We also have set up a repository which
houses all of the documents that have been
developed that give us reports on making our
decisions on how to conduct the remedial design
activities for the site and making a selection of
which alternatives to use. This repository is in
the Rowan County Public Library in downtown
Salisbury.
When we first started our interviews, a
mailing list was also developed at the time, and
then from each meeting ·thereafter, the names of
those who attended have been added to our mailing
list so that we can make sure that those
interested do receive information.
On September the 4th, 1985, the first meeting
was conducted here and that there were about sixty
people, I think, that attended that meeting, and
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that was just the beginning of meetings. At that
time, too, t~e remedial in~estigati6n began and
that identifi_ the nature and extent of the
contamination. This particular meeting covers
groundwater at the site. As part of the remedial
investigation, a risk assessment is conducted and
this evaluates and identifies any risks posed by
specific chemicals. There are six fact sheets out
there in the entrance way covering various
contaminants of concern. The major contaminant of
concern, though, is what we call 1,2-DCA, which is
Dichloroethane. This is a major contaminant of
concern that we're addressing. After remedial
investigation is conducted, that sometimes can
last a year to two ye-rs because extensive
sampling and analytical work is done, and
sometimes we may have to go out a second time to
gather more data if we feel like we have not been
able to get enough at the time. Then the
feasibility study begins. This goes through
various alternatives that can be utilized to treat
the contaminants that are at the site, and this
also supports all of our responses to the
contaminants and the concerns that are listed in
our investigation.
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After the feasibility study has been
completed, we are at the point where we are now,
with the proposed plan fact sheet and our public
meeting. These meetings, or this period, carries
a thirty-day public comment period and if
requested, it can be extended another thirty days.
Once this is completed, when the comment period
ends, a remedy will be selected. That remedy is
selected based on all the documentation that we
have received, plus all public comments that we
get from the public. A record of decision is
recorded and announcing the selection that has
· been made for treatment of the contamination at
the site.
An announcement will appear in an area
newspaper informing the public of the selection as
well as a regular decision fact sheet will be
prepared giving more detail into the alternative
that was selected so that it gives the public a
better understanding of what's going on.
Hopefully tonight, too, through Jon's
explanation of everything that you'll have a good
understanding of what we're proposing, but we've
got some good slides.
This is .the Superfund process. Any time
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throughout that process community relations are
conducted an~ down below is a list of the various
activities that we undertake in keeping our public
informed. There is a technical assistance branch·
that is offered at each Superfund site for the
affected community, and that technical assistance
branch allows the community to organize into a
nonprofit unit and then to contract to have a
consultant come in and help them understand and
decipher all the technical explanations and help
them have a more active part in the decision
making process regarding the site. Right now,
looking at this chart, we are at step five, the
public comment period, and we really request your
comments. This is your site; you live here, we
don't, and we need to know what really affects you
and we would appreciate your comments. I want to
turn the meeting over now to Jon Bornholm who will
go through the alternativei that have been
proposed in the fact sheet. Thank you for your
attention.
MR. BORNHOLM: Thanks, Diane. Just a brief word
about myself. I've been a Remedial Project
Manage·r for the Superfund program since 1984. I
conducted th~ 1988 public meeting here in
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Salisbury on the first operable unit in lieu of my
colleague who was on maternity leave. Hopefully
everybody picked up a handout that looks like
this; it's about twenty pages long. This is
basically all the overheads I'll be going through
tonight. Some of them I'll read through quickly
because you have a copy of them here and you can
look at them more in detail at your own leisure.
But first of all, what I'd like to· do first is
just go through the history of the site just so
that everybody is brought up to date as to where
we're at today.
