NCD991278953_19950106_National Starch & Chemical Corp._FRBCERCLA LTRA_General Notice Letter OU-3 & OU-4 (And Appendix A)-OCR

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET. N.E.
ATLANTA. GEORGIA 30365
rJAN O 5 1995
NOTICE LETTER FOR
REMEDIAL DESIGN/REMEDIAL ACTION /RD/RA}
URGENT LEGAL MATTER--PROMPT REPLY REQUESTED
CERTIFIED MAIL--RETURN RECEIPT REQUESTED
Alexander M. Samson, Jr., Esquire
Counsel, Regulatory Affairs
National Starch & Chemical Company
10 Finderne Avenue
Bridgewater, New Jersey 08807-0500
SUBJ: National Starch & Chemical Company Site
Operable Units #3 & #4
Salisbury, Rowan County, North Carolina
Dear Mr. Samson:
RECEIVED
OFFICE OF THE SECREJAR'f.
This letter is issued to National Starch & Chemical Company
("National Starch") in connection with the above-referenced Site
and notifies National Starch of its potential liability, as
defined by Section 107(a) of the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA), 42 U.S.C.
§ 9607(a), as amended, regarding Operable Units ("OU") #3 & #4 at
the Site.
The purposes of this letter are as follows: first, to
demand reimbursement of response costs that have been expended at
the Site, including interest thereon; second, to notify National
Starch that a 30-day period of formal negotiations with the
United States Environmental Protection Agency (EPA) automatically
begins upon receipt of this letter, which EPA has deemed to be
seven (7) calendar days from the date of this letter; and third,
to provide general and site-specific information in order to
assist National Starch in the negotiation process, specifically a
draft Consent Decree, a copy of the Record of Decision for OU#3 &
#4, _and a draft Scope of Work ( "SOW") . It is the Agency's intent
to combine the negotiations for both OU#3 & #4 into a single
consent decree and SOW.
EPA has documented the release or threatened release of
hazardous substances, pollutants, or contaminants at the
above-referenced Site. EPA has spent public funds and is
considering spending, additional public funds on actions to
investigate and control such releases or threatened releases at
the Site. Unless EPA reaches an agreement under which a
potentially responsible party (PRP) or parties (PRPs) will
properly perform or finance such actions, EPA may perform these
actions pursuant to Section 104 of CERCLA, 42 u.s.c. § 9604.
Printcci on Recycled Paper
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NOTICE OF POTENTIAL LIABILITY
Potentially responsible parties under CERCLA include: the current owners or operators of the Site; persons who at the ti.me of disposal of hazardous substances owned or operated the Site; persons who by contract, agreement, or otherwise arranged for disposal or treatment, or arranged with a transporter for disposal or treatment of hazardous substances; and persons who accept or accepted any hazardous substance for transport to disposal facilities and selected such facilities. Under CERCLA and other laws, PRPs may be liable for all funds expended by the United States government in responding to any release or threat of release at the Site, including planning, investigation, cleanup and enforcement activities associated with the Site. In addition, PRPs may be required to pay damages for injury to natural resources or for their destruction or loss, together with the cost of assessing such damages.
Based on information received during the investigation of this Site, EPA believes that National Starch as the current owner/operator of the Site and owner/operator of the Site at the time of disposal of hazardous substances at the Site may be a responsible party under Section 107 of CERCLA, 42 U.S.C. § 9607(a). Before the United States Governmen~ undertakes further remedial actions, EPA requests that National Starch voluntarily perform the remedial work.
DECISION NOT TO USE SPECIAL NOTICE
In this instance EPA has decided that it is inappropriate to invoke Section 122(e) special notice procedures. Because·EPA has already negotiated several matters involving the Site with National Starch, use of the 120 day moratorium pursuant to Section 122 ( e) is unnecessary. The decision not to use. the special notice procedures does not preclude you from entering into discussions with EPA regarding your participation in response activities at the Site. This decision simply means th.at EPA will not use the special notice procures to govern any future discussions.
While the special notice procedures will not be invoked at this Site, EPA has determined that a shorter period of negotiation would facilitate settlement between EPA and National Starch. Therefore, pursuant to 42 U.S.C. § 9622(a), a 30-day moratorium on certain EPA response activities at_ the Site will begin seven (7) calendar days from the date of this letter. During this 30-day period, National Starch is invited to submit a good faith offer to EPA to conduct the RD/RA. The contents of an acceptable good faith offer are set forth below. Upon the submission of a good faith offer, formal negotiations between the parties towards a settlement providing for National Starch to
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conduct or finance the RD/RA may begin. The negotiation period will be continued for an additional 30 days if, within the initial 30-day period, a good faith offer is submitted. If a settlement is reached between EPA and National Starch within the 30-day moratorium period, the settlement will be embodied in a Consent Decree for the RD/RA.
If a good faith offer is not received within the initial 30-day notice period, EPA may take appropriate action at the Site. However, EPA reserves the right to take action at any time at the Site in the event that a significant threat requiring EPA's immediate response arises.
A good faith offer is a written proposal which demonstrates National Starch's qualifications and willingness to conduct or finance the RD/RA. A.good faith offer to conduct or finance the RD/RA will. include the following elements:
1. A statement of willingness by National Starch to conduct or finance the RD/RA which is consistent with the draft Consent Decree, Scope of Work, and Records of Decision and which provides a sufficient basis for further negotiations.
2. A paragraph by paragraph response to the draft Consent Decree and Scope of Work.
3. A demonstration of National Starch's technical capability to carry out the RD/RA including the identification of the firm(s) that would be used to conduct the work or a description of the process that will be used to select the firm(s).
4.
5.
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A demonstration of the National Starch's capability and willingness to finance the RD/RA.
A statement of the National Starch's willingness to reimburse EPA for costs incurred in overseeing the PRPs' conduct of the RD/RA.
The name, address and telephone number of the party who will represent National Starch in negotiations.
In addition, the good faith offer should indicate whether National Starch is willing to reimburse EPA for the Agency's past costs as demanded herein.
ADMINISTRATIVE RECORD
Pursuant to Section 113(k) of CERCLA, 42 U.S.C. § 9613(k), EPA has established the administrative record which contains documents that form the basis of EPA's decision on the selection
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of a response action for the Site. This administrative.·record is open to the public for inspection and comment. The administrative record can be viewed at the following location:
Library
U.S. EPA, Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
and
Rowan County Public library
· 201 West Fisher Street
Salisbury, North Carolina 28144
DEMAND FOR PAYMENT
In accordance with CERCLA, EPA has already undertaken certain actions and incurred costs in response to conditions at this Site. The cost to date of the response actions performed at the Site through,EPA funding is approximately $305,386.83. This number does not include any RI/FS oversight costs. This number reflects the effect of the cap on RI/FS oversight agreed to by the parties in the Administrative Order on Consent, dated December 1, 1986. A Summary of Costs is enclosed. Pursuant to Section 107 of CERCLA, 42 U.S.C. § 9607, EPA hereby demands payment of the above-stated amount, together with any and all interest recoverable by law.
As .stated above, EPA anticipates expending additional funds to conduct the RD/RA at this Site. Whether EPA funds the entire RD/RA or simply incurs costs in overseeing the parties conducting these response activities, National Starch is potentially liable for these expenditures plus interest.
PRP RESPONSE AND EPA CONTACT PERSON
National Starch is requested to provide EPA with a letter of intent within 10 calendar days of receipt of this letter. The letter of intent should state whether National Starch is planning to submit a Good Faith offer to perform and finance the RD/RA; and is willing to reimburse EPA for response costs.
National Starch's responding letter of intent should include the appropriate name, address and telephone number for further contact.
If EPA does not receive a timely response, EPA will assume that National Starch does not wish to negotiate a resolution of its liabilities in connection with the response, and that National Starch has declined any involvement in performing these response activities. National Starch may be held liable under Section 107 of CERCLA, 42 U.S.C. § 9607, for the cost of the
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response actions which EPA performs at the Site and for any damages to natural resources.
Your response to this notice letter should be sent to:
Stedman S. Southall
Assistant Regional Counsel
U.S. Environmental Protection Agency
345 Courtland Street, N.E.
Atlanta, Georgia 30365
If you have any legal questions pertaining to this matter, please direct them to Mr. Southall at 404/347-2641, extension [2278]. Please direct any technical questions which you may have to Mr. Jon K. Bornholm, Remedial Project Manager, at 404/347-7791, extension [4106].
Due to the seriousness of the problem at the Site and the legal ramifications of National Starch's failure to respond promptly, EPA strongly encourages you to give this matter your immediate attention and to respond within the time specified above.
Thank you for your cooperation in this matter.
~~'~ Joseph R. Franzmathes
Director
Waste Management Division
Enclosures:
Appendix A -Record of Decision Operable Units #3 and #4
Appendix B -Draft Statement of Work Operable Units #3 and #4
Appendix C -Draft Consent Agreement for Operable Units #3 and #4
Appendix D -Cost Summary
cc: North Carolina Department of Health and Natural Resources U.S. Fish and Wildlife Service
U.S. Department of the Interior U.S. Department of Justice
National Oceanic and Atmospheric Administration
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Appendix A -Record of Decision Operable Unit #3 and #4
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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
OCTOBER 1993
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DECLARATION FOR THE
RECORD OF DECISION
SITE NAME AND LOCATION
National 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 National 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 conditionally concurs 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
tl1rough 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 tl1is portion of
the Site.
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The major components of Operable Unit #3 Remedial Action include:
• 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 volatile organic contaminants 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 publicly owned treatment works system.
• Long-term monitoring of the groundwater and surface water and sediment in the Northeast Tributary.
• Implementation of a deed restriction on the property as an institutional control.
• 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 reviews in accordance to Comprehensive Environmental Response, Compensation, and Liability Act of 1980.
ADDmONAL SAMPLING AND MONITORING
Additional monitoring wells shall be installed 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.
~/Yf78~
Patrick M. Tobin {)~0ms
Date Acting Regional Administrator
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DECISION SUMMARY
RECORD OF DE.CISION
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
OCTOBER 1993
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I TABLE OF CONTENTS
I SECTION PAGE No.
I 1.0 SITE NAME, LOCATION, AND DESCRIPTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 .1 2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
I 4.0 SCOPE AND ROLE OF OPERABLE UNIT WITHIN SITE STRATEGY . . . . . . . . . . . . . . . . . . . . 6
1 5.0 ~~M~Ir~ ~~ ~-I:~ -~~~~~~:r.E.~I~:'.~~ _ : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : ~ 52 GROUNDWATER . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
I 5.2.1 SAPROLITE GROUNDWATER . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 5.2.2 BEDROCK GROUNDWATER . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 5.3 SURFACE WATER AND SEDIMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
I 5.4 HYDROGEOLOGICAL SETTING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34 5.5 PATHWAYS AND ROUTES OF EXPOSURE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35
I 6.0 SUMMARY OF SITE RISKS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 43 6.1 CONTAMINANTS OF CONCERN . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 43 62 EXPOSURE ASSESSMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44
I 6.3 TOXICITY ASSESSMENT ............................... : . . . . . . . . . . . . . . . . 45 6.4 RISK CHARACTERIZATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45 6.5 RISK UNCERTAINTY ......... ·.......................................... 46
I 6.6 ENVIRONMENTAL RISK . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47 6.7 SUMMARY ............................................... ·. . . . . . . . . . . . 61
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7.0 REMEDIAL ACTION OBJECTIVES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61 7.1 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARS) . . . . . . . . 61 7.2 EXTENT OF CONTAMINATION............................................ 62 I 0.0 DESCRIPTION OF ALTERNATIVES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 62 8.1 REMEDIAL ALTERNATIVES TO ADDRESS GROUNDWATER CONTAMINATION....... 62
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8.1.1 ALTERNATIVE GWP1/GWL1: No action ................................ 63 8.1.2 ALTERNATIVE GWP2/GWL2: Long Tenn Monitoring and Fencing
A Portion Of Northeast Tributary ............. , . . . . . . . . . . . . . . . . . . . . . . . . 67 8.1.3 ALTERNATIVE GWP3/GWL3: Institutional Controls, Long Term
Monitoring, and Fencing A Portion Of Northeast Tributary . . . . . . . . . . . . . . . . . . . . 67 8.1.4 ALTERNATIVE GWP4NGWL4A: Groundwater Extraction Through
Wells; Treatment by Air Stripping with Vapor-Phase Carbon Adsorption;
and Discharge to POTW . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 68 8.1.5 ALTERNATIVE GWP4B/GWL4B: Groundwater Extraction Wells,
Treatment by Air Stripping with Fume Incineration; and Discharge to POTW . . . . . . . 68
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TABLE OF CONTENTS
SECTION __ . PAGE No.
82 REMEDIAL ALTERNATIVES TO ADDRESS SURFACE WATER AND SEDIMENT CONTAMINATION ........................................ __ • _ 69 8.2.1 ALTERNATIVE SW/SE-1: No Action ............. -........... -. .. .. . • . . 69 8.2.2 ALTERNATIVE SW/SE-2: Long-Term Monitoring . . . . . . . . . . . . . . . . . . . . . . . . . . 69
. ' 9.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES . . . . . . . . . . . . . . . . . . . . . . . 69 9.1 THRESHOLD CRITERIA . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 69 . 9.1.1 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT....... 70 9.1.2 COMPLIANCE WITH APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 70 9.2 PRIMARY BALANCING CRITERIA . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 71 9.2.1 LONG-TERM EFFECTIVENESS AND PERMANENCE . . . . . . . . . . . . . . . . . . . . . . 71 9.2.2 REDUCTION OF TOXICITY, MOBILITY, OR VOLUME . . . . . . . . . . . . . . . . . . . . . . 72 9.2.3 SHORT-TERM EFFECTIVENESS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 72 9.2.4 IMPLEMENTABILITY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 72 9.2.5 COST . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 72 9.3 MODIFYING CRITERIA . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 78 9.3.1 STATE OF NORTH CAROLINA ACCEPTANCE ....•. ·..................... 78 9.3.2 COMMUNITY ACCEPTANCE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 78
10.0 DESCRIPTION OF THE SELECTED REMEDY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 79 10.1 PERFORMANCE STANDARDS TO BE ATTAINED . . . . . . . . . . . . . . . . . . . . . . . . . . . . 79 10.2 GROUNDWATER REMEDIATION......................................... 80 10.3 NORTHEAST TRIBUTARY SURFACE WATER/SEDIMENT REMEDIATION . . . . . . . . . . 84 , 10.4 MONITOR EXISTING CONDITIONS/ADDITIONAL DATA REQUIREMENTS . . . . . . . . . . 84 10.5 COST . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 85
11.0 STATUTORY DETERMINATION .............................................. 85 I 11.1 PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT . . . . . . . . . . . . . . . . . . . 86 11.2 COMPLIANCE WITH ARARS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 86 11.3 COST-EFFECTIVENESS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 86 I 11.4 UTILIZATION OF PERMANENT SOLUTIONS AND ALTERNATIVE
TREATMENT TECHNOLOGIES OR RESOURCE TECHNOLOGIES
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TO THE MAXIMUM EXTENT PRACTICABLE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 86 11.5 PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT .................. 86
12.0 SIGNIFICANT CHANGES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 87
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APPENDICES
APPENDIX A CONCURRENCE LETTER FROM THE STATE OF NORTH CARO[lNA AND RESPONSE FROM THE AGENCY
APPENDIX B-PROPOSED PLAN FACT SHEET
I APPENDIX C RESPONSIVENESS SUMMARY
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FIGURE 1
FIGURE 2
FIGURE 3
FIGURE 4
FIGURE 5
FIGURE 6
FIGURE 7
FIGURE 8
FIGURE 9
FIGURE 10
FIGURE 11
LIST OF FIGURES
FIGURE TITLE PAGE No.
SITE LOCATION MAP • • • • • • • • • • • • • • • • • • • . . • • • • • • • . • • • • • • • • • • • • • 2
LOCATION OF FACILITIES THAT COMPRISE OPERABLE UNIT #3 . . • • . . . . . • • . • 3
DISTRIBUTION OF 1,2-DCA IN THE WATER TABLE ZONE OF THE AQUIFER • • • • 14
DISTRIBUTION OF 1,2-DCA IN THE SAPROLITE ZONE OF THE AQUIFER . • • • • • 15
SAMPLING LOCATIONS FOR GROUNDWATER (WATER TABLE) VIA
WELLPOINTS AND CONCENTRATIONS OF 1,2-DICHLOROETHANE
DETECTED AT EACH WELLPOINT • • • • • • . • • • • • . . • • • • . . • • • . • • . . • . . • . 22
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
CONCENTRATIONS AND ESTIMATED EXTENT OF 1,2-DICHLOROETHANE
CONTAMINATION IN THE BEDROCK ZONE OF THE AQUIFER • • . • • . • • • . • • . . • 26
SURFACE WATER SAMPLING LOCATIONS AND CONCENTRATIONS
OF 1,2-DICHLOROETHANE FROM LAST SAMPLING EFFORT ON
THE NORTHEAST TRIBUTARY . • • • • . . . • • • . • . • . • • • . . . • . • • • . • . . • • . . • 32 SEDIMENT SAMPLING LOCATIONS AND CONCENTRATIONS OF
1 ,2-DICHLOROETHANE FROM LAST SAMPLING EFFORT ON
THE NORTHEAST TRIBUTARY • . • • • • • • . . • • • • . • • • . • • • . • • • . • • • . • . • • • 33
ORIENTATION OF HYDROGEOLOGICAL CROSS-SECTIONAL A-A' . . . . . . . . . . . . . 37
HYDROGEOLOGICAL CROSS-SECTION A-A' . . . . . . . . . . . . . . . . . . . . . . . . . . . 38
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LIST OF TABLES
TABLE TITLE
TABLE 1 RANGE AND FREQUENCY OF DETECTION OF ORGANIC
CONTAMINANTS AND INORGANIC CONSTITUENTS FOUND IN THE
PAGE No.
ENVIRONMENTAL MEDIA SAMPLED . . . • • . . . . . . • . . . . . . . . . . . . . . . . . . . . . . 9
TABLE 2 FREQUENCY OF DETECTION ANO CONCENTRATIONS OF
ORGANIC CONTAMINANTS DETECTED IN GROUNDWATER
SAMPLES COLLECTED FROM WELLPOINTS (WATER TABLE)
AND PERMANENT MONITORING WELLS NS-13 AND NS-14 ................. 16 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 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
TABLE 4 FREQUENCY OF DETECTION, CONTAMINANTS DETECTED, ANO
MOST STRINGENT PROMULGATED STANDARDS FOR CONTAMINANTS
DETECTED IN THE SAPROO::iTE ZONE OF THE AQUIFER . . . . . . . . . . . . . . . . . . • . 24
TABLE 5 FREQUENCY OF DETECTION, CONCENTRATIONS DETECTED, AND
·MOST STRINGENT PROMULGATED GROUNDWATER STANDARDS FOR
CONTAMINANTS DETECTED IN THE BEDROCK ZONE OF THE AQUIFER . . . . . . . . . 27 TABLE 6 SUMMARY OF DETECTABLE CONCENTRATIONS OF 1,2-DICHLOROETHANE
IN SURFACE WATER, SEDIMENT, AND SOIL SAMPLING OF THE NORTHEAST
TRIBUTARY . . . . . . . . . . . . . . . . . . . . . • . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29
TABLE 7 CONCENTRATIONS OF ORGANICS AND INORGANIC$ IN SURFACE
WATER AND SEDIMENT FROM. LOCATIONS SW/SE-12 ANO SW/SE-13 ........ 31
TABLE 8 LIST OF CHEMICALS OF CONCERN IN THE GROUNDWATER POSING
RISK AND THE ASSOCIATED UPPER CONFIDENCE LIMITS (95%)
EXPOSURE POINT CONCENTRATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39 TABLE 9 POTENTIAL CURRENT AND FUTURE EXPOSURE PATHWAYS OF HUMAN
EXPOSURE TO CONTAMINANTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40 TABLE 10 PARAMETERS USED TO DESCRIBE EXPOSURES TO SITE-RELATED
CHEMICALS OF CONCERN . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 48
TABLE 13 SUMMARY OF CANCER RISK ANO NONCANCER HI VALUE .................. 60
TABLE 14 REMEDIAL ACTION OBJECTIVES AND ASSOCIATED GENERAL RESPONSE
ACTIONS ................................................... 64 TABLE 15 SECONDARY SCREENING OF TECHNOLOGIES AND PROCESS OPTIONS
FOR GROUNDWATER . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 65 TABLE 16 SUMMARY OF THE THRESHOLD CRITERIA EVALUATION FOR THE
ALTERNATIVES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 73 TABLE 17 APPLICABLE OR RELEVANT ANO APPROPRIATE REQUIREMENTS . . . . . 74 TABLE 18 SUMMARY OF PRIMARY BALANCING CRITERIA EVALUATION OF THE
ALTERNATIVES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 76 TABLE 19 PERFORMANCE STANDARDS AND CORRESPONDING RISKS FOR OU #3 . . . . . . . . . 81
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AOC
ARAR
AWQC
CAA
CERCLA
cm/sec
CD
CAP
CSF
CWA
1,2-DCA
ESD
EPA
FS
GAC
gpm
HI
HQ
HRS
LDRs
MCLs
MCLGs
mg/kg
mph
MW
NCAC
NCDEHNR
NCGS
NCP
ND
NOAA
NPDES
NPL
NSC
NSCC
O&M
OU
POTW
ppb
ppm
PQL
PAP
PW
RA
RCRA
LIST OF ACRONYMS
Administrative Order on Consent
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 (Supertund)
centimeters per second.
Consent Decree
Community Relations Plan
Cancer Slope Factor
Clean Water Act
1,2-Dichloroethane
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
Not Detected
National Oceanic and Atmospheric Administration
National Pollution Discharge Elimination System
National Priority List
National Starch & Chemical Company
National Starch & Chemical Company
Operation and Maintenance
Operable Unit
Publicly Owned Treatment Works
parts per billion
parts per million
Practical Quantitative Limit
Potentially Responsible Party
Present Worth
Remedial Action
Resource Conservation and Recovery Act
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I RID
RD
RI
I RME
ROD
SARA
I SDWA
SVOCs
TAL
I TBC
TCL
TCLP
I TMV
µg/kg
µg/1
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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
Target Analyte List
To Be Considered
Target Compound List
Toxicity Characteristic Leaching Procedure
Toxicity, Mobility, or Volume
micrograms per kilogram
micrograms per liter
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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BRIOC
70
KANIW'LOIS
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DAVIDSON ~ COUNTY --
\
COUNTY
CABARRUS COUNTY 7
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SCALE: ---0 8 16 MILES
FIGURE 1
LOCATION OF THE NATIONAL STARCH &
CHEMICAL COMPANY SUPERFUND SITE ·
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500 0 500 1000 ~-250 750
GRAPHIC SCALE: ! '=50W
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FIGURE 2
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LOCATION OF FEATURES ASSOCIATED
WITH OPERABLE UNIT #3
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NAOOIW. STARC!i & CHEMIC/I. ColPNtf SLmlRHJ SITE
REcooo Of Deasloll Rlll 0PicRABLE UlfT 13
rinse solutions. This wastewater may include a combination of the following chemicals:
acrylimide, 1,2-dlchloroethane (·1,2-DCA), methyl isobutyl ketone, methanol, styrene, malelc
anhydride, vinyl toluene, suiphonated polystyrene, epichlorohydrin, octyl alcohol, ethyl alcohol,
ally! alcohol, ally! 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 (RI/FS) Work Plan was expanded .. The first RI/FS resulted in OU
#1 ROD which was issued by the Environmental Protection Agency (EPA or 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 beirig 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 scores: 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 letter 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 in 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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NAOOIW. STARCH & CHEMICAL C<:AIPN<f 5'J>ERAH) SITE
AEalRD Of Dease,, RlR ClPE1'ABI.E UIIT 13
Consequently, the OU #2 ROD divided the Site into a third operable unit. Following the signing 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 #2ROD. 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 NSCC to conduct a third RI/FS to determine the source, nature, and extent of contamination entering the Northeast Tributary as required by OU #2 ROD. 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 in Salisbury. A mailing list was developed based upon people interviewed, citizens living around the Site, and people attending Site related 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 for 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 for 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.
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NAOOHAL STARC>< & CIEM""-C<M>Ntt 5uPeRRHl SITE
REcoRo OF llEalQ R>1 ClPERA&.E UlfT 13
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 alternatives reviewed and the remedial 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 Observer newspapers 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 Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (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. These are:
OU #1 --Groundwater in western portion of the NSCC property
OU #2 --Trench Area soils and surface water/sediments in the Northeast Tributary
OU #3 --Groundwater under Area 2, the parking lot, and the wastewater treatment lagoons and the surface water/sediments in the Northeast Tributary
OU #4 --Contaminated soils in and around Area 2 and the wastewater treatment lagoons.
This 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, 1988, 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 was initiated on July 20, 1992, the filing date for the CD. OU #2 ROD specified no action for the soils in the Trench Area, long-tenn monitoring of the soils in the Trench Area, and an investigation to determine the source of contamination being detected in the Northeast Tributary.
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NAmtw. STARC>! & C!EMICAI. Cai>N<Y 5u>ERAJlll SITE
ReooA0 Of OeasK>i RlR ClPeRAa£ UIIT 13
The third OU, the subject of this ROD, addresses the contaminated groundwater emanating from Area 2 and treatment lagoon area. The potential use of this contaminated groundwater as potable water results in an unacceptable future risk to human health as EPA's acceptable risk range is exceeded and concentrations are greater than maximum contaminant levels (Me Ls) as established by the Safe Drinking Water Act. The purpose of this response is to prevent current or future exposure to the contaminated groundwater. OU #3 is the third of four operable units contemplated for this Site.
5.0 SUMMARY OF SITE CHARACTERISTICS
The NSCe OU #3 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 with the acceptance of the vertical extent of contamination in the bedrock zone of the aquifer. The OU #3 RI Report included a Baseline Risk Assessment. The Baseline Risk Assessment defined the risk posed by the hazardous contaminants 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) alternatives for groundwater remediation and the two (2) remedial alternatives for addressing the contamination detected in the surface water/sediment of 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, surface water and sediment of the Northeast Tributary, and the chemical/physical and geoiogicai/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 Remedial investigations conducted at the NSCC facility identified voes 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 VOCs, semi-volatile organic compounds (SVOCs), pesticides, and polychlorinated biphenyls (PCBs); the TAL includes inorganics such as metals and cyanide.
voes, SVOCs, one pesticide, and numerous inorganic analytes were detected in the soils and groundwater and two voes and a number of metals were detected in the surface water/sediment samples.
Background/control samples 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.
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NA raw. ST"'°' l C!EMIC.II. Coil}Nt1 ScffRF\HJ SITE
AE<mo <F Deasok FOO Ol>ERABI.E UlfT 13
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-hexachiorocyctohexane (delta-BHC). It was detected once in the soil and once in the groundwater at very tow concentrations. Pesticides have never been manufactured at1his facility. Cyanide was detected twice in the soil and twice in the groundwater at very tow 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 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 PAP also runs routine air sampling in the active portions of 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 (0 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 were detected. As can be seen in Table 1, the VOCs most frequently detected and observed in the highest concentrations were 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 (SE-12) 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 nortti-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 which 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
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NAllOIW. ST_.,.,. l CHEll1C,11_ Cowl'ANY SU>slRH> SilE
RE<XlAD OF 0eoooN FOO 0PeRAeu: UIIT 13
TABLE 1 RANGE AND FREQUENCY OF DETECTION OF ORGANIC CoNTAMINANTS AND
INORGANIC CONSTITUENTS FOUND IN THE ENVIRONMENTAL MEDIA SAMPLED
COMPOUND SOIL GROUNDWATER SURFACE ~J=DIMENT
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
Trichloroethene 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-
NAraw. STARCH l Clel!CH. ca,,,N« 5uPelR.lll SITE
AEcoRo Of llEasloN RlR OPaw!t£ UIIT 13
TABLE 1 RANGE AND FREQUENCY OF DETECTION OF ORGANIC CONTAMINANTS AND
INORGANIC CONSTITUENTS FOUND IN THE ENVIRONMENTAL MEDIA SAMPLED
COMPOUND SOIL GROUNDWATER SURFACE ~EDIMENT
WATER
Antimony 5,100-8,2000 (5) 2-30 (3) 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) 1-3 (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~,410,000 (4) 10.3-11.4 (2) 23.9-48.5 (2)
Concentrations for water samples are reported in micrograms per ltter (µgn} or in parts per billion (ppb).
Concentrations for soiVsediment samples are reported in micrograms per kilogram (µgfr\g) or in parts per billion (ppb).
Number appearing in parentheses is the frequency of detection.
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-11-
NA110HAL STARCH l C!EMCI<. CCMl'N« &.mlrucl Srre
REcoRO OF DEaslcJ< RlR O!'eiw!t.E UlfT 13
benns arid 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 abandonmenVgrouting of the underground terra-cotta pipes will be completed in December 1993.
In the lagoon area, the source of contamination was eliminated in 1984 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 the 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 saproiite and bedrock zones of the aquifer have also been adversely Impacted by activities at the Site. Contaminants detected in the groundwater include VOCs, SVOCs, one pesticide, metals, and cyanide.. The· pesticide, deita-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 zone of the aquifer.
A total of 61 groundwater samples were collected from 52 different locations. Ali of the groundwater samples were analyzed for VOCs. Only groundwater samples collected from pennanent monitoring wells were analyzed for the full analytical analyses. To summarize the analytical results, a total of 16 different voes, three (3) SVOCs, one (1) pesticide, 14 metals, and cyanide were 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, chlorofonn, 1,2-dichloroethane, 1, 1-dichloroethene, 1,2-dichloroethene (cis-and trans-), 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
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NAIOW. STAID! & ClellCAL CoilJN<t Sl.mruCl SITE
Ra:0Ro Of ~ FOR ClPEAAsLE UNT 13
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.
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 to address this data gap will be collected during the RD.
5.2.1 SAPROLITE GROUNDWATER
Figures 3 and 4 show the distribution of 1,2-DeA 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. Figure 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 most stringent promulgated groundwater standard, the frequency of detection, and the concentrations of contaminants detected in the permanent wells installed to monitor groundwater quality in the saprolite zone of the aquifer. The highest concentration and the greatest variety of voes were found in monitoring well NS-42. voes detected in NS-42 include acetone (310 µg/1), 2-butanone (240 µg/1), 1,2-oeA (82,000 µg/1), methylene chloride (160 µg/1), 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 flushed 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/1), beryllium (2.5 µg/1), chromium (63.6 µg/1). cobalt (66.4 µg/1), copper (487 µg/1). manganese (1,500 µg/1), nickel (39.6 µg/1), vanadium (272 µg/1) and zinc (220 µg/1).
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5.2.2 BEDROCK GROUNDWATER
NA 1101W. STAAC!i l C!olCH. C<lll'IHt SlJl'Effuc) 5nE
RecoRo Of 0easoN RlA ClPERAaE UICT 13
Figure 7 shows the distribution of 1,2-DeA in the bedrock zone of the aquifer. This figure also shows the locations of the permanent bedrock monitoring wells and. the corresponding concentrations of 1,2-DeA detected in each well. Table 5 lists the most stringent pfomulgated groundwater standards, the frequency of detection, and the concentrations of contaminants detected in each bedrock well. 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 (32119/1), 1,2-DeA (99,000 µg/1), 1, 1-dichloroethene (5 µg/1), methylene chloride (66 µg/1), tetrachloroethene (7 µg/I), 1, 1,2-trichloroethane (6119/1), total xylenes (11 µg/1), and vinyl chloride (120 119/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/1), cobalt (93.6 µg/1), and manganese (12,000 119/1).
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 voes. In addition to being analyzed for voes, two of the samples (SW/SE-12 and SWiSE-13) were also analyzed for svoes and metals. Sampling location SW/SE-12 is the upgradienl/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-DeA, 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 al 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-DeA 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-DeA 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-DeA for the last samples collected at these sampling locations. The highest concentration of 1,2-DeA detected in the surface water was 3,200 µg/1 in May 1992 at sampling location SW-13 and the highest concentration of 1,2-oeA detected in the sediment was 7,400 µg/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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Nll50 -
N 550 -
N250 -
ABANDONED RAILROAD SPUR.------.: 6
.'/ ND
6 ND
ND c:,ND
_6
LEGEND
ND GFOJNIMA TER SCREENING POM 6 $HO'MNG 1,2-0CA CQNCEN'TRATIC)N '-I ..
----_ 1.2-0CACONCENTRATlON
10000_/· CONTOUR
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NOTE: Confirmation data
aupP1e,r•1ted by groundwater
acreening data
APPROXIMATE SCALE (ft)
I o 100 200 300 .cxi 500
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'-~ -. --lo
E 250
CHAIN LINK FENCE-----'\
c:,ND
FIGURE 3
13 a:
(/)
(.') z a: c.. (/)
a: ~ LU /u
I I
CONCENTRATIONS AND ESTIMATED
EXTENT OF 1,2-DICHLOROETHANE
CONTAMINATION IN THE GROUNDWATER
AT THE WATER TABLE
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1050 -
750
,so
150
-◄50
. 750 I
-650
• NS-37
(1JJ
ABANDONED RAILROAD SPUR _____ __
I
-350 .50
\ ..
, , , ,
'
NS-33
• (ND) .
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550 I
!
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"---I ~✓
II
LEGEND
• NS-13
(1700)
1 .2-0CA C0NCENTRA TlON
c.<lNTOUR IPP0i
"'
1,2-0CA CONCEN'l"FV,, TIQN
(pp<,), GAOIJNOWA'TER
5AMPl£S
SCAl£(11) .. ---
FIGURE 4
CONCENTRATIONS AND
ESTIMATED EXTENT OF
1,2·01CHLOROETHANE
CONTAMINATION IN THE
SAPROLITE ZONE OF
THE AQUIFER
---------.. ---lllllnoJIILaiWl!lteoilllPwR -REco!lo OF DECISION FOR OPEIW!I.E UNrr 13
-16-
TABLE 2 FREQUENCY OF DETECTION AND CONCENTRATIONS OF ORGANIC CONTAMINANTS DETECTED IN
GROUNDWATER SAMPLES COLLECTED FROM WELLPOINT$ {WATER TABLE) AND PERMANENT MONITORING
WELLS NS-13 AND NS-14
(Samples were only analyzed for VOCs)
FREQUENCY TWP-1A TWP-2
COMPOUND OF (Background)
DETECTION
VOLATILE ORGANIC COMPOUNDS
Acetone 10/15
Carbon Disulfide 3/15 SU 5U
Chloroethane 3/15 10 U 10 U
1,2-Dichloroethane 7/15 10 UJ SU
1, 1-Dichloroethene 1/15 SU SU
1,2-Dichloroethene 2/15 SU SU
1.2-Dichloropropane 1/15 SU SU
Methylene Chloride 3/15 10 U SU
Tetrachloroethene 2/15 SU SU
Toluene 3/15 SU SU
1, 1,2-Trichloroethane 2/15 SU SU
T ricllloroethene 2/15 SU SU
Vinyl Chloride 4/15 10 U 10 U
TWP-3 TWP-4
SU SU
SU SU
SU SU
SU, SU
SU 5 U
5 U SU
10 U 10 U
TWP-5
SU
SU
SU
SU
SU
SU
SU
SU
10 U
TWP-6 TWP-7 TWP-8
SU SU SU
SU SU 10 UJ
SU SU SU
SU SU SU
SU SU SU
SU SU SU
-------------lllnOHA1.-•C-Co11Pft~-W -REcoRD Of DECISION FOR OPERABLE llNrT 13
-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
lWP-9 lWP-10
VOLATILE ORGANIC COMPOUNDS
Acetone 10/15 10 U
Carbon Disulfide 3/15 SU
Chloroethane 3/15
1,2-Dichloroethane 7/15
1, 1-Dichloroethene 1/15
1,2-Dichloroethene 2115
1,2-Dichloropropane 1/15
Methylene Chloride 3115 10 U
Tetrachloroethene 2115 SU
Toluene 3/15 SU
1, 1,2-Trichloroethane 2115
T richloroethene 2115
Vinyl Chloride 4/15
Samples were collec1ed in May 1992.
Concentrations are in micrograms per liter (µg/1) or parts per billion (ppb).
Shaded area Ci ) depicts positive detections.
D -Sample analyzed at secondary dilution.
J -Concentration is estimated.
U -Undetected at the indicated quantitation limlt.
W -Undetected; the associated quantltation limlt is an estimated value.
10 U
SU
10 U
SU
lWP-11
10 U
lWP-12 lWP-13 NS-13 NS-14
10 U
SU 5 UJ SU
10 U 10 U 10 UJ 10 U
10 UJ SU
SU SU 5 UJ SU
SU SU S UJ SU
SU SU 5 UJ SU
10 U 10 U SU 5 UJ
SU SU 5 UJ SU
SU SU 5 UJ SU
SU 5U 5 UJ SU
SU 5 UJ SU
10 U 10 U 10 UJ 10 U
--------------~noild!!.:::1~co~ REco!m Of DECISION FOR Oi'ERAet£ lJifr 13
-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)
COMPOUND
SAMPLING DATE
DEPTH TO WATER
TABLE (feet)
FREQUENCY GW-1"
OF DETECTION .
11/20/92
8
GW-1A GW-1B GW-2"
NA 12/4/92 11 /20/92
NA 8 17.8
GW-3 GW-S" GW-5A GW-6
11/21/92 11/21/92 11/23/92 11/19/92
9.8 6.45 15 6
VOLATILE ORGANIC CoMPOUNDS
Acetone
Carbon Disu~ide
Chloroethane
Chloroform
1,2-Dichloroethane
1, 1-Dichloroethene
1,2-Dlchloroethene
Ethylbenzene
Methylene Chloride
Tetrachloroethene
Toluene
4/33 25,000 U 10 U 10 UJ 250 U 10 U 10,000 UJ
1/33 12,000U SU SU 120U SU 5,000 U
2/33 25,000 U 10 U 10 U 250 U 10 U 10,000 U 10 U 10 U
5,000 U SU SU
SU
1/33 5 U 120 U 5 U 5,000 U 5 U 12,000 U SU SU
1/33 5 U 120 U 5 U 5,000 U 5 U 12,000 U SU SU
2/33 5 U 120 U 5 U 5,000 U 5 U 12,000 U SU
3/33 s u if~ffti~Z~it\\i~l s u Jtlif!Bltli s u 12,000 U SU SU
12,000 U SU 2/33 5 U 120 U 5 U 5,000 U 5 U SU
12,000 U SU SU
GW-6RE
12/16/92
6
10 U
SU
SU
SU
SU
SU
SU
SU
12,000 U SU +---+--s_u_-+-_1_2_o_u_+_s~u-+_s.:.,o..:.o.:.o_u_+_..:.s.:.u_-PW .. 1f&~¾\ffl"'i~"': ... ~f ... ~~""'f'--I
5 U 120 U SU S,000 U 5 U ,i SU SU 12,000 U SU
Trichloroethane 12,000 U SU 1 /33 5 U 120 U 5 U 5,000 U S U SU SU
Vinyl Chloride 25,000 U 10 U 2/33 10 U 250 U 10,000 U 10 U 10 U 10 U 10 U
---------------~~-~-Recooo Of DECISOI FOR ClPERAiu UtlT '3
-19-
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 forVOCs) (continued)
COMPOUND GW-7 GW-7A GW-8 GW-8D GW-88 GW-11A" GW-118 GW-12 GV,·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)
VOLATILE ORGANIC CoMPOUNDS
Acetone 10 UJ 10 UJ 10 R 10 R 10 UJ S,000 UJ 10 R 10 UJ 10 R
Carbon Disuttide SU SU SU SU SU 2,500 UJ SU SU SU
Chloroethane 10 U 10 U 10 U . 10 U 5,000 UJ 10 U 10 U 10 U
Chloroform SU SU SU SU SU 2,SOO U SU SU SU
1,2-Dichloroethane Jf~1~:~t!J§:~;i:Qij})1 ~:!!~~::'.~:~fA!it!'.;!:;~:: SU SU 11111~11\I SU IJllllJJt■ SU
1, 1-Dichloroethene SU SU SU SU 2,SOO U 2,SOO U SU SU
1,2-Dlchloroethene SU SU SU SU 2,SOO U SU SU SU
Elhylbenzene SU SU SU SU SU 2,SOO U SU SU SU
Methylene Chlortde SU SU SU SU SU !il!i\lblla'II :❖,.::=:<;:.·.;', . .;, .. ,, •... -.. •:~:,·};!.: > • SU SU SU
Tetrachloroethene SU SU SU SU SU 2,SOO U SU SU SU
Toluene ~ SU SU SU 2,SOO U SU SU SU
Total Xylenes SU SU SU 2,SOO U SU SU SU u
1, 1,2-Trichloroethane SU SU SU SU SU 2,SOO U SU . I~ SU SU
Trichloroethane SU SU SU SU SU 2,SOO U SU SU SU
Vinyl Chloride 10 U 10 U 10 U 10 U 10 U S,000 U 10 U 10 U 10 U
---- -.. --- - - - ---NA-~-~ AEcoRo Of DECISION FOO Oi'BIAal£ llNrr 13
-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)
COMPOUND
SAMPLING DATE
DEPTH TO WATER TABLE (feet)
I VOLATILE ORGANIC CoMPOUNDS
/ Acetone
GW-13
11/20/92
4.5
10 UJ
GW-14 GW-15
11/21/92 12/17/92
4.5 3
10 U 180 UJ
GW-16A GW-17 GW-18 GW-18A
12/2/92 12/1/92 11/23/92 12/18/92
10 4 7.5 7
10 R 10 R
GW-19
NA
NA
: Carbon DisuHide 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 17U s u
1,2-Dichloroethane SU SU SU SU 17 U !i1iit~ll1a1 .
1, 1-Dichloroethene SU SU SU SU SU SU 17 U s u
1,2-Dichloroethene SU SU ·5 U SU SU SU 17 u 5 u
Ethylbenzene SU SU SU SU SU SU 17U s u
Methylene Chloride SU SU 11 U SU SU SU 17 u 5 u
Tetrachloroethene SU SU SU SU SU 17 u 5 u
Toluene SU SU SU SU SU SU 17 U s u
Total Xylenes SU SU SU SU SU SU 17 U s u
1, 1,2-Trichloroethane SU SU SU SU 17 U s u
Trichloro9thene SU SU SU SU SU SU .i 17 U s u
Vinyl Chloride 10 U 10 U 10 U 10 U 10 U 33 u 10 u
---------------NAnlft~-~ REco!m Of DECISION FOIi ClP£RAel£ lJNT 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)
COMPOUND 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 11/24192
DEPTH TO WATER TABLE (feet) 7 16 11.5 14 19 5.44 5.2
VOLATILE ORGANIC CoMP0UNDS
Acetone 10 U 10 U 20 U 21 u 14 U 12 UJ
Carbon Disuttide SU SU SU SU SU SU SU
Chloroethane 10 U 10 U 10 U 10 U 10 U 10 UJ -10 UJ
Chloroform SU SU SU SU SU SU 5 UJ
1,2-Dichloroethane SU SU SU SU SU t.iitiiti~~i-5 UJ
1, 1-Dichloroethene SU SU SU SU SU SU S UJ
1,2-Dichioroethene SU SU SU SU SU SU SU
Ethylbenzene SU SU SU SU SU SU 5 UJ
Methylene Chloride SU SU SU 16 U 15 U SU S UJ
Tetrachloroethene SU SU SU SU SU SU 5 UJ
Toluene SU SU SU SU SU SU S UJ
Total Xylones SU SU SU SU SU SU 5 UJ
1, 1,2-Trichloroethane SU SU SU SU SU !f!818l■I S UJ
Trichloroethene SU SU SU SU itiii1if.~tr~IJ:i:tt:lii SU SU
Vinyl Chloride 10 U 10 U 10 U 10 U 10 U 11{u 10 UJ
oncantrations are in micrograms per ltter (µg/1) or parts per billion (ppb). Shaded area Ci#) depicts positive detections.
-Detection limtts for voes are elevated; prescreening of sample indicated matrix effects required medium or high level analysis.
, · Concentration reported from secondary dilution. J -Concentration Is estimated. NA -Not Available R -Unusable results.
:E -Resampled. U -Undetected at the indicated quantitation limtt. UJ -Undetected; the associated quantitation limtt us an estimated value.
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N&50 -
N550 -
N 250
-350 -
ABANDONED
RAILROAD SPUR
l"IWP-13I (2400J)
: :---------~---'
'' '' '' : :
''
: :
'' '' '' ''
" '' '' '' '' : :
"
AREA2 ti) "IWP-10
(790J)
"IWP-8
lii(4800J)
• (3200) ··--
"IWP-7@ ~
PARl()NG LOT -(430) ~"IWP-6
' ' (ND) . "IWP-s@
NS-13 (ND) "IWP-4
(ND)
1 "IWP-2@ @ "IWP-3
(ND) (ND)
APPAOXJMA TE SCALE (ft)
' 1 00 200 300 -400 "'
LEGEND
@ "IWP-8
(4800J)
TEMPORARY WEU. POINT
ANO 1.2-0CA
CONCENTRATION (ppb)
LAGOON c:](900) ~\
L .. _so __ c::;----c.'=,===--::.::, =~ ,
E .J50 ~ / E 250
■ NS-14
(ND)
MONITORING WELL
LOCATlON mo 1,2--0CA
CONCENTRA TON {ppb) E 5
FIGURE 5
SAMPLING LOCATIONS FOR
GROUNDWATER {WATER TABLE)
VIA WELLPOINTS AND
CONCENTRATIONS OF
1,2-DICHLOROETHANE DETECTED
AT EACH WELLPOINT
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N 550 -
N 250 -
N-350 -
ABANDONED RAILROAD SPUR.-------
'' ''
; ', ----· -----' '
GW-27
(ND) c.
GW-4A::
(ND) 4':
GW-88 c,
(ND)
GW-18A
(ND) 6GW-18 6 (ND)
c:. GW-18A
(ND)
GW--16-
(420)
.··-·········· GW·S GW-15
(98000) 6 (16000)
;GW-4 6
:(3400) '. c:. GW-14 : :
............. : , ......... (N_D)····
GW-12A GW-12 : GW.J
GW-25 GW-118 (ND)c. G~~::)·6······;,rJ:: 6 G~ci,3 (ND) (ND) 6 (3800),:, (SlOO) --~~"'"-GW-18 GW-11A 6 ~ /" I NS-13
GW-26 □ ['7) Gw-1_f c. I (1300) (4J) 6
(660000) I / 6 GW•22 \ " (ND) GW-1 A ~--N~14 ~~
(4J) GW-246 GW-236
(ND) (ND) FIGURE 6
LEGEND
c. GRClUNOWATcR SCREE>,WQ GW-16 POINT ""1l< 1.2-0CA
(420) CONCENTRATM:lN [WI-)
NOTE: Conftnnatlon data
Wpp6en'16& Ibid by grounctwate, ~"""'
AP!'AOXJMA TE SCALE (II)
0 100 200 3iOO «IQ 500
~ er
(/)
(!) z cc a.
(/)
er ~ w u
E-350 E-
4
CHAIN LINK FENCE __/
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
---------------~~-~ ~ Of DECIS!lff FOR ClPelWU lJtlT 13
-24-
TABLE 4 FREQUENCY OF DETECTION, CONTAMINANTS DETECTED, AND MOST STRINGENT PROMULGATED
STANDARDS FOR CONTAMINANTS DETECTED IN THE SAPROLITE 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 (cisArans)
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
14 U 12 UJ
SU 5 UJ
10 U 10 UJ
10 UJ 10 UJ
5 U 5 UJ
SU 5 UJ
5U 5 UJ
SU 5 UJ
5U 5 UJ
SU SUJ
5 UJ
10 U 10 UJ
10 U 10 U
o.os u I o.os u
NS-33
(Baci<Qraund)
10 U
SU
NS-35
10 U
SU
10U 10U 10U
SU SU
5U
5U
SU SU SU
SU 5U SU
SU SU SU
SU
5U
10 U 10U 10U
10 U 10 U 10 U
0.05 U 0.05 U
· NS-39
10 U 800 UJ 10 U
SU
SU
SU 400 UJ SU
6U 5U
SU 400 UJ SU
5U SU
SU 400 UJ SU
400 UJ SU
800 UJ 10 U
1 a u ~l.Biiffi■ 1 o u
0.05 U
--------m ------NAn~l!!lbu-su-Jdfu,e REcoRo OF DECISION FOR CiPERAaLE U!aT 13
-25-
TABLE 4 FREQUENCY OF DETECTION, CONTAMINANTS DETECTED, AND MOST STRINGENT PROMULGATED
STANDARDS FOR CONTAMINANTS DETECTED IN THE SAPROLITE ZONE OF THE AQUIFER
COMPOUND
INORGANICS
Arsenic
Barium
Beryllium
Chromium
Cobalt
Cyanide
Lead
Manganese
Nickel
Vanadium
Zinc
PROMULGATED
GROUNDWATER
STANDARDS
50
200
4
50
154
. 15"
50
100
5,000
FREQUENCY
OF DETECTION
1/8
8/8
2/8
6/8
2/8
2/8
1/8
8/8
3/8
7/8
2/8
NS-13'
2U
20 U
2U
Concentrations are In micrograms per liter (µg/1) or parts per billion (ppb).
NS-14'
2 UJ
20 U
10 U
NS-33
(Backgn,und)
2U
1 U
10 U
20 U
NA
2U
NS-35 NS-37'
2U 2U
Rl,~J;~~~~f.J]~~i lli)~f~i~i'-:
i!~Jfff47JU%mJ t.f ~~~f:16&141f.f~i
NA 10 U
2 UJ 4.1 U
Shaded area C ) depicts positive detections.
• -Detection ifrnits for voes 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 quantitatlon limit Is an estimated value.
NS-39
1 U
10 U
20 U
NS-42'
20 U
NS-43'
2U
20 U
2U 2U 2U
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750 -
-750 I
-o5()
• NS-24
• NS-38
(1 J)
(Not Sampled)
ABANDONED
RAILROAD SPUR
I
-350 -50
-