The first figure that shows is the
approximate location of the site in Salisbury, and
moving into the background of the site. It was
first owned by Proctor Chemical which was then
been acquired by the present owner, National
Starch & Chemical Company, who continue to operate
the plant today. It is an active facility. As
Diane alluded to before, the site was proposed on
the National Priorities List in 1985. It was
reproposed in 1988 and was finalized on the list
in 1989. Sites that score below a hazardous
ranking score of 28.5 are not added to the list,
the National.Priorities List. Everything above
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28.5 is eligible to be placed on the National
Priorities List and the individual scores for the
ranking process basically the surface water
pathway and air pathway at the time of assessment
scored zero and the groundwater pathway was what
scored and resulted in the site being put on the
National Priorities List.
The first operable unit began in 1986 with
the National Starch and Chemical Company signing a
administrative order on consent with the Agency,
basically agreeing to do the work that we
established for them to do and the rest of the
information pertains to the work done as part of
. operable unit number 1. The remedial
investigation looked at the air, the surface
water, the ground water, as well as the soils.
The proposed plan fact sheet was distributed to
the public and we held our public.meeting. Back
then the public comment period was only three
weeks long. Since that time the Superfund law.has
been revised to a four-week period or thirty days
with a potential extension of an additional thirty
days at the request of the public. That record of
decision was signed on September 30th, 1988 for
operable unit one. And I'll --there's another
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figure that's kind of details where all these
operable units are on the site.
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Operable unit two was initiated back in '89.
Basically what the first record of decision did
was it identified the --the information said that
the groundwater and soil was contaminated, but the
Agency wasn't comfortable with the information
with respect to the soils·contaminated, so the
Agency directed the potential responsible parties
to go back and do an additional investigation
which on operable unit two consists of. Again, we
had a proposed plan fact sheet that was issued to
the public. We had our public meeting and then
the record decision was signed in September of
1990. As an operable unit number --as in the
record decision for operable unit one, this record
decision for operable unit two also required
additional work by the potentially responsible
parties and this became operable unit three.
And basically where we're at right now with
regard to operable unit three, the work was
basically started in 1991 with the remedial
investigation being concluded in March of this
year, at least the field work was. The proposed
plan was distributed on July. Tonight is the
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public meeting for that proposed plan and then the
public commen,tary is --it began, as Diane said,
on July 19th.
Operable unit three consists of two areas.
The plant area, which is the_ active facility
itself, which consists of area number 2, which
includes the reactor room, the tank room, the raw
materials bulk storage room, and the warehouse,
and as well as t~e buried terracotta pipe lines
from the reactor room to their treatment lagoons.
And that the second area of investigation as part
of operable unit number 3, were the lagoons
themselves.
I'm going to try to put it all together for
you. This figure --operable unit number 1 deals
with groundwater flowing in this direction. So
down here, which is basically off this figure,
groundwater contaminated this area and is being
dealt with by operable unit number 1. Operable
unit number 2 basically deals with the
contaminated soils in the trench area, and then
operable unit three, which is what we are talking
about tonight, here is area number 2 which is the
actual plant, and here is the lagoons.
Okay. T_he remedial investigation, again,
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looked at soils, groundwater, surface water and
sediment. As far as the soils, basically we tried
to define three things in the remedial
investigation for each environmental media. We
tried to characterize the contamination, what
contaminants are out there and at what
concentration. We tried to define where that
contamination is coming from and then how far has
it migrated from the source. Basically what we
found is that we had fourteen different volatile
organics in the soils, with 1,2-DCA, or 1,2-
Dichloroethane being the main contaminant at the
site. As far as the source, the lagoons were
unlined prior to 1983. After that time they were
excavated and lined with concrete liners, so they
were acting as a source prior to 1983 and then the
terracotta piping or pipelines coming from the
treatment --or the active facility leading to the
treatment lagoons is the other source on the site.
And then as far as the extent, basically what
the data shows is that it has basically stayed
close to where the source evolved. There was some
migration but all contaminants remain on site.