-

-

-
s
250
I
-:::.···_________ LEGEND ...,..===-==--------1
'
• NS-44
(ND)
NS-34 e (ND)
550
f-,
Ns!is
(11000)
1 .2-0CA CONCENTRA TlON
<:ONTOUA~J
1 .2-DCA CONCENTRATION
(ppb), GAOUNO-NATER
SAMPLES
APPAOlOMATE SCAl£ (fl)
a
c3 a:
Cl)
(!) z ci: Cl.
Cl)
a: <( a LlJ (.)
FIGURE 7
CONCENTRATIONS AND
ESTIMATED EXTENT OF
1 ,2-DICHLOROETHANE
CONTAMINATION IN THE
BEDROCK ZONE OF THE
AQUIFER
---------------NA,i~Jllbi.cllill§ill,~~ AEcoRo OF DECISION F0!1 ClPERAIII.E UNIT 13
-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-Dichloroethene
Methylene Chloride
Tetrachloroethene
Toluene
Total Xylenes
1, 1,2-T richloroethane
T richloroethene
Vinyl Chloride
PROMULGATED
GROUNDWATER
STANDARDS
0.19
0.38
7
s
s
1,000
400
s
2.8
0.015
SElll•VOLATILE ORGANIC COMPOUNDS
Bis(2-ethylhexyl)phthalate 6
Di-n-butyl Phthalate
Di-n-octyl Phthalate
FREQUENCY N5-34 N5-36
OF
DETECTION (Background)
216
3/6
1/6
4/6
1/6
216
1/6
1/6
216
216
216
216
1/6
1/6
1/6
10U
SU
SU
SU SU
SU SU
SU SU
SU SU
s u · tt\1111,1
1 o u l:~r!!;~/~~11~
10 U 10 U
10 U 10 U
10 U 10 U
N5-38'
SU
SU
SU
10 U
10 U
10U
10 U
NS-40 N5-41 N5-44'
10 U 1,200 UD 10 U
10 U
65 U 1,200 UD SU
SU
.
SU
SU
SU
SU
1,200 UD SU
tTli!ltJllll 1,200 UD SU
SU
10 U
!lll~lllJ-· _1,_20_0 u_o-+--llllllllf.l 2,500 UD
10 u ~11111lll 10 u
10 U 10 U
10 U 10 U
---·-----------

-
NATI-AACH~cal!MJX& .. ~ OF OEaSION FOR 0PERA81£ lJHrT 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
(NORGANICS
Barium
Chromium
Cobalt
Copper
Lead
Manganese
Vanadium
Zinc
PROMULGATED
GROUNDWATER
STANDARDS
200
50
1,000
1S'
50
5,000
FREQUENCY NS-34
. OF
DETECTION (Background)
5/6
3/6
1/6
2/6
1/6
6/6
4/6
2/6
10 U
2U
NS-36 NS-38'
10 U
Concentrations are in micrograms per liter (µg/I) or parts per billion (ppb).
Shaded area (I ) depicts positive detections. ·
• -Detection ffmits for voes 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
2U 2U
14 U 130 U
N5-44'
2U
33 U
---------------NATI~~eoB.w,JliL AEcoRo Of DECISION FOR ClPER.181£. lJ!lrr 13
-29-
TABLE 6 SUMMARY OF DETECTABLE CONCENTRATIONS OF 1,2-DICHLOROETHANE IN SURFACE
WATER, SEDIMENT, ANO 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 1,400118' -------------
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 -----350176 1601980 77!23 150 J/9 J ----
SW/SE-10 ----1,200114 1,600/ND 8101310 1,300 J/610 D ----
SW/SE-11 ----ND/ND ND/ND ND/ND ND/ND -- --
SW-12A -------------ND -· I
(Background)
SW/SE-12 ------NS/ND NS/ND 2 J/ND --ND/ND
(Background)
SW/SE-13 -------88013,400 1,80017,400 3,200 D/290 --200 J/1,200 D
SW/SE-14 -------1, 70011,200 1,20014,200 590 D/1, 000 D -· -·
SW/SE-15 ------ND/ND ND/ND ----
SWISE-16 ----------1,300 DJ/61 l --!t -
S0-01 -------ND -· ---· -
S0-02 -------ND -· -----
---------------~Tio:!!311..::.&lllti.eo~edllllln,
-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
S0-03 -------ND --
S0-04 -------ND --
SO-05 ------650 --
S0-06 ------57 --
S0-07 -------ND --
oncentration for surface water samples are in micrograms per liter (µg/1) or parts per billion (ppb)
oncentration for sediment samples are in micrograms per kilogram (µg/kg) or parts per billion (ppb)
SW/SE: surface water/sediment; NS-W/S: water/sediment (EPA samples); SO: soil
FiEcoRo OF DECISION FOO 0PERA8l£ lJNrr 13
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
-Concentration reported from secondary dilution
-Concentration Is estimated
.D -Analyzed for but not detected
S -Not sampled (no water available) .
-Undetected at the indicated quantitation limit
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NAT<lHAI. STMC!i & C!el&ll ColPNtt 5'.FERRH> SITE
REcooc Of Oro.llol< Fa! OPaW!lE UIIT 13
TABLE 7 CONCENTRATIONS OF ORGANICS AND INORGANICS IN SURFACE WATER AND SEDIMENT FROM LOCATIONS SW/SE-12 AND SW/SE-13
COMPOUND/ANAL YTE SW-12 SW-13 SE-12 S--!=-13 (Background) (Background)
ORGANICS
Acetone
1 ,2-Dichloroethane
INORGANIC$
Antimony 30 U 30 U 4.9 UJ
Arsenic 2U 2U
Barium
Beryllium
Chromium
Cobalt
Copper
Lead
Manganese
Mercury 0.2 U 0.2 U
Nickel 20 U 20 U
Selenium 2U 2U
Thallium 2 UJ 2U
Vanadium
Zinc
Samples collected in January 1993.
Shaded area (} ) depicts pcsttive detections. · · Concentration for surface water samples are in micrograms per ltter (µg/I) or parts per billion (ppb) Concentration for sediment samples are in micrograms per kilogram (µg/kg) or parts per billion (ppb) SW · Surface Water Sample
SE -Sediment Sample
D -Concentration repcrted from secondary dilu1ion. 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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N550 -
N250 -
·350 -
-650
ABANDONED
RAILROAD SPUR
: ;·-----------------, ,------
t
I
''
'' '' '' '' '' ':
'' '' '' '' ·-----· '-------
SW-12
(2J)
CHAIN LINK FENCE----------..._
AREA2
SW-10
(1300J)
E 250
APf'ROXJMA,E SC>J..E (IQ
' ,oo 200 )00 C10 "'
LEGEND
ASW-14
(590)
SURFACE WATER
LOCATION mo 1,2-0CA
CONCENTRATION =1
■ NS-14
(ND)
FIGURE 8
M()/l,IITORIM3 'n'ELL
LOCATION AND 1.2-0C.A
CONCENTR>-T10N =1
SURFACE WATER SAMPLING
LOCATIONS ALONG THE
NORTHEAST TRIBUTARY AND
ASSOCIATED CONCENTRATIONS
OF 1,2-DICHLOR0ETHANE
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N 250 -
ABANDONED
RAILROAD SPUR.------
.. . . .. . .
'. . ·-----· , ______ :
AREA2
. . ·--------------· N-..SO. -~ -

-

-
---

-
-------

-

-

-

-

-

-

.

-

-

-

-

-
------

-

-

.

-
.-, .::.-.-:: _-,
-350 -
-650
LAGOON
1
E ·350
,_ ----------'
1~G~
SE-12
(ND)
CHAIN UNK FENCE-----<--
SE-09
(9.J)
E 250
SE-10
(610)
SE-16
(61)
SE-13
. (~\19!.. ....
APP'AOXlM.A TE SCALE (ft)
LEGEND
.& SE-13
(290)
STPEAM SEDIMENT SAMPLE LOCA TlON ANO 1.2-0CA
CONCEN1AA1'0N =1
FIGURE 9
SEDIMENT SAMPLING LOCATIONS
ALONG THE NORTHEAST TRIBUTARY
AND ASSOCIATED CONCENTRATIONS
OF 1,2-DICHLOROETHANE
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NArow. STAAC!< & CHBIICM. ca,,,Nrf 5lffoRHl SITE
REcoAo CF 0Easot RlR CiPElwl£ UIIT 113
Surface water and sediment samples were collected on three occasions from the Northeast Tributary just prior to its leaving the NSCC property. 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 olthe plant prior to the stream leaving the 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 toxicity tests as part of the environmental assessment of this stream. The results of the environmental exposure assessment are discussed in Section 6.6.
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 15A-2B.02) 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 designat_ed 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 15-2L.02). 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 1 O 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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NA110NAL ST,.,.,. & CteilCM. CO,,,Ntf Sl.ffRRJNl 5fTE
REcoAo Of llEa9oH Fa! OPawl..E UlfT 13
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 genUy to the north.
Rock core records show that the upper 1 O to 15 feet of bedrock Is deeply weathered and frlable.
Bedrock begins to appear nonfriable and fresh 15 to 25 feet below the bedrock/saprollte-,lnterface.
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 Tribu1ary 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 (fl/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 area 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 concern for groundwater are listed in the Table 8. This list includes voes, a SVOC, and metals. Contaminants were included in Table 8 if the results of the risk assessment indicated that the contaminant might pose a significant current or future risk or contribute to a risk which is significant. The criteria for including contaminants in this table was a carcinogenic risk level within or above the acceptable range (i.e., 1 E-4 to 1 E-6) or a hazard quotient greater than 0.1. Contaminants were also included if they exceeded either State or Federal applicable or relevant and appropriate requirements. 1,2-DCA is the only the chemical of concern detected in the surface water.
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)
An exposure route (i.e., ingestion, inhalation, or dermal contact) .
A pathway is considered complete when all of the above elements are present.
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NA T10NAI. SrAAai & C!EMICAI. COIIPAHY Sll'E!IA.Ml SITE
Rf<XlROOF DeoS0N AJROPewl£ UPfT '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 may be 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 VOCs were detected in surface soil; and
3) Each of the voes 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
mi crag ram per kilogram ( µg/kg)
3,500
25
2
15
4
Potential current and future human exposure pathways 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.
-------------------
N 1300 -
EX-01
NS-21A
ANS-26
N0.00-c:1 ljl-03 NS-27
J, A
N AEX-04
0 0 '% ........
/8 " 'b ~ co
N-700
) I
E -3200 E-2200
PLANT EAST (h)
E-1200
NS-15
A
" "
N ,, ,,
' ---,, ' --,, I -,, ,,
-" :: :: 'b :: :: ,, ,, ,, ,, ,, ,,
SCAIE!lll
0 IIIIIJIIOtllll-lOII
LEGEND
"' '" •••••••••• ::·· ·,·. ••✓-·::::!,;.::,~
■ lOCATIONS WHEAE N:R.tSAl
SBA2-2 """"'-'""""
CHAIN LINK FENCE
NS-14
'
.... _
...,,_.,.m
'MffllEAEF\.ISALW...S,if.ACHEO
M~fl.£VATUN
0 """""" ;:::
FIGURE 10
ORIENTATION AND LOCATION OF
HYDROGEOLOGIC CROSS SECTION
SHOWN IN FIGURE 7 "
- - - - -------· - - - - - - - -
I
f
..... ..... 1 f Ns.17 HO<» l .....
I I
.....
I ,.,. .. 000
J
....
I j i--o,.
/~~:-
700 I
eoo
500
400 ;,L--..L_-L_L~;..-L__L_J_--';;,ooo~~:'.___L-L...-?--__L_---L'.__,~
2000
~L_L--L7"'~LLL_L~::__,(_LL_L~~~LL-L]
A ""...,.,....
LEOENO A'
FIGURE 11
HYDROGEOLOGIC CROSS SECTION A-A'
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NATlONAL STAAC>i l C!eliC.11. Coil>Nl't' 5uPERRJMl SITE
REooRo CF llrosrJN Fa! Ol>£wa.E UIIT 13
TABLE 8 LIST OF CHEMICALS OF CONCERN IN THE GROUNDWATER POSING RISK AND THE ASSOCIATED UPPER CONFIDENCE LIMITS (95%) EXPOSURE
POINT CONCENTRATION
CONTAMINANTS OF CONCERN
IN THE GROUNDWATER
Acetone
· Bis 2-Chloroeth I ether
Chloroform
1,2-Dichloroethane
-1 1-Dichloroethene
1,2-Dichloroethene cis and trans
1 2-Dichloro ro ane
Meth lene Chloride
Tetrachloroethene
11,2-Trichloroethane
Trichloroethane
Vinyl Chloride
EXPOSURE POINT CONCENTRATION
FOR CONTAMINANTS DETECTED IN
GROUNDWATER (mg/I)
NA
0.04
0.00522
0.431
0.0071
NA
NA
0.00603
0.00478
0.00478
0.00446
0.011
IseMFYOLA°tit~;o~ctANld'Icd~eotiNbS[! \:11111: ! llll;~,;!lfill !II !lrL . "' . . .. . .:f<;M ================"II
Bis(2-Ethylhexyl)phthalate
Antimon 0.0185
Arsenic 0.00194
Barium 0.257
Be Ilium 0.000667
Cadmium 0.00311
Chromium 0.0414
Man anese 2.73
Thallium 0.00104
Vanadium 0.0759
Zinc 1.34
NA -Chemical was not carried through the risk assessment but is listed as a contaminant of concern because it exceeds either State and/or Federal groundwater standards in some monitoring wells.
liii ---