And then try to put it in a figure, these are the
concentrations of 1,2-Dichloroethane in and around
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area number 2, which is right here (indicating on
document), and arranges the concentration range,
the highest concentration was one million six
hundred thousand parts per billion down to non-
detect. And again, these lines out here show the
range of concentrations and then move further away
from the source, the levels of concentration
decrease to non-detect.
And then as far as the lagoon area, again,
this figure is based on concentrations of 1,2-
Dichloroethane. Again, we have a little hot spot
right here, per se, and then as we move away from
that area, the levels decrease again down to non-
detect; and that's soils.
The other --and then when we look at acetone
we tried to put the concentration of acetone on a
figure again. We have the same general area of
location of contamination near the lagoon right
here (indicating on document), as we did with 1,2-
Dichloroethane and basically the same for area
number 2 and this area, and then in this area
where 1,2-Dichloroethane encompassed this whole
area.
As far as groundwater, again, we had .·those
three objectives: one, to characterize what was
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in the groundwater, the types of contaminants and
their concentrations. Number 2, to find out the
source of where that contamination was coming from
and then also to define the extent of
contamination. How far has that contamination
migrated. In the groundwater we found sixteen
different volatile organics. Again, the major
compounds were 1,2-Dichloroethane and acetone. As
you would assume, the source for soils would be
the same source for groundwater and that was the
lagoons prior to being lined and the terracotta
pipeline.
As part of the r~medial investigation we also
tried to define the geology of the soils so we
could determine which way groundwater is flowing,
how quickly it is flowing and what this thing
shows is a cross section of the geology of the
site, (indicating on document) here being the
·northeast tributary, the plant area being
approximately right in this area, and below the
plant we have what is called saprolite, which is
weathered bedrock, basically typicial soils for
this area. Down underneath the bedrock,
underneath the saprolite we have fractured
bedrock, and.then below the fractured bedrock we
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have constant bedrock, which basically there's no
fractures and there"s no groundwater flowing
through that area.
To try to put this all in some type of
meaning and try to define the concentrations and
the extent of contamination. Again, as I
mentioned, the primary contaminant is 1,2-
Dichloroethane, so most of these figures are based
on the concentrations we found at the site of 1,2-
Dichloroethane. Okay. As with the soils, again,
we have basically two hot spots on the site. One
that's near the lagoon area and the second one is
within the area number 2, which is the active
facility. Groundwater is predominantly moving
towards the northeast tributary in this direction
(indicating on document). And this figure
basically shows the concentration of 1,2-
Dichloroethane at the water table.
Okay. This figure, again, is based on
concentrations of 1,2-Dichloroethane in the
groundwater and.the saprolite, which is below the
water table, and again, it's basically showing the
same thing. We have a high concentration of
contaminants in both the lagoon area and the plant
area.
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Then the third figure is the range of
concentratio~ in the bedrock zone, the fractured
bedrock zone. Again concentrations are again --
the higher concentrations are again right in those
areas where the lagoons and the plant are.
The important thing, which I should have
mentioned on all these figures, is that we do have
delineation or a definition of the extent of the
plume, which is ~efined by these dotted lines and
basically the information is showing that the
contaminants in the groundwater are not migrating
off the property. That's an important
·consideration.
Then the last environmental media that was
investigated for this operable unit was the
surface water and sediment in the northeast
tributary. We only found two organics, two
volatile organics there. Again, 1,2-
Dichloroethane and acetone. The source is the
groundwater, the contaminated groundwater, is
discharging into that stream and it extends just
downgradient of the plant area itself. And
basically the next two figures define the extent
of contamination in that stream with the
concentration,s being the numbers in parenthesis,
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with the flow and the stream going this way.
Again, there 'were no detections of these
contaminants upstream of the plant, that's what
the "ND" stands ·for, non-detect. Then as you get
parallel to the plant, you get detection,
concentrations of contaminants. As you move
downstream, again, those concentrations fall off
until you eventually reach non-detect.
During one sampling event at the site,
samples reflected along the entire reach of the
stream down to the property boundary and at that
particular point no detections were --no
contaminants were detected leaving the site.
That's --this map basically is for surface
water and then this figure is for sediment, which
basically follows the same pattern. Upgradient we
have non-detect, just parallel to the site we have
some detections, and then as you move down
gradient, the concentrations decrease until you
reach non-detect.
We tried to lump this all together as to
contaminants detected, the total list of
contaminants detected, is this first table here,
table 1-1. It lists all the organi~s that we've
detected and .. which environmental media they were
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detected in, soil, groundwater, surface water or
sediment. The first numbers basically are the
ranges and then the· numbers in parenthesis are the
frequency of detection. How frequently did they -
-were those contaminants detected. And again,
let me just point out 1,2-Dichloroethane and
acetone were the two primary contaminants at the
site ..
Okay. Using all this information, we go into
a risk.assessment. In order for there to be a
risk, two pieces of the puzzle have to be present.
One, there has to be a pathway. Although you
might have a contaminant here, if you have no
pathway from that source to a population or
something, there cannot be a risk because there's
no exposure. And then the second piece of that
puzzle is the chemical has to have some toxicity
associated with it. If you have a source of
water, water is not toxic, although it is a
pathway, it wouldn't cause risks because water in
itself does not have any toxicity associated with
it.
And not to try to confuse the issue,
basically when we talk about risks, we use.
numbers. We .use --in our --in the EPA we use
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the term ''unacteptable risk," and that is when the
risk is greater than one times ten to the minus
fourth or one of ten thousand people may be
adversely affected by contaminants. And then if
it's a noncarcinogenic chemical we use a hazard
what's called a hazard index and if the hazard
index is greater than one, then that contaminant
in itself poses an unacceptable risk.
Not that I'm going to go through this, but
basically, the important issue here that I want to
point out is one, the site does not pose a current
risk to the public health. There are future
unacceptable risks associated with the site and
these are based on scenarios developed by the
Agency. And there are three scenarios that would
present an unacceptable risk to human health.
First would be if a site was developed as a
·residential area and those folks would build their
own wells and use the groundwater under the site.
That would pose an unacce.ptable risk and these
would be the numbers associated with that risk.
The other --another risk would be a child playing
in surface water, sediment or spring. Then the
third one would be exposure to subsurface soils.
If you're building a foundation, gardening or
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something --the gardening would be --you'd have
to dig real deep though, the soils, that would
pose an unacceptable risk.
But the main point is, that I want to point
out is that there is no current risk posed by the
site based on our information collected to date by
the contaminants present in the soil or the
groundwater. The groundwater does not pose a risk
because there's no pathways to date, meaning that
there are no people using that contaminated
groundwater for probable use, for drinking water.
And as.far as --another part of the risk
assessment is environmental risks. Basically,
what this --the key here is that it's basically
inconclusive to date, because the headwaters of
the northeast creek are just above the property.
There's not much environment for the bionic
organisms to survive in, so they conclusive --it
could not be proven conclusively that the
discharge of 1,2-Dichloroethane into the stream
along with the groundwater is causing an
environmental --an adverse environmental effect.
The next table lists what the Agency has
identified as performance standards or our clean
up goals to b~ obtained by the groundwater
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remediation. There are several changes here, they
are in the handouts, so let me point those out.
One, I believe the State has proposed seven
hundred and I believe that's up for comment right
now and it has not been promulgated. If it's not
promulgated by the time that this record decision
is signed then the clean up goal will be thirty-
five hundred because that is the value that's
promulgated today. Another change, I believe,
there's a typo, is Tetrachloroethane. The State
standaid is point seveh~ I think it says seven in
the handout that you have. Because the
quantitation limits or analytical methods, that
moves up to one, that's the lowest level that we
can detect on parts per billion. And I think this
70 here is also a proposed State clean up goal out
for· public comment and this 70, I think, is
missing and that is already promulgated, that's
already been established as a State clean up goal.