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lalnotW.llli & c-eo.ia.ERFtJIIII -AEcoRo OF DECISION FOR 0PEiwu IJNrr 13
-40-
I TABLE 9 POTENTIAL CURRENT AND FUTURE EXPOSURE PATHWAYS OF HUMAN EXPOSURE To CONTAMINANTS
RECEPTOR
CHILDREN
ADULTS
CHILDREN
MIGRATION/EXPOSURE
PATHWAY
Incidental ingestion of surface soils
Dermal contact with surface soils
Incidental ingestion of subsurface soils
Denmal contact with subsurface soils
Migration of contaminants from soil to protridwater, creek, and springs. Exposure via incidental ingestion. drinking waler ifl\lestion, dermal contact al stream and home, inhalation ol voes at stream and home.
Incidental ingestion of surface soils
Denmal contact with surface sons
Incidental ingestion of subsurface soils
Dermal contact with subsurface soils
Mi9ration of contaminants from Site to springs; incidental ingestion of spring water
INCLUDED IN RISK
ASSESSMENT?
Yes Yes
Yes Yes
No Yes
No Yes
No Yes
No Yes
No Yes
No Yes
No Yes
Yes Yes
REASON FOR INCLUSION/EXCLUSION
Surface soil is currently available for contact by on-sile race tors
Surface soil is currently available for contact by on-site race tors
Subsurface soil is currenlly unavailable for contact. Future development could expose subsurface soil for future recepJors. Children may ingest significantly more soil than adults.
Future development could expose subsurface soil for Mure rece Jors
Contaminant may migrate from soil to groundwater
Surface soil Is currently available for contact by on-site race tors
Surface soil is currently available for contact by on-site race ors
. Subsurface son Is curre~ unavaBable for contact. Future development co expose subsurface soil for future recs tors.
Subsurface son Is currently unavailable for contact. Future development could expose subsurface soil for future recs tors. "
Site-related contaminants are present In lhe creek as a · · result of groundwater discharfl8. Site-related chemicals area afso likely to be present 1n the springs near the creek.
=:; rm iiii iiiii ----. -----llll!IL.i.m.c"'!&fu.,,~• -AEcoRo OF DECISION FOR ClPERAB1£ lJHrr 13
. -41-
TABLE 9 POTENTIAL CURRENT AND FUTURE EXPOSURE PATHWAYS OF HUMAN EXPOSURE To CONTAMINANTS
INCLUDED IN RISK
MIGRATION/EXPOSURE ASSESSMENT? REASON FOR RECEPTOR PATHWAY CURRENT FUTURE INCLUSION/EXCLUSION
LAND USE LAND USE
Migration of contaminants from Site to springs; Yes Yes Site-related contaminants are present In the creek as a dennal contact with spring water result of groundwater discharge. Site-related chemicals
area also likely to be present ,n the springs near the creek.
Use of groundwater as domestic water source: No Yes Future development could result in a production wen In inqestion of drinkinQ water this area· .
Use of groundwater as domestic water source: No Yes Future development could result in a production wen In dennal contact with water this area
Use of groundwater as domestic water source: No Yes Future development could result in a production well in inhalation of VOCs from household water use this area ·
ADULT Migration of contaminants from Site to springs; No No Adults are not expected to play in springs incidental ingestion of and dennal contact with sprinq water
Use of groundwater as domestic water source: No Yes Future development could result In a production wen in inqestion of drinking water this area
Use of groundwater as domestic water source: No Yes Future development could result in a production wen in dennal contact with water this area
Use of groundwater as domestic water source: No Yes Future development could result In a production wen In inhalation of voes from household water use this area ·
CHILDREN Migration of contaminants from Site to creek; Yes Yes Site-related contaminants are present In creek water and incidental ingestion of creek sediment sediment Children fivlng In residential area nearby may lll:lv In the creek
Migration of contaminants from Site to creek; Yes Yes Stte-related contaminants are present l~k water and iJ1C1dental ingestion of surface water sediment Children fivlng In residential nearby may
ooiv In the creek
Migration of contaminants from Site to creek; Yes Yes Stte-related contaminants are present In creek water and dennal contact with sediment sediment Children living In residential area nearby may
play In the creek
liiiii liiii
-- -
---- - - - --- ---1111111 --m'l10NIJ. & ~ ...... coll?~
f'EooRD Of DECISION FOR 01'£RASIE I.INrr 13
-42-
TABLE 9 POTENTIAL CURRENT AND FUTURE EXPOSURE PATHWAYS OF HUMAN EXPOSURE TO CONTAMINANTS
INCLUDED IN RISK
MIGRATION/EXPOSURE ASSESSMENT? REASON FOR RECEPTOR PATHWAY CURRENT FUTURE INCLUSION/EXCLUSION
LAND USE LAND USE
Migration of contaminants from Site to creek; Yes Yes Site-related contaminants are present in creek water and dermal contact with surface water sediment Children living in residential area nearby may
olav in the creek
Migration of contaminants from Site to creek; Yes Yes Detected chemicals may volablize into air inhalation of contaminants partitioning to air from
surface water
ADULTS All pathways identified above No No Adults are not expected to swim or play in the creek
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NAOONAL STARCH l ClellCAI. COIFAHY 9-Jlll SITE
. RECORD ~ DeasloN RlR ClPeRAaE UloT 13
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• 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 under 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 onslte 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 environment 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 risks posed by Site soils will be summarized in OU #4.
6.1 CONTAMINANTS OF CONCERN
Table a provides a comprehensive list of all the contaminants identified as chemicals of concern in the groundwater at the Site. The contaminants and concentrations of these contaminants detected in the groundwater are the major contributors to the significant risk for this Operable Unit. The following sections will concentrate on the risks posed by contaminants listed in Table 8.
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
NATXlNAI. SWICII & C!eoc.11. <:.wN« SlFBRJN> SITE
REroR0 OF 0easooN RlA °"6w!LE U"' '3
The objective of the exposure assessment is to 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 characterizlf 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: . I
• 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.
Table 8 provides the reasonable maximum exposure concentrations which were used in calculating the carcinogenic and noncarcinogenic risks associated with each chemical of concern In the groundwater.
The surface water and sediment pathways were evaluated for a current and future trespasser (age 7-16 years) and a future child resident (age 1-12 years) for incidental ingestion, dermal absorption and inhalation exposure to chemicals of potential concern in these media The exposure frequency and duration for the trespasser scenario were 143 days per year and 1 O years, and 286 days per year and 12 years for the resident scenario. The body weight was 45 kilograms for the trespasser and 22.5 kilograms for the. resident. The exposure duration was the same for exposure to spring water; the frequency of exposure was 71 days per year for the trespasser and 143 days per year for the child resident.
As stated previously, the contaminants and concentrations of these contaminants detected in the groundwater are the major contributors to the significant risk for this Operable Unit and the only chemical of concern in the surface water is 1,2-DCA. Although, the impacted groundwater Is not currently being used as a drinking water source, the aquifer itself is being used as a source of
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NATIOHAL STARCH l CleilCAL ColFAll'I' &.mlRN> Srre
REcxlRO Of llEasloo RI! ClPeRAel£ UNT 13
drinklng water; therefore, this resource should be maintained at drinklng water quality. Table 10 lists the specific parameters used to model the site-specific groundwater Intakes for OU #3. The .exposure point concentrations for surface water outside the plant operations area and Inside the plant operations area in the Northeast Tributary are 1.04 milligrams per liter (mg/I) and 1.26 mg/I.
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. RiDs, 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. RiDs 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,Os 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 11.
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.
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
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NATDW. STARCH l Cleir.ti Coil>ANY SU>eRA.ol) SITE
RaXlAO Of lleasoN Rlll CiPswu UNT 13
contaminant concentration iri 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 (Hlj 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 cilld future) Identified at the Site are listed In Table 12.
The HQ Is calculated as follows:
Non-cancer HQ= CDI/R,D, where:
COi = Chronic Daily Intake
R,D = reference dose; and
COi 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. Table 12 provides the computed chemical intakes values along with the calculated risks. Excess life-time cancer risk is calculated from the following equation:
Risk= COi x SF, where:
Risk = a unit less probability (e.g., 2 x 10->) of an individual developing cancer;
COi = chronic daily intake averaged oyer 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 1 o"" 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 at 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. Where the cumulative carcinogenic site risk to an individual is less than 1 E-4 and the noncarcinogenic HQ is less than 1, a RA is generally not warranted. If an RA is initiated at a Superfund 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 13. The cumulative future risk and hazard index posed by the groundwater at the Site is 2 x 10·3 and 60 tor a child, respectively. The only chemical that exceeded EPA's risk range in surface water and spring water was 1,2-DCA.
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. Other major
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NATlO!W. STARCH & C!elJC.11. Cola>-5<JPERRH> Sm;
AEcoRo OF DeaOON RlR 0PeRAelE UIIT '3
uncertainties of the NSCC OU #3 human health baseline risk assessment are: uncertainties associated with predicting future land use, uncertainties associated with estimating chemical concentrations at receptor locations, uncertainties with the toxicity assessment, and uncertainties associated with assumptions used in the exposure models. Use of upperbound estimates tends to overestimate exposure and the effect of more than one upperbound parameter tends to produce an conservative estimate. The assumption that future exposure concentrations will be equal to current concentrations Increases uncertainty because environmental concentrations appear to vary over time. And the assumption that residences will be constructed on the plant operations area under the future land-use scenario also adds to the uncertainty.
Models used to predict exposure concentrations have inherit uncertainties associated with them. These uncertainties are associated with predicting the movement of the contaminants and the receptors as well as the assumptions made (e.g., skin surface area, soil adherence factors, and absorption coefficients for soil and water).
6.6 ENVIRONMENTAL RISK
The ecological risk assessment for OU #3 evaluated risks to the aquatic and benthic (bottom-dwelling) organisms in the Northeast Tributary. These organisms can be exposed to site-related contaminants i_n surface water and/or sediment. The main ecological contaminant of concern in this tributary is 1,2-DCA. To determine if there were any effects of 1,2-DCA on the benthic communities inhabiting the Northeast Tributary, a Rapid Bioassessment Protocol was used to conduct an ecological field assessment during Phase I of the RI for-OU #3. Results indicated that tributary segments with historically elevated 1,2-DCA levels (adjacent to the plant operations area) were devoid of sensitive macrobenthic species and exhibited generally lower taxa richness and abundance than the reference station. However, the benthic assemblages were not dominated •by taxa known to be tolerant of chemical stress. This portion of the Northeast Tributary is located near the stream's headwater area .. In view of the naturally-limiting factors associated with a headwater stream of this type, ecological impacts resulting from the presence of 1,2-DCA in the Northeast Tributary could not be determined.
During Phase II of the OU #3 RI, chronic toxicity tests were performed on surface water and sediment samples to further examine the ecological impairments noted during the field assessment. Surface water tests were conducted using fathead minnows and water fleas, while amphipods and water fleas were used for whole sediment tests. The measurement endpoints (survival, growth, or reproduction) did not differ significantly between site samples (containing elevated levels of 1,2-DCA) and reference or laboratory samples (containing little or no 1,2-DCA). These test results initially suggested that ecological impairments observed in the Northeast Tributary resulted from natural stresses rather than the presence of 1,2-DCA or other chemical contaminants. However, chemical analysis of surface water samples collected at the same time and locations as those for the toxicity tests indicated that the level of 1 ,2-DCA in the sample collected adjacent to the Site (200 ug/I, estimated value) had decreased below historic levels for that area (800-3200 ug/I) and was below the screening level (2000 ug/1) thought to be potentially toxic to aquatic organisms.
__ liiiiil _______________ _ ----,.,.TIONAL""""Sf"'ARCH & ~ Coll?AH'I 5uPERRJNo SITE
TAB°LE 10
Pathway/
Parameter"
Age
IR
Fl
EF
ED
BW
AT-Noncancer
AT-Cancer
REcoRo Of DECISION FOR O!>ERl&f i.lHrr 13
-48-
PARAMETERS USED To DESCRIBE EXPOSURES To SITE-RELATED CHEMICALS OF CONCERN
Current Land Use
Current Conditions
Outside Plant Operations
Area
Future Conditions
Inside Plant Operations
Area
Future Land Use
(Resident)
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, 1991 b)
See text
90% upperbound of time lived in one place
(EPA, 1991b)
Standard default for adult exposure (EPA,
1991b)
365 x ED
365 x 70 yr lifetime
,}
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---------------~~-~ REcooo Of OECISKJH FOR ClfERAl!lE UNIT 13
-49-
.
TABLE 10 PARAMETERS USED To DESCRIBE EXPOSURES To SITE-RELATED CHEMICALS OF CONCERN
Pathway/
Parameter"
Current Land Use
Current Conditions
Outside Plant Operations
Area
Future Conditions
Inside Plant Operations
Area
i ~trili .<lhti~t wlfti titiiliwmtllI
ON
Age
SA
CF
PC
ET
EF
ED
BW
AT-Noncancer
AT-Cancer
Future Land Use
(Resident)
Reasonable Maximum
Exposure
UCL or maximum
concentration in groundwater
0-30 years
21,500 cm2
0.001 Ucm3
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
iiil --· -----------~n~&il!!l!!keo~IIIIIL
TABLE 10
Pathway/
Parameter"
Ca
Age
IR
ET
Shower
Indoors
EF
ED
BW
AT-Noncancer
AT-Cancer
REcoRO OF DECISION FOR CiPERABI.E UNrT 13
-50-
PARAMETERS USED To DESCRIBE EXPOSURES To SITE-RELATED CHEMICALS OF CONCERN
Current Land Use
Current Conditions
Outside Plant Operations
Area
Future Conditions
Inside Plant Operations
Area
Future Land Use
(Resident)
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, 1991 b)
Upperbound estimate (EPA, 1991 b)
Upperbound estimate (EPA, 1991 b)
See text
Upperbound estimate (EPA, 1991 b)
Standard default_ for adult exposures (EPA,
1990a)
365 x ED
!t 365 x 70 yr lifetime
1!!!!!!!!1 1!1!1 11m 111111 1iiii iiiil --------- --- -
NATIONAL STARCH & CtEUICAI. COUPANY SUPE!IFU<D SITE
AEcoRD OF OECIS_ION FOR OPERABLE UNIT 13
-51-
i
i TABLE 10 PARAMETERS USED To DESCRIBE EXPOSURES To SITE-RELATED CHEMICALS OF CONCERN
Pathway/
Parameter"
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
{Chilid Resident)
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
-------------------
TABLE 10
Pathway/
Parameter"
Cw
Age
SA
CF
PC
NATIOIW. STARCH & CIEMICAI. COMPANY SllPERRJto SITE
AEcooo Of DECISION FDR DPERABLE UNIT 13
-52-
PARAMETERS USED To DESCRIBE EXPOSURES To SITE-RELATED CHEMICALS·OF CONCERN
Current Land Use
Current Conditions
Outside Plant Operations
Area
Future Conditions
Inside Plant Operations
Area
Future Land Use
(Chilid Resident)
Reasonable Maximum
Exposure
UCL or maximum
concentration in groundwater
1-12 years
8,900
0.001 Ucm3
Reference(s)/
Justification
Assumed
Average for whole body
(EPA, 1992a)
' i I I ' ' l
!
!
f I ' 1
I.
EPA, 1992a .. t ------+----------1----------+-----'------+-------------il I Chemical-specific cm/hr
ET 0.2 hour/day
EF 350 days/year
ED 12 years
BW 22.5 kg
AT-Noncancer 4,380 days
AT-Cancer 25,550 days
EPA, 1991b i
See text I
Corresponds to age exposed '1
Average for years exposed
(EPA, 1990b) I
I
ED x 3.65 days/year I
I
70-year lifetime x 365 days/year [
f I' f ~
- - -·--· - - - ----- ------, ! NATIONAL STARCH & CHEMJC.11. Coll?ANY 5u?EllFIJIO SITE . ·
1
,
TABLE 10
Pathway/
Parameter"
Ca
Age
IR
ET
Shower
Indoors
EF
ED
SW
AT-Noncancer
AT-Cancer
REcoAo Of DECISION FOR OPERABLE lJHrr 13
-53-
PARAMETERS USED To DESCRIBE EXPOSURES To SITE-RELATED CHEMICALS OF CONCERN
Current Land Use
Current Conditions
Outside Plant Operations
Area
Future Conditions
Inside Plant Operations
Area
Future Land Use
(Chilid Resident)
Reasonable Maximum
Exposure
Calculated from UCL or
maximum concentration in
groundwater
1-12·years
0.63 m3/hr
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 inhalation rate as adults
Upperbound estimate (EPA, 1991 b)
Upperbound estimate (EPA, 1991 b)
See text
Corresponds to age exposed
Average for years exposed (EPA, 1990b)
ED x 365 days/year
70-year lifetill\!! x 365 days/year
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 for noncarclnogens; 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
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NAllOIW. STARCH & CHEMIC.IL CoiiPANY Sl.mlR.,«J Sm
AEcoRn OF 0EasoN R'.lfl °"8W!lE UIIT I:
TABLE 11 SUMMARY OF NONCANCER TOXIC EFFECTS OF CHEMICALS OF POTENTIAL CONCERN I INHALATION ORAL R!Dd. CRITICAL EFFECT UNCERTAINTY GASTROINTESTINAL CHEMICAL Rf~ (mg/kg/day) . AND FACTOR' ABSORPTION (mg/kg/day) TARGET ORGAN' (Inhalation; oraQ FACTOR' I ll!!'!!!!'!!!!!'!!!!!'!!!!!!!!!!!!BB!!!'!!!!!!!B!!!'!!'11'l!!!!'!!!!!!!B'1!l'!!'J!\l!!!!(ln!!!!h!!!!a1at91oen!!!!; ol!rae1)99!!!!!!!!!!!!!!!!!!!!'!'!!!!!!!!!!!'!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
I Acetone ND 1 X 10·lh
I Bis(2-Chloroethyl)ether ND ND
Chloroform ND 1 X 1Q"2h
I
1,2-Dichloroethane ND ND
I 1, 1-Dichloroethene ND' 9 X 10"3h
1,2-Dichloroethenel ND 1 X 10"2b
I
I 1,2-Dichloropropane
Methylene Chloride
1 X 10·3h ND
9 X 10"1 h Gx10·2h
I Tetrachloroethene
1, 1,2-Trichloroethane
ND 1 X 10·2h
ND 4 X 10•3h
I Trichloroethene ND 6 X 1Q·3k
Vinyl Chloride ND ND I
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I Antimony ND 4 X 10"'h
I Arsenic ND
I Barium 7 X 10•2h
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Beryllium ND 5 X 10'3h
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NA; liver, kidney
damage
NA;NA
NA; fatty cyst on
liver, liver lesions
NA;NA
NAm; hepatic lesions
NA; decreased
hematocrtt and
hemoglobin
'NA; NA
NA; liver toxictty
NA; hepatotoxictty
NA; clinical
chemistry alterations
NA;NA
NA; NA
NA; blood glucose,
cholesterol
NA;
hyperpigmentation,
keratosis
Fetotoxictty;
increased blood
pressure
NA; ND
NA; 1000 0.9
NA; NA 0.9
NA; 1000 1.0
NA; NA 0.9
NA; 1000 0.93
NA; 3000 0.9
NA;NA 0.9
100; 100 1.0
NA; 1000 0.9
NA; 1000 0.9
NA;NA 0.9
NA; NA 0.9
NA; 1000 0.05
NA; 3 0.98
1000;3 0.1
NA; 100 0.001
-55-
NAllON.ll STARCH & CHEMICAL C:OW,,Nr< Stl'ERRNl 5m
REcorul OF 0EasoN FOO ClPeRAaE I.INT f! I
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TABLE 11 SUMMARY OF NONCANCER TOXIC EFFECTS OF CHEMICALS OF POTENTIAL CONCERN
INHALATION ORAL R!Dd CRITICAL EFFECT UNCERTAINTY GASTROINTESTINAL CHEMICAL R!Cd (mg/kg/day) AND FACTOR" .. ABSORPTION (mg/kg/day) TARGET ORGAN° (Inhalation; oraQ FACTOR'
. (Inhalation; oraQ
Cadmium (water) ND 5X10"h NA; proteinuria, NA; 10 0.06 renal damage
Cadmium (food) ND 1 X 10•3h NA; renal damage NA; 10 0.06
Chromium Vl0 ND 5 X 10•3h Nasal mucosa 300; 500 0.05 atrophy; ND
Manganese (water) 1 X 10"h 5 X 10'3 h Respiratory; CNS 300; 1 0.05
Manganese (food) 1 X 10"h 1.4 X 10•1 h Respiratory; CNS 300; 1 0.05
Thallium1 ND 6 X 10'5h NA; increased NA; 3000 0.05 SGOT and serum
LDH levels, alopecia
Vanadium ND 7 X 10·3b NA; none observed NA; 100 0.05
Zinc ND 3 X 10'1 h NA; anemia NA; 10 0.5 I • ND = Not determined
b Source: 1992 HEAST, including July 1992 and November 1992 Supplements. I. 0 Value given is for Chromium VI, assuming all chromium found is Chromium VI.
d The reference concentration or reference dose is the dOse below which no adverse effects are likely to be seen (EPA, 1991 c and 1992c). • Determined by the EPA (1991c, 1992c). 11 The oral R+D is multiplied by the Gastrointestinal Absorption Factor (GAF).
g NA = Not applicable. .
h Source: IRIS. ·I I Values given are for 1,2-cis-Oichloroethene.
k From the Environmental Criteria and Assessment Office of the U.S. EPA, Cincinnati, Ohio.
m By analogy to thallium sulfate, adjusting for differences in molecular weight.
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-56-
TABLE 12 ESTIMATED POTENTIAL FUTURE LAND USE RISK FROM CARCINOGENS
POTENTIALLY
EXPOSED
POPULATION
Child Resident
Adult Resident
CHEMICAL
1, 1,2-T richloroethane
1,2-Dichloroethane
Arsenic
Beryllium
Bis(2-chloroethyl)ether
Bis(2-ethylhexyl)phthalate
Chloroform
Methylene chloride
Tetrachloroethene
T richloroethene
Vinyl chloride
Total RISK
Total Media
1, 1,2-T richloroethane
1,2-Dichloroethane
DERMALLY
ABSORBED
DOSE
(mg/kg/day)
5.22 X 10-a
1.09 X 10-~
2.52 X 10-a
8.67 X 10·9
1.09 X 10-6
5.58 X 10-6
6.04 X 10·7
3.53 X 10·7
2.98 X 10-6
9.27 X 10-7
1.20 X 10-7
1.01 X 10-7
2.12 X 10.;
DERMAL
CONTACT
RISK
3.31 X 10·9
1.10 X 10·5
4.50 X 10-a
3.73 X 10·5
1.34 X 10-6
8.68 X 10-a
3.68 X 10·9
2.65 X 10·9
1.72x1o':7
1.13 X 10-a
9.05 X 10·•
5.00 X 10·5
6.42 X 10·9
2.14 X 10·5
INGESTED
DOSE
(mg/kg/day)
6.99 X 10·5
6.29 X 10·3
2.83 X 10·5
9.?5 X 10-a
5.84 X 10.;
1.90 X 10.;
7.62 X 10·5
8.82 X 10·5
6.98 X 10·5
6.51 X 10·5
1.60 X 10.;
5.61 X 10-5
5.05 X 10-3
INGESTION
RISK
3.98 X 10-a
5.72 x.10 ..
4.96 X 10-5
4.19 X 10·5
6.43 X 10.;
2.66 X 10-6
4.65 X 10·7
6.61 X 10·7
3.63 X 10-a
7.16x10·7
3.04 X 10.;
1.62 X 10·3
3.20 X 10-6
4.60 X 10.;
NATIONAi. STARCH & CHEMICAL C.0MPANY SUPE!IFU<D SITE
REcoRO OF DEClSION FOR O!'ERABu; UNIT 13
INHALED
DOSE
(mg/kg/day)
9.01 X 10-a
1.52 X 10·3
NA
NA
1.74 X 10-6
NA
1.36 X 10·5
. 1.42 X 10·5
1.62 X 10·5
1.42 X 10·5
3.82 X 10-s
!~
7.24 X 10-6
1.22 X 10·3
INHALATION
OF voes
RISK
5.13 X 10"7
1.38 X 10.;
NA
NA
2.09 X 10-6
NA
1.10 X 10-6
2.41 X 10-8
3.25 X 10-a
8.50 X 10-a
1.15 X 10-s
1.53 X 10.;
1.83 X 10-3
4.12 X 10"7
1.11 X 10.;
-------------------NATIONAL STARCH & CHEMICAL COMPANY SUPERFL"1l SITT
RECORD OF DECISION FOO 0PERA81£ UNIT 13
-57-
I TABLE 12 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 RISK (mg/kg/day) RISK (mg/kg/day) RISK
(mg/kg/day)
Arsenic 4.89 X 10.a 8.74 X 10.a 2.28 X 10·5 3.98 X 10·5 NA NA
Beryllium 1.68 X 10.a 7.24 X 10"5 7.83 X 10.a 3.37 X 10·5 NA NA
Bis(2-chloroethyl)ether 2.12 X 10.a 2.59 X 10-6 4.70 X 10◄ 5.17 X 10◄ 1.40x 10.a 1.68 X 10.a
Bis(2-ethylhexyl)phthalate 1.08 X 10·5 1.68 X 10·7 1.53 X 10◄ 2.14 X 10-6 NA NA
Chloroform 1.17x10.a 7.15 X 10"9 6.12 X 10·5 3.74 X 10·7 1.09 X 10"5 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 10·5 1.94 X 10-8
Tetrachloroethene 5.79 X 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.a
Trichloroethene · 1.80 X 10-6 2.20 X 10.a 5.23 X 10·5 5.76 X 10·7 1.14X10"5 6.83 X 10.a
.
Vinyl chloride 2.33 X 10"7 1.76 X 10.a 1.29 X 10◄ 2.45 X 10◄ 3.07 X 10-s 9.21 X 10.a
Total RISK 9.71 X 10-5 1.30 X 10·3 1.23 X 10◄
Total Media 1.52 X 10-3
-------------------NATIONAL STARCH & CIEVICAL CoVPANV SUPE!IRJ<O SITE
RECORD OF DECISIOH FOR ()pfRABLE lJNrr 13
-58-
I TABLE 12 ESTIMATED POTENTIAL FUTURE LAND USE HAZARD ASSOCIATED WITH NONCARCINOGENS
' .
I POTENTIALL y
EXPOSED
POPULATION CHEMICAL
DERMALLY
ABSORBED
DOSE
(mg/kg/day)
DERMAL
CONTACT
HQ
INGESTED
DOSE
(mg/kg/day)
INGESTION
HQ
INHALED
DOSE
(mg/kg/day)
;;:;:::::::t
::::::::::::::-::::,:-:·:-:-:-·:·.;.·.·::.:-:::::::::::::::::::::::::::::::::::::::.·.;.:.;.:-::::::·.::::::::::::;:::::;:::::;:;:;:::::;:;:;:;:;::,:.:-:-:-;:;.;.;:;:;:;:;.~
INHALATION
OF voes
HQ
Child Resident 1,1,2-Trichloroethane 3.05 X 10-7 8.46 X 1 □-5 4.08 X 10_. 1.02 X 10"1 NA NA
NA 1,2-Dichloroethane 1.05 X 10-5 1.17 X 10'3 6.05 X 10_. 6.05 X 1 □-2 NA
Aluminum 2.21 X 10·3 1.47 X 10'2 2.48x10° 8.27 X 1 □-1 NA NA
Antimony 1.40x10-6 7.00 X 10-2 1.57x 10·3 3.94 X 10° NA NA
Arsenic 1.47x10·7 5.00 X 10_. 1.65 X 10_. 5.51 X 10'1 NA NA
Barium 1.95 X 10'5 2.79 X 10-3 2.19 X 10'2 3.13 X 10"1 NA NA
Cadmium (water) 1.98 X 1 □-7 6.60 X 10-3 2.65 X 10_. 5.30 X 10'1 NA NA
Chromium 3.14 X 10-6 1.26 X 10'2 3.53 X 10"3 7.05 X 10"1 NA NA
Manganese (water) 2.07 X 1 □-~ 8.29 X 10'1 2.33 X 10'1 4.66 X 101 NA NA
Thallium 7.91 X 10-6 2.64 X 10'2 8.88 X 10-5 1.48 X 10° NA NA
Vanadium 5.76 X 10-6 1.65 X 10'2 6.47x10·3 9.24 X 10'1 NA NA
Zinc 1.01 X 10_. 5.47 X 10"3 1.14x10·1 3.80 X 1 □-1 NA NA .
1.01 X 10° 5.69 X 101 ,f Total HQ 7.67 x 10
Total Media HI 5.79 x 101
-Adult Resident 1,1,2-Trichloroethane 2.37x 1 □-7 6.57x 10·5 1.31 x 10,. 3.27x 1 □-2 NA NA
r---------t------r-----t--------t-------j---'-----t------;1
1,2-Dichloroethane · 8.15 x 10-6 9.06 x 10.. 1.94 x 10 .. -1.94 x 10·2 NA NA
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-59-
TABLE 12 ESTIMATED POTENTIAL FUTURE LAND USE HAZARD ASSOCIATED WITH NONCARCINOGENS
POTENTIALLY DERMALLY DERMAL INGESTED
EXPOSED ABSORBED CONTACT DOSE INGESTION POPULATION CHEMICAL DOSE HQ (mg/kg/day) HQ
(mg/kg/day)
Aluminum 1.71 X 10·3 1.14 X 10·2 7.97 X 10·1 2.66 X 10'1
Antimony 1.09 X 10-6 5.44 X 10-2 5.06 X 10_. 1.26 X 10°
Arsenic 1.14 X 10·7 3.88 X 10_. 5.31 X 10·5 1.77 X 10'1
Barium 1.51 X 10'5 2.16 X 10-3 7.04 X 10~ 1.01 X 10'1
Cadmium (water) 1.54 X 10'7 5.13 X 10-3 8.52 X 10-5 1.70 X 10-1
Chromium 2.44 X 10-6 9.75 X 10'3 1.13 X 10'3 2.27 X 10-1
Manganese (water) 1.61 X 10_. 6.44 X 10'1 7.49 X 10'2 1.50 X 101
' Thallium 6.14 X 10-8 2.05 X 10-2 2.86 X 10·5 4.76 X 10'1 I I
Vanadium 4.47x 10.s 1.28 X 10-2 2.08 X 10~ 2.97 X 10-1
Zinc 7.87 X 10-5 4.24 X 1 i)·3 3.66 X 10'2 1.22 X 10·1 .
Total HQ 7.81 X 10·1 1.83 X 10°
Total Media HI
NATIONAL STARCH & CIEMICAL CoMPANY SUpE!IF\JNO SITT
RECORD OF DECISION FOR Of'ERAB1£ UNIT 13
INHALED INHALATION
DOSE OF voes
(mg/kg/day) HQ
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
NA NA
9.86 X 10·7
1.91 X 101
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-60-
NA110NAL SrJ.RCJ< & C>EwlCM. ca,,,IK1 SUl'ERRJNO SITE
. Rroo!uJ OF OeaOON RlR ClPERABlE UNIT 13
TABLE 13 . SUMMARY OF CANCER RISK AND NONCANCER HI VALUEa
Receptor/
RISK or HI
Child/RISK
Child/HI
Adult/RISK
Adult/HI
Child/RISK
· Child/HI
Adult/RISK
Adult/HI
Child/RISK
Child/HI
Adult/RISK .
Adult/HI
Child/RISK
Child/HI
Adult/RISK
Adult/HI
Current Land Use
Current Conditionb Future Conditionc Future Land Used
8 X 10·5 1 X 10◄ 4 X 10◄
6 X 10·2 4 X 10"2 1 X 10-1
NA NA NA
NA NA NA
4 X 10·9 9 X 10.g 1 X 10·7
5 X 10·7 6 X 10·7 6 X 10-s
NA NA NA
NA NA NA
2 X 10·5 2 X 10"5 1 X 10◄
1 X 10·2 1 X 10"2 3 X 10~
NA NA NA
NA NA NA
NA NA 2 X 10·3
NA NA 6 X 101
NA NA 2 X 10·3
NA NA 2 X 101
a 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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6.7 SUMMARY
NATIONAL STARC>< & CHEWColl. CtNPN<r 5u>ERRNJ SITE
REcooo Of DEaOON FOR OPaw!I£ UNIT 13
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 beneath
and downgradient of the Site as a potable source of water and the potential adverse Impact contaminated soils will have on groundwater quality. The unacceptable, future risk is due to the presence of contaminants at concentrations above EPA's MCLs for 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 has been made between the presence of 1,2-DCA in the Northeast Tributary and the 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. However, the RI report did conclude that the source of 1,2-DCA in the Northeast Tributary is the contaminated groundwater in the saprolite zone of the aquifer discharging into this stream. Since very high concentrations of 1,2-DCA (660,000 µg/1) have been found in the groundwater, the potential for discharge of groundwater contaminants above levels of ecological concern is possible. Hence it is necessary to institute long-term monitoring ofthe Northeast Tributary.
7.0 REMEDIAL ACTION OBJECTIVES
Section 5.0 defined the extent and characterized the contamination and the environmental.setting
of OU #3. Section 6.0 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 14.
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(9)(2) are those requirements that address problems or situations sufficiently similar to the
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NATIONAL STARCI< & CHEMICAi. ca,,,!Nf SU>ERru<o SITE
AEcoRo OF DEaSION RlR 0PERABt£ UNIT 13
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 17.
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.
8.0 DESCRIPTION OF ALTERNATIVES
Due to an insufficient evaluation of soil remediation technologies in the June 21, 1993 FS document, this ROb 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 15 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 ii they are difficult to implement due to Site constraints or contaminant characteristics, or ii the technology has not been proven to effectively control the contaminants of concern. Table 15 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 live (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".
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Alternative GWP1/GWL1:
Alternative GWP2/GWL2:
Alternative GWP3/GWL3:
. Alternative GWP4NGWL4A:
Alternative GWP4B/GWL4B:
-63-
No action
NAOOWL STAOC!< & C!eilCJL CrNf;.NIY SU>ERRIHO SITE
RfOJAD Of DroSION R'.JA OPawllE UlfT 13
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."
8.1.1 ALTERNATIVE GWP1/GWL1: No action
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 time 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". 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, operation and maintenance (O&M) costs would be incurred for conducting 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.
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-64-
TABLE 14 REMEDIAL ACTION OBJECTIVES AND
ACTIONS
MEDIUM I REMEDIAL ACTION OBJECTIVE
Groundwater For Human Health: Prevent ingestion of
water having levels of 1,2-DCA resulting in
cancer risks exceeding the 10◄ to 10.., risk
range.
For Environmental Protection: None,
groundwater concentrations have not
conclusively been found to represent an
environmental hazard.
Surface Water For Human Health: None, surface water is
not a drinking water source. Existing
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
with sediments having levels of 1,2-DCA
resulting in cancer risks exceeding the 1 o◄
to 10.., risk range.
For Environmental Protection: None.
NA110NAL STARCH & CKMCIL Cola>ANY SU'E!IRHl SITE
Rl:OORD Of OeaOON FOS OP€IWl.E UNT '3
ASSOCIATED GENERAL RESPONSE
I GENERAL RESPONSE ACTION I
No Action
· Instltutional Control
Containment
Containment/Treatment
Collection/Discharge
Collection/TreatmenVDischarge
No Action
Monitoring
No Action
Monitoring
-- --·----·--·-------·-General
Reaponsa
Action
NoAdlon H
H
Technology Type
WA --rtd-
Proces• Option
H WA I
H Dood-I
~ H Ver11c:al &aurlllce RowConlrolHL--'~=====..:.V:.::-=----1
,J1 c:on-tlonlilEldracllonWello I
EJdlactlon 11 EnhlnoedExtJ••··-I
SU-llraln In T-I
~ In-: j Or>Sl• lltochmoe '•"" .... , ' ~: LhPOlW I
1 Or>.----I
EJdlactlon
£nl'a>ood Eld111caCN,_
l -llraln H ... ....._T_ I
t Nt I
➔ ,,,_,,,T_,,_ ~ . Cat>on I
l SINm I
~: O>ddalon I
c-.r-Chen1c:al Tr----I
~ ~ p--, OU-1 PnltrMrrwil l'Wmllffl I
~ r ... ..-
1 ---I
lnatltutlonal
lmplernenteblllty
~L1.plw.1••t11>1e
,, ... ,.,llbll
lu ... 1•1table
Nol......,._lor_
ln.,._,.11 __ Modende Dffllcully . ...... -
......,.__ -Dffllcully
......,._ -Clfflcully
1.,.-,a,llbll
Nol ........ 11..i lor-
e..,~. N, El, ..... -llo~
Eaoly~
••·•••llhll ...........
--Tec:t,...,,.
lnc>lo,1••-wth lllfflcully
.,.....,__-lllfflcully
Effectiveness
In Meeting PRO•
NolEllodlw
~E-
Nol E-· Wll•-
T-to MNI .,_
E--E_
Nol Effec1"'9 • WIil• -
T-.itoMNIPRGo
v_., E-
Efllc::ltvw : f
llnpnwonEllldlf•-
Modoratot, E-
TABLE 15 SECOND SCREENING OF TECHNOLOGIES AND PROCESS OPTIONS FOR GROUNDWATER
Coat
Low
Low
'--Jo Modocih
i.-toModocale
Mud.:.aw, l-lgh
1.awtoModocale
Low
High
Modwa.l)tlgh
Mtd::.....,Hflti
High
High
Modocalo., High
-.,al-- - - - - - -·--- - - - - - -
Raopona-
Actlon
.:.oDeclkJrvTrMI
Technology Typa
On-Slo 0
_______ _.. -Opllon Aololnod
Proceae Option
r--POTW
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lnatltutlonal
lmplementablllty
h-c>--wlll, --Dllllculy
~ i ... I• iblble
"'1>1omn-wllll Modo. .. Dllllculy ~-ablo wlh llfflb,ty
Eflactlveneaa
In Meeting PRG■
E-
Ellodlw
Ellodlw
E-
TABLE 15 SECOND SCREENING OF TECHNOLOGIES AND PROCESS OPTIONS FOR GROUNDWATER
l.olflo-
.....
Modo.illlll High .
High
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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:
-67-
$ 0
$ 22,000
$ 227,000
None
None
Over 30 years
NA 110HAL STAAO! & C!EMIC.II. Cou!'AHY SlJ>eRAJNo SITE
AEcooo Of DEosloN FOR OPBW!IE UNIT 13
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 in unacceptable exposure concentrations in either water column or sediment or both.
Capital Costs:
Annual O&M Costs:
Total PW Costs for 30 Years:
Time to Design:
Construction Time:
Duration to Achieve Clean-up:
$ 178,000
$ 138,000
$1,479,000
None
None
Over 30 years
8.1.3 ALTERNATIVE GWP3/GWL3: lnstltutlonal Controls, Long Term Monltorlna. 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 any other institutional controls. The specific institutional controls to be implemented include: using deed restrictions.to control the installation of new wells on plant 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 on the PRP ensure the institutional controls are in place, are reliable, and will remain in place after initiation of O&M. Groundwater monitoring and the five year CERCLA review would be conducted for 30 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:
-68-
$ 198,000
$ 138,000
$1,500,000
None
None
Over 30 years
NAllOfW. STAR<>l & C!<EMl'.:.ll CoilPAHY SIR:RAJNO SITE
RE00RD OF 0EasoN FOR °""1wlLE UIIT 13
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 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 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.
Capital Costs:
Annual O&M Costs:
Total PW Costs for 30 Years:
Time to Design:
Construction Time:
Duration to Achieve Clean-up:
$1,437,000
$ 740,000
$5,792,000
1 year
6 months
15 to 30 years
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
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NA110HAL STARCH & CHEMICAL CouPAHY SU>E!!ru«) Sile
RE<XlOo Of DeaSION A:lR 0PEIW!l£ UIIT 13
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 . water and sediment samples would be collected from the Northeast Tributary annually instead of once every five years. · ·
· Capital Costs:
Annual O&M Costs:
Total PW Costs for 30 Years:
Time to Design:
Construction Time:
Duration to Achieve Clean-up:
$ 0
$ 92,000
$867,000
None
None
Over 30 years
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 detailed 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 prdteclive 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(1)(1 )(ii)(C). Table 16 summarizes the
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NAllONII. STARCH & CIEllk:.11. C<:MPN<'! SlJPERFIJIC Sl!E
. REcooo OF ilEas1oN FOil Cll>flW!l£ UNT 13
-70-
· 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 10-3.
Alternatives GWP2/GWL2, GWP3/GWL3, GWP4A/GWL4A, and GWP4B/GWL4B, provide adequate protection for human health by preventing ingestion of potentially contaminated groundwater and surface water. Alternatives GWP4A/GWL4A 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 GWP4A/GWL4A and GWP4B/GWL4B would indirectly remediate the surface water and sediment, since the groundwater remediation would decrease the potential for contaminants to reach the tributary via groundwater discharge. Both of these alternatives 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. Aiternative GWP3/GWL3 would not be as protective of the environment because contamination would continue to migrate into the tributary through groundwater discharge. Neither Alternatives GWP1/GWL1 nor GWP2/GWL2 would provide protection for human health. 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 with 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 tor waiving an ARAR. Site specific ARARs are identified in Table 17.
MCLs and State groundwater quality standards are ARARs for Site groundwater. By leaving contaminants above these standards in the groundwater, Altem·atives GWP1/GWL 1, GWP2/GWL2, and GWP3/GWL3 would not comply with these ARARs. Therefore, these
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NAllOfW. STARCH & CHBIICII. COilPNIY Su>eRFIHJ 5nE
REalRO Of llroSIOO RlR OPaw!LE UlfT 13
alternatives would not achieve,the requirements of the NCP. Alternatives GWP4NGWL4A and GWL4B/GWL4B would obtain perfonnance 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 GWP4NGWL4A and GWL48/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. However, the long-tenn monitoring requirement associated with SW/SE-2, if done inconjunction with remediation of the groundwater, would serve to verify that groundwater contaminants are not migrating into the tributary at levels of concern for human health or the environment.
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 18.
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/GWL1, GWP2/GWL2, and GWP3/GWL3 groundwater contamination would not be actively remediated; therefore these alternatives cannot be considered to be pe,nnanent or effective remedial solutions as these alternatives do not remove, treat, or isolate subsurface contamination. The long-term effectiveness of Alternatives GWP1/GWL1 and GWP2/GWL2 is questionable, because of the lime ii would require for "Nature" to clean "ltselr. 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 MC Ls or North Carolina Groundwater Standards. Alternatives
GWP4NGWL4A and GWP48/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 and prevent them from migrating into the surface water and sediment of the tributary via groundwater discharge. The reliability of Alternatives GWP4NGWL4A and GWP48/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 revie:,vs 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.
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NAllOfW. STARCH & CHBIICAI. COllf'N« -...0 SITE
llEcoRo Of OEasloN R>I ClPeRABlE UIIT 13
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 GWP4A/GWL4A 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/GWL1, 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 voes 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.
9.2.4 IMPLEMENTABILITY
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 worth 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 an alternative is the amount of capital
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-73-
NA110NAL SrARCII & CIEWic.ii. ca,,,,.,,~ SITE REcoAD OF OeaSIOH FOO ClPaw!l£ UlfT '3
.. TABLE 16 SUMMARY OF THE THRESHOLD CRITERIA EVALUATION FOR THE
ALTERNATIVES
iil:1Ali1lllllllllllif1Dlfll lllllt;~!l-All1l l~!:,::::;:1■-
GWP1/GWL1: No Action Does not eliminate any exposure Not in compliance
pathways or reduce the level of risk.
GWP2/GWL2: .Long Term Does not eliminate any exposure Nol in compliance Monitoring; Fence Portion of pathways, reduces potential risk of
Northeast Tributary exposure to contaminated surface
water/sediment by fencing stream.
Contamination would continue to
discharge ·into Northeast Tributary.
GWP3/GWL3: lnstltutional Controls; Potential off-site contaminant migration Not in compliance Long Term Monitoring; Fence would not be eliminated. Institutional
Portion of Northeast Tributary controls would eliminate risk posed by
using contaminated groundwater as
potable water. Contamination would .
continue to discharge into Northeast
Tributary.
GWP4A/GWL4A: Groundwater Off-site contaminant migration would be In compliance . Extraction; Treatment Via Air eliminated . Eliminates potential risk of Stripping and Vapor-Phase ingestion, inhalation, and dermal
Adsorption; Discharge io POTW absorption. Eliminates contamination
entering Northeast Tributary.
GWP4B/GWL4B: Groundwater Off-site contaminant migration would be In compliance Extraction; Treatment Via Air eliminated. Eliminates potential risk of Stripping and Fume Incineration; ingestion, inhalation, and dermal
Discharge to POTW absorption. Eliminates contamination
entering Northeast Tributary.
SW/SE-1: No Action Protective of human health but may not No Federal or State
be protective of the environment. ARARs for contaminants
detected in stream.
SW/SE-2: Long-Term Monitoring Protective of human health but may not No Federal or State
be protective of the environment. ARARs for contaminants
detected in stream.
- --------- -
-74-
TABLE 17 APPLICABLE QR RELEVANT AND APPROPRIATE REQUIREMENTS
STANDARD REQUIREMENT,
CRITERIA, OR LIMITATION
GROUNDWATER
Saia Drinking Wat.er Ad
Nat.ional Prmary Drinking
Wat.er Standards
Maximum Contaminant Laval
Goals
SURFACE WATER
Clean Wat.8f Ad
Ambient Wat.er Quality Criteria
(AWQC)
Nat.ional pollutant [);sctiarga
Elimilation System (NPDES)
National Pretraat.ment Program
Wat.er Quality Management
Plans (WOMP)
CITATION
42 u.s.c § 300
40 CFA Part 141, Subpart B
40 CFA Part 141, Subpart F
33 u.s.c. §§ 1311, 1313, 1317
40 CFA Part 131
40 CFA Part 122, Subpart C
40 CFA Part 403
40 CFA Part 130
DESCRIPTION
Establishes standards for drinking wat.ar
Establishes haalh-basad standards for pu,lic
wat.er systems maximum contaminant levels
(MCLs)
Establishes drinking wat8f quality goals set at.
levels of no known o, anticpat.ad adverse haalh
effects
Def11es laws responsible fo, protection of Iha
integriy of the nations wat.8fS
Sets criteria fo, wat.ar quality based on toxicity to
aquat.ic o,ganisms and human ~h
Defr,es charge limits for pollutants; use of best
available technology economically achia~le fo,
toxic poflu1ants discharged to surlaoa wat.ers
Sets imits for discharge to POTWs
Sets criteria for wat.er quality based on toxicity to
aquat.ic o,ganisms and human health; discharge
must comply wi1h EPA-approved WOMP
l!!!!!!I !!!!!I
APPLICABLE/RELEVANT
AND APPROPRIATE
No/Yes
No/Yes
No/Yes
Yes/Yes
No/Yes
Yes,No
Yes,No
No/Yes
liiiiil -NATIONAL STARCH & CIE111CAL COMPANY &JpERfLt<D SITE
RECORD OF DECISlON FOR ClPERABU UNIT 13
CoMMENTS
The MCLs for organic and ino,ganic contaminants
must be addrassed as the groundwat.ar is a being
used a source for drinking wat.ar
MCLGs are appropriate at this Site as I ls a source of
drinking water
The AWQC for o,ganlc and ino,ganic contaminants
are relevant and appropriat.e
[);scharge fnom fadltties must comply with NPDES
regulations
Pretreatment ragulat.ions must be met If wastewat8f Is
discharged to a POTW
Criteria avalable for~"' and fish consumption; H
waster. wat.er is discharged to a wat8fWay, ~ must be
in accord wlh a WQMP
---·----- - -
-l!!!!!!!!!I !!!!!9 !!!!!I
-75-
TABLE 17 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
STANDARD REQUIREMENT,
CRITERIA, OR LIMITATION
AIR
Clean Air Act 40 u.s.c. §§ 1857, 7409, 7411,
7412
National Prmary and 40 CFR Part 50
Secondary Ambient Air Quality
Standards
National Emissions Standards 40 CFR Par1 61
for Hazardous Air Pollutants
(NESHAPs)
GROUNDWATER, SURFACE WATER, AIR
Nor1h Caroli'la Drinkilg WIIl.8' and OCA.C Title t SA, Chaplor 2,
Groundwator Standards ~9( 2L
Nor1h Caroli'la Wator pollution NCAC T'rtle 1 SA, Chapter 2,
Control Regulations Subchaptor 2H
Nor1h Caroli'la Air Pollution Control NCAC Thie 1 SA, Chapter 2,
Requirements Subchapter 2D
DISPOSAL· DISCHARGE To SURFACE WATER/POTW
North Caroli'la Surface Water NCAC Thie 1 SA, Chapter 2,
Quality Standards Slbchapter 28
Nor1h Caroli'la Wator Pollution NCAC Thie 1 SA, Chapter 2,
Control Regulations ~er2H
Nor1h Carolna Air Pollution Control NCAC Thie 1 SA, Chapter 2,
Requirements Subchapter 2D, 2H
DESCRIPTION
ldentifl9S laws responsible lor protection of the
nations air qualtty
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 qualhy
standard exists
Establishes groundwator class<>s and regulates
wator qualhy standards
Establishes penmh procedures and condhions for
wastewater discharges
Establishes emission lmtts for air 'pollutants
Surlace water qualtty standards
Regulates surtace water discharges and
discharges to POlWs
Air pollution control and ar 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
== =-illil --NATIONAL STARCH & CIEIIICIJ. CoMP/.NY SUPSUU<O SITE
AEcoRo Of DECISKJN FOR ClPER.IBlE lJNrr 13
CoMMENTS
Applkable for on-she treatment untts having air
emissions
Applicable for on-she treatment untts with hazardous
emissions
The guidelines for allOWlE!e levels of toxic organic
and ino(ganic contaminants are appficable as the
groundwal9' is used as a drinking wator source
Must be complied wlh ii wastewater is d'ischarged to
surtace water
Air regulations must be complied with H treatment
resu b i'l air em lsslons
Standards must be maintained after d'JSCharge of
treated water
Must be complied wllt H discharged to surtace Wal«
or POlW is necessaiy
Must be considered H trea!ment results In ar
emissions
-- -- - --- ----I!!!!!!! 1!!11!1
-76-
TABLE 18 SUMMARY OF.PRIMARY BALANCING CRITERIA EVALUATION OF THE ALTERNATIVES
GWP1/GWL1: No
Action
GWP2/GWL2: Long-
Term Monitoring;
Fence Portion ol
Northeast Tributary
GWP3/GWL3:
Institutional Controls;
Long-Term Mon~oring;
Fence Portion of
Northeast Tributary
Does not meet ARARs. Length ol
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 permanent). Fence
would reduce potential of exposure
to 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, except natural
attenuation.
None, except natural
attenuation.
None. None.
None. None.
None. None.
== i:;:;;; liiliii --NATIONAL STARCH & CIEWICAI. COMPANY &JpERFUfl) SITE
RECORD OF DECISION FOA OPERA81Ja UNrr 13
0 227
0 1,479
0 1,500
-·---.. - - - ----1!!!11!1 ~ =::; liiliilii iiii! --NATIONAL STARCH & CIEMICAL CoMPANY SU!'eRru<o SITT
FIEcoRO OF DECISION FOil ClPERASlE 1JNrr 13
-77-
TABLE 18 SUMMARY OF PRIMARY BALANCING CRITERIA EVALUATION OF THE ALTERNATIVES
GWP4NGWL4A:
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-Tenn
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.
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 construct
12 months to design
6 months to construct
None.
i None.
5,792
5,270
151
867
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NATl()H.IL STAAO! & CHEMIC.II. Coio>AHY SUPeRA/ND SITE
Arolrul Of DeaOON ~ OPSWll.f UNT '3
-78-
required to be deposited at the present time at a given interest rate to yield the total amount necessary to pay for initial construction costs and future expenditures, including O&M and future replacement of capital equipment.
More detailed information on the development of the total present worth costs for each alternative can be found in Section 8. -
Alternative GWP 1 /GWL 1
Alternative GWP2/GWL2
Alternative GWP3/GWL3
No Action
Long-Term Monitoring, Fence Portion of
Northeast Tributary:
Institutional Controls, Long-Term Monitoring,
Fence Portion of Northeast Tributary:
Alternative GWP4A/GWL4A Groundwater Extraction/Air Stripping/
$ 227,000
$1,479,000
$1,500,000
Vapor-Phase Carbon Adsorption/POTW Discharge: $5,792,000
Alternative GWP4B/GWL4B Groundwater Extraction/Air Stripping/
Fume lncineration/POTW Discharge :
Alternative SW/SE-1
Alternative SW/SE-2
9.3 MODIFYING CRITERIA
No Action
Long-Term Monitoring
$5,270,000
$ 151,000
$ 867,000
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 conditionally concurs with the selected remedy as described in Section 10. The State's correspondence providing conditional concurrence, along with the specific conditions, and the Agency's rnsponse to the stipulated conditions can be found in Appendix A.
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, 1993. The public comment period on the Proposed Pian began July 19, 1993 and closed on September 16, 1993.
Written comments were received from the City of Salisbury and NSCC during the public comment period. The questions asked during the August 3, 1993 public meeting and the Agency's
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NATIONAL STARCH & CHEMICAL COMPANY SUPERFUND SITE
RfooRO OF 0EaSION FOR OPERABlE UNIT #3
response to the written comments are summarized in the Responsiveness Summary, Appendix A. Since no input was received from the community at large, it is infeasible to assess the community's acceptance 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 GWP4NGWL4A 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 a deed restriction as the institutional control.
Long-term monitoring of the groundwater and the surface water/sediment in the Northeast
Tributary.
• 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.
• More accurately evaluate the direction and speed of the flow of groundwater in the bedrock.
• Cor:iduct 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 17 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 met/attained by the NSCC OU #3 RA are listed in Table 19.
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NATKJNALSTARCH & CHEMICAL COMPANY SUPERRJHD SITE
RECORD OF OECISON fOO DPERAB!.E UNIT 13
Table 19 provides the remediation goals to be achieved at this Site along with the range and
frequency of detection for the listed contaminants. 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 8, 9, 10, 11, 12, and 13.
.10.2 GROUNDWATER REMEDIATION
The groundwater remediation alternatives selected for the OU #3 at the NSCC Site are
GWP3/GWL3 and GWP4NGWL4A • 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 19 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
and saprolite extraction wells would have an estimated combined flow of 15 gallons per minute
(gpm) and 1 O gpm, respectively. The lagoon area bedrock and saprolite extraction wells will have
an estimated combined flow of 6 gpm and 30 gpm, 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 plum·es 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 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. The estimated volume of groundwater adversely impacted
by past Site activities is 131 million gallons.
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 any or
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.
- - - ------

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TABLE 19 PERFORMANCE STANDARDS AND CORRESPONDING RISKS FOR OU #3
CHEMICAL OF
CONCERN
GROUNDWATER
Acetone
Bis(2-Chloroethyl)ether
ChlorofonTI
1 ,2-Dichloroethane
1 , 1-Dichloroelhene
1,2-Dichloroethene (cisltrans)
1,2-Dichloropropane
Methylene Chloride
Tetrachloroethene
1, 1,2-Trichloroethane
T richloroethene
Vinyl Chloride
RANGE AND
FREQUENCY { )
OF DETECTION
(µg/1)
9-4,200 (15)
13-32 (2)
7-6,900 (2)
1~.000 (30)
1-14 (3)
1-200 (4)
5 (1)
1-160 (5)
1-7 (4)
1-5 (10)
1-5 (4)
1-120 (8)
PERFORMANCE STANDARDS (CLEANUP GOALS)
PERFORMANCE
STANDARD
(µg/1)
700
5
7
70
5
5
2.8
POINT OF
COMPLIANCE
The Entire
Plume of
Contaminated
Groundwater
BASIS oi=
STANDARD
State
CRQUState(b)
CRQUState(b)
CRQUState(b)
MCUState
MCUState
CRQUState(b)
MCUState
CRQUState (b)
CRQUState(b)
State
CRQUState (b)
== =-a liiiiii iiiiil -
NATIONAL STAACH & CHE•JCAL CoMPANY SUPERFUro SITE
RECORD OF DECISION FOR OPERABtE UNIT '3
CORRESPONDING RISK LEVELS
CHEMICAL-SPECIFIC AME RISK
CANCER(a) NON-CANCER ( a)
NA 1.0
1E-4 NA
2E-7 NA
2E-6 NA
!E-4 NA
NA 0.2
2E-6 NA
1E-6 NA
1E-6 0.003
2E-6 0.006
9E-7 0.01
SE-5 ii NA
\ ! ' ·I
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--- --- --11!!1 I!!!!! I!!!!!! !!Ill ml == . l:iiiila liiiiiil liiiiiil --
-82-
TABLE 19 PERFORMANCE STANDARDS AND CORRESPONDING RISKS FOR OU #3
CHEMICAL OF
CONCERN
RANGE AND
FREQUENCY ( )
OF DETECTION
PERFORMANCE STANDARDS {CLEANUP GOALS)
PERFORMANCE
STANDARD
POINT OF
COMPLIANCE
BASIS OF
STANDARD
(µg/1) (µg/1)
Antimony 2-30 (3) 6 MCL
Chromium 12.9-59.6 (6) 50 State
Manganese 28-12,000 (14) 50 Sta1e
Thallium 1-3 (2) 2 MCL
Zinc 22-6,410,000 (4) 2,100 State
SURFACE WATER
1,2-Dichloroethane 2-4,400 (19) 2,000 Northeast Tributary EPA, Ragion IV Chronic
on NSCC Property Screening Value
µg/I --micrograms per liter
NATIONAL STARCH & CHEMJCAI. COMPAHY SUP~O SITE
RECORD OF DECISION FOR 0PER-'8LE UNIT 13
CORRESPONDING RISK LEVELS
CHEMICAL-SPECIFIC AME RISK
NA 0.4
NA 0.3
NA 0.3
NA 0.9
NA 0.2
NA NA
MCL --Maximum Concentration Limit as Specified in the Safe Drinking Water Act I~ --The risk levels are based on a 2 liter daily consumption rate by a 70 kilogram individual. . ,i
CRQUState --Where the Maximum Allowable Concentration Of A Substance Is Less Than The Limit Of Detectability
(NCAC 15-2L.0202(b)(1 )) and where CRQL is the Contract Required Quanlitation Limit
State -· State Groundwater Quality Standards (NCAC 15-2L.0202)
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NATlOHAL STARC!< & CfeucM. CowPAHI' 5u>ERRJHo SITE
AECoRn OF OroSIOH FOO OPEAABI.E UIIT 13
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 reniedy may be able to achieve this goal.
Such contingency mea~ures 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.
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. ·
II it is determined, on the basis of the preceding criteria and the system performance data, that certain portions of the aquifer cannot be .restored to their beneficial use, all of the following measures involving long-term management may occur, for an indefinite period of time, as a modification of the existing system:
a) engineering controls such as physical barriers, or long-term gradient control provided by low level pumping, as 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/maintained 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.
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NATIOHAI. STARO< & CHEMICAL COIIPN« 5u'ERRJNo 5<TE
RecoRo CF OEaSION FOIi OOew!I.E UNIT 13
The decision to invoke any or all of these measures may be made during a periodic review of the remedial action, which will occur at 5 year intervals in accordance with CEFICLA Section 121 (c).
The RA shall comply with all ARARs listed in Table 17. The presence of contamination in the groundwater will require deed restrictions to document their presence and could lirriiffuture 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 of 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 paired surface water and sediment samples at a minimum of four (4) sampling locations. 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 19 for two consecutive sampling events, the number of sampling points and the sampling frequency may be reduced.
10.4 MONITOR EXISTING CONDmONS/ADDmONAL 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 tci 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 bedrock 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 19 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 groundwater sample collected. This sampling effort will continue until the groundwater remediation system is
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NA!10N.IL STAAO< l CHeillCII. Ca.lPN« SU>e!ANl SITE
REcoRo OF DEaSION RlR OPalAaE lhlT 13
I functional and the monitoring procedures specified In the Operation and Maintenance Manual are implemented.
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Analytical Monitoring Weil Sampling Samples Are To To Be Sampled Frequency Be Analyzed For S1mroh!e wells
NS-13 Annually voes, TAL metals NS-14 Annually voes
NS-33 Annually voes NS-35 Biannually voes, T AL metals . NS-37 Annually voes NS-39 Annually voes NS-42 Biannually voes, TAL metals NS-43 Annually-voes Bedrock Wells
NS-34 Annually voes
NS-36 Biannually voes, TAL metals NS-38 Annually voes NS-40 Biannually voes, TAL metals NS-41 Annually voes NS-44 Annually • voes
10.5 COST
The total present worth costs for the selected alternatives Is
Alternative GWP3/GWL3: ·
Alternative GWP4NGWL4A:
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
Procedure.-,,
To Be Used
EPA Methods 8240 + 6010
EPA Method 8240
EPA Method 8240
EPA Methods 8240 + 6010
EPA Method 8240
EPA Method 8240
EPA Methods 8240 + 6010 .
EPA Method 8240
EPA Method 8240
EPA Methods 8240 + 6010
EPA Method 8240
EPA Methods 8240 + 6010
EPA Method 8240
EPA Method 8240
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:
TOT AL CONSTRUCTION COSTS
TOTAL PW O&M COSTS (at annual PW O&MCosts 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
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NAllOHAI. STARO< & Ci<EMICAI. COwf>ANY 5<MRAH> SITE
Aro'.JRo Of DEaSION FOR OPaw!t£ lJIOT '3
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 17. 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.
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,
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12.0 SIGNIFICANT CHANGES
NATIOIW. STAAO< & C!EIIICAI. ea,,,N« SUPERf\JICl Sflc Ra::oRo~ Clea!DI FOROPewlr..E UIIT'3
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 publicon,July 15, 1993.
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, GWP48, 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 µg/1 for 1,2-DCA at the periphery of the plume. However, the use of 5.0 µg/1 as a cleanup goal for 1,2-DCA and the selection of the periphery 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 µg/1. The point of compliance, as described in Section 8.1, is throughout the entire plume. By changing these two conditions, the estimated remediation timeframe is lengthened which results in a different O&M cost for Alternatives GWP4A, GWL4A, GWP4B, and GWL4B. The total present worth costs tor Alternative GWP4NGWL4A becomes approximately $107,000 less than the total present worth costs for Alternative GWP4B/GWL48. Since both alternatives achieve 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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SEP 24 •93 12:56 SUPERFUND SECT. 029 P02
State of North Carolina
Department of Environment, Health, and Natural Resources. ..
512 North Salisbury Street • Raleigh, North Carolina 27604 ..
James R Hunt, Jr., Governor ij . ,
ni . , :{,iii·, Jonathan R Howes, Secretary
r 23, 1993
·Mr. Curt Fehn,·Chief·· ··
NC Remedial Section
U.S. EPA Region IV
345 Courtland Street, N.E.
Atlanta, GA 30365
Subj: Conditional Concurrence with the Record of Decision National Starch and Chemical Company NFL Site
Salisbury, Rowan County, NC
Dear Mr. Fehn:
The Division of Solid Waste Management (DSWM) has completed review of the attached Draft Record of Decision and concurs with the selected remedy subject to the following conditions.
1.
2.
The NC Groundwater Standard for trans 1,2-dichloroethene is 70 ug/1 not 100 ug/1 as shown in the Draft ROD. The Performance Standard for this contaminant in Table 21 (page 109 of the Draft ROD) as well as the groundwater standard data in Table 4 (page 24 of the Draft ROD) should be corrected accordingly.
New State Groundwater Standards (15A NCAC 2L .0202) have been approved by the NC Environmental Management Commission and the Rules Review Committee. The new standards will take effect October 1, 1993. For acetone the new standard is 700 ug/1, and for xylene the new standard is 530 ug/1. These new standards are based on the latest health information and represent the best science. Furthermore, these are the standards that have been approved and will be in effect during the remedial efforts. Therefore, the Division of Solid Waste Management requests that the performance standards presently in the Draft ROD be modified to reflect the new NC Groundwater Standards.
PO. Box 'I7687. Raldgh, North Grolln~ 27611-7687 Tck,:,hooe 919-733--498-4 Fn / 919-733-0513
An Equ.111 Opportunity AfftmatiVI!' Actton Empk,ye,..
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SEP 24 '93 12:57
Mr. Cun Fehn
22 September 1993
Page2
SUPERFUND SECT. · 029 P03
3. DSWM concurrence•on this Record of Decision and the 5elected remedy.for the site is based solely on the information contained in the attached Draft Record of Decision. Should DSWM receive new or additional information which significantly affects the conclusions or remedy selection contained in the Record of Decision, it may niodlfy or withdraw this concurrence with written notice to EPA Region IV.
4 . DSWM concurrence on this· Record of Decision in no way binds the State to concur in future decisions or commits the State to participate, financially or otherwise, in the clean up of the site. The State reserves the right to review, comment, and make independent assessments of all future work relating to this site.
The DSWM appreciates the opportunity to comment on the Revised Draft Record of Decision for the subject site, and we look forward to working with EPA on the final remedy. H you have any questions concerning these oomments please oontact Bruce Nicholson or me · at [phone].
bln\let\nsou3con
cc: Michael Kelly
Bruce Nicholson
Jon Bombolm
Attachment
Sincerely,
Jack Butler, PE
Environmental Engineering Supervisor
Superfund Section
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET. N.E.
ATLANTA, GEORGIA 30365
SEP 2 4 1993
4WD-NCRS
Mr. Jack Butler, PE Environmental Engineering Supervisor Superfund Section Division of Solid waste Management North Carolina Department of Environment, Health, and Natural Resources P.O. Box 27687 . Raleigh, North Carolina 27611-7687
RE: Conditional Concurrence on operable Unit #3 Record of Decision for the National Starch & Chemical Company Superfund Site from North Carolina Division of Solid Waste Management
Dear Mr. Butler:
EPA-Region IV appreciates the Division of Solid Waste Management, North Carolina Department of Environment, Health, and Natural Reeourcee's concurrence on the Record of Decision (ROD) for Operable Unit #3 at the National Starch & Chemical Company Superfund Site located in Salisbury, North Carolina. For the record, EPA would like fa· respond to your September 23, 1993 conditional concurrence letter. Your letter, along with this response, will be included in Appendix A of the ROD. These letters should stand as official documentation·that EPA-Region IV and Division of Solid waste Management have agreed on the preferred alternatives at this point in time.
,For your information,· the Agency has incorporated the States' s groundwater standard of 70.0 µg/1 for trans-1,2-dichloroethene in all the appropriate tables. The AgenCy has also incorporated 700 µg/1 as the performance standard for acetone in the ROD.
Please· contact me at ( 404) 3457-7791 if you have any questions or comments regarding this matter.
Sincerely yours,
1f K f:>cJwJ ~
Jon K. Bornholm
Remedial Project Manager
cc: Curt Fehn, EPA
Bruce Nicholson, NCDEHNR
Printed on Recvcled Paocr
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APPENDIX B
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 prefel'T1ld options for addressing the con1aminated groundwater and surface water/sediment
associated with Operable Unit #3 at the National Starch & Chemical Company Superfund Sile 11 Salisbi.Jy, North Carolina. The
term "Operable Unir is used when individual actions are taken as a part of an overall site cleanup. A runber of operable units
can be used in the course of a site cleanup. (Terms in bold lace print are defined in a glossary locatlld at the end of this
publication.) This document has been prepared and is being issued by the U.S. Environmental Protection Agerq (EPA), the lead
Agency for ~ite activities, and the North Carolina Department of Environment, Health and Natural ReSOtxces (NCDEHNR), the
support agency. EPA. 11 consultation 'llilh NCDEHNR, ~acted and oversaw lhe Remedial Investigation and Feasibility Study,
_ and 'llill select a remedy for Operable Unit #3 only after the public comment period has ended and all information submitted 10 EPA
during this time has been reviewed and considered.
EPA is issuing this Proposed Plan as part of its public participation responsibiities 11 accor1lance with Section 117(a) of the
Comprehensive Environmental Response, Compensation, and Uablllty Act (CERCLA), also known as Superfund.
This document summarizes information lhat is explained _in greater detai in the Remedial Investigation Report lhe Feasibiity Study
Report, and other documents contained in Iha lnfonnatlon Reposltory/Admlnlstratfve Record for this Sile. EPA and Iha Stale
encourage Iha public to review these docunents ID better understand Iha Site and lhe Superfi.Jld activities lhat have been
conducted. The Administrative Record is available lor public review locally at Iha Rowan Public Library at 201 West FISher Street,
Salisbury, Norlh Carolina. .
EPA. in consultation wilh NCDEHNR, may modify the preferred alternative or select another response action presented 11 lhis Plan
and the Remedial Investigation and Iha Feasibility Study Reports based on new rnormation aoo'or public comments. Therefore,
the public is encouraged 10 review and comment on all alternatives identified here.
A fourlh Operable Unit 'llill be developed ID address Iha contaminated soils and source of contamination at the Site in Iha near
future.
THIS PROPOSED Pl.AN
1. Includes a brief backgro4sld ol the Site and lhe principal
findings of Operable Unit 13 Site Remedial
Investigation;
2. Presents Iha remecial (clieaB.Jp) alternatives lor Iha Site
considered by EPA;
3. OuUines the criteria used by EPA to recommend a
remedial altemalve for use at the Sile;
4. Provides a summary of Iha analysis of the remedial
alternatives;
5. Presents EPA's rationale for its preiminary seledion of
lhe preferred remedial alternatives; and
6. Explains lhe oppor1unities for the public 10 comment on
the remedial alternatives.
PUBLIC MEETING:
DATE: August 3, 1993
LOCATION: Agricultural Extension Center
2727 Old Concord Road
Sallsbury, North Carollna
TIME: 7:00 PM • 9:00 PM
PUBLIC COMMENT PERIOD:
July 19, 1993 -August 17, 1993
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AIRPORT ROAi)
<lii,e ' "°" ) ~ '-
N
Figure l
'" Ool.VIOSON '{ COUmY -70
\
ROW"' COUmY
KANNAPLOIS ----c;_;;:;;R~UmY 7-
/
';~!>·,,//;;\,::,. __ _
,,
--------· ----------,--\ /.---: \ ---' _ -ll __
sa• 1000
250 750
GRAPHIC SCALE: 1•=500'
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SITE BACKGROUND
The National Starch & Chemical Company (NSCC) faciUty
occupies 465 acres on Cedar Springs Road on the outskirts
. of Salisbury, Nor1h Carolina (refer to Figure 1). Presently,
land use immedialely adjacent to the Sile is a mime of
residential and industrial developments. East and south of the Site are indus1rial. pa,ks consisting primarily of ight
industrial operations. The west and north sides of the NSCC
property are bordered by residential developments. Refer ID
the flgure 2 for Sile location.
A surface stream, referred to as the Northeast Tribu1ary,
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). Surface water runoff from the
eastern side of the faciUty discharges in1D this lributary. The
focus of the Operable Unit #3 Remedial Investigation was ID detennine the source, · nature, and extent of the
contamination entering this stream.
Primarily, NSCC manufactures textile.finishing chemicals
and custom specialty chemicals. VofaUJe and seml-vofaUle
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
wasle stream from the manufacturing process includes wash
and rinse solutions. 1 ·
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Operable Unit #3 focused on the areas of the faciUty referred
to as Area 2 and the wmiwater treatment lagoons (refer to
Figure 3). Plea 2 consists of the following operations: Area
2 Reactor Room, the Tank Room, Raw Material Bulk
Storage, and the Warehouse. The lagoon area i1cludes
three lagoons. A foU1h lagoon was i1staled in 1992 for
pretraabnent of contaminated {1011ldwaler as part of the
Operable Unit 11 Remedial Action (RA). ..
As the result of finding contaminants in grO\Jldwater and in
the surface water/sediment of the Nor1heast Tributary, the
original scope of WOik specified in the ilitial Remedial
lnvestigatiolvFeasibiity Study Work Plan has been
expanded Iv.ice. Tu:. :irst P.emedial Investigation and
Feasibility Study resulted in the &rst Record of Decision
(ROD) ID be issued by the Agerq on September 30, 1988
for the NSCC Supe,Md site. The findings of Operable Uni
#2 Remedial lnvestigation!Feasibility Study led to the second
Record of Decision, rendered by the Agerq on September
30, 1990. As in Operable Unit 11 and Operable Unit #2, the
work performed for Operable Urit #3 is being pelfonned by National Starch & Chemical Corporation, the Potentially
Responsible Party (PAP). The engineering contractor hired
by the PAP ID conduct Operable Unit #3 work is rr
Corporation.
The NSCC site was proposed for irdusion on the
NaUonal PrtOf!lles List in Ap,il 1985 and finalized on the list in October 1989. The Site had a Hazardous Ranking System score of 46.51. Only
Sites with a Hazardous ~ System score of 28.5 or higher are eligible to be placed on the
National Priorities List.
SCOPE AND ROLE OF OPERABLE UNIT
WJT1ffi SITE STRATEGY
As with many ~ sites, the NSCC site is
complex. Consequently, EPA divided the work in1D
three manageable components caJed Operable
Units (OU). These operable units are:
OU-1 • Gl"Ollldwater in western portion of the
NSCC property
OU-2 • Trench Area soils and surface
water/sediments in the Northeast
Tributary
OU-3 • GrDln:tl¥ater/su1ace wate</sediments in
the areas of Nea 2, the lagoons, and the
Northeast Tributary
SITS DP 1'09. onuau tml"IT t l
on:um., aarr tl
Dfi<m.L ftUICII ' C2Dl:IC&L CODU'T ._.,...
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------------------······---
RESlA. TS OF THE REIIEDW. INVESTlGA T10N
FOROU-3
_ Three envil'0/lll8lllal mecia (soils, gn)\ll(t,vater, and SU'face
water/sediment) have been adversely impacted by contamination originali1g from lhe NSCC plant and from
past chemical hardng and <isposal practices of the facility.
The prima,y contamlnanl at lhe Sile Is t ,2-dlcllloroelhane
(1,2-DCA). This contaminant is known as a chlorina1ed
organic comf)Ollld lhatYOlatiizas readily and is classified as
a probable human carcinogen. A carcinogen Is any substance lhat can cause or contribule to the development
of cancer. Other organic chemlcals were also detected.
The chemicals of concern at the Site are (iSlad
· alphabetically): acem, bis (2-dlloroelhyl) ether, bis (2-
ethy1hexy1) . phttialate, 2-butanone, cadmium, carbon
disulfide, chloroform, chloroethane, delta-BHC, 1,2·
dichloroethene, <i-lHlU\y1 phttialale, <i-n«lyl phttialate,
ethyl benzene, methylene chloride, styrene,
tetrachloroethene, toluene, 1, 1,2-trichloroethane,
lrichloroethene, vi1yt clilride and total xylene. The folowing
inorgarics were also def8cled: alunirun, antimony, arsenc,
barium, berytlun, ct.-omun, cobalt. copper, cyaride, lead,
manganese, merw:y, nickel, selenium, thalium, vanadium,
andzilc.
The OU-3 soil investigation has generated ample information
to characterize the contamination, determine lhe source, and
define lhe extent of contamination in the vldos8 soi zone.
The vadose zone is comprised of subswface soi lhat is not
salllated wilh waler. The inleliaai between the vadose
zone and the sabzalad zone is commonly referred to as the water table. FOl.l188n differert wlatie organic comf)Olllds,
one sem~YOlalie organic compotnj, Md one pesticide were
detected in the vadose sols. The prina,y swce of
contamination in Area 2 were l:uied, leamg terra-cotta
piping used to ransport waste streams from tle production area to the treatment lagoons. The sout:e of the · contaminants deteeled in the lagoon area is the soi undet'.
and around the lagoons 'Micll were contaminated prior to
lhe lagoons being inea with concrele.
OU-3 defined the nalll'e of groundwater contamination (lhe
contaminants present an:! lhei-concentralions) but additional
woik is needed to completely define lhe extent of groimwater contamilation, especialy in lhe bedroek zone
of the aqwtw. The aqufer is slixivided into l'M>
inlercomecied zones, tle shallow zone and tle bedrock
zone, Boll of llese zones have been adversely inpacted
by acti'lities at the NSCC plant. Sixteen different YOlatile
organic comf)Olllds and fol.r semi-volatile orgaric
compounds were detected in the groundwater. GrolllCt,vater
in the shalow zone i1 lhe vlcimy of the lagoons is flowing at
an approximale speed of 80 feet per year. This rate slows
ID approximately 27 feet per year just east of the lagoon area.
The highest concentrations of contamilation detected in the
Northeast Triluta,y were found just east of the plant The
levels of these YOlatie organics decrease downstream as
these contaminants YOlaliize ilto Ile-atmosphere. TIIO
samples. one sllface water and one sediment, were
collecled from the Northeast TrbJtary just prior ID hi stream leavilg the NSCC property and flowing l.llder Airport
Road. No contaminants were detecled in tlese samples
which indicates lhat lhe ikaihood of contamination leavilg
the Sile via Sl.riace waler/sediment is milimaJ. Toe
apparent scxrce of lhe orgarics in !tis stream is the
cisdlarge of contamjnaled groundwater i1ID the stream.
lno<garics were detected in al ttvee of the eovirorrnental
mecia sampled (sois; "1)U1dwaler, and Sllface waler and
seciment). All of Ille metals delecled are nall.nlly ocwmg
and hl variation in concentrations detected does not
indicate the Site is releasing inorganic contamilants into tle
enviromlent.
Land 8....--~•c•
::-( (-==-=--·-•-,,___•-1--0 --, ~ Saprol l't. I
CC l cy) as. _,_::,
/
Fractured
W•nth•r-ed
Bedrock
S.dr-oct.::
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SUIIIIARY Of sm: mSKs
A task of lhe Remedial Investigation/Feasibility Study is ID
analyze and estimate the lunan health and envirorvnental
problems that could rasult ff 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 ff no ramedial action is
taken, EPA evaluates the raasonable maximum exposura
levels for currant and future exposure scenarios to Site
contaminants. Scenarios wera developed for residents fiving
on or near to the Site as weU as for employees working on
lhe Site. In conducting !his assessment, EPA focuses on
lhe adverse human heallh effects lhat could rasult from
long-terin daily, direct exposure as a result of ingestion,
inhalation, or dennal contact ID carcinogenic chemicals
. (cancer causing) as weR as lhe adverse heallh effects lhat
could result from long-tenn exposure to ~Ilic
chemicals present at lhe Site. EPA considers a long-tenn
resident beginning as a young child being exposed daily for
30 years ID be a reasonable maximum exposure scenario for
future exposure IO the NSCC site.
A goal of the NJ(lrq is ID reduce the risk posed by a
Superfund Site IO fewer lhan one person out of 10,000 being
al risk of developing cancer. This is the minimum risk lhe
Agerq will allow, typically lhe Agerq aspiras ID be even
more protective and stlives IO tower the risk so lhat at a
minimum, only one person out of one milion may be
adversely Impacted by lhe contamiration found at a
Superfund Site.
EPA has concluded lhat lhere are no major~ risks ID
human heallh at the Site. Exposure pathways evaluated in
lhe Risk Assessment wera ingestion, inhalation, and. direct
contact 10 contaminants in the soil, groundwater.and surface
water/sediment The only reason groundwater does not
pose a current risk is because the contamination in lhe
groundwater has not migrated beyond lhe property boundary
and consequendy, has not impact any private, potable weU.
Thera are no potable we Us located on Site.
However, thera are three unacceptable Mure carcinogenic
risks associated wilh lhe contamination at lhe Site. The first
scenario resulting in an ll1acceptable future risk is having
residents iving in homes built on or near the Site and using
lhe groundwater as potable water. Another unacceptable
future risk is the exposure of a child ID surtace water,
sediment, and spring water. The third unacceptable future
risk involves exposing individuals to contaminated
subsurface soil. The future residential use of lhe
groundwater would also result in an unacceptable future risk
due Ill lhe presence of noncarcinogenic chemicals in lhe
groundwater.
A semi-quantitative assessment of the Northeast Tributary
was also conducted as partof lhe Risk.Assessment This
environmental assessment inciuded chemical, ecological,
and 10xicological investigations of the surface water and
· sediment coUected from the Northeast Tributary. The data
generated by the environmental assessment fol.Wld adverse
ecological mpacts 'r1 araas ot lhe stream where elevated
levels of 1,2-0CA wera deledad, However, the assessment
could not conclude !hat lhe contaminanls originating from
the Site, primarily 1,2-DCA. are the sole cause of ths impact Thera is a strong indication that the nauaJly-lmiting
fae10rs of the stream itself results 'r1 lhe dinnshed runbers
of benthic (bottom-dweling) organisms In tis section of lhe Northeast Tributary. ·-co
REIIEDIAI.. ACTION OBJECTlVES
Remedial action objectives (RAOs) were developed based
on the results of lhe Risk Assessment, an examination of
potential Applicable o, Relevant and Appropriate
Requirements (ARARs), and threats to grOllldwater and
the Northeast Tributaly. Action-, location-, and
chemical-specific ARARs wera examined. Chemical-specific
ARARs for groundwater include maxJnun concentraaon
levels (MCLs) as specified in the Safe Dmking Water Act
and Norlh Carolina Grot.ndwater Standards. ~ summary,
the Remedial Action Objectives are:
FOR GROUNDWATER
For Human Health: Pravent ingestion of water
having concenvations of 1,2-0CA resulting i'I
cancer risks above acceptable lmits . . .
For Environmental Protection: None, groundwater
concentrations have not been louod 10 rapresent
an enwonrnentaJ hazard.
FOR SURFACE WATER
For Human Heallh: None, surface water is not a
drinking water SO!ml.
For Environmental Protection: No,.,, surface
water concentrations have not been identified as
the sole cause for the imited benthic populations.
FOR SEOIMEITT
For Human Heallh: Prevent direct contact wilh
sediments having levels of 1,2-0CA resulting i'I
cancer risks above acceptable lmits.
For Enworvnental Protection: None.
The objective of a remediation is to obtain stringent heallh
risk levels. For groundwater, al chemical-specific ARARs,
which include MCls and lhe Nor1h Caro1iia GrOIJldwater
Standards, wil be acneved where the specified
concentration is ECMica.ly detectable. The estinaled
volume of contaminated groimwater req,..iring rarnediation
is 131 mulion gallons.
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For more rnonnation about the Rem ediaJ Action Objectives
and altemati'18S for Iha NSCC OU-3 site, please refer to Iha June 21, 1993, Feastiity Study docunent and other documents available lor review at the Adminstrati'/8 Record
located at the Rowan Mic Ubraiy.
SUIIIIARY OF RE11ED1AL AI.TERNATlVES
The following section provides a summary of the alternatives
developed in Iha Feasibility Study (FS) Report. The l)linaiy
objective of the Feasibility Study was kl detennine and
evaluate alternati'18s for cleaning up the Site. Descriptions
. of the clean-up allernatives are summarized below. The Report contains a ll10l'8 detailed evalualion'description of each alternative.
The cost information provided below for each alternative
represents. estimated total present llOrU1 (PW) of each
alternative. Total presen1 Y«>l1h was calcuated by combining the capital cost plus Iha present WOl1h of the annual operating and maintenance (O&M) costs. Capital cost irdudes construdion, engineering and desi!11,
equipment, and silll development Operating costs W8l8
calculated for activities that continue alter completion of construction, such as routine operation and maintenance of . treatment equipment, and groir,dwalllr monitoring. The
present worth of an alternative Is the amooot. of capital required to be deposited at the present time at a given
interest rate to yield the total amOt.nt necessaiy kl pay for
initial construction costs and futlxe expenditures, irduding
operation and maintenance and~ Jture replacement of capital equipment.
REMEDIAL ALTERNATIVES TO ADDRESS GROUNDWATER CONTAMINATION
The. groin!walllr remedial allematives for addressing contaminated gr0\lldwalllr were considered separalely for Area 2 and Iha lagoon area. Area 2 altematives are identified by "P" for. Iha Plant and Iha alternatives dealing
wilh Iha contaminated gr0\lldwalllr associated with Iha
lagoon area are identified by "L".
ALTERNATIVES GWP1 AND GWL1: No Ac11oll
Capital Costs:
Annual O&M Costs:
Total PW Costs for 30 Years:
Time to Desi!11:
ConsructionTllll8:
DI.ration kl Achieve Clean-up:
$ 0
$ 22,000
$ 227,000
None
None
Over30yeara
CERCLA req..ires that the "No Action" alternative be
evaluated at every Supemn:t Site to establish a baseli'e for
comparison. No flr1t1er activities wolid be conducted Ylitl
regard kl Iha 1)1'0\Rt«ater benealh Iha Site ~ this
allemative ~.e., lhe Site Is left ·as 1s1-Because flese
alternatives do not entail cornaminant removal or destruction, a review of Iha remedy woud be conducted ev8f}' Ive years
in accordance "MIil CERCLA Section 121(c). Operaoog
· costs are based on conducling tis review every live years which includes monitoring Iha gnx.rdwalllr ooder Iha Sile once every five years b' a period ol 30 years.
ALTERNATIVES GWP2 AND GWL2: LONG TERII
IIONITORJNG, 1'ENCM; A PollTloli OF NoRTIEAST TliBVTARY
Capital Costs:
AmJ3I O&M Costs:
Total PW Costs for 30 Years:
Time to Design:
Construction Tllll8:
DI.ration kl Achieve Clean-up:
$ 178.000
$ 138~
$1,479.000
None
None
Over 30 years
These al1ematives are siniar to Allematives GWP1 and GWl.1, except tllder Altematives GWP2/GWL.2 additional
monitoring wells woud be instaled.11!)1Jldwal9r monitorilg
data woud be colecEd amJaly nstead of once every five years, and a portion of the Northeast Tributary "M>uld be fenced.
ALTERNATIVES GWP3 AND GWL3: 1NSrmmo1w.
Colm1oLs, FEliCIIG A PoRTION OF NoRTIEAsT TRiBvrARY
Capital Costs:
AnooaJ O&M Costs:
Total PW Costs for 30 Years:
Tlll18 to Desi111:
ConS#l.dionTlll18:
DI.ration kl Achieve Clean-up:
$ 198.000
$ 138,000
$1,500.000
None
None
Over 30 years
These allllmalives for 1)1'0\Rt«ater contamination in Nea 2
and lhe lagoon area are i:lenlicaJ to Allematives GWP2 and GWl.2, except Alilrative GWP3/GWL3 ilcludes institulional
controls. No reme<iation activities YIOUd be conoocted for
grNldwater. The additional costs are associated wilh
preparing and Ung deed resn::tion(s) and inplementing Ille
other institu1ional conrols. The specific institutional controls
to be implemermd include: using deed restnctions kl control
the installation of new wells on both Ile plant property and ~ property; track pune migration; and install fencing
arOUld lhe Noltleasl Tributary kl lin1it access D contaminaild suface water and seament. A •pune· is the discharge of a contaminant from a gven point of origin in water or ai', for example, smoke from a smokestack.
These allllmaoves provide no reduciioo in 'IQUT\8, mobility · or l:lxicity of lhe contaminants, however, they can reduce or
eliminate ~ expo51.r8 p.!Mys and the resutant risk kl
the p,.blic. As part ol lhese altemalives, the ~lllr
wolid be mooit0rad on a )'8al1y basis. As EPA may not
ha'/8 the auth)rity kl inplement these i1stiUJtional controls,
the respor,sibiitf rests with Ile Stale ol North Caroina kl
8l1SlJ'8 lhe institutional conuols are in place, are reliable, and will remai'l n place a/lllr ntiation of O&M. Theretore, the responsbity tor inpllementing and enlotting instiMionaJ
controls faJJs on Ile Stai! of Holtl Carolina. Grou'ldwater
moritoring and Ive '.l'8a' CEACLA reviews wolid be
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conducted for 30 years. The O&M cost is for both Area 2 and the lagoon area.
ALTERNATIVE GWP4A: GROVIONATER ExrRN:rloN
THROUGH WEus AND TREAT/ENT BY AIR STRl'PIIG WITH V APOII-PHAsE CARBON ADsollPrloN
Capital CoslS:
Annual O&M Costs:
Total PW Costs for 30 Years:
nme to Design:
Construction nme:
Duration to Achieve Clean-up:
$ 648,000
$ 306,000
$2,222,000
1 year
6 months
15 to 30 years
This alternative ilcludes exracting gro!Xldwater by means
of extraction wells downgradient of Area 2; volatile organics
removal through ai stripping; control of emissions to the
atmosphere from hi air strwer through vapor-phase
carbon adsorption; and coml:ined discharge with treated
groundwater from OU-1 to the Salisbury publicly owned
treatment works (POTW). The treated effluent must meet
permit UmilS set by the Saflsbury POTW. Spent activated
carbon. would be changed out and sent to a commercial
regeneratiorvrecyding faciUty. The five year review CERCLA
requirement would apply to this alternative.
ALTERNATIVE GWL4A: GROIMDWATER EmlAcnoN
WELLS, TREAT/ENT BY AIR ST1I/PPING lfflH VAPOR-PIIAsE
CARBON ADsollFTIOII
Capital Costs:
Annual O&M Costs:
Total PW Costs for 30 Years: nme to Design:
Construction Tune:
Duration to 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 gro!Xldwater associated
with the lagoon araa.
ALTERNATIVE GWP48: GROUMJWATER Exn!ACTJON
WELLS, TIIEATIENT BY AIII S71ul'PINo WITH FlillE
IHCINERATION
Capital CoslS:
Annual O&M Costs:
Total PW Costs for 30 Years: nme to Design:
CoostriJGtionTime:
Duration to Aclveve Clean-up:
$ 766,000
$ 299,000
$2,274,000
1 year
6 months
15 to 30 years
This alternative is identical to Alternative GWP4A. except
that the control of emissions to the atmosphere from fie air
stripper woud be accomplished througi fllne ncineration.
ALTERNATIVE GWL48: GRO/MDIYATER EmlAcnoN
WELLS, TREAT/ENT BY All SrRIPPIIIG WITH Fl.tlE
IHCIIIERATION
Capital CoslS:
Annual O&M Costs:
Total PW Costs for 30 Years:
nme to Design:
Construction Time:
Duration to Achieve Clean-up:
$ 913.000
$ 360,000
$2,996.000
1 year
6 mon1hs
20 years
This al1emalive is identical to Al1emalive GWP4B except for
lhis alternative adcresses contamimted _.groimwater
associated Yli1h the lagoon araa. -
ALTERNATIVE GWP4C: GROUIDWATER EXTRACTION
WELLS, TREAT/ENT BY~ CARBON AlJsoRFTIOII
Capital CoslS:
Annual O&M Costs:
Total PW Costs for 30 Years:
Tune to Design:
Construction nme:
Duration to Actveve Clean-up:
$ 788,000
$ 432,000
$4,305.000
1 year
6 months
15 to 30 years
This alternative ildudes extracting ~tar by means
of extraction wells downgradient of Anea 2; volatile organics
removal tlvough iqljd-phase carbon adsorption and combined discharge wi1h treated grotr,aw'ater from OU-1
discharge to fie Salisbury POTW. The lreated effluent must
meet permit limilS set by fie Salistuy POTW_ Spent · activated carbon wood be regenera1ed. The five year
review CERCLA requiremant v.oold apply to this al1emative.
ALTERNATIVE GWL4C: GROIMDWATER EmlACnON
WELLS, TREAT/ENT BY l.JoUl>.PHAsE CARBON ADscRPnoll
Capital CoslS:
Annual O&M Costs:
Total PW Costs for 30 Years:
Tune to Oesigl:
Construction TN118:
Duration to Achieve Clean-up:
$ 987,000
$ 941,000
$8,375,000
1 year
6 monlhs
20 years
This al1emative is idenlcal ID Mlmalw GWP4C except this
alternative addresses ~1er associated
with the lagoon araa.
ALTERNATIVE GWLSA: GROIMDWATE11 EmlACnON
WELLS, TREATIENr BY AIR ~ WITH VAPOlf-PHAsE
CARBON ADscRPTION, IH-SmJ 8/oREJEDIATION REol.JIRING
GROUIDWATER INJECT"KJN OF MmliENTs
Capital CoslS:
Annual O&M Costs:
Total PW Costs for 30 Years: nme to Design:
Construction Time:
DI.ration to Actveve Clean-up:
$1,003,000
$ 798,000
$7,4T7,000
1 year
6 monU1s
15 to 30 years
This alternative ildudes extacing ~ter by means
of exlradlolT wels locaEd downgader1t of hi lagoons;
volatile orgallCS removal ttroug, air slripping; cootrol of
I !-' I I ·I I · I I I ,. ·-----------------~ ----· ------------------emissions tl the almosphere from the at stripper, lhrough vapor-pi'lase carbon adsorption; combining a portion of lhe discharged grollldwaterwilh llllated grot.lldwater 1rom· OU· 1 for discharging tl the Saistuy POlW, polisling the remaining portion of Ile grot.lldwater by at stripping tl cleanup goals before lr;ldlrlg lhe llllated grou,dwaler along wilh nutriel11s inlD lhe contaminated area ti promote In-situ biodegradation of Ile contaminants. "n-sibf means to keep in place Q.e., the llllalmenl is conducted In its origiial place). The llllated effluent being discharged to lhe Saistuy . POlW must meet penM imits set by the Salisluy POlW. Spent activated carbon would be regenerated. The five year review CERCLA requirement would apply ti this alternative. ALTERNATIVE GWL5B: GIIOIMDWATBI EXTRACTION WELLS, TliEATIENr BY All STRIPPING WITH .FIJIE INC/NERA no 11, IN-Sm/ BIOREIIEDIA TION REQUIRING GROUMJWATER IHJECTION OF Mml1ENrs Capital Costs: AnriuaJ O&M Costs: Total PW Costs for 30 Years: · Time to Design: Construction Time: Duration to Ameve Clean-up: $1,365,000 $ 733,000 $7,000,000 1 year 6 monlhs 15 to 30 years This alternative is sinilar to Altemative GWL5A except control of emissions of the vapor coming from the first air stripper would be accomplished hough the use of a II.me incineration. ALTERNATIVE GWL.5C: GIIOUIDWATBI EXl'RACTION THROUGH WELLS, TliEATIENr BY UOIJID.l'HAsE CMBOII ADSORPTION, IN-SITU 8/0REMEDIATION REQUIRING GROUMJWATER INJECTION OF MmliEHTs Capital Costs: AnriuaJ O&M Costs: Total .PW Costs for 30 Years: Time to Design: Conslruction rune: DI.ration ti Acnew Clean-up: $1,216,000 $ 1,631,000 $13,853,000 1 year 6 months 15 to 30 years This allemative includes extracting grot.lldwaler by means of extraction W8ls loealed downgradent of the lagoons; volatile organics removal lhrough ~ carbon adsorption; combirwlg a portion of lhe cischarge v.ilh reated groundwater from OU-1 for clscharging ti the Salisbury POTW; the remaining portion of the teated grOllldwater would be re-irflciad, along wilh rutrients, back ntll the contaminated area to promote in-sitJ biodegradation of tie contaminants. The treated effulnt being cischarged tl hl Salisluy POlW 'Mil meet perm~ linits set by the POTW. Spent activated carbon wolid be changed out and sent to a commercial regeneration taciity. The fMI year review CERCLA requi"ement wolid apply. The teated effluent must meet permij linits set by tie POIW. · The live year review CERCLA ~ent wolid apply tl this allllmative. ----•-••••••------•--•--•--~•••·r~----~-. REIIEDIAI. ALTERNA11VES TO ADDRESS SURFACE WATER AND SEDIIIENT CONTAIIINATION ALTERNATIVE SW1/SD1: No Acnoll Capital Costs: Amual O&M Costs: Total PW Costs for 30 Years: Time to Design: Construction Time: Duration ID Achieve Clean-up: $ 0 S 16,000 $1~1,000 None None Over 30 years No fl.flher activities woud be conducted on Sllface water or the sediment in the Nc~~asl Tributary. As v.ilh Alternative GWP1/GWL 1, lhis stream wood be left ·as is'. Samples would be colected and analyzed 81181)' live years as part of the live year review CERCLA recµrement which aw!Y kl this altematiYe. ALTERNATIVE SW2/SD2: l.ONG-TERM Mo/lTORMG Capital Costs: Amual O&M Costs: Total PW Costs for 30 Years: Time to Design: Construction Time: DI.ration tl Ameve Clean-up: $ 0 $92,000 $867,000 None None Over 30 years This alternative is siriilar to Alternative SW1/SD1, except lllder Alternative SW2/S02, SIJ'face water and sediment samples would be colected from the Northeast Tributaiy am.ially ilSl8ad of once 81181)' five years. CRITERIA FOR EVALUATltG REIIEDIAI.. ALTERNATIVES EPA's selection of 1he preferred~ allemative for the NSCC OU-3 site, as desaibed in tis Proposed Plan, is the resut of a comprehensive evaluation and screenng process. The Feasibility Study for tie Sile was conoo::ted to identify and analyze lhe allllmatiYes considerad for addressing contamination at the Site. The Feasibiity Study and other docunents for the NSCC OU-3 sis describe, in detai, the allematives considered, as wel as the process and aileria EPA used tl narrow 1he list kl potaotial remeciaJ alternatives to address the Site contamination. As stated previously, all ol these docunents are ava.iabie for ~ review in hl information reposiilly/admirisuative record. Allematives GWP4C, GWL4C, GW\.5A, GWLSB, and GWLSC W8f1I not retailed lor te detailed analysis because the other allemaMs, wolid achiew tie same deg8e of proleetion tor tunan h8altl and the envilOmlent but at a substantially lower cost EPA always uses the k>l1owvlg rvne a1tena ti 8'/aluae allllmatives identified in hi Feasbity Study. The remed.al allllmative seleded b' a ~ sile must actieve the
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two ttveshold criteria as well as attain the best balance
among the fi'l8 evaluation criteria. The nine criteria are as
foUows:·
THRESHOLD CRITERIA
1. Overall protection of human health and the
environment The degree to 'Mlich each
alternative eliminates, reduces, or . controls
thraats to public health and the envitolvnent
ttvough treatment, engineering melhods or
institutional controls.
2. Compltance With Applicable or Relevant and
Approp!1ate Requirements (ARARsl: The
alternatives are evaluated for compliance with all
state and federal envirorvriental and public health
laws and requirements that apply or are relevant
and app.,opriale kl the site conditions.
EVALUATING CRITERIA
3. Cost: The benefits of inplementing a particular
remedial alternative are weighed against the cost
of implementation. Costs irdude the capital
(up-lront) cost of implementing an alternative over
the long term, and the net prasent worth of both
capital and operation and maintenance costs.
4. lmplementabUlty: EPA considers the technical
feasibility (e.g., how difficult the alternative is kl
construct and. operate) and administrative ease
(e.g., the amooot of coordination with other
government agencies that is needed) of a remedy,
including the availabi~ty of necessary materials and
S8rlices.
5. Short•tenn effectiveness: The length of time
needed kl implement each alternative is
considered, and EPA assesses the risks that may .
be posed lo workers and neartly residents during
construction and implementation.
6. Long-tenn effectiveness: The alternatives are
evaluated based on their ability to maintain reliable
proleetion of l)li)ic health and the environment
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 (1) the hannfu natura of
the contaminants, (2) their ability kl move tlvough
the envrom,ent, and (3) the volume or amolllt of
contamination at the site.
MODIFYING CRITERIA
8. State acceptance: EPA requests state comments
on the Remedial ffitlstigation and Feasibility
Study reports, as well as the Proposed Plan,
and must take Ink> consideration whether the
state conan ..-;tt,, opposes, or has no comment
on EPA's preferred alternative.
9. Commmlty acceptance: To 8f1Sll'8 that the
public has an adequate oppol1Unity kl provide
input, EPA holds a Plilic comment period and
considers and responds to all comments received
trom the community prior kl the fi1al selection of a
remedial action.
EVALUATlON OF Al.1ERNA11VES -~ ~
The following summary profiles the performance of the
preferred alternatives n terms of the nine evaluation criteria
noting how It compares kl the other alternatives under
consideration. The comparative analysis for the
groundwater remediation alternatives is as foUows:
GROUNDWATER REMEDIATION
The lollowing alternatives were su!Jjecled to detailed
analysis for migration corrtrol:
/Jtemattva GWP1: No action with regard to the
grooodwater in Area 2
IJtemaUve GWP2: Long-Term Groundwater Monitoring of
in Area 2 with Fencing A Portion of Northeast Tributary
IJtemaUva GWP3: · Institutional Controls with regard lo the
grol.fldwater in Area 2 with Fencing A Portion of
Northeast Tributary
/JtemaUva GWP4A: Grooodwater Extraction Through
Wells Downgradient of Area 2 and Treatment By I.Jr
Strwng with Vapor-Phase Carbon Adsorption ¥with
Combined Discharge to the Saisbury POTW
/JtemaUva GWP4B: Groundwater Extraction Through
Wells Downgradient of Area 2 and Treatment By I.Jr
Strwing With . Fume ilcineration ~th Combned
Discharge to the Salsbury POTW
AJtamaUva GWL 1: No Action with regard to the
grOUldwater in the lagoon area
A11ema11vt GWL2: Long-Term Grol.fldwater Momoling of
in the lagoon area ¥with Fencing A Portion of Northeast
Trt,utary
Abmallva GWL3: Institutional Controls with regard lo the
~tar i1 the lagoon area with Fencing A Portion
ot Northeast T rbJtary
/JtemaUve GWUA: Grooodwater Extraction Through
Wells Oowngradient of the lagoon Area and
Treatment By "6 Stripping with Vapor-Phase Carbon
Adsorption with Combined Discharge kl the Saisbury
POTW
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AltemaUve.GWL48: Grot.ndwaler Ex1laction Through Wells Downgradienl of hi Lagoon Area and Trealment By
Air Stripping With Fl.Ille ~ration with Combined
Discharge to the Saisbuy POTW
Overall Protection: AlanaMs GWP2, GWl.2, GWP3,
GWL3, GWP4A, GWUA, GWP48, and GWl.48 provide
adequate protection for tunan health by preventing
ingestion of potentialy contami1aled Q1'01mWa1er and
surface water. AJtematives GWP4A, GWP48, GWL4A, and
GWl.48 would afford the grealest prolection kl tunan health
because tt would substantially reduce the contamination in
the groundwater and prevent the potential for exposure
through use of existing or lub.la rff site weas. AJtematives
GWP4A. GWP48, GWL4A, and GWl.48 would also
remediate the surface water and sediment, which would
eliminate the potential for exposure via ingestion of these
media. These allematives protect the enwmnent by
removing contaminants from grwidwaler, controling the
extant of groundwater contamination, and reducing the
contamination in the ~ and downstream surface
waters. Neither Alternatives GWP3 nOf GWL3 would protect
the envil'OMlent because contamination would continue kl migrate into the tributary ltv'ough gr01Jldwaler discharge.
None of the Allernatives GWP1, GWL 1, GWP2, or GWl.2
wil provide protection for either tunan 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 amooot and concentration
of contaminants.
Compliance with ARARs: A11ematives GWP4A, GWP48,
GWL4A, and GWL48 would obtain pertonnanc:e standards
for gr0Uldwatar (MCLs and North Carolina Grolrldwater
Standards), surtace water and sedment at the poilt of
compliance. These aJlematives would also comply with location-and action-specific ARARs related kl the discharge