What the law, Superfund Law, requires us to do is
to select the most stringent clean up goals. So
basically what I tried to do, is I tried to list
the· federal clean up goals here, the State clean
up goals here, and whichever is the smallest
number, the most stringent clean up standard is
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the one that's listed in the shaded area and that
will be the o.ne that will be included into the
record decision as the clean up goal or
performance standard. And then the other
difference is the addition of that number, which
again is the proposed State clean up. It's a
rarity when they go up in concentration rather
than going --rather than decreasing.
And then this is the last half of that table.
As you may notice, this table has fewer compounds
than that table 1-1 1 that lists all the
contaminants that were detected. Basically the
reason is that the other contaminants did not pose
a risk. These are the contaminants that were
detected on site that posed an unacceptable risk.
And as far as --as far as the surface water, we
really don't have any' established clean-up goals
that are written into laws. We use what is called
"TBC's," to be considered. They're not
enforceable by any law or any faction, but the
goal. is to achieve a level of two hundred thousand
micrograms per liter in the surface w_ater, and
that should be three thousand, I believe, a little
typo there, with range concentrations from two to
three thousan_d, so we' re just above that goal
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here.
Basicall¥ that's the end result of the
remedial investigation, with all that information.
Using that information we go on to the feasibility
studies. Basically, all the feasibility study is
is a screening process going step-wise, looking at
the.cookbook range of remedial· alternatives or
techniques that we could use at the site and then
through a process of screening that.we narrow that
list down to a shorter list that we take into a
detailed analysis.
So the first step of the process is to
eliminate all those techniques that just won't
work at the site. Then following that we use the
second step which is the screening process and we
use three criterias to evaluate those remaining
technologies to eliminate those that aren't worthy
of passing through the process. And the next
couple of· slides basically just show the cook
this is basically thi cookbook list of all the
technologies that were initially considered and
the shaded areas are those that were rejected; and
then one more page to that entire table. And then
in the right hand column under "Comments" is the
rationale fo~ rejecting the technologies. That's
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the first screening; if the technology just is not
implementable·at the site, it gets thrown out.
The second step of that screening process is
a little. bit more detailed.. Again, we are looking.
at the three criteria, institutional
implementability, effectiveness and cost. And in
this table the ones that are --the blocks that
are encircled in bold are the ones that were kept.
Again, the rationale as to why each of these
alternatives are either kept or rejected is stated
under the criteria.
And then once we get through that screening.
process we develop our remedial alternatives. The
first step is to combine appropriate technologies
into remedial alternatives to address the
contaminants in each of the environmental media
that are of concern. In this instance we are
looking at groundwater and surface water. And
then, again, we use the same three criteria to
look at the remedial alternatives to evaluate
them. And those alternatives that survive, those
remedial alternatives, that survive that screening
then go through a detail evaluation using these
nine criteria. To date, only seven criteria have
been used. The public comment period incorporates
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·these last two, the State acceptance, as well as
the community·acceptance, and that's the primary
reason why we're here tonight. All of these --
the special criteria and the evaluating criteria
have already been done and that was done in part
by the feasibility study efforts. And then the
modifying criteria is basically the result of the
public comment period.
And then to just ~riefly review those
remedial alternatives that basically survived the
process of elimination. This lists the
alternatives that we are required by law to carry
through the whole evaluation process, the no
action alternatives. That gives us a baseline to
evaluate the 6ther alternatives from it.
Basically, what a no action alternative is you
don't do anything with the site. Then let me
point out why there --the "P" stands for the
plant and the ''L'' stands for the lagoon area.
The second alternative we are looking at
long-term monitoring as well as fencing portions
of the northeast tributary where we had elevated
levels of contaminants in the surface water and
sediment.