to the POTW and ai' emiSSion corwols. Alternatives GWP1,
GWL 1, GWP2, GWl.2, GWP3, and GWL3 are not expected to meet pertonnance siandalds at the point of compliance,
however, Alternatives GWP3 and GWl.3 would comply with
the location-specific ARAR related kl operations at a
hazardous wasil site.
-Long-term Effectiyeneff and Permanence: AJtematives
GWP4A, GWP48, GWL4A, and GWl.48 would provide an
effective and pennanent solrtion for 11QOOdwater, surface
water, and sediment because the chemicals of concern
would be removed from the grwidwater and destroyed.
The reliabity of these aJtamatives is 11¢ These
alternatives would not pose a tunan health or
envil'OMlentaJ risk at the poiri of compiance and no
treatment residuals would be left on Site. Alternatives
GWP3 and GWl.3 would prevent potentiaJ fu1ll'e risk by
preventing the installation of aildng wells in any areas
exceeding MCLs or North Carolina Grcx.r,q«ater Slandards.
Allematives GWP1, GWl.1, GWP2, and GWl.2 wil not be
protective of lunan health and lhe enviroMlenl in the long
term because these altamatives do not remove, real, !lr
. Isolate subsi.rface contamination. Five-year CERCI..A
mandated reviews wil be r8ql.ired for al of the alanatives.
Reduction of Toxicity, Moblty or Voune: Alternatives
GWP4A, GWP48, GWL4A, and GWl.48 would l8<iJce the
toxicity and YOlllne of contamination In~ ltroc.qi
removal and trealn)ert. They would aso 18<iJce the klxicity
and vo11.111e of contamination in swface water and S8Clmenl.
Allematives GWP1, GWl.1, GWP2, GWl.2, GWP3, and
GWl.3 do not cfrectly nwce klxici1y, moliiity;« ~ of
~. Sllface water or sedinelt c:ontarnimtion.
Short-term Eflectiveness: All of the alternatives can be
implemented without sigrificant risk to the comrmr,ity or
on-site WOl1<ers and without adverse environmental impacts.
Implementability: None of the allematives pose Significant coni:enis regarding inplementation.
Cost Total present worth costs (based on 30 years) for the groundwater aJlematives are presented below:
AltemaUves GWP1/GWL1 -No action: $227,000
AJtemaUves GWP2/GWL2 -Long-Term Monitoong with
Fencing A Portion of Northeasl Tribuary:
$1,479.000
AltemaUves GWP3/GWL3 -Institutional Controls with
Fencing A Portion of Northeasl Tribuary:
$1,500.000
A1t8ma11vt GWP4A • Glw1dwater Ex1ractior/Alr
Strwii'9'Vapor-Phase Cartlon Adsolption/POTW
Discharge: $2,222,000
AJtemaUve GWP4B -GrOllldwater Ex1ractior/Alr
Sbippi~e lncineratior\'1'0TW Discharge :
$2,274,000
AltemaUve GWL4A -Gr0U1dwaler Extraction/Ai"
Strwil'9'\lapor-Phase Cartlon Adsolption/POTW
Discharge: $3,570.000
AltemaUve GWL4B -GrOlildwaler Extraction/Ai'
Stripping/Fume lncineration/POTW Discharge:
$2,996,000
SURFACE WATER/SEDIMENT
The following aJlematives were Sl.t;ecild to detailed
analysis for suface wailf and sedimen remeda1ion:
Alternative SW1/S01: No Action
AltemaUve SW2/S02: Long-Tenn Morlbing
Overall Protection: lxlder present conditions. both
Alternatives SW1/S01 and SW2/S02 W0Ud be proective of
lunan health, bli may not be~ ol the enworment.
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If higher concentrations of contaminants are cischarged ini>
Ille stream from hi groll'ldwater, then nei1her alteinative
may be prollletiw of tunan heaJlh 110( lhe enworvnent
Compliance with AAAAs: There are no Federal or State
ARARs for Ille contamnants deteded in lhe surface water
or sediment
Lonq-tenn Effectiveness and Pennanence: Under cirrem
conditions, Alternatives SW1/S01 and SW2/S02. would be
prollletiw of human heal1h bu1 possibly not the ell'liroMlenl
If higher concentrations of contaminants begin discharging
into the tributary, none of lhese alternatives may be
prollletiw of human heaJlh.
Reduction of Toxicity, Mobility or Volume: Bolh Alternatives
SW1/SD1 and SW2/SD2 could lead to a reduciion of volatile
contaminanl6 11 lhe tributary, however, nei1her of lhese
alternatives would resut In lhe c.iestruction of the 'IOlatile
contaminants. These contaminants would be transferred
from lhe tributary to lhe almosphere lfYough lhe process of
volatilization.
Short-tenn Effectiveness: All of lhe alternatives can be
implemented without significant risk t> lhe comml.flity or
on-site worxars and without adverse environmental impacts.
Implementability: None of the aJtematives pose sigrlfican1 · concerns regarding inplementalion.
Cost Total present worfl costs (based on 30 years) for the
Slrtlce water/sediment altsmalives are presented below:
AltemaUve SW1/S01 -No Action: $151,000
AltemaUve SW2/S02 -Long-Tenn l.brlomg: $867.000
State Acceptance: The NCOEHNR has niviewed and
provided EPA wilh comments on lhe reports and data from
the RI and lhe FS. The NCOEHNR has also reviewed 1tis
proposed plan and EPA's preferred alternative and presently
concu-s with EPA's selectioi1.
Community Acceptance: CommLrity acceptance of lhe
preferred altemati\18 wil be evaluated after hi pubic
comment period ends and a response to each comment wil
be lncfuded In a Responslwness Swrmary v.tich wil be
a part of the Record of Decision (ROD) for lhe 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 EP~ preferred alternatives are:
GROUNDWATER REMEDIATION
ALTERNATIVES GWP3B AND GWL3B: Long-Term Monitori~titutional Controls; ALTERNATIVE GWP4B: Groundwater Extraction Through Wells and Treatment By Air Stripping with Fume Incineration; and ALTERNATIVE GWL4B: Groundwater Extraction Through Wells andTreatinent 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 WATE.Ri'SEDIIIENT
ALTERNATIVE SW2/SD2: Long-Term Monitoring Cost: $867,000
An active groundwater remediation alternative 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 could change in response to public comments.
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COIIIIUNITY PARTICIPA 110N
EPA has developed a commlllity relations program as mandaled by Congress~ Superlund 10 respond 10 citizen's concerns and needs for lntomiation, and to enable residents and public officials 10 parttj)at8 in hi decision-making process. Nllic involvement activities llldertaken at Superlund sites consist of inlerviews with local residents and 8'ecied oflicials, a commlrity relations plan for each site, fact sheets, avaiabiity seSSlons, pubic meetings, puiic comment periods, newspaper advertisements, sile visits, and Tecmlcal AssiSlance Grants, and any other actions needed 10 keep the commlrity informed and i1volwd.
EPA is conducting a 30-day public convnanl period from July 19, 199310 August 17, 1993, 10 provide an opporlillityforpublic involvement in selecting the final deaoop method for llis Site. Public input on all altematives, and on the infonnalion' that~ the alternatives is an important contribution 10 the remedy selection process. During this comment period, the public is i'1vi1ed 10 at1end a public meeting on August 3, 1993, at the Agricu1uraJ Extension Center Aucitorit111, 2727 Old Corolld Road, sar151xxy, North Carolina begiming at 700 p.m. at which EPA will present the Remedial lnveStigatio!V Feasibiity Study and Proposed Plan . describing the preferred alternative for treatment of the contamnated gr0111(Mater at the National Starch & Chemical Company Superfund Site and ID answer any questions. Because llis Proposed Plan Fael Sheet provides ony a summary description of the cleanup alternatives being considered, the public is encolJaQ8d 10 consult the infonnation reposiloly for a more detailed explanation.
During this 30~y period, the public is inviled ID review all sile-relaled dorunents housed at the information reposiloly localed at the Rowan County Public Library, 201 West Front Stree~ Salistuy, North Caroina and offer comments 10 EPA either oraly at the public meeting which wil be r8COOled by a C0\lt repolllr or in written form m,g this time period. The adual remedial action could be different from the preferred alternative, depending upon new infonnation or statements EPA may receive as a resut of public comments. tt you prefer 10 submn written comments, please mail them poSlmarked no later t.an midriglt August 17, 1993 to:
D/an//Banett
NC Comnxmlty Flelatlons Coordinator
U.S.E.P.A., Rsglon 4
North R8m«IJa/ SI.J»rfund Branch
345 Court/and 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 claanup,watmenl of the Sita. EPA's final choice of a remedy will be issued in a Record of Decision (ROD). A dorunent called a Responsiveness SUmnary summarizing EPA's response 10 al JU)lic commenls wil also be Issued with the ROD. Once the ROD is signed by the Regional Admili51rator l wil become part of hi Admilistrative Record (located at hi Library} which contails all documents used by EPA in making a final detennination of the best cleallJp,t8atme for the Sii!. Once the ROD has been approved, EPA wif begin negotiations with fie Poeendally ll8sponsJble Parties (PRPs) 10 allow l1em fie opportLr,ity 10 design, implement and absorb al costs of the remedy delellnined in the ROD in accordance with EPA guidance and protocol. tt negotiations do not resut in a setllernenl, EPA may conduct the remedial activity using Superuld Trust monies, and sue for reimtusement of ltS costs with the assistance of the Department of Justice. Or EPA may issue a lllialeral aaninistrative order or directly file suit to force the PRPs 10 conduct hi remedial activity. Once an ageemer,t has been reached, toe design of the selected remedy will be developed and implementation of the remedy can begin. The preceding actions are the standard procedures utilized do.Jing the SupelMd process.
As part of the Sup8IUld pl'OlµITI, EPA provides affeCled commlrities by a Supertlnl site wi#l the opportLr,ity 10 apply for a Technical Assistanc:e Grant (TAG). Tlis grant of 14110 $50,000 enables the gro14110 hill a tacmical advisor or conSlAtanl 10 assist them in interpreting or commenting on site findings and proposed remedial action plans.
For more infonnation concerning this grant program, please contact:
Ills. Hosematy Pattoi1, Coordinator
NC TIClncal Asslstal1Cf Grants
Wast, llanagemtnt Division
U.S.E.P .A., Region 4
345 COllllland Street, NE
Atlanta, GA 30365
[phone]
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INFORMATION REPOSITORY LOCATION: ..
Rowan CoCA1ly Public Library
201 West Fisher Street
Salisbury, North Carolna 28144
Phone: {704) 633-65711
Hours: llonday • Friday 8:00 un. · 9:00 p.m.
Slllnay 9:00 a.m. • 5:00 p.m.
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FOR IIORE INFORMATION ABOUT SITE ACTIVTilES, PLEASE CONTACT:
llr. Jon Bomholm, Remedial Project llmiager or
11s. Diani Barrett, NC Comnullty Relations Coordinator
North SUperfund RemedJal Branch
Wasta llaiagemert Division
U.S. Enmlmlerul Plalactk>n Agalc:y, Region IV
345 Cour1land S1r8et, NE
Allanla.Ga30365
ToD Free No.: 1~
GLOSSARY OF 1ERIIS USED IN THIS FACT SHEET
Aquffsr: tv, ~ geological lonnation, or group of formations, con1ainnQ usable amOUlls of ~tar that can Sl.WIY weas and springs.
AdmlnlstralJve R«ord: A fie wlich is maintained and contains all W"bmation used by the lead agency m make its decision on the seleclion of a method m be utiizad m clean up,wat contanw1don II a ~ sile. Thi& fie is held in the information repository for public review.
AppllcalM ar Rel•vint I/Id Approprl6IS Rsqulremants (ARA/la): The lederal and stail ~ that a seled8d remedy must allait These reqliremenls may vary among sms and various ~
8-llllll R&t Ass • ,illl'lt: A means of estimatilg the amot.Jll of damaQe a ~ sile coud C3IISll to l'unal1 heath and the envirom1ent. ObjecUves of a risk assessment are m: help determrie hi need tor action; ~ detennine the leYeli of chemicals that can remain on toe sits aflef cteaoop and stil prol9ct health and tie enwomient; and provide a basis for comparing tiffef9nt cleat'4) methods.
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· Carcln~llll: Any substance that can cause or con1ribute 10 the production of cancer; cancer-producing.
Comprehensive Environmental Response, Compensation and Liability Act (CERCLA): A federal law passed in 1980 and modified il 1986 b'f Ille Superfund Amendments and ReaU1horization Act (SARA). The Acts craaled a special tax paid by producers of various chemicals and oi products that goes into a Trust Fund, commonly known as Supernr,d. These Acts give EPA Ille authority to imestlgate and clean up abandoned or lllC001roled hazatdous wasle sites utiizilg money from Ille Superfl.l1d Trust or by taking legal action 10 forte parties responsible for Ille contamination 10 pay for and clean ~ hi si1e.
Groundwater: Water found beneath Ille 8a/1h's surtace that fills pores between materials such as sand, soi, or iµvef {usually in aquffers) which is ottan used for supplying wells and springs. Because groundwater is a major source of dtinking water lhere is growing concern over areas where agricultural and industrial pollutants or substances are getting into groundwater.
Hwrdous Ranlclng System (HRS); The principle saeening 1001 used by EPA to evaluate risks 10 public health and Ille environment associated with hazardous waste sites. The HRS calcufates a score based on Ille potential of hazardous subslances spreading from Ille site through the air, SUlface water, or groundwater and on other faciors such as nearby population. This score is Ille primary factor in deciding ff Ille site should be on Ille National Priorities List and, ff so, 'lltiat ranking ij should have compared to other sites on tie 1st.
Information Reposltor,: A file containing accurate up-to-date ilformation, teclYlical reports, reference documents, information about the Technical Assistance Grant, and any other materials pertinent 10 lhe site. This file is usually located in a public buiding such as a library, city hall or school, that is acoessible for local residents.
Maximum Contaminant L.svllls (MCl.s): The maximum permissible level of a contaminant in water delivered to any user of a public water system. MCLs are enforceable stlndards.
National Pollutant Dlscharpe Elimination System (NPDES): A provision of the aean Water Act which prohibits the discharge of pollutants into waters of the Inked Slates unless a special permit is issued by EPA. a state or {where delegated) a tribal government on an Indian reservation allowilg a con1rolled discharge of liquid after tt has ~ treatment.
National Priorities List (NPLJ: EPA's list of Ille most serious uncontrolled or abandoned hazatdous waste sites identified for possible long-term remedial action IXlder Superfund. A site must be on Ille NPL to receive money from the Trust Fund for remedial action. The list is based primarily on the score a site receives from the Hazard Ranking System (HRS). EPA is requi.red to update the NPL at least once a y8N.
Potsntlally Respons/ble Pat1les (PRPs): My ildividuaJ or company • including owners, operators, lranSporfllrs, or generators • potentially responsible tor, or con1Jibuting to, Ille contamination problems al a Superfund site. Whenever possible, EPA requires PRPS, through administrative and legal actions, 10 clean up hazardous waste sites PRPs have contaminaled.
Remedial /nvest/gstlM'Feaslb/Uty Study (Rl/FS): The Remedial Investigation is an irHlepth, extensive sampling and analytical study to gather data necessary to detennine tie nalure and ex1ent of contamination at a Superlln1 site; 10 establish criteria for cleaning up the she; a de~tion and analysis of Ille potential cleanup alternatives tor remedial actions: and support the lechnical and cost analyses of the alternatives. The Feasibiuty study also usually recommends selection of a cost-i!ffective al1ennative.
Record of DBClslon (ROD): A public document thal amounces and explains which method has been selected by the ¾feocy to be used at a Super1lr,d Sile to clean ~ the contamination.
Responsiveness Swmwy: A summary of oral and written public comments received by EPA during a public comment period and EPA's responses 10 those comments. The responsiveness summary is a key part of the Record of Decision.
Ssm/•VolatJ/s OrpanJc Compowds (SVOCs): Carbon~ng chemical compounds thal al a relatively low temperalure, fluctuate between a vapor state (a gas) and a liquid state.
Volatile OrpanJc Compounds (VOCS): Any organic compound that evaporates readily into the ai-at room temperature.
Water Table: The level below which the soil or rock is sattraled with water, somlimes referred to as Ille upper SUlface f the saturated zone. The leveJ of grol.vidwater.
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MAILING UST ADDmONS
If you are not already an OCI' maJD~ Ust 111d would Ilka to be placed an the 1111 to l'ICelvt futll'e lnfomlallon an the Na11onal Stan:11 & a.nc:al ~ ~ SIii, pl81188 C0111)18111 llu form 111d l'81Um to Illa» a.ratt, Conlnunlty Relatlons Coordinator II the above lddrlss:
NAME-·-----------------------------
ADDRESS,-· ----------------------------
CITY, STATE, ZIPCODE: ___ "'----------------------
PHONE NUMBER_·--------------------------
U.S. Envnvnonlol PftlloCliaa AQt,,cy :145 c.u.1land SlrNI, N.E.
Allarlla,Goorg11'°"5
-~-a..... ' 01.-lllmll, Carnrrlnly-c-d.
,loo Bomholm, Romodlol ~ ... r:•4 :a.._
,,.1y for Privu Uoo S300
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APPENDIX C
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.
I _ 1.0 OVERVIEW . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
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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............................... 4 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 . . . . . . . . . . . . . . . . . . . . . . . . 7
4.4 ESTABLISHMENT OFA SITE CLEANUP LEVEL FOR
1,2-DICHLOROETHANE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
4.4 SELECTION OF THE MOST COST EFFECTIVE REMEDIAL
ALTERNATIVE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
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
The 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 or OU3) 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
The Environmental Protection Agency (EPA) conveyed its preferred remedial alternative for 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
Observer newspapers. 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, to respond to any questions or address any
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OU 13 National Starch & Chernical Company
Responsiveness Sunvnary
concerns expressed during the public meeting, and to take their comments and make them a part of the official record. A copy of the transcript from the August 3 public meeting was placed in the Information Repository for public reading. The Proposed Plan Fact Sheet, the newspaper ad, and the press release all informed the public that the 30-day public comment period woult:I run from July 19 to August 17, 1993. However, a request was made for a 30-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:
• Contaminated groundwater 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;
Treatment will consist of air stripping to achieve concentrations to meet discharge requirements set forth by the City of Salisbury wastewater treatment system;
Long-term monitoring of the underlying aquifer; and
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 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
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OU #3 National Starch & Chemical Company
· Responsiveness Summa,y
A-3
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.
A 1985 newspaper article indicated there were 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. 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 iri Atlanta, Georgia to house the Administrative Record for the Site. The Information Reposiiory 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?
Area of soil contamination?
In what direction is the contamination migrating and has the contamination migrated off the NSCC property?
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:
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3.1 SOIL REMEDIATION ALTERNATIVES
OU #3 National Starch & Chemical Company
Responsiveness Summary
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.
3.2 AREA OF SOIL CONTAMINATION
Q: Where's the soil now?
A: An overhead was used to show the extent of soil contamination.
3.3 MIGRATION OF CONTAMINATION
Q: Has any of the contaminaiion 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 Agency received.
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OU #3 National Starch & Chemical Company
Responsiveness Sunmary
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 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 NPDES 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 headworks methods. We request your assistance in
resolving this compliance issue.
RESPONSE: Currently, IT Corporation which is NSCC's contractor, 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 OU #3, then all entities involved, the Agency, North Carolina Department of Environment,
Health & Natural Resources (NCDEHNR), the City of Salisbury, the potentially
responsible party (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: 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
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OU #3 National Starch & Chemical Company
Responsiveness Summary
results that would allow a determination of the effectiveness of a no action soil alternative.
RESPONSE: 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 FS report did not provide sufficient 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 rerriediation technologies providing sufficient rationale for the elimination and/or retention of appropriate technologies that can address the soil contamination at the Site.
Another concern which was highlighted during the review of the draft Proposed Plan focused on the potential presence of either a free-phase or residual dense non-aqueous phase liquid (DNAPL) in the soil in Area 2. 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 document. 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.
COMMENT #3: We disagree with the !:PA for the need of another Operable Unit. Based on the investigative data that has been collected the source of contamination of the subsurtace soils is well defined. In fact, 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 for the establishment of OU4. The agencies want the OU3 FS expanded to include more active remedial actions for the soil because they suspect that DNAPL may be present in the soil and if the DNAPL continues to release from the soil to the groundwater the groundwater remediation will not succeed in cleaning up the aquifer. 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 pertorm. The testing procedure along with the proposed borehole location is provided as Attachment A. (This attachment has not been
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OU #3 National Starch & Chemical Company
Responsiveness Surm,ary
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 monitoring of. the groundwater to determine if no action is sufficient for the subsurface soils. 11.,.increased concentrations of contaminants or no substantial decrease in concentrations of contaminants are noted after 5 years of active groundwater remediation then other remedial options may have to be considered.
RESPONSE: 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. In other words, the OU #3 FS report failed to meet the requirement set forth in Section 121 CERCLA. This section states, EPA shall ·conduct an assessment of ... alternative treatment technologies, that in whole, or in part will result in a permanent...significantly decrease in the toxicity, mobility ... ". The FS report failed to discuss alternative treatment technologies for soil. The FS report discussed only institutional controls and long-term monitoring. ·
ff a ONAPL 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. ff necessary, the OU #4 FS report will need to address this issue.
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 ERC 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.
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OU #3 National Stardl & Chemical Company · Responsiveness Sunvna,y
A-8
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. Such undertakings on the part of NSC could be incorporated into an enforceable Consent Decree in which NSC would agree io 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.
RESPONSE: 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 containinantplume. • 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.
COMMENT #5 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 cieanup standards (i.e. ARARS). The final rule, 40 CFR 300.430 (f)(5)(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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A-9
OU #3 National Starch & Chemical Company
Re.sponsiveness Sunvnary
· The groundwater plume boundary has been well defined as depicted in 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 integrafopart of the establishment of compliance points is the implementation of Institutional controls. Institutional controls are required at this site in order to prevent Mure human exposure to contaminants remaining within the waste management area (i.e. groundwater plume upgradient of the compliance points).
Ttie 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 consent decree, administrative order, contract, etc. National Starch should make a recommendation to the agency.
A ESPONSE: The Agency maintains that the point of compliance will be throughout the entire plume of contamination. Refer to the response for Comment #4 for the supporting rationale. 1
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 ii 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 ("POL") (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 POL as determined by EPA.
RESPONSE: 40 CFR 300.400(g)(4) states, "Only those state standards that are promulgated, are identified by the State in a timely manner, and are more stringent than federal requirements may be applicable or relevant and appropriate·. The state
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OU #3 National Starch & Chemical Company
Responsiveness Summary
groundwater quality standard for 1,2-DCA is 0.38 µg/1 as specified in North Carolina Administrative Code (NCAC) 15-2L.0202(g). However, NCAC 15-2L.0202(b)(1) allows the state groundwater quality standard to be raised to the detectable concentration. Consequently, the Agency raised the groundwater . performance standard for 1,2-DCA from 0.38 µg/1 to 1.0 µg/1 as 1.0 µg/1 is the detection limit for 1,2-DCA under the drinking water analytical protocols, EPA method 524.2. Based on the Superfund Analytical Methods for Low Concentrations Water for Organic Analysis for the Contract Laboratiry Program, dated June 1991, the quantitation limit for 1,2-DCA is set at 1 µg/1.
40 CFR 300.430(f)(1 )(ii)(C) provides the grounds for invoking a waiver. Based on the Agency's evaluation on the request for a waiver to the State's groundwater quality standard (NGA C 15-2L. 0202), the Agency concluded that the request does not satisfy any of the specified grounds for invoking a waiver.
COMMENT #7: The federal MCL for 1,2-DCA is 5 ppb. The NCDEHNR groundwater standard for 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 for 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 analytical 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 for 1,2-DCA, the EPA detennined that "the costs associated with the additional removals, i.e., from 0.005 mg/1 to 0.001 mg/1, 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 for 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 for 1,2-DCA should be 5 ppb.
RESPONSE: Although the argument set forth in this comment is straightforward, it does not address the ultimate reason why the Agency selected a performance (clean-up) standard of 1 microgram per liter (µg/1) or /part per billion (ppb) for 1,2-DCA. To have selected anything else (i.e., the maximum contaminant level (MCL) for 1,2-DCA) as requested by this comment would have resulted in this Record of Decision (ROD) in being out of compliance with the law. 40 CFR 300.400(g)(4) states, "Only those state standards that are promulgated, are identified by the State in a timely manner, and are more stringent than federal requirements may
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OU #3 National Starch & Chemical Company
Responsiveness Summa,y
be applicable or relevant and appropriate•. The state groundwater quality standard for 1,2-DCA is 0.38 µg/1 as specified in NCAC 15-2L.0202(g}. However, NCAC 15-2L.0202(b)(1) allows the state groundwater quality standard to be raised to the detectable concentration. Consequently, the Agf1ncy raised the groundwater performance standard for 1,2-DCA from 0.38 µg/1 to 1.0 µg/1 as 1.0 µg/1 is the detection limit for 1,2-DCA under the drinking water analytical protocols, EPA method 524.2.
4.4 SELECTION OF THE MOST COST EFFECTIVE REMEDIAL ALTERNATIVE
COMMENT #8:. 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.
RESPONSE: Both the vapor-phase carbon adsorption technology and the fume incinerator technology achieve the same degree of protection and treatment of the emissions from the air stripper. As directed by 40 CFR 300.430(f)(1 )(ii}(D}, the Agency should select the most cost effective alternative. Based on the information provided in Comment #9, the Agency concurs with the request stated in this comment and has selected vapor-carbon adsorption as the choice of treating the emission generated by ttie air stripper.
COMMENT #9: 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 lime .. 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 Alteralive 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.
RESPONSE: The Agency appreciates the above information and as specified in the response to Comment #8, concurs with the request to change the treatment technology for the emissions from the air stripper from fume incinerator to vapor-phase carbon adsorption.
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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
CC!rn·rlatte CLaurt 3Reµorting, ilnr.
!3a•t ©ffice !lax llEzg
O::liarlatt,. 'Xart~ 0::.rrnlino 2S22G
(7lN) 373-03-t7
il:ail Jm (BOO) -Ei6-g..Jz..J
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Ms. Diane Barrett
Community Relations Coordinator
United States Environmental Protection
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
* * * * * * * *
Agency
Pages
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32 -33
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This is the proposed plan public meeting for
the National Starch and Chemical Company Superfund Site i.n
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 Diane 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 L~en 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
plah that addiessed 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 thi.nk, that attended that meeting, and
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that was just the beginning of meetings. At that
time, too, the remedial investigation 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 years because extensive
sampling and analytical work is done, and
sometimes we may have to go out a second time to
gather mor~ 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 investiga_tion.
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After the feasibility study has be.en
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
8
-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 and 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 alternatives 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
Manager 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 tha~ 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 Wµter
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 uni~ one. And I'll --there's another
~---·. -···· .... -.. ,,., .... , •. -,.,.-~--~-·····---•·•·--· _ .,,__, __ ,.._==::c.._.:..r.,....,........,_~~~--~-·cci:r: "'-'=W..a:a',
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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 b~ck 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 respon.sible
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 dis~ributed on July. Tonight is the
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public meeting for that proposed plan an~ then the
public commentary is --it began, as Diane said,
on July 19th.
Operable unit three consists of t~o areas.
The plant area, which is the active facility
itself, which consists of area number 2, which
includes the reactor ro.om, the tank room, the raw
materials bulk storage room, and the warehouse,
and as well as the 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 lin.ed with concrete liners, so they
were acting as a source prior to 1983 and then the
terracotta piping or pipelines corning 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 mill_!,~n 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 object~ves: 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 remedial investigation we also
tried to define the geology of the soils so we
could _determine which way groundwater is flowing,
how qu~ckly 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 typical 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
concentration in the bedrock zone, the fractured
bedrock zone. Again concentrations ar~, 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 defined 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, tha~: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 organics 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 parenth~sis 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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I . the term '"unacceptable risk,'' and that is when the
risk is greater than one times ten to the minus
fourth or one of ten thousand people m~y 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 unacceptable 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 da.te, 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 .:a,_7ven
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,
th~re's a typo, is Tetrachloroethane. The State
standard is point seven. 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 m_ost stringent clean up standard is
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the one that's listed in the shaded area and that
will be the one that will be included into the
record decision as the clean up goal o:rc,,
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, 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 ~ar 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 water, and
that should be three thousand, I believe, a little
typo there, with range concentrations from two to
three thousand, so we're just above that goal
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here.
Basically that's the end result of the
remedial investigation, with all that 4)formation.
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 the 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 for 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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thes~ 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 briefly 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 evaluatiop process, the no
action alternatives. That gives us a baseline to
evaluate the other 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
n.
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monitoring, implementing institutional controls,
and then, again, fencing that portion of the
northeast tributary where elevated lev~}s 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 through extraction wells, and the only
diff~rence 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 discharg~d 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 coming 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 a~ that stream, we will
remediate the stream as well.
The next page lists what EPA has identified
as our .preferred alter~atives. 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 coming 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 necessary 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
for 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 -~s the
building that was built on 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
these.
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Basically that's the end of my p~sentation.
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. I~'s our opinio~ 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 which is near the lagoon 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 ~as 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 ½hink it's one parts per billion,
---~,-----
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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 right 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 mee.ting? Okay. Well, we
thank you very much for your attention and for
coming and the meeting is adjourned.
MR. BORNHOLM: Thank you.
(WHEREUPON, the meeting was concluded at 8:00
p. M. )
* * * * * * * *
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STATE OF NORTH CAROLINA
COUNTY OF MECKLENBURG
36
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 tinder 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 unless otherwise specifically requested in
writing, the tape for this transcript will be retained for
thirty days from the date of this certificate.
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RECORD OF DECISION
.REMEDIAL ALTERNATIVE SELECTION
OPERABLE UNIT #4 ·
NATIONAL STARCH & CHEMICAL COMPANY SITE
SALISBURY, ROWAN COUNTY
NORTH CAROLINA
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV
ATLANTA, GEORGIA
SEPTEMBER 1994
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DECLARATION FOR THE
RECORD OF DECISION
SITE NAME AND LOCATION
National Starch & Chemical Company
Cedar Springs Road, Salisbury, Rowan County, North Carolina
STATEMENT OF BASIS AND PURPOSE
This decision document presents the Operable Unit Four Remedial Action for the National
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 concurs with the selected remedy for Operable Unit Four. The
State's concurrence on this Record of Decision 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 fourth and final Operable Unit for this Site. The first two
Operable Units addressed the contamination associated with the Trench Area. The third and
fourth Operable Units addressed the contamination associated with the active production area of
the National Starch & Chemical Company facility and the wastewater treatment lagoon area.
Operable Unit Three addressed the contaminated groundwater and this Operable Unit addresses
the contaminated soils.
This Operable Unit, Operable Unit #4, is a contingency remedy initially relying on natural
degradation processes to reduce the level of contaminants in the soil. In the event that natural
degradation fails to result in a significant reduction in soil concentrations within two years of the
signing of this Record of Decision, the contingency remedy will be implemented. The contingency
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remedy involves the installation of a soil vapor extraction system with an emissions control technology such as fume incineration or activated carbon filtration or a combination of both to control air stream discharged to the atmosphere.
The major components of the selected remedial alternative for Operable Unit #4 include:
)
• Devise and implement a biodegradative study to substantiate that natural degradation is occurring, identify where in the subsurface the degradation is occurring, and determine the rate of degradation.
• Implement institutional controls including deed restrictions and maintenance of both the fence around the plant operations area and the paved areas around Area 2.
• Develop and implement a long-term monitoring plan to ensure that natural degradation
continues to be effective until the specified performance standard is achieved and maintained.
Performance of five (5) year reviews in accordance to Section 121(c) of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 until
the cleanup goals specified in this Record of Decision are achieved.
The major components of the contingent remedial alternative include:
• Volatile organic contaminants will be removed from the soils by means of a vapor extraction systems.
• Extracted contaminated air from Area 2 will initially be treated using fume incineration.
After concentrations of contaminants decrease in the extracted air, this contaminated vapor will be treated via vapor-phase activated carbon adsorption filters prior to the air stream being released into the atmosphere.
• The extracted contaminated air from the lagoon area would be treated using vapor-phase activated carbon adsorption filters to remove the volatile organics prior to the air stream being released into the atmosphere.
• The contaminants captured by the vapor-phase carbon filters would be destroyed through the thermal regeneration of the used activated carbon at an off-site, commercial regeneration facility.
A review/assessment would be performed in accordance to Section 121(c) of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 to verify that ihe soil vapor extraction system is proceeding as anticipated or achieved the specified cleanup goals stipulated in this Record of Decision.
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
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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 frve years after commencement of remedial action to ensure that the remedy continues to provide adequate protection Of human health and the environment.
G~rn~k
John H. Hankinson, Jr. · / Date Regional Administrator
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DECISION SUMMARY
RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
OPERABLE UNIT #4
NATIONAL STARCH & CHEMICAL COMPANY SITE
SALISBURY, ROWAN COUNTY
NORTH CAROLINA
· PREPARED BY:
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV
ATLANTA, GEORGIA
SEPTEMBER 1994
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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 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
5.1 SOILS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
5.2 GROUNDWATER ............................................... 26 5.3 SURFACE WATER AND SEDIMENT ................................. 27 5.4 HYDROGEOLOGICAL SETTING . . . . . . . . . . . . . . . . . . . • . . . . . . . . . . . . . . . . 27
6.0 SUMMARY OF SITE RISKS . . . . . . . . • . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28
7.0 REMEDIAL ACTION OBJECTIVES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31 7.1 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS ........ 32 7.2 PERFORMANCE STANDARDS ..................................... 32 7.3 EXTENT OF CONTAMINATION .................................... 32
8.0 DESCRIPTION OF ALTERNATIVES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33 8.1 REMEDIAL ALTERNATIVES TO ADDRESS SOIL CONTAMINATION ......... 33 8.1.1 AL TERNA Tl VE S 1: No ACTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33 8.1.2 ALTERNATIVE S2: NATURAL DEGRADATION AND INSTITUTIONAL
CONTROLS . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38 8.1.3 ALTERNATIVE S3: SOIL VAPOR EXTRACTION WITH FUME
INCINERATION AND ACTIVATED CARBON FILTER
TO CONTROL EMISSIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40 8.1.4. ALTERNATIVE S4: SOIL VAPOR EXTRACTION WITH ACTIVATED
CARBON Fil TER TO CONTROL EMISSIONS . . . . . . . . . . . . . . . . . . . . . . . . . . 41
9.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES ............... 41 9.1 THRESHOLD CRITERIA ..................•....................... 41 9.1.1 OVERALL PROTECTION OF HUMAN HEALTH AND
THE ENVIRONMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45 9.1.2 COMPLIANCE WITH APPLICABLE OR RELEVANT
AND APPROPRIATE REQUIREMENTS ......................... 45 9.2 PRIMARY BALANCING CRITERIA . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46 9.2.1 LONG-TERM EFFECTIVENESS AND PERMANENCE . . . . . . . . . . . . . . 46 9.2.2 REDUCTION OF TOXICITY, MOBILITY, OR VOLUME .............. 46 9.2.3 SHORT-TERM EFFECTIVENESS ............................. 47 9.2.4 IMPLEMENTABILITY ...................................... 47 9.2.5 COST .................................................. 47 9.3 MODIFYING CRITERIA . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 48 9.3.1 STATE OF NORTH CAROLINA ACCEPTANCE ................... 48 9.3.2 COMMUNITY ACCEPTANCE ................................ 48
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10.0 DESCRIPTION OF THE SELECTED REMEDY ........................... 48 10.1 PERFORMANCE STANDARDS TO BE ATTAINED .................... 50 10.2 SOIL REMEDIATION .......................................... 50 10.3 BIODEGRADATION STUDY ................... -.................. 50
10.4 COST . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50
11.0 STATUTORY DETERMINATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51 11.1 PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT . . . . . . . . . . . 51 11.2 COMPLIANCE WITH ARARS .................................... 51
11.3 COST-EFFECTIVENESS ....................................... 51 11.4 UTILIZATION OF PERMANENT SOLUTIONS AND ALTERNATIVE
TREATMENT TECHNOLOGIES OR RESOURCE TECHNOLOGIES
TO THE MAXIMUM EXTENT PRACTICABLE . . . . . . . . . . . . . . . . . . . . . . . . 51 11.5 PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT .......... 52
12.0 SIGNIFICANT CHANGES ........................................... 52
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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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FIGURE 1
FIGURE 2
FIGURE 3
FIGURE 4
FIGURE 5
FIGURE 6
FIGURE 7
FIGURE 8
FIGURE 9
FIGURE 10
FIGURE 11
FIGURE 12
LIST OF FIGURES
FIGURE TITLE PAGE No.
SITE LOCATION MAP • • • • • • • • • • • • • • . • • • • . . • • • • . • • • . . . • • • . • • • • . • 2
LOCATION OF FACILITIES THAT COMPRISE OPERABLE UNIT #4 . • . • . • . . • . . • • 3
LOCATION OF SOIL SAMPLES COLLECTED FROM PARKING LOT . • . . • . . • . • • • . 11
CONCENTRATIONS ANO EXTENT OF 1,2-DICHLOROETHANE
CONTAMINATION IN THE SOIL IN AREA 2 •. '. • • . . • • • . . . • • • • . . . • • • . • • . . 14
SOIL CROSS SECTION LOCATION MAP ..••....••..•.•....•.•..•.... 15
SOIL PROFILE A-A' WITH 1,2-DICHLOROETHANE CONCENTRATIONS
IN SOIL AT AREA 2 ••.••••••••••.•••..•.•.•••••...••....•.... 16
SOIL PROFILE B-B' WITH 1,2-DICHLOROETHANE CONCENTRATIONS
INSOILATAREA2 •••••••.••••..•••.. : ••.•••••...••..•••..•• 17
CONCENTRATIONS ANO ESTIMATED EXTENT OF 1,2-DICHLOROETHANE
CONTAMINATION IN THE SOILS AT THE WASTEWATER TREATMENT
·LAGOON AREA • • . . • • • . . • • • . . • • • • . . • • . . . • • • . . • . . . . . . . . . . . . . . • 18
SOIL PROFILE B-B' WITH 1,2-DICHLOROETHANE CONCENTRATIONS
IN SOIL AT THE WASTEWATER TREATMENT LAGOON AREA ....•.•...•..•• 19
DISTRIBUTION OF ACETONE IN SOILS IN AREA 2 AND THE
WASTEWATER TREATMENT LAGOON AREA •••••..• ; .•. • . . . . . . • • . . . • . . . 20
BEDROCK STRUCTURAL CONTOUR MAP SHOWING CROSS SECTION
LOCATION A-A' . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29
HYDROGEOLOGICAL CROSS-SECTION A-A' . . . . . . . . . . . . . . . . . . . . . . . . . . . 30
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TABLE 1
TABLE 2
TABLE 3
TABLE 4
TABLE 5
TABLE 6
TABLE 7
LIST OF TABLES
TABLE TITLE
RANGE AND FREQUENCY OF DETECTION OF ORGANIC
CONTAMINANTS AND INORGANIC CONSTITUENTS FOUND IN THE
PAGE No.
ENVIRONMENTAL MEDIA SAMPLED • • • • . . • • . • • . • • • • • • . • • . • • • • • . . • • . . • 9
VOLATILE ORGANIC COMPOUNDS IN AREA 2 SOILS • • • • • • . • • • • • . • • . • • • . . • 21
VOLATILE ORGANIC COMPOUNDS IN SOIL SAMPLES FROM
WASTEWATER TREATMENT LAGOON AREA • • . • . . • • • . • . • • • . • • • . . . • • • . . . 23
CONCENTRATIONS OF INORGANIC ANALYTES IN SOIL
CONTAMINATION CHARACTERIZATION SAMPLES ••••••.•••••••••••.••• ; .. 25
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS • • • • • • . . • • • . • . 34
INITIAL SCREENING OF TECHNOLOGIES AND PROCESS OPTIONS
FOR SOIL REMEDIATION • . • . . • . . . . • • • • . . . • • • • . • • • • . . . • • • . . • • • • . • . 42
SECONDARY/FINAL SCREENING OF TECHNOLOGIES AND PROCESS
OPTIONS FOR SOIL REMEDIATION ....•.•...•••...•••...•••..•...•.• 44
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AOC
ARAR
CERCLA
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DNAPL
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e.g.
EPA
I FS
ft/day
ft/yr
HRS
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MCLs
mg/kg
I NCAC
NCDEHNR
NCP
I ND
NPDES
NPL
NSC I NSCC
O&M
OU
I BCPs
ppb
ppm
I PRP
PW
RA
RCRA
I RD
· RD/RA
RI
I RI/FS
ROD
SARA
I SVOCs
TAL
TBC
TCL
I TCLP
TMV
UAO
I µg/kg
µg~
voes
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LIST OF ACRONYMS
Administrative Order on Consent
Applicable or Relevant and Appropriate Federal, State or Local
Requirements
Comprehensive Environmental Response, Compensation, and Liability Act
of 1980 (Superfund) '
Consent Decree
Dense Nonaqueous Phase Liquid
1,2-Dichloroethane
for example ·
Environmental Protection Agency
Feasibility Study
Feet per day
Feet per year
Hazardous Ranking System
that is
Maximum Contaminant Levels
milligrams per kilogram
North Carolina Administrative Code
North Carolina Department of Environment, Health, and Natural Resources
National Oil and Hazardous Substances Pollution Contingency Plan
Not Detected
National Pollution Discharge Elimination System
National Priority List
National Starch & Chemical Company
National Starch & Chemical Company
Operation and Maintenance
Operable Unit
Polychlorinated Biphenyls
parts per billion
parts per million
Potentially Responsible Party
Present Worth
Remedial Action
Resource Conservation and Recovery Act
Remedial Design
Remedial Design/Remedial Action
Remedial Investigation
Remedial Investigation/Feasibility Study
Record of Decision
Superfund Amendments and Reauthorization Act of 1986
Semi-volatile Organic Compounds
Target Analyte List
To Be Considered
Target Compound List
Toxicity Characteristic Leaching Procedure
Toxicity, Mobility, or Volume
Unilateral Administrative Order
micrograms per kilogram
micrograms per liter
Volatile Organic Compounds
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RECORD OF DECISION
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
OPERABLE UNIT FOUR
NATIONAL STARCH & CHEMICAL COMPANY SUPERFUND SITE
SALISBURY, ROWAN COUNTY, NORTH CAROLINA
· 1.0 SITE NAME, LOCATION, AND DESCRIPTION
The National Starch & Chemical Company Site (NSCC Site or the "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) #4 are shown in Figure 2. OU #4 includes the following areas of the NSCC facility: Area 2, the parking lot, 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 installea 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 #4 (i.e., Area 2 and the wastewater treatment lagoon area) 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 NSCC facility. Another industrial park is located along the southern property line. A mobile home park adjoins the extreme southwestern corner of the 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
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N
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'" J OA\IIOSON
\ COUN'IY -
MIU.
BR10C
\
COUNTY -------IWIHAPLOIS CABARRUS COUN'IY 7
I
SCALE: - --·---0 8 16 t.llLES
FIGURE 1
LOCATION OF THE NATIONAL STARCH &
CHEMICAL COMPANY SUPERFUND SITE
- ----- - --------1!!!!11!!1
-=------------------------,----------'-_.:...,_ _____ ---, ~~
------
AIRPORT
ROAD
500 0 500 1000 ~-~--_] 250 750
GRAPHIC SCALE: 1'=500'
FIGURE 2
LOCATION OF FEATURES ASSOCIATED
WITH OPERABLE UNIT #4
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. -----.. -.. ---------. ----. ---------------------· --·---·--------------------. -. -. -..
-4-
NATIONAL STAROl & CHEMICAL CoMPANY 5uPERRJNO SITE
AEcoRo Of OECl~ON FOR 0PERA81£ UNIT #4
cleaning processes. The liquid waste stream from the manufacturing processes include reactor and feed line wash and rinse solutions. This wastewater may include a combination of the following chemicals: acrylimide, 1,2-dichloroethane (1,2-DCA), methyl isobutyl ketone, methanol, styrene, maleic anhydride, vinyl toluene, sulphonated polystyrene, epichlorohydrin,
octyl alcohol, ethyl alcohol, ally! alcohol, ally! 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 (RI/FS) Work Plan was expanded. The first RI/FS resulted in OU #1 ROD which was issued by the Environmental Protection Agency (EPA or 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 resulted in the development of OU #3 and OU #4. OU #3 ROD was signed on October 7, 1993 and required a more thorough evaluation of alternatives to address the soil contamination in Area 2 and the wastewater treatment lagoon area (i.e., 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 scores: 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.
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 letter was sent on May 30, .1986 to provide NSCC an opportunity to conduct the first Fil/FS. A good faith offer was submitted and negotiations were concluded with NSCC signing an Administrative Order on Consent (AOC) on December 1, 1986. NSCC, the Potentially Responsible Party (PRP), has performed OU #1, OU #2, OU #3, and OU #4 under the direction and requirements specified in the December 1986 AOC.
The first RI/FS was completed on June 21, 1988 and September 8, 1988, respectively. Following the signing of OU #1 ROD, the Agency sent a special notice letter to the PRP 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. To date, NSCC is in compliance with the requirements of the July 1989 UAO.
In support of OU #2, NSCC generated Supplemental RI and Feasibility Study {FS)
Reports. These reports were prepared in accordance to the December 1, 1986 AOC. These reports were completed in May 1990 and September 1990, respectively. The Supplemental
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NATlONAL STARCH & CH-EMICAl CoMP.AHY SUPERRJNO SnE
RECORD Of DEOSION ~R OPERABt.E UNIT 14
RI reported continued detections of contaminants in the Northeast Tributary but did not identify the source of this contamination. Consequently, the OU #2 ROD divided the Site into a third operable unit. Following the signing of the OU #2 ROD, the Agency sent the PAP another special notice letter in March 1991 to initiate negotiations on a second CD. This CD governed the implementation of the OU #2 RA. 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 NSCC to conduct a third RI/FS
to determine the source, nature, and extent of contamination entering the Northeast Tributary as required by OU #2 ROD. As with the previous RI/FS efforts, the 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. Due to an inadequate evaluation of source control remediatfon alternatives in the OU #3 FS document, the Agency decided to split the groundwater and source control efforts into OU #3 and OU #4, respectively. The OU #3 ROD was signed on October 7, 1993 and required a fourth operable unit. On October 12, 1993, EPA requested NSCC to initiate OU #4 in accordance to the December 1986 AOC. Since only the evaluation of the source control remediation alternatives was in question, the June 1993 OU #3 RI sufficed as the OU #4 RI report. The June 20, 1994 OU #4 FS was conditionally approved by the Agency on July 8, 1994. NSCC will be provided an opportunity to conduct the OU #3 and OU #4 RD/RA as specified in this ROD and OU #3 ROD through the issuance of a third RD/RA special notice letter.
3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION
In 1986, community relations activities tor 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 in Salisbury. A mailing list was developed based upon people interviewed, citizens living around the Site, and people attending Site related public meetings. The mailing list also includes local, State, and Federal public servants and elected officials.
Numerous fact sheets were mailed and several public meetings were held with respect to OU #1, OU #2, OU #3, and OU #4. The following community relations activities were conducted by the Agency with respect to OU #4.
The public was informed through the Proposed Plan Fact Sheet and an ad published on July 12, 1994 in The Salisbu,y Post newspaper of the July 26, 1994 Proposed Plan Public
Meeting. The Proposed Plan Fact Sheet was mailed to the public on July 8, 1994. The basis of the information presented in the Proposed Plan was the June 1994 OU #4 FS document.
The Proposed Plan also informed the public that the public comment period would run from July 12, 1994 to August 11, 1994.
Prior to the Proposed Plan Public Meeting, representatives from EPA met with City and County officials to present to them a summary of information to be shared with the public during the evening public meeting. This meeting also provided locally elected officials the opportunity to ask questions and make comments concerning the Agency's proposed activities.
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NATIONAL $TARO{ & CHBUCAI. COMPANY 5uPeRRJNo SITE
REcoRo OF DEOSION FOR DPERABLE UNIT 14
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 alternatives reviewed and the remedial alternative selected by the Agency, and inform the public that the public comment period on the Proposed Plan would conclude on August 11, 1994. 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.
After the Proposed Plan public meeting, the Agency received a request for a 30-day extension to the public comment period which extended the public comment period to midnight September 9, 1994. A notice was mailed on August 9, 1994 to the addressees on the mailing list informing them of this extension. An ad was also published in the August 11, 1994 edition of The Salisbury Post newspaper informing the public that the public comment period had been extended to September 9, 1994.
Pursuant to Section 113(k}(2)(B)(i-v) and 117 of.Comprehensive Environmental
Response, Compensation, and Liability Act of 1980 (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 Salisbllry, North Carolina. A copy of all literature distributed at each public meeting, as well as a transcript of meeting proceedings, were also placed in the Information Repositories.
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. These are:
OU #1
OU#2
OU#3
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
OU #4 --Contaminated soils in and around Area 2 and the wastewater treatment
lagoons.
. This ROD has been prepared to summarize the remedial selection process and to present the selected remedial alternative for the contaminated soils in and around Area 2 and the wastewater treatment lagoons. Although neither surface nor subsurface soils pose an
unacceptable current risk to the public health, there are unacceptable future risks due the
concentration of chemicals found in the soils associated with OU #4. Based on a comparison between the target compound list (TCL) analytical results for 1,2-DCA in soil to the
corresponding toxicity characteristic leachate procedure (TCLP) concentration by using a least squares linear regression on the data, it was hypothesized that the current concentration of
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NA110NAL STAROl & CHEM""-CoMPANY SUPERF\J!ID SITE
AEcoRO OF DEOSON RlR OPEIWllE UNIT 14
1,2-DCA in the soils could adversely impact the underlying groundwater above the
performance standard presented in the OU #3 ROD which 1 microgram per liter (µg/1) or 1 part per billion (ppb).
EPA has already selected remedies for OU #1, OU #2, and OU #3. Construction on the · OU #1 remedial action phase began in August 1990. OU #2 was initiated on July 20, 1992, the filing date' for the CD. OU #2 ROD specified no action for the soils in the Trench Area, long-term monitoring of the soils in the Trench Area, and an investigation to determine the ·· source of contamination being detected in the Northeast Tributary. The Agency will combine
negotiations for performing the RD/RA for OU #3 and OU #4 with NSCC.
The purpose of this response is to prevent current or future exposure to the
contaminated soils. OU #4 is the final operable unit for this Site.
5.0 SUMMARY OF SITE CHARACTERISTICS
The NSCC OU #4 RI/FS is complete. The June 2, 1993 RI report, conditionally
approved by the Agency on July 7, 1993, identified the sources, characterized the nature, and defined the probable extent of the uncontrolled hazardous wastes in the soil, groundwater,
and surface water/sediment in the areas addressed by this Operable Unit. The June 1993 RI report included the Baseline Risk Assessment. The Baseline Risk Assessment defined the
risk posed by the hazardous contaminants present in the areas investigated. The Proposed
Plan.Fact Sheet, based on the June 20, 1994 OU #4 FS document,.provided the public with a summary of the detailed analysis of the four (4) soil remediation alternatives. ·
The overall nature and extent of contamination associated with this area of the Site is based upon analytical results of environmental samples collected from surface and subsurface soils, the groundwater, surface water and sediment of the Northeast Tributary, 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 were screened for volatile organic compounds (VOCs) as the previous Remedial
Investigations 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 TCL and target analyte list (TAL) constituents. The TCL includes VOCs, 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. Detailed discussions on groundwater and surface water/sediment
were provided in the OU #3 ROD.
Background/control samples were collected for groundwater and surface water and sediment. No background surface or subsurface soil samples were collected, 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 results for the upgradient sediment sample collected from the Northeast Tributary was used to portray
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NATIONAi. STARCH & CHBIIC& Coul>ANY SUPERRJNO SITE
REcooo OF DECISION FOO DPERABI.E UNIT #4
background conditions for evaluating inorganics detected in surface and subsurface soil samples.
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-hexachiorocyclohexane (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. The concentration of delta-BHC is below health base clean up goals. Based on the above information, the following contaminants or group of contaminants will not be discussed in the following sections: PCBs and pesticides. The following sections discuss the results and interpretations of the data collected and generated for each environmental medium investigated as presented in the June 1993 RI report.
Air samples were not collected, however, the air was monitored during the RI field work as part of the field 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 of the facility as part of their internal, corporate health and safety procedures.
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. These soil samples were collected in 59 different locations in the following three areas of the Site: the parking lot, Area 2, and the wastewater treatment lagoon area. These soil samples included 11 surface · soil samples (0 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.
A total of 14 different VOCs, one (1) SVOC, one (1) pesticide, 14 metals, and cyanide were detected. As can be seen in Table 1, the VOCs most frequently detected and observed in the highest concentrations were acetone, 2-butanone, chloroform, 1,2-DCA, toluene, and vinyl chloride (listed alphabetically). A variety of inorganic analytes were also detected in the soils. Although these inorganic analytes occur naturally in soil, elevated concentrations of cyanide and eight (8) metals were detected. The following metals were either detected in onsite soils but not in the background sample or detected onsite at concentrations at least two times greater than the background concentration: barium, chromium, cobalt, copper, manganese, nickel, thallium, and vanadium.
As stated earlier, the landfarmed saturated soils from the wastewater treatment lagoon area was used as fill material in the expansion of the parking lot. Prior to placement of this soil in 1988, the soil was sampled and analyzed. The concentration of 1,2-DCA in the sample collected was 533 ppb. Figure 3 provides the location of the.two soil samples collected in the parking lot area in June 1992 as part of the RI. The concentrations of 1,2-DCA were 220 ppb and 370 ppb in samples PLS-1 and PLs,2, respectively. Six (6) other VOCs were detected in these two soil saniples.
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NAllONAI. STARCH & C!<BIK:AL COIIPN<Y SUPERRJHO SfTE
REcoRD OF DECOSON FOR 0PERA81£ UNIT #4
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)
8is{2-chloroethyl)ether 13-32 (2)
Bromodichloromethane 1-220 (7) 1 (1)
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 (1)
Ethylbenzene 9-36 (2)
Methylene Chloride 1-160 (5)
Tetrachloroethene 2 (1) 107 (4)
Toluene 1-3, 100 (12) 1-120 (3)
1, 1,2-Trichloroethane 1-3 (4)
Trichloroethane 11-17 (2) 1-5 (10)
Total Xylenes 1 (1) 2-90 (4)
Vinyl Chlortde 32-190 (12) 1-120 (8)
Bis( 2-ethylhexyl) phthala te 8 (1)
Di-n-butyl Phlhalate 2-17 (3)
Di-n-octyl Phthalate 2 (1)
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NATKlffAI. STARCll & CHEMICAL COIIPNtl SUPERF\JND SITE
RECORD OF DEC>SION FOR OPERABLE UNIT #4
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
Delta-Hexachlorocyclohexane 22 (1) 0.16 (1)
Antimony 7,600 (1) 5,100-8,2000 (5) 2-30 (3)
Arsenic 530-2,900 (7) 2.4 (1) 1,100-1,900 (2)
Barium 33,300-198,000 (7) 28.2-737 (8) 32.1-38.2 (2) 50,300-88,400 (2)
Beryllium 240-680 (7) 1-2.5 (2) 490-980 (2)
Chromium 10,000-97,900 (7) 12.9-59.6 (6) 35, 100-36,500 (2)
Ccbalt 13,700-74,100 (7) 47-66.4 (2) 23,600-28,000 (2)
Ccpper 46,700-161,000 (7) 12.4-23.7 (2) 48,400-90,300 (2)
Cyanide 2,500-21,900 (2) 12-16 (2)
Lead 1,300-9,400 (7) 3.3-3.9 (2) 3,000-15,100 (2)
Manganese 382,000-2,610,000 (7) 1.5-12,000,000 (14) 60-134 (2) 162-1,020,000 (2)
Mercury 50-60 (2)
Nickel 4,900-22,900 (7) 23.4-39.6 (3) 10,300-11,600 (2)
Selenium 880
Thallium 2,500 (1) 1-3 (2) 380
Vanadium 71,600-379,000 (7) 10.7-272 (11) 14.8-24.4 (2) 146,000-176,000 (2)
Zinc 19,700-50,000 (7) 22-6,410,000 (4) 10.3-11.4 (2) 23,900-48,500 (2)
Concentrations for water samples are reported in micrograms per ltter (µg/1) or in parts per billion (ppb). Concentrations for soil/sediment samples are reported in micrograms per kilogram (µgikg) or in ppb. Number appearing in parentheses is the frequency of detection.
NA --Not Analyzed
- ---
N-50
N-650 L
E -650
- -
0 100
-- -
LAGOON 1
. .
E -350
APPROXIMATE SCALE (ft)
I
200 300 400
--
LAGOON 2
I .
E, 50
500
--------
_,,· .
' ' ---·······---------
E 250
LEGEND
■ SOft.BOAINOLOCATION
; WASTE-WATER LINE, ARROW IND1CATES f O<RECTION OF FlOW
ABANDONED LINE
FIGURE 3
LOCATIONS OF SOIL SAMPLES
COLLECTED FROM PARKING LOT
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NATION& STARCH & CHEMICAL COMPANY SuPERRIND SITE
AEcoRD OF OEOSION FOR OPERABIE UNIT #4
The objective of investigating the vadose zone in Area 2 and the wastewater treatment 1agoon area was to establish the lateral and vertical extent of soil contamination, the location of the highest levels of 1,2-DCA in the soils, and to estimate the mass of contaminants
present in the soils. Figures 4 through 9 show the lateral and vertical distribution of 1,2-DCA, the location of the sampling points as well as the highest concentration of 1,2-DCA detected in each boring, and the depth this sample was collected.
Contamination of soil by 1,2-DCA is most extensive around Area 2. The lateral· extent of soil contamination in this area is shown in Figure 4. In Area 2, there are two areas where soil contamination is concentrated:
• along an elongated area northwest of the main plant and
• · in a broad area northeast of the loading docks and warehouse area.
Cross-section lines A-A' and 8-B' shown in Figure 5 illustrate the locations of vertical contamination profiles at Area 2. Figures 6 and 7 show the vertical distribution of 1,2-DCA in soils at Area 2 along cross-sections A-A' and 8-B', respectively. Unsaturated soils at Area 2 exhibited a pattern of 1,2-DCA concentrations decreasing downward. The distribution pattern of 1,2-DCA at Area 2 is that which would be expected from leaking pipes; concentrations
comparatively high in soils near the ground surface, and decreasing downward. This type of pattern is very well developed along the soil profile B-B'. Soils at Area 2 are capped by concrete and asphalt surfaces; therefore, recharge or infiltration through the soil at this
location is extremely restricted. The analytical data for the samples collected to evaluate Area 2 is presented in Table 2.
In the area around the wastewater treatment lagoons, 1,2-DCA contamination in soil is much less widespread. The lateral extent of contamination in this area is shown in Figure 8. The orientation of cross-section C-C' is shown in Figure 5. Figure 9 shows the vertical distribution of 1,2-DCA in soils at the wastewater treatment lagoons. Where unsaturated soils exhibit 1,2-DCA concentrations, the levels either increase downward towards the water table or exhibit non-detectable levels until the water table is reached. The highest levels are found
in soils near the northeast corner of Lagoon 2 (Figure 8) just above the water table. The analytical data for the samples collected to evaluate the soils in wastewater treatment lagoon area is presented in Table 3.
The vertical soil contamination pattern found in the soils at the wastewater treatment lagoon area is in stark contrast to the pattern observed in the profile for Area 2. The soil contamination profiles of Area 2 and the wastewater treatment lagoon area indicate that the concentrations of contaminants in the soils in the vadose zone at the wastewater treatment lagoon area are decreasing. This reduction is due the infiltration of precipitation flushing the contaminants downward; whereas, the impervious surfaces in Area 2 effectively prevent the infiltration of precipitation and thereby eliminate this flushing action.
Acetone is also widely distributed in the soils around Area 2 and the wastewater
treatment lagoon area as can be seen in Figure 1 O. Around the wastewater treatment lagoon area, the distribution of acetone in soil appears to be very similar to the distribution pattern of 1,2-DCA in the soil. However, the same cannot be said for the distribution of acetone in Area 2. In Area 2, no distribution pattern is evident.
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NATlONAl STAAO< & CHEMICAL COMPANY SUPERF\JND srre
AEroRD OF DEC>SION FOR DPERABLE UNIT '4
Table 4 presents the analytical data for the samples analyzed for SVOCs, pesticides, and inorganics. This table also presents the analytical data for sample SE-13 which was used to define the background conditions for inorganics. All metals detected are naturally occurring for this area. Metals do not present an unacceptable risk.
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 RI, the following sources of contamination have been identified. In Area 2, two sources of contamination were identified: the buried, terra-cotta (fired-clay)
pipeline and a solvent recovery system (distillation unit). The underground terra-cotta pipeline transported wastewater from the production area to the wastewater treatment lagoons. In February 1994; NSCC completed the replacement of the terra-cotta pipeline with an overhead stainless steel pipeline, therefore, the terra-cotta pipeline is no longer in use. The solvent recovery system now sits on a bermed, concrete platform so that any spills associated with the operation of this system are controlled and not released into the environment.
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 collects in the sumps and is then pumped through above ground pipes to the wastewater treatment lagoons.
In the lagoon area, the source of contamination was eliminated in 1984 when NSCC · lined its lagoons with concrete. The contamination currently being detected in the soils and groundwater in this area is the result of past practices and the residual contamination in the soil.
The only additional field work conducted to support the OU #4 FS focused on addressing the concern that 1,2-DCA may exist as a dense nonaqueous phase liquid (DNAPL) or as a residual DNAPL in the soils. In September 1993, six soil samples were tested using a hydrophobic dye. The soil samples were collected from the area of the Site containing the highest soil concentrations of 1,2-DCA identified in the June 1993 RI report. The result of the hydrophobic dye test on these six soil samples indicate that 1,2-DCA does not exist as a free liquid in the soils at the Site. These six samples were also chemically analyzed. The data is present below:
Sample
20A-6-8
20A-8-10
20A-10-12
20A-14-16
20A-18-20
Depth Sample
Was collected
6-8 feet
8-10feet
10-12feet
14-16 feet
18-20 feet
Concentration
of 1,2-DCA
micrograms per kilogram (µq/kg)
190,000
60,000
95,000
4,300
27,000
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APPROXIMATE SCALE (ft)
0 100 200 300 400 500
- --
s --··pMii<iNo
LOT
-----
LEGEND
■ SOIL BORING LOCATION SHOWING MAXIMUM
1,2-IJCA CONCENTRATION (ppb) ANO
(DEPTH (ft)) OF MAXIMUM CONCENTRATION
. · ·1£b 1,2-DCA CONCENTRATION CONTOUR
I WASTE-WATER LINE, ARROW INDICATES + DIRECTION OF FLO'N
NOTE: Conftnnatlon data supplemented by
son screening data
FIGURE 4
CONCENTRATIONS AND
ESTIMATED EXTENT OF
1,2-DICHLOROETHANE
CONTAMINATION IN THE
SOILS IN AREA 2
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CHAIN LINK FENCE---~ NORTHEAST ___ ►\
ORNEWAY
C
IBIBUTARY
A
__ SBA2-05a ..... SBA2-07 SBA2-15
·······: SBA2-13 1
8 ! ; • ■SBA2-19 :~-14 ■ SBA2\·lG
SBA2-11 ! ! SBA2-08 SBA2-06 j j SBA2-~ . ■--
SBA2-10 ii ' ! ; SBA2-1
....
I
.. ---SBA2-04 _-_-_-_-_-_-_-_-_-_-_-_-_-_-_-,-..
_-_-SBA2-09 -_--_-_-•
it?<< tL-03.
SBLA-04 -
SBLA-12 ! ■:
PARKING
AREA
SBLA-14
• SBA2-02
I ■ SBA2-18
SBLA-11
SBLA-23 SBLA-06 • I ■ ■ ■ ■SBLA-OS SBLA-10
B'
SBLA-24 ■ "-'--;SBLA-01 ·
I--+---':--+--, ~SBLA-15 [] SBLA-22
SBLA-07
LAGOON 1
SBLA-20 ■ SBLA-02
SBLA-19
SBLA-18 ■SBLA-03
LAGOON2 ■
SBLA-09
SBLA-08 ■
/
LEGEND
■ SOIL BORING LOCATION FIGURE 5
A A' SOIL CROSS SECTION LOCATION MAP
L_j CAOSSSECTIONLOCATION
AP PAO XI MA TE SCALE (ft) ..----0 100 200 300 ,oo 500
----A
775
~
" 770 !!,.
C ?: 0 .c (/J
"' "' "' <ii u (/J
<ii u t: a, >
"' 1ii E ·;:;
0 a. a. <
765 -
760 -
755
750
745 -
LEGEND
□
(410)
(1393* )
[SBA2-07]
I I I I I I
~ 5 ~
------
Top of Grade
[SBA2-07] t [SBA2-19)
1
,o'
"
r1110J
I
Bedrock
Location of soil sample
1,2-DCA laboratory analytical results in ppb
1 ,2-DCA field analytical results in ppb
Soil boring ID#
Bedrock/Soil interface
1 ,2-DCA concentration contour line (ppb)
---
[SBA2-20]
\
\
> \
0 30 "
------A'
775
[SBA2-12]
770
'b ,,.
I 765
(211 °)
(298)
(380) 760
755
750
745
FIGURE 6
SOIL PROFILE A-A' WITH
1,2-DICHLOROETHANE CONCENTRATIONS
IN SOIL AT AREA 2
-------------------B
772
770
(SBA2-11J
. (SBA2-20J
s g_ 765
C ~ .c (/)
~ 760 "' a,
<ii u (/)
<ii ·E 1ss
a, > a,
<ii E § 750
a. a. <(
745
740
LEGEND
0
(17316')
(170)
[SBA2-11] ,,,
~s ~
(3)
(2)
Bedrock
Location of soil sample
(SBA2-09J
1 ,2-DCA field analytical results in ppb
1,2-DCA laboratory analytical results in ppb
Soil boring ID#
Groundwater elevation
1,2-DCA concentration contour line in ppb
(330)
(1300)
Bedrock
Horlzoot.Bl Scafe (ft.)
0 30 60
Perched
Water Table
FIGURE 7
Northeast
Tributary
B'
772
70
765
760
755
50
745
740
SOIL PROFILE 8-8' WITH
1,2-DICHLOROETHANE CONCENTRATIONS
IN SOIL AT AREA 2
i
i
i
/
i i I
--------- -- - --
I '.:!: ,/
DRIVEWAY
·················J
WASTE-WATER COLLECTION PIT
SBLA-14
290(3.5)
1. PARKING
AREA
Ii AMMONIA SURNINQ SHED
/f i SBLA-11
. SBLA-23 SBLA-06 SBLA-04 J' .... s·sc.;;;:1·s··· .. : .... ).,_• ,1(17-SJ
LA;goN ◄ - --~t~~~1-·-NDl ___________ :;=~9::\,i( :~:-~□-J-J~~~J-4-05 ... C~:J~lfs;o
3 . . ---• -.· . . ' • ! SBLA-22 :' ·,, • \ ····<;,''""f:·c."/-·-···· SBLA-01
--0 100
l t 5J(5.5) • : I ~-,1· ,., ....... ·f;I ····• -.,... ··•65(7 5) ··• ' •,\ ,\: ,: .
SBLA-07
36(9.5)
LAGOON 1
APPROXIMATE SCALE (ft)
I
200 300 400
SBLA-20 ···-.:-:~: :·-~,000 ND ·• ..•. •
SBLA-19
ND
SBLA-18
19000(7.5)
LAGOON2
500
SBLA-08 ■
3J(1.5)
• SBLA-09
2J(3.5)
-----
LEGEND
SOIL BORING SHOWING 1,2-0CA CONCENTRATION
■ (ppb) AND (OEFTH (rl)) Of MAXlMUM
CONCENTRATION
j WASTE-WATER LINE. AmC1N INDICATES
DIRECTION OF FLOW
ABANOONEO LINE
..... _ -• ~. 1,2-0CA CONCENTRATION CONTOUR
10000-./
NOTE: Confirmation data supplemented by
9011 screening data.
FIGURE 8
CONCENTRATIONS AND
EST/MA TED EXTENT OF
1,2-DICHLOROETHANE
CONTAMINATION IN THE
SOILS AT THE WASTEWATER
TREATMENT LAGOON AREA
-
. -------------------
775
770
C ~ .c 765
(/)
"' <U
745
C
[SBLA·24) SBLA-23)
SBLA-22)
SBLA-07) [SBLA-06)
(NO)
(5) c,.or
(-.!;GENO
0 Location of soil samples
{ND*) 1 ,2-DCA Field concentration in ppb
[SBLA-04)
[SBLA-15)
[SBLA-14)
-,r----u_ [SBLA-05]
(NO)
(NO1
(NO)
(NO)
(NO)
(NO)
(NO)
{3.0) 1,2-DCA Laboratory concentration in ppb
(ND) 1,2-DCA analyzed for but not detected
[SBLA·14]Soil boring ID#
. " . Static groundwater level
"10 ~ 1 ,2-DCA Concentration contour line in ppb 0 ,0 "
C'
775
Top of grade 770
765
[SBLA-10)
[SBLA-11)
760
(13) 755
'o
(Nd')
750
(3)
(NO) (NO~
745
(7)
FIGURE 9
SOIL PROFILE B-B' WITH
1,2-DICHLOROETHANE CONCENTRATIONS
IN SOIL AT THE WASTEWATER
TREATMENT LAGOON AREA
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LEGEND
CHAIN LINK FENCE------, NORTHEAST ____ \
TRIBUTARY
---------
r
....
DAJVEWAY ! ·:~~¼r?• PARIONG ,
SBLA-12: AAEA .
SBLA-04 ND ■, :
· ............ --------·······
1100 ~ ; SBLA-14 .. -,------.
SBLA-23 sc1.;(o;i .·::->: r~~;::'.:;::·~·S_·■:;bt-11
ND ':' :: ·., . .,l_-:-ssLA-05 . Bu,-1µ
SBLA-24 ■ ■ .' 51 ■ f ·. i ·•··■ 230 ·._.--1100 _:
ND : ■ : ~-■ ■ SBLA-01 . _:. _.·
SBLA-22 : '. ·• ·,\j60 : : .
[]
ND . . ' ■SBLA-02 _.' /
SBLA-07 ·-,SBLA-18'. '-__ 3SOO .-· : g 24J --,130: ■SBLA-03.'/
ct -· 150
.J LAG09N 2 ■ . $BLA-09 LAGOON1 ~----.'.'130J
1000 . 100--:-: ■,, ,
1 o-----: '.SBLA-Oll • .
·. ·-.2200 . . . .
SOIL BORING SHOWING ACETONE ■ CONCENTRATION (ppb) FIGURE 10
.... ____ ACETONE CONCENTRA.llON
100_/. CONTOUR (ppb)
DISTRIBUTION OF ACETONE
IN SOILS IN AREA 2 AND
THE WASTEWATER TREATMENT
LAGOON AREA
APPROXIMATE SCALE (ft) r:::-::-
0 100 200 300 400 S00
---------------NA,....AACH_ICA!._,SUP~m; RECORD OF DECISION FOR OPERABLE UNIT 14
-21-
TABLE 2 VOLATILE ORGANIC COMPOUNDS IN AREA 2 SOILS
COMPOUND NAME
Acetone
2-Butanone
Chloroform
1,2-Dichloroethane
Methylene chloride
Tetrachloroethene
Toluene
Vinyl chloride
COMPOUND NAME
Acetone
2-Butanone
Chloroform
1,2-Dichloroethane
Toluene
SBA2-01
2-4 ft
12/06/92
6U
12 U
SBA2-07
8-10 ft
12/21/92
SBA2-02
0-2 ft
12/06/92
SU
6U
13 U
SBA2-07
18-20 ft
12/21/92
65 UJ
14 U
SBA2-02
2-4 ft
12/06/92
SU
SU
6U
12 U
SBA2-07
20-22 ft
12/21/92
14 UJ
14 U
SBA2-03
4-6 ft
12/19/92
SBA2-04
2-4 ft
12/19/92
70 U
7 U 35 U
7U
7U
7U
13 U
SBA2-08
0-2 ft
12/21/92
42 UJ
14 U
35 U
35 U
35 U
SBA2-08
2-4 ft
12/21/92
55 UJ
17 U
SBA2-05
20-22 ft
12/19/92
13 U
7U
7U
13 U
SBA2-08
18-20 ft
12/21/92
12 UJ
SBA2-06
4-6 ft
12/20/92
38 U
SBA2-09
12-14 ft
12/22/92
15 UJ
SBA2-06
8-1011
12/20/92
33 U
33 U
66 U
SBA2-09
14-16 ft
12/22/92
24 UJ
SBA2-06
20-22 ft
12/20/92
SU
SU
13 U
SBA2-09
16-18 ft
12/22/92
18 UJ
SU
120 U
au 7U 7U 7U SU SU idiu;~l:@x:i: SU SU -------------+----+----+----+----+----r-----+-----
1, 1 ,2-Trichloroethane a u 7U 7U 7U SU SU SU SU
--------· -------NATI-ARCH~~SUPEl!alm
-22-
TABLE 2 VOLATILE ORGANIC COMPOUNDS IN AREA 2 SOILS
COMPOUND NAME
Acetone
2-Butanone
1,2-Dichloroethane
Methylene chloride
Styrene
Tetrachloroethene
Toluene
Concentrations in ppb.
SBA2-10
6-8 ft
01/19/93
6U
6U
D · Compound analyzed at a secondary dilution.
SBA2-11
4-6 ft
01/19/93
6U
6U
SBA2-11
6-8 ft
01/19/93
6U
6U
J • Compound detected but below the quantitation limit; value estimated.
E · Concentration reported from outside of standard calibration curve.
Shaded areas depicts positive detection.
SBA2-15
4-6 ft
01/20/93
.7U
7U
SBA2-16
2-4 ft
01/20/93
SBA2-18
12-1411
01/20/93
SBA2-19
12-1411
01/22/93
3,000 U
RECORD OF DECISION FDA OPERABLE UNIT #4
SBA2·20
_4-6 ft
01/22/93
1,900 U
SBA2-20
8-1011
01/22/93
1,100 U
1,600 U 1,900 U 1,600 U
; M11#1~iiri]i :,l~~~,qlil@Iiti _ii!~~oiri,ri,01iii11
790 U 930 U 800 U.
790 u 930 u !iiiiiiiiiiffit:ili
790 u 1r~W:~~:t:rns;~?::1:R?1 ~:;pr;:;~~t~P.Q;f:::
--------------NATIONALSTARCH&CHEMICAL&MPAIIYSUP-SITE -
RECORD OF DECISION FOR OPERABLE UNIT #4
-23-
TABLE 3 VOLATILE ORGANIC COMPOUNDS IN SOIL SAMPLES FROM WASTEWATER TREATMENT LAGOON AREA
COMPOUND NAME
Acetone
Bromodichloromethane
2-Butanone
Chloroform
Dibromochloromethane
1,2-Dichloroethane
Methylene chloride
Toluene
COMPOUND NAME
Acetone
Brornodichloromethane
2-Butanone
Chloroform
Dibromochloromethane
1,2-Dichloroethane
Methylene chloride
Toluene
SBLA-01
2-4 ft
12/07/92
7U
SBLA-04
0-2 ft
12/08/92
6U
·6 U
SBLA-01
4-6ft
12/07/92
7U
SBLA-04
2-4 ft
12/08/92
SBLA-01
6-8 ft
12/07/92
6U
SBLA-04
10-12 ft
12/08/92
7 U 36 U
SBLA-020-
2 ft
12/07/92
7U
SBLA-05
2-4ft
12/08/92
6U
6U
6U
SBLA-02
2-4 ft
12/07/92
7U
7U
7U
SBLA-05
4-6 ft
12/08/92
6U
6U
6U
SBLA-02
4-6 ft
12/07/92
6U
6U
6U
6U
SBLA-03
2-4 ft
12/08/92
7.U
7U
SBLA-03
4-6 ft
12/08/92
7U
7U
SBLA-03
6-8 ft
12/08/92
6U
6U
6U
--------------NA~TAAC-MICAL&MP~SUP-SITE -RECORD OF DECISION FOR 0PERA8l£ UNIT 14
-24-
TABLE 3 VOLATILE ORGANIC COMPOUNDS IN SOIL SAMPLES FROM WASTEWATER TREATMENT LAGOON AREA
COMPOUND NAME
Acetone
SBLA-07
8-10ft
12/09/92
Bromodichloromethane 6 U
Dibromochloromethane . 6 U
1,2-Dichloroethane
Methylene chloride
Toluene
COMPOUND NAME
Acetone
2-Butanone
1,2-Dichloroethane
Methylene chloride
Tetrachloroethene
Toluene
Total xylenes
1, 1,2-Trichloroethane
. Trichloroethane
Concentrations in ppb.
6U
SBLA-12
8-10ft
01/06/93
17 U
30 UJ
7U
7U
7U
7U
7U
SBLA-08
0-2 ft
12/15/92
6U
11 U
6U
9U
SBLA-12
10-12 ft
01/06/93
18 U
11 U
21 UJ
6U
6U
21 UJ
6U
6U
SBLA-08
4-6ft
12/15/92
9U
19 U
9U
9U
16 U
9U
SBLA-13
10-12 ft
01/06/93
20 U
14 U
7U
7U
7U
7U
7U
7U
E -Concentration reported from outside of standard calibration curve.
Shaded areas depicts positive detection.
SBLA-09
2-4ft
12/15/92
7U
SBLA-14
0-2 ft
01/07/93
10 U
13 U
18 UJ
6U
6U
6U
6U
6U
SBLA-10
6-8 ft
12/16/92
7U
SBLA-14
2-4 ft
01/07/93
12 U
18 U
23 UH
9U
9U
9U
9U
9U
SBLA-10
16-18 ft
12/16/92
7U
SBLA-18
6-8 ft
01/07/93
SBLA-11
12-14 ft
12/16/92
7U
SBLA-22
4-6 ft
01/08/93
6U
6U
SBLA-11
16-18ft
12/16/92
7U
SBLA-23
2-4 ft
01/09/93
6U
6U
SBLA-24
6-8 ft
01/09/93
18 U
6U
6U
J -Compound detected but below the quantitation limit; value estimated.
D -Compound analyzed at a secondary dilution.
- --- -----·---- ---·---NATIONAL STAACH & CHE~ICAL CoMPANY SUPERF\JND SITE
RECORD OF DECISION FOR OPERABLE UNIT #4
-25-
TABLE 4 CONCENTRATIONS OF INORGANIC ANALYTES IN SOIL CONTAMINATION CHARACTERIZATION SAMPLES
COMPOUND/ANAL YTE
SE-12
(Background)
SEMIVOLATILE ORGANICS
Delta-BHC ND
hthalate
'INORGANIC$
Antimon
· Arsenic
Barium
·Be Ilium
• Cadmium
Chromium
Lead
Nickel
· Selenium
Thallium
Vanadium
Zinc
SBA2CC-06
4-6 ft
0.52 U
0.26 U
Concentrations are in milligrams per kilogram (mg/kg) or parts per million (ppm).
J -Concentration is estimated.
SBA2CC-06
8-10 ft
0.25 U
0.25 U
SBA2CC-09
12-14 ft
11 U
940 U
U -Undetected.
SBA2CC-09
14-1611
11 U
940 U
SBA2CC-20
4-6 ft
11 U
890 U
SBA2CC-20
8-1011
10 U
870 U
SBALCC-18
6-8 ft
Shaded areas depicts positive detection.
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-26-
NATIONAL STARCH & CHEMIC.AL COMPANY SUPERFUND SITE
REOORD OF DEOSION FOR OPERABLE UNIT #4
After reviewing the data presented in Table 1 and reviewing the history of the chemicals
used at the NSCC facility, it becomes apparent that a few of the compounds listed in Table 1
were not used at the facility. These include chloroethane and vinyl chloride. Their presence
at the Site indicates that some of the contaminants are being transformed by agents within the
environment. Currently, the identity of these agents is unknown; however, they are believed
to biological and not chemical.
5.2 GROUNDWATER
The nearest private potable wells are approximately 400 feet north of the NSCC property
line, which is approximately 2,100 feet from Area 2. These wells are approximately 2,100 feet
from the edge of the plume and 2,400 feet from the lateral extent of the contaminated soil.
These private potable wells are completed in the bedrock formation. ·
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. 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 zone of the aquifer.
A total of 61 groundwater samples were collected from 52 different locations. All of the
groundwater samples were analyzed for voes. Only groundwater samples collected from
pennanent monitoring wells were analyzed for the full analytical analyses. To summarize the
analytical results, a total of 16 different voes, three (3) SVOCs, one (1) pesticide, 14 metals,
. and cyanide were detected in the groundwater. voes detected in concentrations that exceed
either Federal Maximum Contaminant Levels (MCLs) or State groundwater quality standards
include (listed alphabetically) acetone, 1,2-dichloroethane, chloroethane, trichloroethane, 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.
Two plumes of contamination in the groundwater in the saprolite zone were delineated.
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 flushed out of the
unsaturated soils through the natural processes of precipitation and percolation.
The highest total concentration of volatiles and the greatest variety of volatiles were
found in the groundwater in the bedrock zone just downgradient of the wastewater treatment
lagoons. This finding also supports the conclusion that contaminants are being flushed out of
the unsaturated soils through the natural processes of precipitation and percolation in this
area of the Site.
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-27-
5_3 SURFACE WATER AND SEDIMENT
NATIONAL STAR~ & CHEMICAL. COMPANY SUPERFUND SITE
RECORD OF OEaSION FOR OPERABLE UNIT #4
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 were also analyzed for SVOCs
and metals. Each sampling event has shown contamination to be present in the surface
water and sediment of this tributary directly adjacent to Area 2. To date, only two (2) VOCs,
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.
No contaminants were detected downstream of the plant prior to the stream leaving the
NSCC property which indicates that under normal weather conditions, no contamination is
leaving the Site via the Northeast Tributary.
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 15-2L.02).
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 1 O to 100 feet below ground surface.
The deepest bedrock was encountered was in the vicinity of the Northeast Tributary. Figure
11 shows the orientation of the hydrogeological cross-section of the Site which is displayed in
Figure 12.
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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-28-
NATIONAL STARCH & CHEMICAL COMPANY SUPERRJND SITE
RECORD OF 0EaSI0N FOR OPERABLE UNIT #4
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 1 O 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 g_roundwater
discharge along its entire reach. This explains the presence of contaminants being detected
in the sur1ace 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 (fVday) and 0.01 to 1.13 Wday, respectively. Based of the above
infonnation, the horizontal flow of groundwater in the saprolite was estimated to have a
velocity of 80 feeVyear (Wyr) in the lagoon area and 27 Wyr in Area 2. ·
6.0 SUMMARY OF SITE RISKS
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 environment if contaminated
media (i.e., the soils) at the Site were not remediated. The baseline risk assessment is
incorporated into the June 1993 RI report which can be found in the NSCC Administrative
Record.
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
(1) a source or mechanism of chemical release to the environment, (2) a transport medium
(e.g., soil, groundwater, air, etc.), (3) an exposure point (where a receptor will contact the
medium), and (4) an exposure route (i.e., ingestion, inhalation, or dermal contact). A pathway
is considered complete when all of these elements are present.
Since use of the land surrounding the NSCC·facility is a mixture of residential and
commercial, two scenarios were evaluated in the baseline risk assessment. The first is where
the property remains as a commercial area in the future and secondly, the property is
transformed into a residential area in the future.
-------------------
N 1300 -
g
N0.00
ff,O
Jj ~-'It
2
ANS-26
l;,l-03 NS-27
A
AEX-04
NS-15
A
' " " " :: " " " " " :: "
" ,, ,, ,. ,, '' -,, " ""' :: :: :: :: s It II ------" ---------------------------------,
SCA1£(TIJ
0 1002DO:!I00'008'l0
LEGEND
■ SBA2·2
A
NS-14
l.OCAT()NS WKERE lllff\.lSM. """"""" ......,, """"'°""
loOHITOOl«l WEU.
WHERE FIEFUSAl. WM IIU,CNEO
N-700 h--,~)~/....,.....4--~.,.:..l .-.-+m---?--r-.---..-----.--.---,---,-,--l,...+-,---.-lr-i'---f'"-r-+J!IL.1-rH / !IEOflOC:1( Ell\'4TOH
0 co,mxm
E-3200 E-2200 E-1200
PLANT EAST (It)
CHAIN LINK FENCE
-,....
FIGURE 11
BEDROCK STRUCTURAL CONTOUR
MAP SHOWING CROSS SECTION
LOCATION A-A'
-------------------
aoo
700
aoo I
J
500
0
A
HS-21
I
L£0ENO
500 ,00
A'
FIGURE 12
HYDROGEOLOGIC CROSS SECTION
LOCATION A-A'
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NATIONAL STARCH & CHEMICAL COMPANY SUPERFUND SITE
RECORD OF DEOSION FOR OPERABLE UNIT #4
Based on the information collected during the RI, the following pathways were
considered in the baseline 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;
• 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 under 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; and '
• 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.
The baseline risk assessment indicated that there were no unacceptable current risks
from direct soil exposure. Future use of the Site as a residential area was also considered
with no unacceptable risks resulting from direct contact to surface soil. Future risks for
children exposed to subsurface soils that become surface soil without dilution of the
contaminant (1,2-DCA) concentration in Area 2 were 2 x 1 O"" (2 in 10,000), just outside EPA's
acceptable risk range of 1 x 10 .. to 1 x 1 o-•. However, the risk manager considers this
scenario so unlikely that it will not be a basis for the remedial decision. The remedial decision
will be based on protection of groundwater.
7.0 REMEDIAL ACTION OBJECTIVES
Section 5.0 defined the extent and characterized the contamination and the
environmental setting. Section 6.0 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. Protection of human health may be achieved by either reducing
exposure or reducing contaminant levels. Protection of the environment includes the
protection of natural resources for future uses.
The specific remedial action objectives and general response actions for the
contaminated soils at the Site are:
For Human Health --Prevent release of contaminants from soil that could result in
contaminant levels in excess of groundwater cleanup objectives
specified in the OU #3 ROD
• For Environmental -Protection --Continue containment of contamination
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NATIONAL ST.A.AQ-1 & CHEMICAL. Cot.4PJJff SUPERFUN0 SITE
REOORD OF 0EaSl0N FOR OPERABLE UNIT #4
7.1 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARS)
Section 121 (d) of CERCLA, as amended by Superfund Amendments and
Reauthorization Act of 1986 (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(9)(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-specific and
location-specific ARARs for the selected and contingent remedial alternatives are listed in
Table 5. The chemical-specific ARAR is discussed in Section 7.2 PERFORMANCE
STANDARDS. .
7.2 PERFORMANCE STANDARDS
Currently, there are no Federal or State ARARs that govern the cleanup for the
contaminants present in the OU #4 soils if the contaminated soils are not excavated. The
following soil performance standard (cleanup goal) for 1,2-DCA is based on 1,2-DCA leaching
into the underlying groundwater. The concentration of 1,2-DCA that could be left in the soil
without increasing the concentration of 1,2-DCA in groundwater above the most stringent
groundwater quality concentration (NCAC 15-2L.0202) for 1,2-DCA was estimated to be 169
µg/kg. This concentration was based on comparing the TCL analytical results for 1,2-DCA in
soil to the corresponding TCLP concentration using a least squares linear regression.
7.3 EXTENT OF CONTAMINATION
Figures 4, 6, 7, 8, 9, and 1 O reveal the lateral and vertical extent of soil contamination
in Area 2 and the wastewater treatment lagoon area. These soil contamination delineations
are based on contamination levels detected in the soil as well as where there were no
detections of contaminants in the soil.
The estimated.volume of soil contaminated above 169 µg/kg is over 231,300 cubic
yards. The quantity of contaminated groundwater in one pore volume of the aquifer beneath
Area 2 and the wastewater treatment lagoon area is estimated to be 131 million gallons (OU
#3 ROD).
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NATIONAl STARCH & CHEMICAL COUPAf./Y SUPERFUNO SITE
RECORD OF 0EOSION FOR OPERABLE UNIT #4
8.0 DESCRIPTION OF ALTERNATIVES
Table 6 inventories those technologies that passed the initial screening for remediating
contaminated soil. In the initial screening, process options and entire technologies were
eliminated from consideration if they were difficult to implement due to Site constraints or
contaminant characteristics, or if the technology had not been proven to effectively control the
contaminants of concern. Table 7 presents the results of the final screening of the soil
remediation technologies. Effectiveness, implementability, and relative capital and operation
and maintenarice 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 four (4) soil remediation alternatives retained to address the estimated 231,300
cubic yards of contaminated soil are described below.
8_1 REMEDIAL ALTERNATIVES TO ADDRESS SOIL CONTAMINATION
Alternative S1:
Alternative S2:
Alternative S3:
Alternative S4:
· No Action
Natural Degradation & Institutional Controls
Soil Vapor Extraction with Fume Incineration and Activated
Carbon Filter to Control Emissions
Soil Vapor Extraction with Activated Carbon Filter to Control
Emissions
The cost infonmation below represents the estimated Total Present Worth of each
alternative. Total present worth was calculated by combining the capital cost plus the present
worth of the annual operating and maintenance costs. Capital cost includes construction,
engineering and design, equipment, and site development. Operating costs were calculated
for activities that continue after completion of construction, such as routine operation and