The third alternative would be long-term
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monitoring, implementing institutional controls,
and then, again, fencing that portion of the
northeast tributary where elevated levels of
contaminants were detected, that were already
outside the fenced area. That's already --the
fence is already in existence.
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Alternative number 4, 4-A, --okay; all the
fours are basically the same. It's extracting
groundwater thro~gh extraction wells, and the only
difference between A and Bis the type of
treatment for the extracted groundwater.
Under A the water will be treated through a
air stripper. I have some pictures of that just
to help you picture what an air stripper is, and
then the contaminated exhaust coming off the air
stripper would be treated through a vapor
incinerator with the treated groundwater being
discharged through the local sewer system.
Then under alternative B, again, we're using
air stripping as our primary treatment. Excuse me
--A is --alternative 4-A deals with air
stripping and using carbon absorption which means
the off gas coming from the air stripper to remove
the contaminants out of that air stream prior to
being discharged to the environment, with the
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groundwater discharging --with the treated
groundwater being discharged to the local sewer
system. Then alternative 4-B uses the fume
incinerator and the activated carbon to treat the
exhaust gas corning from the air stripper.
As far as the surface water, the first
alternative is no action, the second one is long-
term monitoring. Basically, it's our opinion that
by treating the groundwater we will be addressing
the contaminants that are migrating into the
_surface stream along with the contaminated
groundwater, so when we stop the migration of the
contaminated groundwater at that stream, we will
rernediate the· stream as well.
The next page lists what EPA has identified
as our preferred alternatives. Basically it's
long-term monitoring along with institutional
controls along with groundwater extraction using
air stripping as the primary treatment, using fume
incinerators to treat the off gas corning off the
air stripper and then discharging all the treated
groundwater to the local sewer system along with
the rest of the discharge at the existing site
that goes to the Salisbury treatment plant and
then as far as the surface water, just long-term
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monitoring, continue to sample, to provide the
data necessa:r;y. to assure that the stream is being
remediated by the groundwater remediation system.
Then the last page basically lists
conversations between us and the State. We were
uncomfortable with the evaluation that was done
ior the soils part of the site, so we have we
are going to request that the National Starch and
their contractors revisit that, which will result
in a fourth operable unit, which will mean another
public meeting, which will just discuss the soil
remediation aspect of the site, and hopefully that
will occur within. about four months, estimated
time frame.
Just for some pictures of what an air
stripper is, (displaying photographs) these
pictures were taken at another Superfund site
called Chemtronics. It is in Swannanoa, North
Carolina. Basically, this is a picture of the
computer system that runs the whole groundwater
extraction system.
Okay. This basically is the extraction well,
drilled down to the bedrock. It has pressure
sensors in it. It has meters to measure the flow
and this is ~11 fed back into the computer system
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so that the computer can turn the pump on and off
as necessary ..
Okay. This is the house --this. is the
building that was built dn site to house the
treatment system. The blue stack sticking out is
the air stripper.
Okay. The first apparatus that the
groundwater discharges into once it gets pumped
out of the ground is called an equalization tank
and this is a picture of one. Basically, it
allows basically the purpose of it is to have the
main system see a constant flow of of water
flowing through it. Okay. This is the base of
the air stripper. Air is blown into the bottom
and the water is pumped to the top and allowed to
trickle down as the air is flowing up forcing the
volatile organics out with the water.
Okay Following the air stripper is the water,
groundwater, is pumped through these canisters
which contain activated carbon. Basically, it
polishes the water to ensure that all the
contaminants have been removed, and then from this
point it's discharged into the Buncombe County
sewer system. There's one more.· Here we go. And
then this is a picture of what a fume incinerator
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looks like. That's all I have for pictures of
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32
Basically that's the end of my presentation .
Because we have a court reporter and because this
is for the record, if you have any comments or
questions, please state your name and you need
anything else?
(WHEREUPON, the reporter indicated
negatively.)