maintenance of treatment equipment, and monitoring. 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 amount necessary to pay for initial construction costs and future expenditures,
including operation and maintenance (O&M) and future replacement of capital equipment.
A 7 percent discount rate was used to calculate the Present Worth Operation & Maintenance
Costs.
0_1_1 ALTERNATIVE S1: No action
The No Action alternative is included, as required by CERCLA, to establish a baseline
for comparing the benefits achieved by the other soil remediation alternatives. Under this
alternative, no cleanup activities would be implemented to remediate the adversely impacted
soils at the Site (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·
--·-- - - - - - - - --- --- --NATIONAL STAACH & CHEt,JCAL COMPANY SUPERFIJND SITE
-----------------------------------------------------,------RECOROOF DECISION FOR OPERABLE UNIT '4-
·-34-
TABLE 5 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
On-site Container
; Storage
Soil Sampling
and Testing
Actions to limtt worker exposure to hazardous
wastes or hazardous substances, including
training and monttoring.
Coniainers of hazardous was1e must be:
Maintained to good condftion
Compatible with hazardous waste to be
stored
Closed during storage (except to add
or remove waste)
Inspect container storage areas weekly for
deterioration.
Place containers on sloped, crack-free base,
and protect from contact with accumulated
liquid. Provide containment system wnh a
capactty of 1 0 percent of the volume of
containers of free liquids.
Remove spilled or leaked was1e in a timely
manner to prevent overflow of the
containment system.
Keep compatille malerials separate.
Separate incompalille materials stored near
each other by a dike or other barrier.
Any non-waste material (e.g., groundwater or
soiij that contains a hazardous waste must be
managed as if tt were a hazardous waste.
Construction, operation, and
maintenance, or other activities
with potential worker exposure.
RCRA hazardous waste (Isled ·
or characterstic) held for a
temporary period before
treatment, dsposal, or storage
elsewhere. (40 CFR 264.10) in
a container (i.e., any portable
device in which a material is
stored, transported, disposed of,
or handled).
Non-was1e material containing
Isled hazardous waste
40 CFR 264.171
(15A NCAC 13A.0009(j))
40 CFR 264.172
(15A NCAC 13A.0009(j)]
40 CFR 264.173
(15A NCAC 13A.0009GJ]
40 CFR 264.174
(15ANCAC 13A:0009U)]
40 CFR 264.175
(15A NCAC 13A.0009G)J
40 CFR 264.177
(15A NCAC 13A.0009U)]
RCRA ·contained in'
principle
These requirements are applicable or
relevant and appropriate for any ·
contaminated soil or treatment system
waste that might be containerized and
stored on site prior to treatment or final
disposal. Soil containing a listed waste
must be managed as if n were a
hazardous waste so long as tt contains
the Isled waste.
S3
S3
S3
S3
S3
- ---- - - - - ----------NATIONAL STARCH & CHE~ICAL CoMPANY SUPERF\JNO SITE
----------------------------------~----------------c---,------AECOROOF DECISION FOR OPERABLE UNIT #4
-35-
TABLE 5 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
LOCATION REQUIREMENT(S) PREREQUISITE(S) CITATION COMMENTS A' RAb TBC'
All Off-Site Shipment The off-stte shipment of hazardous waste Generating site to shjl waste off 40 CFR 262 NC: S3
Requirements for requires that all RCRA and DOT site. 15A NCAC 13A.0007 . Generator must keep inspection
Hazardous Waste Per requirements for manifesting and shipping 40 CFR 263 records for 3 years
RGRA and Department papers as needed, marking, labeling, 1 SA NCAC 13A.0008 . D, F, H, & I on NC manifest mus!
of Transportation (Don placarding, and special requirements based 40 CFR 171 through 179 be completed.
Regulations Will Be Met or type of carriage (i.e., rail, aircraft, public
by the OU #4 Site highway, etc.) be met.
(Generator) and
Transporter
Closure No Post-General perlormance standard requires Applicable to land-based untt 40 CFR 264.111 S2
closure Care . elimination of need for further maintenance containing hazardous waste. 11 SA NCAC 13A.0009{h)) S3
(e.g., Clean and control; elimination of post-closure Applicable lo RCRA hazardous
escape of hazardous waste, hazardous waste {fisted or characteristic) Closure) cons1i1uen1s, hazardous waste decomposition placed al Site after the effective
producls. date of the requirements, or
disposed only before the
effective date of the
requirements, or tt treated in
situ, or consolidated within area
of contamination. Designed for
cleanup that will not require
long-term management.
Designed for cleanup to heatlh-
based slandards.
Disposal or decontamination of equjlment, May apply to piping and 40 CFR 264.178 S3
and structures. container or tank liners and [1 SA NCAC 13A.00090)J
hazardous waste residues. 40 CFA 264.111
Removal or decontamination of all waste [1 SA NCAC 13A.0009{k)) .
residues, contaminated containment system
components (e.g., liners, dikes), and
structures and equipment contaminated wtth
waste.
- - --- ---- - - -- ----- -
NATIONAL STARCH & CHE~ICAL COUPANY SUPERFUND_SITE_
--------------------------------:-------------------------IREREOCOOFRIDDOFOF DECISION FOR OPERABLE UNIT #4
-36-.
TABLE 5 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
LOCATION REQUIREMENT(S) PREREQUISITE(S) CITATION COMMENTS A' RA' TBC'
Treatment of wastes subject top ban on land Treatment of LOR waste 40 CFR 268.43 • Table The substantive portions of these S3
disposal mus! attain levels achievable by Best ccw requirements are to be considered in the
Demonstrated Treatment Technologies for [15A NCAC 13A.0012(c)) disposal of any OU #4 stte waste that ~ a
each hazardous constttuent in each fisted restricted hazardous waste.
waste,
1,2-DCA (U077) non-wastewater 7.2 mgA<g
total
RCRA Treatment, A regulated RCRA TSDF must submtt an Regufaled RCRA TSDF 40 CFR 270.10 lhrough Though NPL snes are exempt from the S2
Storage, and application for a permft (Including both Parts 270.65 permitting process, all substantive S3
Disposal Facility A and 8). requirements of the permitting process
(TSDF) Permitting must be met.
Operation of Air Registration of Air Pollution Sources . Emission of air pollution 15A NCAC 20.0202 The director may require the owner or S3
Pollution Source operator of a source of air pollution to
register that source.· Must submit a "G"
sheet.
Toxic Emission Clean Air Act (CAA) as Emission of 1,2-DCA Section 112(a)(1) Because it appeal! !hat NSCC Is a major 53
(Chemical: 1,2-Amended in 1990 Section 112(9) source of Hazardous Air Pollutants (HAPs)
pursuant to Section 112(a}(1) of the CAA, Iha DCA) venting or incineration of 1,2-0CA or any HAP
may also trigger the requirements of Section
I 12(g) ot the CAA The proposed Section
. 112(g) rule will apply to a major source/facility
which emit-s a HAP in exceedance of the
corresponding de minimis level (once
promulgated). This provision applies only in a
state whera a 40 CFR Part 70 operating permit
program has been delegated or 'IVhere a 40
CFR Part 71 operating permit program (yet lo
be proposed) is effective. This t 12(g) trigger
will require the development of a case-by-case
maximum achievable control technology
determination for the venting process or the
incinerator. (Note: A HAP source is
considered to be major if it emits or has the
potential to emit 10 tons of any one HAP or 25
tons of any combination of HAPs.)
-- -- - --- - - - ----- ---NATIONAL STARCH & CHE~ICAL CoMPANY SUPERFUND SITE
---------:--------------------------------------------.,---~--RECORD OF DECISION FOR OPERABLE UNIT 14
-37-
TABLE 5 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
LOCATION REQUIREMENT(S) PREREQUISITE(S)
Toxic Air Pollutant Guidelines. Emission of 1,2-0CA
Permil Requiremenls for Toxic Air Pollulanls. Emission of 1,2-DCA
Applicabilily-2H.0610(a)
Emitting In Prevention of Significant Deterioralion (PSD) Emitting In Rowan County,
Attainment of Review which is designated attainmenl
Unclasslflable or Unclassifiable for all
Area for any regulated pollutants.
Criteria Pollutant
(1,2-DCA)
a -Applicable Requirements for Alternatives as noted.
b -Relevant and Appropriate Requirements for Alternatives as noted.
c -Criteria "To Be Considered" for Alternatives as noted.
CITATION
I5ANCAC20.IIOO
15A NCAC 2H.0610
North Carolina Toxic Air
Pollutant Control
Regulations, A Summary
of !he requirements, July
31, 1991
CAA Section 107
COMMENTS A' RAb TBC'
S3
De minimis for permitting requ~ements for S3
1,2-DCA is 260 lbs/yr. NSCC emitted
approximalely 58,956 b/year. Perrnil will
be required.
A loxics review is required for ·existing S3
facifilies Iha! begin perrnilled conslruction
of a new source of any amount of any.-
lisled loxic pollutant after April 30, 1990".
This will require computer air dispersion
modeHing for a predicled maximum annual
average concenlralion al Iha property line
lo compare with Iha acceptable (AALI ol
3.8 µg/m'
Proposed new and modified sources in S3
Rowan Counly are potentially subjecl to
PSD review. NSCC is classified as an
existing major stationary source. Addition
of a SVE syslem is a modification,
therefore, must check for significant
emissions increase of any pollutant
subject to regulation under CAA (i.e.,
VOCs) PSD de minimis • 40 tons per
year increase; compare this lo projected
1,2-DCA emissions alter SVE syslem
addition to delermine if PSD review is
required.
Note: All parenthetical citations are from North Carolina Hazardous Waste Management Regulations, North Carolina Administrative Code, Title 15A,
Chapter 13 -Solid Waste Management, Subchapter 13A -Hazardous Waste Management.
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-38-
NATIONAL STARCH & CHEMICAL COMPANY SUPERFUND SITE
RECORD Of DEaSI0N .FOR OPERABLE UNIT #4
review of the Site remedy every five years in accordance with CERCLA Section 121 ( c). This
review process will continue every five years until the performance standard (cleanup goal) for
the identified contaminants in the soil are achieved. The implementation of this remedy could
begin immediately and would have no negative impact on future remedial actions.
If no action is taken migration of contaminants from the soil into the underlying aquifer in
the vicinity of the wastewater treatment lagoon area will continue. This migration results from
the natural movement of precipitation (e.g., rain and melted snow) moving through the soils
and carrying the contamination downward as the precipitation recharges the aquifer. This
migration force does not exist in Area 2 as this area is covered with concrete building
foundations and asphalt driveways. These structures prohibit precipitation from percolating
into the underlying soils. Therefore, all precipitation becomes surface runoff which is
controlled by the slope of the asphalt driveways and the curbs built around the asphalt
driveways. Surface runoff is directed into sumps where the water is pumped to the
wastewater treatment lagoons. Although Alternative S1 does not actively reduce or eliminate
soil contamination, it is anticipated that the levels of 1,2-dichloroethane will decrease over time
due to the process of natural degradation.
. There are no initial capital costs for Alternative S1. Annual operating costs are based
on conducting periodic monitoring of the soil in order to prepare the five ·year review every five
years for a period of 30 years. As part of the five year review, soil samples will be collected
for chemical analyses once every five. years in both areas, Area 2 and the wastewater
treatment lagoon area.
Capital Costs:
Annual O&M Costs
First Year:
Second Year:
Third Year and Later:
Present Worth O&M Costs:
Total Present Worth Costs for 30 Years:
Time to Design:
Construction Time:
Duration to Achieve Clean-up:
$ 0
$ 16,000
$ 0
$ 0
$199,000
$199,000
None
None
Over 30 years
8.1.2 ALTERNATIVE 52: Natural Degradation & Institutional Controls
Natural degradation relies on natural processes to destroy the contaminants present.
The most common degradation process is the result of microorganisms (bacteria, fungus, etc.)
present in the soil using the contaminants as an energy (food) source; thereby, destroying the
contaminant. The presence of two chemicals at the Site, chloroethane and vinyl chloride,
neither of which were reportedly used at this NSCC facility, is a strong indication that 1,2-DCA
is being transformed via natural degradation process(es). The rate and effectiveness of the
natural degradation process is dependent on a number of environmental factors, such as
nutrient availability, soil moisture content, presence or absence of oxygen in the soil, etc.
Using a published half-life of two (2) years for 1,2-DCA in the environment under
anaerobic conditions, the following degradation rates were estimated: in less than 1 O years,
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NATIONAi... STAAQ-1 & CHEMICAL C0"4PANY SUPERFUND SITE
RECORD OF DEaSION FOR OPERABLE UNIT #4
the concentration of 1,2-DCA should decrease a concentration of 7 mg/kg; in less than 21 years the concentration of 1,2-DCA should decrease to 169 µg/kg, the concentration that can remain in the soil but not adversely impact the quality of the underlying groundwater above the performance standard for 1,2-DCA; and in approximately 35 years, the concentration of 1,2-DCA in the soil should reach a concentration of 1 mg/kg. It was estimated over 130 years of pumping the groundwater will be require to remediate the groundwater to the specified
ARAR of 1 µg/1, as specified in the OU #3 ROD.
As part of this alternative, a biodegradative study will be conducted. This study will be designed to (1) confirm or refute that natural degradation in the soil is occurring in the area of OU #4, (2) if confirmed, locate where in the subsurface environment biodegradation is occurring, and (3) ascertain if biodegradation will reduce the soil contamination within a reasonable timeframe to a level which will protect groundwater and will not cause an
exceedarice of the OU #3 groundwater cleanup goal for potential breakdown products (such as vinyl chloride). In the event that natural degradation is occurring at an acceptable rate, then the data from the biodegradation study will be used in the CERCLA Section 121 (c) required 5-year review. With the completion of the overhead pipeline in February 1994, no additional contamination should be entering the soils beneath the Area 2 building. Based on the degradation discussion above, a substantial decrease in the concentration of 1,2-DCA in the soil should be observed over the next several years. In the event that the concentration of 1,2-DCA in the soil does not decrease as anticipated, a contingent remedy consisting of an active soil remediation technology (as described in Alternative S3 below) shall be implemented
to achieve the reduction of contaminant levels that would be protective of the quality of the underlying groundwater.
As this alternative is not a "No Action" alternative ii is important to recognize the need for continued monitoring of the Site. The biodegradative processes are subject to numerous
outside influences that may-change over time (e.g., precipitation, infiltration, soil/nutrient
chemistry, etc.). Therefore, should the decision be made to remain with natural degradation, a long term monitoring plan will be prepared which shall govern monitoring until the performance standards are met. The monitoring parameters will include those that pertain to the biodegradative processes (e.g., soil gases/degradation products/nutrients) as well as direct
measures of contaminants in question. The biodegradative study is to accomplish the goals specified above and the long term soil monitoring is to provide data that substantiates that natural degradation is continuing to occur in the adversely impacted soils of OU #4.
Institutional controls include using various controls and deed restrictions. The specific institutional controls considered for this alternative are 1) using and maintaining the existing fence around the plant operations area to limit access to the contaminated areas; 2) repair and sealing of all cracks, seams, and other points of infiltration through the paved or built-over · areas, 3) periodic inspection and maintenance of paved areas around Area 2 to insure the integrity of the cap over this area, and 4) a deed restriction to control future land use of the NSCC property. The deed restriction will contain language to accomplish the following four objectives: 1) to inform any potential buyer of the property of the contamination present, 2) restrict future land use which would decrease the likelihood of human exposure to
contaminated soils, 3) to prevent the installation of a potable well at the Site until the levels of contamination in the groundwater under the Site are deemed safe, and 4) to prevent
excavation in contaminated soils without sufficient personal protection for the workers. The suitable deed restriction shall be recorded in the appropriate county registrar's office.
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Capital Costs:
Annual O&M Costs
First Year:
Second Year:
Third Year and Later:
Present Worth O&M Costs:
-40-
Total Present Worth Costs for 30 Years:
Time to Design:
Construction Time:
Duration to Achieve Clean-up:
NATIONAL STARCH & CHEMICAL Cm.ffANY SUPERRJND SITE
REOORD OF DEaSION FOR OPERABLE UNIT #4
$196,000
$ 4,000
$ 0
$ 0
$ 50,000.
$246,000
3 months
1 month
Over 30 years
• The Total Present Worth Cost is approximate and
was developed without regard for long term
monitoring, therefore, Total Present Worth Cost
may be slightly higher than that presented.
8.1.3 ALTERNATIVE S3: Soll Vapor Extraction with Fume Incineration and Activated
Carbon Filter to Control Emissions
This alternative will remove volatile organic contaminants by means of vapor extraction
wells installed in the soil above the water table. A preliminary design for Area 2 suggests a
system of 10 horizontal soil vapor extraction wells drilled underneath the buildings and
driveways. These 1 O extraction wells will remove a total of 1,300 cubic feet per minute of
contaminated air. The preliminary design for the wastewater treatment lagoon area suggests
a system of seven vertical extraction wells removing a total of 20 cubic feet per minute of
contaminated air. The extracted contaminated air from Area 2 would be treated using fume
incineration to destroy the volatile organics prior to the air stream being released into the
atmosphere and the extracted contaminated air from the lagoon area would be treated using
vapor-phase activated carbon adsorption filters to remove the volatile organics prior to the air
stream being released into the atmosphere. The contaminants captured by the vapor-phase
carbon filters would be destroyed through the thermal regeneration of the used activated
carbon at an off-site, commercial regeneration facility. The incineration of chlorinated organics
in the fume incinerator will create hydrochloric acid gas that will require a scrubber. The
scrubber water will require treatment and disposal.
Remediation of the soil in Area 2 and the wastewater treatment lagoon area is expected
to be completed within 4 to 7 years and 1 to 2 years, respectively. A review/assessment in
accordance to CERCLA Section 121 (c) would be performed to verify that the soil vapor
extraction system is proceeding as anticipated or accomplished the specified cleanup goals
that will be stipulated in the Record of Decision.
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Capital Costs:
Annual O&M Costs
First Year:
Second Year:
Third Year and Later:
Present Worth O&M Costs: .
-41-
Total Present Worth Costs for 7 Years:
Time to Design:
Construction Time:
Duration to Achieve Clean-up:
NATIONAL STARCH & CHEMICAL COMPANY SUPERFUND StTE
RECORD OF 0EOSION FOR OPERABLE UNIT #4
$2,887,000
$ 507,000
$ 416,000
$ 416,000
$2,394,000
$5,281,000
9 months
3 months
Over 7 years
8.1.4 ALTERNATIVE S4: Soll Vapor Extraction with Activated Carbon Filter to Control
Emissions
This alternative is identical to Alternative S3 with the exception that the extracted
contaminated air from both areas would be treated using vapor-phase activated carbon
adsorption filters to remove the volatile organics prior to the air stream being released into the
atmosphere. As before, the contaminants captured by the vapor-phase carbon filters would
be destroyed at an off-site, commercial regeneration facility.
Capital Costs:
Annual O&M Costs
First Year:
Second Year:
Third Year and Later:
Present Worth O&M Costs:
Total Present Worth Costs for 7 Years:
Time to Design:
Construction Time:
Duration to Achieve Clean-up:
$2,918,000
$3,353,000
$1,566,000
$ 475,000
$6,270,000
$9,188,000
9 months
3 months
Over 7 years
9.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
Section 8.0 describes the remedial altematives that were evaluated in the detailed .
analysis of alternatives set forth in the June 20, 1994 OU #4 Feasibility Study Report. This
· section summarizes the detailed evaluation of the soil remediation alternatives in accordance
with the nine (9) criteria specified in the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP), 40 CFR Section 300.430(e)(9)(iii).
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(1)(1 )(ii)(C).
-----
General
Response
Action
No Action
Institutional Action
- - --
Technology Type
NIA
Access Restrictions
-----
Process Option
Assessment-
Technlcal
lmplementablllty
NIA
Deed Restrictions
Fencln SI ns
---- -
Comments
Fence already In place.
[==:§~Tuiii~==J---c==::::£~~===~-.----C-lay-/So_11 __ ~ containment Capping . _
Corx:rete
L-JL_..:So~ll:.;Vc,a=~:.;r Ee;xt:,:r,::B,:c<l,::IO::_nc.___,I -Steam/Air Strl--"' Inn I
1.--JJ)\#fWMlVltrlffCQtfori"/@{%'tt%/I Not applicable for volatlle organic contaminants.
-!ii%f1n6fti"imKf:,SlilbllltatlOiit!f)¥1 Not eppllceble for volatile organic contaminants
··-------:;Hifttl""'\lf}I Innovative, commercially unproven technology.
Bloventlna I
fi,i~[!i[~ [IBB]filt[Ex~·ca)jj····~-"a~t~ki~ll[P[:r~Ewfilfffilkfili:ill}---{::.fil~J[ti§\0()~-~nv~··•,·i~n@tt~o~"ti'~Al~IE~x~·ca~·-v~-aillHOill'"i1~-"::::.filt~illtillt ia~1~~e~~o:rn~~ru~~~essible; Excavation could
,,,.,,,M.,,,,,,,,Nott>RCAALllni:tflll.:,::.:.:;:,:;.;::::.
TABLE 6 INITIAL SCREENING OF TECHNOLOGIES AND PROCESS OPTIONS FOR SOIL REMEDIATION
--
----
General
Response
Action
------
Technology Type
--·-
Process Option
Assessment-
Ti,chnlcal
lmplementablllty
i?H!C&MimloiialExcaiiatl6n+Yi'
- - ---
Comments
Plan area Is mostly Inaccessible; Excavation could
damage lagoon structure
Innovative technology
Innovative technology
Not eppllcable for organic contaminants.
Not appllcable for organic contarrylnanls.
No such faclllty exists.
No such facmty exists.
TABLE 6 INITIAL SCREENING OF TECHNOLOGIES AND PROCESS OPTIONS FOR SOIL REMEDIATION
-
-------- --- - -- ---- -
General
Response lnstllutlonal Effectiveness
Action Technology Type Process Option lmplemenloblllty In Meeting RAOs Cost
No Action NIA tU.e -Easily Implementable Not Effectlvo Low
Deed Restrictions Easily Implementable Somewhat Effective Low
lnstilullonal Action Access Restrictions
Fencln SI ns Easily Implementable Somewhat Effective lo'N
~ Clat/Soll lmplemen1able with Difficulty Somewhat Effective Low
Containment Capping
Concrete lmJ)lementa~le with Olfflculty Somewhat Effective Low
Easily Implementable Effective Moderate
In Situ Treatment In Situ Treatment Steam/Air Strl Implementable with Difficulty Effective High
Bioventln Easlly Implementable Somewhat Effective Modera!e to High
-Process Option Retained
TABLE 7 SECOND/FINAL SCREENING OF TECHNOLOGIES AND PROCESS OPTIONS FOR SOIL REMEDIATION
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-45-
NATIONAL STARCH & CHEMICAL CoMPANY SuPERFUNO SITE
RECORD OF 0EOSI0N FOR OPERABLE UNIT #4
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.
As stated in Section 6._0, under current conditions the Site does not pose an
unacceptable risk to human health or the environment. Future use of the Site as a residential
area was also considered with no unacceptable risks resulting from direct contact to surface
soil. Future risks for children exposed to subsurface soils that become surface soil without
dilution of 1,2-DCA in Area 2 were just outside EPA's acceptable risk range. However, this
scenario is so unlikely that it was not a basis for the remedial decision. The remedial decision
was based on protecting groundwater.
All four alternatives, S 1, S2, S3, and S4 are expected to provide long-term protection for
human health and the environment in conjunction with the OU #3 remedial action. However,
Alternatives S2, S3, and S4 will provide protection, more quickly, from exposures to
contaminated subsurface soils. Of these three alternatives, Alternatives S3 and S4 will afford
the greatest protection to human health as they substantially reduce the contaminants in the
soil within 4-7 years of initiation of the alternatives. Under Alternatives S1 and S2,
contaminant levels are anticipated to decrease as a result of natural degradation. Alternatives
. S3 and S4 protect the environment by removing contaminants from the soil, thereby
eliminating the potential for migration of contaminants to groundwater. In conjunction with the
OU #3 groundwater remedial action, Alternatives S1 and S2, will also be protective of the
environment. This protection .stems from the following factors: 1) all contaminated soils are
within the groundwater plume to be remediated by OU #3, 2) the OU #3 remediation will
prevent the spread of contaminants and remove contaminants from the groundwater, and 3)
soil contaminants should be reduced by natural processes within the timeframe required to
complete the OU #3 groundwater remediation. Alternative S1 does not provide short term
protection for hunian health, however, as discussed previously, the Site does not pose an
unacceptable risk under the current use scenario.
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 st_ate environmental laws, or provide justification for waiving an ARAR. Site action
and location specific ARARs are identified in Table 5.
As long as the soils are left in place (i.e., not excavated), no Federal or State ARARs for
contaminants found in the OU #4 soils are triggered. Alternatives S3 and S4 will comply with
action-specific and location-specific ARARs which include operations at a hazardous waste
site, disposal of used activated carbon as solid waste, and air emission controls. Alternative
. S2 will comply with the location-specific ARAR related to operations at a hazardous waste site
and there are no action-specific ARARs that apply to this alternative. No ARARs were
identified for Alternative S 1 as no action is being taken.
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9.2 PRIMARY BALANCING CRITERIA
NATIONAL STARCH & CHEMICAL COMPANY SUPERRJNO SITE
RECORD OF DEaSION FOR OPERABLE UNIT #4
Five criteria are used to evaluate the overall effectiveness of a particular remedial
alternative.
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.
Alternatives S3 and S4 will provide effective and permanent solutions for the
contaminated soil. The chemicals of concern will be removed from the soil by the soil vapor
extraction system and destroyed. Neither alternative will leave any treatment residuals on
Site. The reliability of both Alternatives S3 and S4 is high because they rely on proven and
applicable technologies and the extent of the contamination is relatively well defined. The
reliability of Alternative S4 is higher than Alternative S3 because of the maintenance problems
associated with the fume incinerator. Alternatives S1 and S2 do not directly remove, treat, or
isolate subsurface contaminants; therefore, they are comparable to one another in terms of
reducing potential residual risks. However, contaminant levels should gradually decrease to
levels that would be protective of groundwater quality due to natural degradation processes.
The time required to reach this concentration falls well within the OU #3 groundwater
remediation timeframe (estimated to be 130 years). Alternative S2 involves long-term
institutional controls to prevent future exposures to subsurface soils as well as the use of the
contaminated groundwater beneath the NSCC facility. The projected adequacy and reliability
of these controls depends on-land use, but should be relatively high because the impacted
area is small, within the plant boundaries, and land use is not expected to change. Soil
monitoring and periodic reviews at five-year intervals will be required for all four alternatives,
but the duration of performing such reviews for Alternatives S1 and S2 is expected to be much
longer. The long term effectiveness and permanence of Alternatives S1 and S2 are
dependent on the rate of degradation and effectiveness of the OU #3 remedial action.
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 toxicity, mobility, or volume (TMV) of the contaminants present at the
Site.
Both Alternatives S3 and S4 actively reduce the toxicity and mass of contaminants in
the soil. This is accomplished through the removal of the contaminants from the soil via the
soil vapor extraction system followed by fume incinerator or the thermal destruction of
contaminants trapped on the carbon filter. Neither Alternative S1 nor S2 directly reduce the
toxicity, mobility, or volume of contaminants through an engineered treatment process, but
reduction due to natural processes is expected to occur well within the time period required
for, and in conjunction with the OU #3 groundwater remediation.
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9.2.3 SHORT-TERM EFFECTIVENESS
NATIONAL STARCH & CHEMICAL Cm.!PANY SUPERRJNO SITE
RECORD OF OEaSl□N FOR OPERABLE UNIT #4
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.
There are no short-time risks posed to site workers, the general public, or the
environment associated with either Alternative S1 or S2. There are minimal short-term risks
associated with Alternative S4 which are primarily due to general safety issues associated
with the construction of the soil vapor extraction and air emissions treatment systems. In
addition to risks associated with Alternative S4, Alterative S3 as two additional risks,
maintenance problems associated with the fume incinerator and the handling of hydrochloric
acid generated by the scrubber associated with the incinerator. Potential risks could also exist
during the operating period, especially workers exposure to fugitive vapors. If either the
carbon adsorption or fume incinerator/scrubber systems malfunction, temporary volatile
organic emissions would be' controlled and minimized through properly installed monitoring
and control processes. Surface runoff during construction, as for any construction project,
would be controlled to protect nearby surface waters.
9.2.4 IMPLEMENTABILITY
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.
Alternative S1 requires no-implementation. Alternative S2 will be easy to implement
because minimal construction activities are required. Both Alternatives S3 and S4 are
projected to require approximately 12 months to design and construct, and approximately 4 to
7 years of operation.
9.2.5 COST
This criterion assesses the cost of an alternative in terms of total present worth cost.
Total present worth was calculated by combining the capital cost plus the total present worth
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 soil monitoring. The
present owrht (PW) of an alternative is the amount of capital required to be deposited at the
present time at a given interest rate to yield the total amount necessary to pay for initial
construction costs and future expenditures, including O&M and future replacement of capital
equipment.
More detailed information on the development of the total present worth costs for each
alternative can be found in Section 8.
Alternative S1 -No Action: $ 199,000
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NATIONAL STARQ-l & CHEMICAl COl.!_PANY SUPERFUND SITE
RECORD OF 0EaSI0N FOR OPERABLE UNIT #4
-48-
Alternative S2 Natural Degradation and Institutional Controls:
Alternative S3 Soil Vapor Extraction with Fume Incineration
and Activated Carbon Filter to Control Emissions:
Alternative S4 -Soil Vapor Extraction with Activated Carbon
Filter to Control Emissions:
9.3 MODIFYING CRITERIA
$ 246,000
$5,281,000
$9,188,000
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. North Carolina Division of Solid Waste Managment
(NCDSWM) has also reviewed the Proposed Plan and EPA's preferred alternative and
concurs with the selected remedy as described in Section 10. The State's correspondence
providing concurrence can be found in Appendix A.
9.3.2 COMMUNITY ACCEPTANCE
The Proposed Plan Fact Sheet was distributed to interested residents, to local
newspapers and radio and television stations, and to local, State, and Federal officials on July
8, 1994. The Proposed Plan public meeting was held in the evening of July 26, 1994. The
public comment period on the Proposed Plan began July 12, 1994 and closed on September
9, 1994.
Written comments were received from one citizen, the City of Salisbury, and NSCC
during the public comment period. The questions asked during the July 26, 1994 public
meeting and the Agency's response to the written comments are summarized in the
· Responsiveness Summary, Appendix A. Minimal input was received from the community at
large.
10.0 DESCRIPTION OF THE SELECTED REMEDY
This is a contingency ROD. Alternative S2 is selected for addressing the contaminated
soils at the Site with the contingency remedy being Alternative S3. Briefly, the selected
remedy (Alternative S2) for this Site is:
• Perform a "Biodegradative Study" to (1) substantiate that natural degradation of
contaminants of concern is occurring in the OU #4 area, (2) identify where in the
subsurface of the OU #4 area degradation is occurring, (3) determine the rate of
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-49-
NATIONAL STAR~ & CHEMICAL. COMPANY SUPERFIJND SITE
RECORD OF 0EaSION FOR 0PEAA.BLE UNIT #4
degradation, and (4) develop and implement a for long term monitoring plan (refer to
Section 8.1.2) to monitor the biodegradative process until the performance standards
have been achieved. The collection of this data will begin after this ROD.
• In the event that the "Biodegradative Study" cannot substantiate the occurrence of
significant natural degradation of 1,2-DCA and other contaminants of concern, or the
study shows that degradation products increase the site risk, the contingent remedy
(Alterative S3) shall be implemented. For the purposes of this ROD, "significant
biodegradation" is defined as a statistically significant decrease in levels of
contaminants of concern (particularly 1,2-DCA} that is coupled with multiple indicators
of biological activity, which includes the appearance of degradation products such as,
but not limited to, chloroethane, ethane, vinyl chloride, ethene, carbon dioxide,
hydrogen sulfide, methane, and soluble iron(II}} and the depletion of electron acceptors
(including oxygen, nitrate, iron, sulfates, or others}. This decision will be made by EPA
two years after the signing of this ROD.
• If, at any time, the Biodegradative Study or long term monitoring indicates that Site
risks are increasing due to incomplete biotransformation of contaminants of concern
(transformation to vinyl chloride which do not continue to ethene as an end product}.
The contingency remedy may be implemented.
• The institutional controls to be implemented are deed restrictions and maintenance of
both the existing fence around the plant operations area and the paved areas around
Area 2. A deed restriction will be recorded in the appropriate county registrar's office
to prohibit any owner of the Site from utilizing the groundwater as potable water until
such time as the contaminated plume meets drinking water standards. A plan will also
be developed by NSCC, as needed, to protect workers in the event that the
contaminated soils are to be excavated prior to the levels of 1,2-dichloroethane
reaching the appropriate direct contact health based risk concentration (i.e., 7 ppm).
NSCC will provide EPA written confirmation that the worker(s} read and understood the
plan.
• · Five year reviews/assessments, in accordance with CERCLA Section 121 (c}, will be
performed until the specified performance standard for 1,2-DCA in the soil is achieved
(i.e_, concentration of 169 ppb).
The contingency remedy, Alternative S3, includes the following activities:
• Volatile organic contaminants will be removed from the soils by means of vapor
extraction systems installed in the soil above the water table. The extracted
contaminated air from Area 2 will initially be treated using fume incineration to destroy
the volatile organics prior to the air stream being released into the atmosphere. After
concentrations of contaminants decrease in the extracted air, this contaminated vapor
will be treated via vapor-phase activated carbon adsorption filters. The extracted
contaminated air from the lagoon area will be treated using vapor-phase activated
carbon adsorption filters to remove the volatile organics prior to the air stream being
released into the atmosphere. The contaminants captured by the vapor-phase carbon
filters will be destroyed through the thermal regeneration of the used activated carbon
at an off-site, commercial regeneration facility.
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NATIONAL STARCH & CHEMICAL COMP).Jf( SUPERRJND SITE
RECORD Of OEOSION FOR OPERABLE UNIT #4
-50-
A review/assessment in accordance to CERCLA Section 121(c} will be performed to verify that the soil vapor extraction system is proceeding as anticipated or has accomplished the specified cleanup goals that will be stipulated in the Record of Decision.
10.1 PERFORMANCE STANDARDS TO BE ATTAINED
Table 5 lists the action-specific and location-specific Site 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 performance standard for 1,2-DCA in the soils to be met/attained by the NSCC OU #4 RA is 169 µg/kg or ppb. This is the anticipated concentration that will protect the quality of the underlying aquifer of being adversely impacted above the remediation goal established for 1,2-DCA in the OU #3 ROD.
10.2 SOIL REMEDIATION
The RA shall comply with all ARARs listed in Table 5. The presence of contamination
in the soils will require deed restrictions to document their presence and could limit future use of the area known to be affected by the contaminated soils.
10.3 BIODEGRADATION STUDY
A Work Plan .to implement and govern the "Biodegradative Study" will be developed for EPA approval as soon as possible after the signing of this ROD. The objectives of this Biodegradative Study Work Plan are: (1) confirm or refute that natural degradation in the soil is occurring in the area of OU #4, (2) if confirmed, locate where in the subsurface environment biodegradation is occurring, and (3) ascertain if biodegradation will reduce the soil contamination within a reasonable timeframe to a level which will protect groundwater and will not cause an exceedance of the OU #3 groundwater cleanup goal for potential breakdown products.
10.4 COST
The total present worth costs for 30 years for the selected alternative is $246,000 and $5,281,000 for the contingency remedy.
The break down of these costs are specified below. The present worth (PW) cost components are:
Selected Remedy --Alternative S2
Capital Costs
TOTAL PW O&M COSTS (at annual PW O&M Costs of $4,000)
TOTAL PRESENT WORTH COST
$ 196,000
$ 50,000
$ 246,000
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NATIONAL STAR~ & CHEMICAL COMPANY SUPEAFUND SITE
RECORD OF OEaSION FOR OPERABLE UNIT #4
Contingency Remedy --Alternative S3
Capital Costs
-51-
TOTAL PW O&M COSTS (at annual PW O&M Costs of $416,000)
TOTAL PRESENT WORTH COST
11.0 STATUTORY DETERMINATION
$2,887,000
$2,394,000
$5,281,000
Based on available information, both the selected and contingent remedies satisfy the
requirements of Section 121 of CERCLA, as amended by SARA, and the NCP. Both
remedies provides protection of human health and the environment, are cost-effective, utilize
permanent solutions to the maximum extent practicable, and satisfy the statutory preference
for remedies involving treatment technologies.
11.1 PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
In conjunction with the OU #3 RA, both the selected and contingent remedy will protect
human health and the environment. The potential for exposure to Site contaminants via
dermal, ingestion, and inhalation pathways will be greatly reduced.
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 action and location-specific ARARs which are to be
attained is included in Table 5. No waivers of Federal or State requirements are anticipated
for OU #4.
11.3 COST-EFFECTIVENESS
The selected soil remediation technology is more cost-effective than the other
acceptable alternatives considered. The selected remedy will provide greater benefit for the
-cost as it is anticipated to permanently remove the contaminants from the impacted soils. In
the event the selected remedy is not effective in attaining the specified performance standard,
the contingent remedy is a proven technology for removing and destroying VOCs in soils.
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
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-52-
NATIONAL STARCH & CHEMIC.Al. COMPANY SUPERRJND SITE
RECORD OF 0EaSI0N FOR OPERABLE UNIT #4
through treatment; short-term effectiveness, implementability, and cost; State and community
acceptance; and the statutory preference for treatment as a principal element. The contingent
remedy will satisfactorily fulfill the above parameters as well.
11.5 PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT
The preference for the treatment of contaminated soil is satisfied by the use of
· employing indigenous microorganisms to degrade the volatile contaminants in the soil at the
Site. It is anticipated that the principal threats at the Site will be eliminated by use of this
treatment technology. In the event that the selected remedy will not achieve the specified
performance standard within an acceptable timeframe, the contingent remedy also satisfies
the preference for treatment.
12.0 SIGNIFICANT CHANGES
The July 1994 Proposed Plan Fact Sheet for OU #4 identified two potential alternatives
as the contingent alternative in the event that natural degradation could not be substantiated.
The two alternatives were Alternative S3 Soil Vapor Extraction with Fume Incineration and
Activated Carbon Filter to Control Emissions at an estimated cost of $5,281,000 and
Alternative S4 Soil Vapor Extraction with Activated Carbon Filter to Control Emissions at an
. estimated cost of $9,188,000. The emphasis of the Proposed Plan Fact Sheet was to stress
the fact that an active remedial action alternative would be implemented if natural degradation
was not occurring. This ROD selected Alternative S3 as the contingent alternative as this
alternative is more cost effective than Alternative S4.
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APPENDIX A
CONCURRENCE LETTER FROM THE STATE OF NORTH CAROLINA
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state of North Carolina
Department of Environment. Health and Natural Resources
Division of SoUd Waste Management
James B. Hunt, Jr .. Governor
Jonathan B. Howes. Secretary
WIiiiam L. Meyer, Director
September 29, 1994
&"?'A -__ •;)[~ a ,;,., _____ •
DEHNA
Mr. Curt Fehn, Chief
NC Remedial Section
U.S. EPA Region IV
345 Courtland Street, N.E.
Atlanta, GA 30365
Subj: Conditional Concurrence with the Record of Decision for OU4
National Starch and Chemical Company NPL Site
Salisbury, Rowan County, NC
Dear Mr. Fehn:
The Division of Solid Waste Management (DSWM) has completed review of the
attached Revised Record of Decision for Operable Unit 4 (OU4) and concurs with the
selected remedy subject to the following conditions.
1. The DSWM is aware that institutional controls are subject to uncertainties regarding
enforceability. Our concurrence is with the understanding that EPA shall attempt
to reach an enforceable agreement with the responsible party regarding stipulated
penalties which the responsible party will incur if the property is sold. We request
that we be notified prior to entering these negotiations so that we may provide EPA
with infonnation and input regarding this issue.
2. DSWM concurrence on this Record of Decision and the selected remedy for the site
is based solely on the information contained in the attached Record of Decision.
Should DSWM receive new or additional infonnation which significantly affects the
conclusions or remedy selection contained in the Record of Decision, it may modify
or withdraw this concurrence with written notice to EPA Region IV.
P.O. Box 27687, Raleigh, North Carolna 27611-7687 Telephone [phone] FAX [phone]
Ari Equal Opportunity Amrmatlve Action Employer 50'I. recycled/ 1 ()ll, post-consumer paper
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Mr. Curt Fehn
9-29-94
Page 2
3.
4.
DSWM concurrence on this Record of Decision in no way binds the State to concur in future decisions nor commits the State to participate, financially or otherwise, in the clean up of the site. The State reserves the right to review, co=ent, and make · independent assessments of all future work relating to this site.
The responsible party for this site is undergoing a review of its compliance with the North Carolina Hazardous Waste Management Rules. Concurrence on this Record of Decision in no way affects or alters the compliance requirements or enforcement
of the North Carolina Hazardous Waste Rules which are administered by the Hazardous Waste Section of DSWM.
· The DSWM appreciates the opportunity to co=ent on the Revised Draft Record of Decision for OU4 for the subject site, and we look forward to working with EPA on the final remedy. If you have any questions concerning these co=ents please contact Bruce Nicholson or me at [phone].
bin \let\nsou4con
cc: Michael Kelly
Bruce Nicholson
Jon Bornholm
Attachment
Sincerely,
Jack Butler, PE
Head, Remediation Branch
D
D
m·
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I APPENDIX B
I PROPOSED PLAN FACT SHEET
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SUPERFUND PROPOSE~ PLAN FACT SliEET .,
Region 4
OPERABLE UNIT #4 _;_SOIL;REMEDIATION.;IN~~~T
·· · OPERATIONS AND IBEATMENT LAGOON AREAS
. NATIONAL STARCH.& CHEMICAL COMPANY
.. .,_,· i· •
July 1994 . . . . . Salisbury, RoY!,an County,,~9~h.(;arQlijna
T~lnbokllacl""~ll8ddlllldln1;lossar,locltldltff,slfld_~(t/,U~lca.··~~~-~.Bl*,ltls~~be. ·~• tecbnlCBI doclinilnt,;;;; has bilen pnpaiecl IXi prcwltl61 bfttsr unclsistandltii to lhll ct · : , , ·· :· ·
INTHODUCTlON
. Tlis ~;sedPlan sum~arizes Iha June 20, 1994 Operable Unit . 14 (OU #4) Feasibiity Study and Identifies Iha preferred clearRJp
option for addressing Iha comamlnated soU associated with Area 2 and Iha wastewater lreatment lagoon area at Iha National Starch & Chemical Company (NSCC) Superfund Si1e In Safisluy, North Caror111a. The tenn "Operable Unir Is used when ildividual actions are taken as a part of an overaD sHe clearRJp. A runber of operable units can be used In Iha C0l1'S8 of a stte clearlJp. !'-5 Fourth Operable Unit Is anticipated ID be 1he last Operable UM for the NSCC sile. The Proposed Plan Fact Sheet for Operable Uri! #3 (OU #3), which addressed the contaminated grou,dwaler