MR. BORNHOLM: Please state your name before
you make your comment or ask your question. I'll
open it up to you. Do you have any questions or
comments?
MS. BARRETT: Jon must have really informed
you mighty well, to not have any questions.
MR. YOUNG: I'm Wes Young. What's wrong with
the soil that you have to go back to.the operation
MR. BORNHOLM: It's not what's wrong. The
alternatives that were looked at and the
feasibility studies, in our opinion, did not go
far enough and we want them to do a further
evaluation of the remedial alternatives that may
be available to address the soil contamination at
the site.· It's our opinion that sufficient data
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already exists. but basically ours will be a really
an effort of more evaluation of the technologies
available.
MR. YOUNG: Where's the soil now?
MR. BORNHOLM: The soil is --this shows both
areas (indicating on document). This is the
figure that delineates the distribution of acetone
in the soils. There's a hot spot of contamination
in this area whi<:h is near the lag_oon area and
basically in this area at the facility. This area
that's shaded here is the plant itself which is on
a concrete foundation and then the area between
here, over here, and over here is all paved,
driveways. Basically, the contaminated soil is
down under the facility itself.
And then as far as this area is concerned,
the levels of contaminants in the groundwater are
higher than the levels in the soil which basically
indicates that through natural --the process of
natural percolation of rain, snow through the
soil, it's carrying that contaminant to the
groundwater and it's our feeling that with the
groundwater pump and treat system will catch that
contamination as it migrates into the groundwater,
at least for _this area in here. That's the
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initial idea. Any other questions or comments?
MR. BEAR: Does any of the contamination
left the soil yet? Left the property?
34
MR. BORNHOLM: To the best of our knowledge,
no. Could you state your name please for the
record?
MR. BEAR: Odell Bear.
MR. BORNHOLM: To the best of our knowledge,
no. Based on all the information from operable
units one, two and the work done as far as
operable unit three, no contamination has left the
site.
MR. BEAR: Something was in the paper about
it traveling north) is that true?
MR. WINSTON: Its tending to follow the
stream. It's tending to follow the stream in a
northerly direction.
MR. BORNHOLM: Which flows in a northerly
direction.
MR. WINSTON: It hasn't gotten off the site,
off the property.
MR. BORNHOLM: (Indicating on document) This
is the figure for groundwater and saprolite area
and there is a well down here with a concentration
of one --I think •it's one parts per billion,
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35
.which is right at our detection levels, that we
can't detect below that, per se. And then the
paired well with that, which is in bedrock has the
same concentration. Again, that's ri'ght at the
quantitation limits of our current technology for
detecting contaminants, so one day that could be
zero and one day that could be one, depending on
the --how finicky the machines are. So
basically, what that's showing us is that the
contaminants have not left the site via
groundwater, through the groundwater.
MS. BARRETT: Are there any more questions
before we conclude our meeting? Okay. Well, we
thank you very much for your attention and for
corning and the meeting is adjourned.
MR. BORNHOLM: Thank you.
(WHEREUPON, the meeting was concluded at 8:00
p • M. )
* * * * * * * *
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36
STATE OF NORTH CAROLINA
COUNTY OF MECKLENBURG
I, Shannon S. McGilberry, Certified Verbatim
Reporter and Notary Public; do hereby certify that foregoing
public meeting in the referenced matter was taken by me and
transcribed under my supervision and that the foregoing
thirty-six (36) pages constitute a verbatim transcription of
same.
I do further certify that I am not of counsel
for or in the employment of any of the parties to this
action, nor do I have any interest in the result thereof.
IN WITNESS WHEREOF, I have hereunto
subscribed my name, this 16th day of August, 1993.
My Commission Expires:
August 16, 1993
Shannon S. McGilberry
Certified Verbatim Reporter
Notary Public
PLEASE NOTE that un~ess otherwise specifically requested in
writing, the tape for this transcript will be retained for
thirty days from the date of this certificate.