ooder1ying these same areas of the NSCC property, was distributed to ttie public In July 1993. ·
The Environmental Protection f>(;ercy (EPA), lead !>(;ency for Sile activities, prepared this Proposed Plan with Iha assislance of Iha North Caronna Department of Environment, Health and Natural Resources (NCDEHNR), the support agercy. The data and information presented In Iha Remedial Investigation for OU #3 also supported the OU #4 FeaslblUtyStudy. EPA, In consuttation with NCDEHNR, wiD select a remedy for OU #4 only after Iha publ"lc comment period ends and aD lnfonnation submitted ID EPA during this time has been reviewed and considered.
EPA Is Issuing this Proposed Plan as part of Its public participation responsibiDties In accordance with Section 117(a) of Iha Comprehensive Envlronmental Response, Compensation, and UablUty Act (CERCLA), also known as Superfund. Ttis Proposed Plan Fact Sheet summarizes lnfonnation presented in
the June 1993 OU #3 Remedial Investigation Report, which
Includes Iha Baseline Risk Assessment, and Iha June 20/1994 OU 14 Feasibiity Study document, and other documents contained
In the lnlonnaUon Reposltcxy/AdmlnlstraUve Record for this Sile. EPA and the State encourage the public to re~ lhese documents to better understand Ille Site and 1he Superfund activities conducted. The Administrative Record Is avalable for
pubric review locally at 1he Rowan Pubric Ubrary at 201 West Fisher Stree~ Salisbury, North Caroli"-8. .
. • • 1 .. •.·. ,. • ..
EPA, i1 consultation with NCDEHNR, may modify the preferred allernative or select another response action presented In !tis Plan and Ille Remedial Investigation and the Feasibility Study Reports based on new lnfonnation and/or public comments. Therefore, the publ"ic Is encouraged to review and comment on an alternatives discussed below. This Proposed Plan:
1. Includes a brief background of the Site and the principal fildings of OU #3 Site Remedial Investigation and the recent
hydrophobic dye lest
2. Presents the remedial (cleanup) alternatives for OU #4 considered by EPA;
3. Ou1!ines the evaluation crileria used to recommend a remedial . alternative;
4. Summarizes the analysis based on the evaluation criteria;
5. Presents EPA's rationale for Its recommended remedial
alternative; and
6. Explains the opportunities for the public to comment on the remedial alternatives and become involved in the process.
PROPOSED PLAN PUBLIC MEETING:
DATE: July 26, 1994
LOCATION: Agrfeultural Extension Center
2727 Old Concord Road
Salisbury, North Carollna
TIME: 7:00 PM • 9:00 PM PUBLIC COMMENT PERIOD: July 12, 1994 -August 11, 1994
',
SITE BACKGROUND OU 13 • Grouoowater In Area 2 and Ile wastewater lrealment lagoon aiea; Sllface water/sediments In the Northeast Tribu1ary . .
-. . . . ~
OU #4 • Sons In Area 2 and the wastewater treatment lagoon area. ,
RESULTS OF nlE OU 13 REMEDIAL INVESTIGATION USED FOR OU 14 FEASIBILITY STUDY
The NSCC facility occupies approximately 465 aaes on Cedar Springs Road fiw miles south of Jhe City:'ot•1Saliswy, Noi1h · C3rolina (refer to R{Jlir,. 1), . Presemly, )and --~ iffl!nediately adjacent to lhe Site Is .iLmix1118 .. of reslden1ial and hfustrlal de'lelopments,. East and. sou1h O! ,lhe;Si!il are-~ ~ consisting prmarfly of light hfustrlal operations. The west and nor1h sides of lhe NSCC property are bordered by residential developments. Refer to lhe Fl(JIJl9 21or S!te location. . • , ,, .. ,-. , ;', • .. , '';, ;('; : ''.,~'. ; f,. ! ' · •··,. · As reported in previous FaclSlleets,contaminants haw beenWld A artace sb"eam on tile NSCC,property, .referrecLto as Ille -lnlheso«ls,goundwalsr,andSllfacewa!Brfsedimeil!onlheNSCC Northeast Tributary ff ~ to Cedar ~ Road and property.. lllS C0111ami1ati0n..... • ~--. be llaCed bJ!ck to past_. chemical passeswffhlnSO~~ maruiaciiifng·araaoi'lhe~(mfe/. handf11g and clsposal paclices,ofthe NSCC facifty: The scmes to Rgure ~-Sllface water MOIi from lhe 'easierri;&lde oflhe of Ille contimilation were ldell!ified. The types and concentrations facirty <ischarges in1D tlis ttxrtary. · The prtmafy"'objective of of lhe con1amilants ha'l8 been verified. The extent of contamilalion Operal)le Units 13_ and 14 was to determine Ille SOlll:8, nabie, and In Ille \l8doSe soB zone has been defined. The vadose zone Is extent of the. contamination bel~ contiMusly .delected In this comprised of Sl.tJsl.rlace soil lhat Is not saturated v.i1h water. The · stream on lhe NSCC property. , , ·"' .. ,, , _ · , . , · • Interface .between Ille vadose zone and the i'safi.rated zone is commonly refelTBd to as lhe water table. Folnsen different volatile Primarily, NSCC marufactires teldie-finishing chemlcals and custom organic C0lllJ)Olllds, one seml-w1atile orgaric compollld, and one specialty chemicals. Volatile and seml-YOlatlle organic chemcals pesticide were de1BCl8d In the vadose soils. are used In lhe production process al~ Wi1h acidic. and alkaline solutions. Acidic and alkaline solutions are also used 1n the deaning The primary SOt.fC8S of contamination 1n Area 2 were a tuied, processes. The waste stream from lhe manufaclullng process leaking terra-cotta (fired clay) pipeline ard · a solvent recovery inclu:les wash and rinse solutions. · system. The terra-cotta pipelile transported iquld was1e from nea 2 to lhe wastewater ireabnent lagoons. Replacement of the terra· cotta pipeline Wi1h an owrhead stainless steel pipetine was completed ln Febl\lary 1994. Therefore, Ille terra-cotta pipelnl is no lo~r In use. Spils associated Yti1h operati~ the solvent recowry system haw been con1ained since 1988 v.t.en a conaete containment struc1l.re was constructed al0l.l1d the solvent recovery system. Prior to this, material contaili~ 1,2-dichloroe1hane was spiDed directly onto lhe grollld. The S0IJ'C8 of lhe contaminants detected In lhe wastewater treatment lagoon area is the son under and around the lagoons which were contaminated prior to 1he lagoons being rllled wilh concre1e.
Operable Uni1S #3 and #4 focus on lhe areas of lhe faclll1y refelTBd to as Area 2 and lhe wastewater treatment lagoons (refer to Rgure ~-Area 2 consists of 1he foDowing operations: Area 2 Reactor Room, _lhe Tank Room, Raw Material Bulk Storage, and the WarehOuse. The lagoon area Includes lhree lagoons. A fourth lagoon was 1nstaDed in 1992 as part of the treatment system built to treat the contaminated groundwa1er being extracted from lhe aquifer as part of 1he Operable Unit #1 (OU #1) Remed"lal Action.
As in Operable Uni1S #1, #2, and #3, lhe work performed for OU #4 was financed by NSCC, 1he Potentlally Responsible Party.
The NSCC site was proposed for Inclusion on lhe National Pr1011tles Ust In April 1985 and finalized on !he tist In October 1989. The Site had a Hazarclous Ranking System score of 46.51. Only Sites.Ytilh a Hazardous Ranking Sys1em scora of 28.5 or higier are eligible to be placed on the National Priorities List.
SCOPE AND ROLE OF OPERABLE UIIT wmilN SITE STRATEGY
As with many Superfund sites, the NSCC site is complex. Consequen11y, EPA divided the work 1111D four manageable components caDed Operable Units (OU); lhey are:
OU #1 • Groundwa1er In 1he western portion of 1he NSCC property
The primary contaminant is 1,2-dlch1010e1hane v.tiich Is a chlorinated organic compound that is typically used as a solvent. 1 ;2-Dichloroethane volatitizes readily and is classified as a probable human carcinogen. A carcinogen Is any substance 1hat can cause or contribute to 1he developme(l1 of cancer.
Other organic chemicals were detected. The chemicals of potential concern at the Site are (isled alphabetically): acetone, bis (2-chloroethyl) elher, bis (2-elhylhexyl) phthalate, 2-butanone, cadmium, carbon disulfide, chloroform, chloroethane, de11a-BHC, 1,2· dichloroelhene, di-n-butyl phthalate, di-n-octyl phthalate, ethyl benzene, methylene chloride, styrene, tetrachloroelhene, toluene, 1, 1,2-trichloroethane, trichloroelhene, vinyl chloride and total xylene. The following inorganics were also detected: aluminum, antimony, arsenic, barium, beryOium, chromium, cobalt copper, cyanide, lead, manganese, mercury, nickel, selenium, thaflium, vanadium, and zinc.
OU #2 • Trench Area soils and surface water/sediments in !he The only field work performed to support OU #4 activities in addition Northeast Tribu1ary . to !he field investigation conducted as part of OU #3 was a
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hydrol)ho!jc ~ lesl Tll8 -~~~jye-~~ ~ .iOC!~ ID --deteimlne tt 1.2-dichloroelhane existed as a riqt.ad In the subsurface sons at the Site> 1.2-Dichlciroelhane tiebrigs 10 ihe lanilly of chemicals Iha! ff sufficient !jU3ntities of 1,2-dichloloelhane are present, then the 1,2~~1haneiwil consoida\8 i1. the subsl.Vface env1rorvnen1 and 1orm poo1s · of ·1,2-dichloloelhane. 11 . was Important ID determine H 1,2-dichloroelhane exl~ as: a liquid · lrithe SWSIJface•eiivfrmerit as'h ~·1m· iocrii through experiences at olher Superfln! sites that the presence of such a poof of CClllamlna1lon -wll"· act• as -a· iconlilJouS · · sotrce · of contamination for many, many years. Consequenay, the presence . of such a poof of contamination W0IM control the success or lalll'8 of the Sile's dearlJI) as well as the cost of the cfeanJp~ ·Once i1 the ·Stbslrface. n 1s ·cifliclA·u norkl\¢ss1J1ef1o ri1ciciwf"a11 or ttie lrappei1 pooled oontamlnant froni the glOlnl. ·. · · ·
In a hydrophobic dye lest. a soil or grooodwalar sample is mixed i1 , a glass container that contails a solution of wa18r and a dye that will attach llseff to 1,2-dichloroelhane. H no dye is loll1d cfi,vng ID the sides of the glass container, then 1,2-diclioroelhane doesnot exist as a free llqljd ii the sample tested. To insure the most useful information was obtained, the six sol samples used In the hydrophobic dye test were colected 1nxn· the area of the Site contalring the highest son concentrations of 1,2-dichloroelhane. 'Qle resuts of the hydrophobic dye test (September 1993) on these six samples incfleate that 1.2-dichloroettiane does not exist as a free llQlid In the sols at the Sile. ·
Replacement of the terra-cotta pipelne with an overhead stainless steel plperine er1111inated the release of 1.2-<lichloroelhaile ID the soils beneath Nea 2 and, t.dtimately, ID the lllde~ytng groundwater. The coo.crate flooring of the building Q.e., the lollldalion} and the asphalf driveway that surrounds the building act as an impervious cap. By replacing the leaking terra-cotta pipeline with the overhead pipeUne, two goals were achieved. Rrst the source of contamination was eliminated. Second, water leaking from the terra cotta pipe comprised a driving force for the oowrr«ard migration of 1,2-dichloroelhane, and this driving fort:e was also eruninated. Therefore, It is not expected that contaminants present in the soa will adversely impact groundwater.
All the metals Onorganics) detected in the son are naturaRy oco.ning. The difference in concentrations between the background sediment sample and on-site son samples indicate the Site has not released inorganic contaminants Into the environment.
SUMMARY OF SITE RISKS
A goal ol the Remedial rnestigatiorvFeasibility S!IJdy process is ID analyze and estimate the human health and envirorunental problems that coud resut tt the contamination Is not cleaned up. This analysis is called a Baseine Risk Assessment. In calcu!ating risks ID a population If no remedial action is taken, EPA evaluates the reasonable maximum exposure levels under current and potential
Mure exposure scenarios ID Site contaminants. The risk scenarios evaluated In the Baseline Risk Assessment under current conditions lnclllled trespassers on lhe f-iSCC Site as we"iiasemployees
EPA's goal atSuperfund sites ls Ii> ieduce the excess lifetime cancer risk due ID chemicals presant at the Sile. Tl-ds means that h! chance of contracting cancer is between one kl ten thousand and one In one mlf10n. · · " ·
In the exp0Sll8 assessmeni, 'EPAco•re;i' ~ of soi, lmalalion of SOU vapor and/or particu!a,tes, and direct contact as the likely exposure pathways Iii the tiuman recepiors.
EPA concluded that under current conditions, the soil contamination associated with OU f4 does not pose an unacceptable~ risk to human health. There Is no current unacceptable risk because there Is no complete exposura pattwiaf for. the contaminants 10 · reach the J)(blic at large. However, three futuni risk scenarios were Identified which could lead ID unacceptable future risks as a reSIAt ot being exposed ID the chemical contamina&iiiai" the Site. The first scenario Involves residents living in homes built on or near the Site and using the contaminated grounctNaier'as their source for potable water. The key exposure pathway In this scenario is the use of the contaminated groundwater as a polable source. The second scenario that could result In another unacceptable fulure risk Is the exposure of a child ID the surface water, sediment and spring water. Currently, the potential for exposure through this pathway is significantly reduced because access to that portion of the stream where elevated concentrations ot contaminants are present is encompassed within the fenced area of the NSCC property. The third, potential unacceptable future risk Involves exposing kxfividuals ID contaminated subsurface soil. This risk exists for both wor!(ers . on-site as wen as future residents living on-site and digging into the subsurface soils. The wor!(er risks can be greaUy reduced by providing adequate personal protection.
REMEDIAL ACTION OBJECTIVES
The main goal of Remedial Action Objectives is to protect human health . and lhe envirorunent by preventing exposures ID concentrations of contaminants above risk-based human health or environmental standards. Protecting human health may be achieved by eilher reducing exposure or reducing contaminant levels. Protection of the environment includes protection of . natural resourtes for Mura uses.
In identifying the Remedial Action Objectives, the mdings of the Baseline Risk Assessment were used as wen as an examination of all potential federal and state environmental Applicable or Relevant
and Appropriate Requirements (ARARs). . ARARs · can be categorized ilscheml~, locati~c. o~actioo-specific.
Chemical-specific: ARARs ,Bili 'aciceptable expoSlie · 1eveIs to
particular chemicals ancfls lhe imit Iha! must be met for Iha!
contaminant within an"envlromientaf mediiin (le. water, sol, or at) .
at a specific coinpriance ·point 1.0catiot,-sjjecffic ARARs address
&lte-specifi: aspects sucli as ciiticaJ habitat upon which endangered species or lhrealened species depeiicis; lhe presence·ot i welland,
01'. tistoricaly signlfjcant ~s. A.cUori:sPdc ,equrements are con!rols gr res1ricti~ .. for,:~ .. ~s refa!8d to lhe Implementation or the proposed reme<lial alternative. In summary,
lhe Remedial Action Objectives for soils In Area 2 and Ille waslewater treatment lagoon area are: · . . .. ~··' . ...,... .... '•' ..-.:. ·~·.,,~, ..... . ~ , ~-· .. · · ... -. / ,.-,, , .. · • ·c· . ',; , •• ' ·. • For H1111an Heal1h: · Prevent direct contact wi1h sons having
levels resuting In cancer risks above acceptable linits
• For Human Heal1h: Prevent release or contaminants. from son ' . that could resut In contaminant levels in excess of groundwater
deanup objectives spedfied In lhe OU 13 Record or. Decision
• For Environmental Protection: Continue contannent of
. contamination.
The objecti~ of a Superjl,ild ; Sile. cleanup )s to reduce lhe contamination to concentrations specified by •ARARs• or Iha! is protective of human health. There are no Federal or Sta!ll ARARs Iha! govern Ille cleallJp of contaminated sols Iha! are not excavated. The tonowlng soi performance standards (cleanup
goals) for 1,2-dichloroethane were based on (1) 00'8CI contact expoSlie and (2) leaching of 1,2-<lichloroelhane Into the underlying
groundwa!llr.
Risk-basedconcentrationsfor1,2-<lichloroelhanewerecalculatedfor
the following exposure scenarios: a worker exposed to contaminated
soil and a Mure resident exposed to contaminated soil. The
concentration protective of a worker is 63 milligrams per kilogram
and for a Mure resident, 7 milfigrains per kilogram. Based on the
data collected, no surface sons at the Silll exceeded Ille risk-based
value of 7 mDligrams per kilogram for 1,2-dichloroethane. Therefore,
surface soils do not pose an unacceptable risk to human health
under current or Mure exposure scenarios.
However, subsurface soils underneath Area 2 and the wastewater
treabnent lagoon area have 1,2-<lichloroelhane concentrations of
1,600 milligrams per kilogram and 19 milfigrams per kilogram
respectively, both exceeding 7 miHigrams per kilogram. ff these soils
should be exposed under a future residential scenarios O.e., during
digging or construction), they would pose an unacceptable health
risk.
The next step in establishing Site cleanup goals Is to develop soil deanup levels to prolllct groundwa!llr. EPA determines what
concentration of contaminant can remain In the sou without leaching
to groundwater In quantities that would be above a protective level
for the groundwa!er. The estimated concentration of 1,2·
dichloroelhane that could be left In the soil without increasing the
conceil!ration of 1,2-dichforoethane In groundwa!er above the most ·s1r1ngeni giMct,v.ilerqual"1t)•concentration (NCAC ,15-2l.0202) .for
1,2-dichloroelhane Is 169 miaograms per lalogram. . . . . .
Ba~~~n Iha _risk-based value of 7 mDligrams per labQram; the
estimalei:I volirne of soil containina!ed above this concentration is 35.940 .Citic yards:· The estimated volume or son contamlnaled
above\169 ~s per kilogram is over 231,300 Cttlc.yanls.
SU~Y OF ~EDIAL ALTERNATIVES
'°: 'I"}" ,•..-,.(~-. .. ' •'•: .. •I • ,l • -., .. :.:-·t".
The folowr~i_~ SU'lllllarizes Ille cleamJp lllchoologies and altemalives developed In Ille OU .14 Feaslbiily Sludy doa.menl for addressing Ile soil cxintamlnation .In Area 2 and the wastewa1er trealment lagoon area. Desalptiolis.ot the clean-up allemalives are summarized below. ·• ··· ·
The'~t fnfonnation ·~ represents the estima!ed total present
worth of each allemafive ... Total present WO!lh was ca.loilated by
comblring Ille capital cost plus the present worth of the arruif operating . and mainlllnance COs1S, C3pilal . cost inckJcles
consllUction, engineering and. desi;n, equipment, and ... si1e
development. Operating costs were calculated for activities that contirul after completion or COl1S1ruc1ion, such as routine operation
and maintenance of..treabnent equipment, and•monilollrV-The
preserii worth of an alternative Is the 81ll01111 of capital l'8Qtlred to
be deposillld at the present time at a given inferest ralll to yield the
total amount necessary to pay for Initial construction costs and future expencilures, Including operation and maintenance · and full6e
replacement of capital equipment.
For more Information about the Remedial Action Objectives and al!ematives for OU 14, please refer to the June 20, 1994 Feasabirrty Sludy dlocunent and other documents available in the information
repository In the Rowan Pub!:~ Library.
REMEDIAL AL TERNA Fi ES TO ADDRESS SOIL
CONTAMINATION .
The four alternatives for addressing contaminated soils in::IUde:
AltemaUve S1: No Action
AltemaUve S2: Natural DegradaUon & Institutional Controls
AltemaUve S3: Soll Vapor ExtractJon with Fume Incineration
and Acttvated Carbon Riter to Control
Emissions
AltemaUve S4: · Soll Vapor Extraction with Acttvated Carbon
FIiier to Control Emissions
A description of each att2:native follows:
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Capital Costs: . $ ,. · 0 Annual Operating & Maintenance Cosis . ., ;, ,.
First Year: $ 16,000
Second Year: $ " 0
ThlrdYearandl.aler: .... ·.,·,~.>·'"··; .• > •,:,:f•···"·· O Present Wor1h Operating & Maintenance Costs: $199,000
Toial PreseniWor1h Costs for 30 Years: $199,000
TiJl\8JO Design: : ,,, . , i:•. ~.,. Constuction Time: , . · None .. Duration ti, AcNeve Cleari,uj): . , , ,. · :. · Over 30 years
, " ,., . ;'""".• .•' , .. •_:l,,: CERCLA ieql,dres that the 'No Action' alternative be evalualed at every Supemnl Site to establish a baseline for coinpartson. , No fllther actMties would be conductecfwlth Site soils lllder dis alternative Q.e~ the Site Is left •as ls1 , Beamse,tlis alternative · nellher removes nor destroys the cormliiatlon Q.e.; contunnation . Is left on-site), a review of the remedy .will need to be conducted
every five years In accordance with CERCLA Section· 121 (c). This review process wiil continue every five years until the cleafflJp goals
for the Identified contaminants In the S\)R !Ir& achieved. .. , •
H no action Is taken migration of contaminants from the son Into the
underlying aquifer In the vlclrjty of the wastewater b'eatment lagoon
area wiD continue. This migrati011 results from lhe natural movement
of precipitation (e.g., rain and melted snow) moving through the soils
and carrying the contamination downward as the precipitation
recharges the aquifer. This migration force does not exist In Area 2 as this area Is covered with concrete Ix.dicing foundations and asphalt driveways. These structures prohilllt precipitation from
percolating Into 1118 underlying sons. Therefore, an precipitation
becomes surface· runoff v.tiich Is controlled by the slope of the asphalt driveways and the curbs built around the asphalt driveways.
Surface runoff Is directed into sumps where lhe water Is pumped to thewastewaterb'ealmentlagoons. AlthoughAttsrnative S1 does not actively reduce or eliminate soil contamination, tt Is. anticipated that the levels of 1,2-oichloroelhane wiD decrease over time due to lhe process of natural degradation.
There are no initial capital costs for Alternative S 1. Annual operating
costs are based on conducting periodic monitoring of lhe soil in order to prepare lhe five year review every five years for a period of 30 years. As part of the five year review, soil samples wiD be collected for chemical analyses once every five years in both areas, Area 2 and the wastewater treatment lagoon area.
ALTERNATIVE,S2:-NATURAL DEGRADAOON AND INfflTIITIONAL
CONTROLS
Capital Costs: $196,000
Annual Operating & Maintenance Costs
FIIS! Year: . $ 4.000 .
Second Year: $ 0
.• Tlird Year and l.aler: . . $ O Present Worlh Operating & Maintenance Costs: · $ 50.000 ·
Total Present Worth Costs for 30 Years: . $246,000 .. Time to Design: · ' 3 momhs · Construction Time: " • · 1 monui ·
Duration to Aclieve Clea!H4>: Over 30 years . .
Natural degradation reies on natural processes 1D desiroy lhe
contaminants present The most common degradation piocess Is .the reS141 of mlcroollJalisms (bacteria. fungus, ele.) present In lhe . soil using Ille contaminants as an energy {looaf source; tlieieby,
destroying the contaminant. The presence of 2 cliemlcals at lhe Site, chlOI081hane and vinyl chloride, nei1her of which were' used at this NSCC facility, Is a strong ixlication that 1.2-di~ Is being transformed via natural degradation process(es). The ra1e and effectiveness of the natural degradation process Is dependent on a number of environmental factors, su:h as nutrient availablity, soil moisture content. presence or absence of oxygen In the sol, etc. . ... ~ . . ...
Using published lnfon)lation, the foDowing degradation rates were estimated: In less than 10 years, lhe concentration of 1,2·
dichloroelhane should decrease to lhe direct contact health based
risk concentration of 7 miDgtams per kilogram; In less than 21 years
lhe concentration of 1,2-dichloroelhane sholi<I decrease to 169 micrograms per kilogram, the concentration that can remain In lhe
soil but not adversely impact the quality of· lhe under1ying
groundwater above the performance standard for 1.2-dichloro·
ethane; and In approximately 35 years, the concentration of 1.2-
dichloroelhane In the soi should reach a concentration of 1 microgram per kilogram. h estimated that It wiD require over 130 years of pumping the groundwater, as required by OU #3, to remediate the groundwater to the specified ARAR of 1 microgram per iter.
As part of this alternative, a biodegradative study will be conducted.
This study will (1) confirm that natural degradation In lhe soD is occurring and (2) ascertain if biodegradation will reduce the soil contamination during remediation of OU #3 groundwater lo a level that will not cause an exceedance of the OU #3 groundwater
cleanup goal. In the event that natural degradation is occurring at an acceptable rate, then the data from the biodegradation study will be used in the CERCLA Section 121(c) required S•yearreview. With
the completion of the overhead pipeline in February 1994, no
additional contamination should be entering the soils beneath the
Area 2 building. Based on the degradation discussion above, a substantial decrease in the concentration of 1,2-oichloroethane in the soil should be observed over the next several years: In the event
that the concentration of 1,2.<flChloroethane in the soil does not decrease as anticipated, a contingent remedy consisting of an active soil remediation technology (such as described in Alternative S3 or S4 below) shall be rnplemented to achieve the reduction of
contaminant levels lhat-.would be protective of the·qualily of the · uriderlying groundwater. · ·
lnstilutional con1TOIS Include using various conb'ols and deed restrictions. The specific Ntitutional con1rOls considered for tlis allernative are 1) using and malntainng the existing fence arolJld the plant operations area to imit access to Iha contamlnaled areas; 2) periodic inspection and malnlenance of paved areas 8101n!-Alea 2 to lnsi.re the ~ly of Iha cap over tis araa.' and 3) a deed reS11iction to control lulll'e land use of the NSCC;jroperty. · ·The deed resirlction wiD contail language to accomplish the folowqi fou' objectives: 1) to lnfonn any polential bu)'er of lhe'property of Iha contamination present, 2) reSfricl lulll'e land use MlCh W0l'1 decrease the ikelilood of tun an expoSlia ti eontaminal8d sois,'3) to pievent the lnslaDation of a potable wen at the Site llltil the levels of contamlnation In the groundwal8r ll1der Iha Site 818 deemed safe, and 4) to prevent excavation In contaminal8d soils withOul sufficient personal prolection for the workers. The &lital)le deed reslriction , shall be recorded In Iha approprlale COlllly reglsb'ar's office.
ALTERNATIVE . S3: SOL VAPOR EXT1IACTloN · WTTH FUME IHciHERATION AND ACTIVATED CARBON FLTER TOCclNTla EMISSIONS
Capital Costs:
Annual Operating & Maintenance Costs
First Year. .
Se<:ond Year.
Third Year and Later:
Present Wor1h Operating & MainJenance Costs: Total Present Worth Costs for 7 Years: . rune to Design:
Conslruction Time:
Duration lo Achieve Clean-up:
$2,887.000
$ 507.000
$ 416,000
S 416,000
$2,394.000
$5,281,000
9 months
3 mon1h
Over7 years
This allernative wiU remove volatile organic contaminants by means of vapor extraction wens insla!led in the soil above the waler table. A preliminary design for Area 2 suggests a system of 10 horizontal soil vapor extraction wells drilled uooemeath the buildings and driveways. These 10 extraction wells wiD remove a lotal of 1,300 cubic feet per minute of contaminaled air. The prefiminary design for the waSlewaler treatment lagoon 818a suggests a system of seven vertical extraction wells removing a total of 20 culllc feet per minute of contaminated air. The exraciad contimlnaled air from kea 2 would be trealed using fl.lTle incineration to destroy the volatile organics prior to the air stream being released into the atmosphere and the extracted comaminated air from the lagoon area wot,jd be treated using vapor-phase activaled calbon adsorption filters lo remove the volatile organics prior to the air stream being released in1o the atmosphere. The conlaminants captured by the vapor-phase carbon fillers would be destroyed through the thennal regeneration of the used activaled carbon at an off-site, commertial regeneration facility. Remediation of the soil in Area 2 and the waslewater treatment lagoon area Is expected lo be compleled within 4 lo 7 years and 1 lo 2 years, respectively. A review/assessment in accordance to CERClASection 121 (c) would be perlonned lo verify that the son vapor exraction system Is proceeding as anticipated or accomptished the specified cleanup
goals Iha! Wl1 be 5ti/!Ulated in Iha Record of Oecisim' ,-, . . .
ALTERNATIVE S4: SOL V~ ExTRAcrloN.,WTTH,ACTIVATED . CARBCW FILTER TO C0NTFa. EAIISSIONS • . : ,. .
Capital Costs: $2,918,000 Arnial 9Pe!aJing & Maintenance Costs '""' ' ·:· · . :,, ·' · ArsiYear. ,;.,: · ··· ,,,,,, · · ·.$3.353:000 Seconl Year: . . :: $1,566.000 Ttinivear and Later: ... f 475.000 • Present WQrtl Operating & Maintenance Costs: .$6.270.000C Total Present WOl1h Costs for 7 Years: $9, 1ss;ooo. Time to Design: · . , 9 moillhs,._ • , Corislriii::tion Time:' '.. 3 monlll Duration t> Ar:Neve ClearHJp: · ·, •.c, ' · 0'l8r 7 years
' "
This aiternativiiis ~ to Altemitive S3 ~th the e• that the eXlracled ixxfulrialed air from both areas .woud be b'ealed uslnig vapor-pliase activa1e<1 cartioii' adsorption miers ro reinow the volatile orgmcs prior to the u stream belriJ' released into the atmosphere. As belore; the contaminants captured by Die vapor-phase carbon filte!s would be destioyed'.at an off-site, commercial regeneration faciily. · . '
CRITEFDA FOR EVALUATING REMEDIALALTERNATIVES
The selection of the preferred de8l1JI) alternative for the NSCC OU 14, as described In tis Proposed Plan, Is the l'8SIJI. or a comprehensive screening and evaluation process. The Feaslbilily · Study for OU 14 was conducled lo Identify and analyze the allematives considered for addressing contamination In Area~ and the wastewater treatment lagoon area.· The Feasibiity Study and other documents for the NSCC OU #4 site desciibe, In detall, the allernatives considered, as weU as the process and criteria EPA used lo narrow the fist of the polential remedial alternatives to address the soil contamination in this portion of the,NSCC faciity. As stated previously, au of these documents are avaJlable for public review in the i:lfonnation repository/administrative record. · . ·"··
Ailernative S5 -Bioventing was not retained for the detailed analysis . because this alternative does noi provfde any appraclable improvement in reduction of risk or other performance measuement over either Alternative S3 or S4.
EPA always uses the following nine aiteria lo evaluale alternatives identified in the FeasibiDty Study. The remedial alternative selected for a Superfund site must achieve the two threshold criteria as well as attain the best balance among the five evaluation criteria. The nir'Ml criteria are as follows:
THRESHOLD CRITERIA
1. Overall protection of human health · and tile environment Toe degree to which each alternative enminates, reduces, or controls threats lo public health and the envirorvnent through treatment, engineering methods or institutional controls.
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_,2.,, COmpllance -,Wllh Applicable •. :or -. Relevant·' i ind -· _ Approp,late Requirements (ARARsl: The ~YI!~ !Ir( evaluated for comp&ance wtth" all state and • federal envirorvnental and pub[ic heal1h laws and requirements tliai apply or are relevant and appropria~ to the site conditions. -
EVALUATING CRITERIA,·
t. .• ' . . ' . ,--· ._.,,. • • 3 .. Cost The benefits of lmplementing __ a ~,-~~ · aJtemati'le are ~ agailst the' cost of lmplemeritation.
Costs Include the capital (t.p-front) cost of Implementing an allematiw over the long tenn, and the net presentworUi of both capital and operalian and makl18nanc:e costs. ·' •--· · , '.
4. lmplementabl11ty: EPA considers the lechnlcal leaslbility'(e:g., how difficult the al1amatiw Is to consw:t and operate) and admlnstratiw ease (e.g.; ihe amOllll of cooidiriation wflh other govemment agencies that Is needed) ol a remedy, Including the avallability of necessary matertals and services.
5. Short-term · effecllveness: The 1englh of time needed 10 Implement each alternative Is considered, and EPA assesses the risks lhat may be posed 10 workers and nearby residents during cons1ruc1ion and Implementation.
6.. Long-term effectiveness: The alternatives are evaluated based on their ability to mainlain refiable protection of pub[ic health and the envfromlent over time once the cleanup goals have been mel
7. Reduction of contaminant toxicity, mobility, and volume: EPA evaluates each alternative based on how It reduces (1) the hallnful nab.Jre of the contami'lants, (2) their ability 10 move through the envirorvnent, and (3) the volume or amount of contamination at the site.
MODIFYING CRITERIA
8. State acceptance: EPA requests state comments on the Remedial Investigation and FeasibiHty Study reports, as well as the Proposed Plan, and must take Into consideration whether the state collC\l'S with, opposes, or has no comment on EPA's preferred alternative.
9. Community acceptance: To ensure lhat the public has an adequate opportunity to provide input, EPA holds a public comment period and considers and responds to all comments received from the community prior to the final selection of a remedial action.
EVALUATION OF ALTERNATIVES
The following SlJllmary profiles the comparative analysis of the four alternatives In tenns of the nine evaluation criteria:
Overall Protection: All lour alternatives. S1, S2, S3. and S4 are expected 10 provide long-term protection for human health and the
. It:/.,,~ I .•:·.. • ' .'' . . . ~-. environment.-~ corv,ction wi1h the OUc>f3 'remecial''ac:tion. ,, . ,, IJ\,. ,"~ . . . ' . However, Allernati',_'8s S2;•S3; and S4 wiD provide protection; more quickly, from exposures to contaminated subsurface soils. Of these three ,allema!ives, Alternatives S3 and S4 will afford. the greatest pi'otiictioii: t) )unari health :as they substantially' lllduce the .. comanilnants In the son within _·4-7 :years of lri6alion of the ·;: alternatives.. Under Altematives S1 and S2, contamlnailt levels are
0 .'.~p.iled:,~iicleaease\8SC8 ;rest.ft Of :naturaf degradation. ,'. ;~~, 63,_, and -.~ .protect , the . envi'onment · by removing .,.,co~~ :.~. f!\8 , ~11, __ thereby, erunlnating the potential for ' migr!ition of contaminants.to grotnlwater. In COl1UflClion wi1h the _ •· oui3:~ i:emedial action; Alternatives s1anc1 s2, wi1 . also be J)IOlecllvll.of the envirom1enl.'f.Thls protectiorfsteins'fri>m the following factors: 1f al COn1ammted soils are within the pmwater pl\1118 ,being remediated by OU #3, 2) the OU #3 _ ~ati90 ~ pllV8l)I the spread of contaminants and remove . i:onfami(lanls from the grotnlwater, and 3) soil contamilanls should be reduced by na1Lral processes within the timeframe reqlired t, complete 1118 OU #3 giwidwater remediation. Altemativil S1 does not plO'lfde short term.protection for human health, however, as discussed previously, the Sile does not pose an unacceptable risk llldertlie current use scenario.
' -'~· Compliance With ARARs: As long as the sons are left ~ place O-e. not excavated), no Federal or State ARARs for contaminants In sous are triggered. Alternatives _ S3 and S4 will comply with action-specific and location-specific ARARs which Include operations ata hazardous waste slte,disposal of Used activated caibon as sorld waste, and air emission controls. Alternative S2 wiD comply with the location-speeffic ARAR related to operations at a hazardous waste site· and there are no action-specific ARARs lhat apply 10 this alternative. No ARARs were Identified for Alternative S1 as no action Is being taken._
Long-term Effectiveness and Permanence: Alternatives S3 and S4 will provide effective and permanent solutions for the contaminated so11. The chemicals of concem will be removed from the soD by the soD vapor extraction system and destroyed. Neither alternative will leave any treatment residuals on Site. The refiability of both Alternatives S3 and S4 Is high because they rely on proven -and applicable technologies and the extent of the contamination is relatively well defined. The renabinty of Alternative S4 is higher than Alternative S3 because of the maintenance problems associated with the lume Incinerator. Alternatives S1 and S2 do not directly remove, treat or Isolate subsur1ace contaminants; therefore, they are comparable in terms of reducing potential residual risks. However, contaminant levels should gradually decrease to levels lhat would be protective of groundwater quality due to natural degradation processes. The time required to reach this concentration fans well within the OU #3 groundwater remediation timeframe (estimated to be 130 years). Alternative S2 involves long-term institutional controls to prevent future exposures to subsurface soils as well as the use of the contaminated groundwater beneath the NSCC facility. The projected adequacy and refiabtlity of these controls depends on land use, but should be relatively high because the Impacted area is small, within the plant boundaries, and land use is not expected to change. Soil monitoring and periodic reviews at five-year Intervals
wiD be required for all three alternative: 4 the . dll'ation of performing such reviews for Alternatives S1 and S2 ls expected 10 be midl longer. The bng term elleetiveness and permanence of .· . Alternatives S1 and•S2 are dependent'on"9:8 ratf!if~dation ., aill_effectiveness of the OU 13 remedial action.· .,,. , 1••• • • 1
.1 t, ' J • • '" Reduction of Toxtcttv, MobOlty or Volume: Both Alternatives S3 and 84 actively reduce the toxicity and mass of contaminants il the soli. -ms Is accomp&shed hough the moval cif the contain1nants . from the soD via the soil vapor exlracti6il'system folowed by !line . Incinerator or the thermal destruction of oomailllnants ripped on the , cai1lon filter •. Neither Alternative S1 nor'.fl2 ~t)eclJc:e the . toxicity, molllity, or w111ne·of eon1am1nan1s 1t,oui,fm(qneered . 'traatment .,process. but reduction due .,10 naliral ,processes Is expec1e<1 10 OCClr we1 w111-.i the time poooif~ b', and n .. COl1\lldion wi1h the ou 13 grou,ct,yali!r ieniediallon/ '· · · . ··-. . ,,. . Shon-term Elfectlveness: There ~·no short-time risks posed 10 site WOlkers, the general jUllic. or the envtromtent associated ..ith either A11ematiw S1 or 82. Theri, are ·mwriial"stioit-lBrm risks associated with Altemative 84 which are prmarlly die to general ' safety Issues associated with the'coilstu:tion of ttie ·son vapor exlraclion and air emissions treatment systems. il addition 10 risks associated wflh Altemalive 84, AHerative S3 as two additional risks, maklter.ance problems associated wilh the hine lnclneralDi' and the handling of hydrochloric acid generated by the scrubber associated with the Incinerator. Potential risks co!MI also exist dim.I the operating period, especially WOlkers exposure 10 lugltiYe vapors. n
.EPA'S PREFERRED ALTERNATIVE
ei1her the c:albon adsori: or fume lnc:ineralDi'/samber systems malfunction, temporaiy YOlatile orgaric emlssi:Jns woold be ~led and minimized~ pro~hslal)ed moRIOring' and control processes. Surf<!~ rirlolf. dim.I cons1ruction, as for any construction project, would be comrolled 10 prolect neart,y Sllface waters.
lmptementablllty: AHematiV8 S1 recpres no Implementation. Altemalive s2 wiil be easy 10 mplernent because 6tlle 10 no construction Is required. Both Altematives S3 and S4 are projecied to reqti'e approxtnately 12 months 10 design and cons1ruct, and 8Plii!miate1y 4 to 7 years of operation. · • · ·
.£2!!: Total present WOlth• costs for Ile sons altematives are presented beJo:w.: .~~ "•,.-; ... ·, ~:-;· :-C-' .• '
Altemative S1 '. No Action:
Altemative S2 • . Nalltal Degradation and
Institutional Controls:
Altemative S3 -Son Vapor Extraction wilh Fllll8 Incineration and Activaled carton
$ 199,000
$ 246.000
Filter to Con1rol Emissions: $5,281,000
Altemative 84 • Son Vapor Ex1raction wilh Activated Carbon Filter
to. ~ntrol Emissions: $9,188.000
After conducting the allove delalled analysis, EPA Is proposing the following altemative 10 address the contaminated soi In Area 2:anc1 the wastewater treatment lagoon araa The EPA preferred son remediation alternative Is:
ALTERNATIVE S2 : HAMAL DEGRADATION AHO INsTIMlOIIAI. CotirROLS
Based on a,rent lnfonnation, this altemati\/8 appears to provide the best balance of trade-<>ffs with respect lo the nine criteria that EPA uses to evaluate altematives. EPA believes the preferred alternative WiD satisfy the statutory requirement of Section 121 (b) of CERCLA, 42 USC 9621(b), which provides 1hal the selected alternative be protective of human health and !he en'liroM\8111, comply with AAARs, be cost eflec1ive, and utirize permanent solutions and treatments to the maximum exlent practicable. The selection of the allove alternative Is prerimlnary and could change i1 response lo public comments.
As this alternative relies on natural degradation to clean the sotls, NSCC wiD be required to substantiate Iha! naluraJ degradation Is occurring, Identify where In the subsurface the degradation Is ocrumg, and determine the rate ol degradation The coDection ol this data via the blodegradative study will begin alter Record of Decision for OU #4 Is signed.
In the event Iha! the biodegradative study data cannot subslan1iate the occurrence of natural degradation a contingency remedy, such as Altsmalive S3 or 84, will be implemented. It Is anticipated Iha! this decision will be made within two years of the sigring of the OU#4 Record ol Decision.
The ins1ilutional controls to be mplemented am deed reslrictions and maintenance of both !he existing fence around the plant operations area and the paved areas around Area 2. NSCC Will record. in !he appropriate county registrar's office. a deed restriction 11 which NSCC, and any subsequent owner of the Site, would be prohibited from utrnzing the groundwater for drinking water purposes until such time as the contaminated plume meets drinking water standards. NSCC wiU also develop a plan Iha! wil protect any worker In the event Iha! the contaminated soils need to be dug into prior to the levels of 1.2.eflChloroelhane reach the appropriate direct contact health based risk concentration. Maintaining the fence will reduce the fikelihood of trespassers gaining access to the conwnlnated areas, and repairing aacks in !he paved area will help prevent 1,2-<!ichloroelhane from leaching from the soas inlD the t.mer1vino · _fer.
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••• ,,,.,._ ,. ,, 0 •• ,. •· COMMllN!TY PAHTICIPATION
-· ,' 'J. •• ,.., • •. ,•.,,.. • EPA has developed a comrmnty relations program as mandated by Col9ess Lllder Superfu,d to respond to citizen's concerns and needs for Information, and to enable residenls and pullic officials to partidpale i1 the decision-making process. Public Involvement activities llldertaken at Superfu,d slllls consist of lnleM!ws with local residents and elecled officials, a commll'ily relations plan for each si!e, fact sheets. avaBabllity sessions,·JU)llc meetings, ptAlllc'comment peiiods. newspaper adveitisenients: sltii visits. and TeclVllcal Assistlnce Grants. and any other actions needed to keep the commlllity infonned and lnYolved.
EPA Is conducting a 30-day publlc comment pel1od from July. 12, 1994 ID August 11, 1994, to Jl!Ovide an opportlllity for pubflC Involvement In seleclilg the final c:lenlp method for lli,s Sile. ,, Nll'ic lr1)UI on an alternatives, and on the ilformalion that suwarts lhe aJternatiYes Is an knpollant contr1bu1ion to the ram~ _selection JllOC8SS. Olmil tlis comment peood. the publlc Is Invited ID attend a pubUc meeting on August 3, 1993, at the AQ!ICUllllnll Extension Center Auclltor11111, xm Oki Concord Road, Sansbury, North C&rollna beginning at7:00 p.m. at which EPA vtil prasentlhe Remedial mestigation' Feasi'biltty Study and Proposed Plan desating lhe preferred alternative for treatment of ttie cootamlnated 69B at !he NSCC Supemnl Site and lo answer any questions. Because this Proposed Plan Fact Sheet provides only a S1J11mary description of the cleanup alternatives being considered, the publ'ic is encouraged 10 consult lhe Information reposi!Oly for a mora.detaBed explanation.
During this 30-day comment period, !he pJ)lic Is in'liled to l8'liew all siiHelaled doa.ments housed at the ilfonnalion repository localed at the Rowan County Public Library, 201 West Fisher Stree~ Salisbury, Nor1h Carolina and offer~mments to EPA either orally al the public meeting or In written fonn dlling lhis time period. The aClual remedial action coud be different from the preferred alternative, depenolllQ upon new ilfonnation or statements EPA may receive as a resut of pulfic comments. H you prefer ID submit writlen comments, please mail them postmarked no later than midnight August 11, 1994 to: · · ·
Diane Barrett
NC Comnxmlty Relations Coorrllnator
U.S.E.P.A., Region 4
North Remed/al Slf>el1Ul1d Branch
345 Courtland Str98t, NE
Atlanta, GA 30365
All comments wfB be reviewed and a response prepared in making lhe final detennination of lhe most appropriate alternative for cleanup.,treatment of lhe Site.. EPA's final choice of a remedy will be issued in a Record of Decision (ROD). A document caned a Responsiveness SUnlnary summarizing EPA's response to an public comments will also be issued with !he ROD. Once !he ROD is signed by the Regional AdministralDr it will become part of the Administrative Record (located at !he Library) wtich con1ains all documents used by EPA i1 making a final detennlnation of !he best cleanupllraatment for lhe Si1e. Once !he ROD has been approved, EPA wi1 begin negotiations with the Potentlally Responslble Parties ID allow them the opportunity to design, inplement and absorb all costs of lhe remedy delennined In the ROD i1 accordance with EPA guidance and protocol. H negotiations do not result in a settlement. EPA may conduct lhe remedial activity using Superfixld Trust mories, and sue for reimbursement of its costs with !he assistance of lhe Department of Justice. Or EPA may Issue a unilateral administrative order or directly !Be suit to forte NSCC 10 conduct !he remedial activity. Once an agreement has been reached, lhe design of the selected remedy wi0 be developed and implementation of lhe remedy can begin. The preceding actions are lhe standard procedures utilized during lhe Superfund process.
As part of lhe Superfund pcograni, EPA provides aflecled communities by a Superfund site_Ytilh lhe opportunity to apply for a Teclvlical Assis1ance Grant (TAG). This grant of up to $50,000 enables lhe group to hire a technical advisor or consultant to assist lhem in interpreting or commenting on site findings and proposed remedial action pians.1 :·· !.' . . . . . . . . For more Information concerning this grant program, please contact · Ats. Rosemary Patton, Cootrllnator . . NC TIIChnlca/ Assistance Grants
.· Waste Man/lgemtNII DMslon
U.S.£P.A., Region 4
345 Cowfland Slree4 NE
Atfanta, GA 30365
[phone]
INFORMATION REPOSITORY LOCATION:
. Rowan County Public Ubrary
201 West Fisher S1n1et
Salisbury, Nor1l1 caroona 28144 ·
Pllone: [phone]
H01111: Monday • Fllday · ·· ·. 8:00 Lffl. • 9:00 p.m. Saturday . 9:00 am. • 5:00 p.m.
FOR MORE INFORMATION ABOUT SITE ACTMllES, PLEAS~ CONTACT:
. Mr. Jon Bomholm, Remedlal Pro)ect Manager or Ms. Diane Banett, NC Conlnllllty Rel811ons Coordinator North Superfund Remedial Ek'anch
. Waste Management DMslon U.S. Env!ronmental Protection Agency, Region IV 345 Courtland Street, NE
AUanta, Ga 30365
Toll Free No.: 1-800-435-9233
MAILING LIST ADDffiONS
II you are not already on our maifing ist and would like to be placed on lhe fist to receive lulura Information on the Natlonal Starch & Chemlcal Company Superfund Site, please complete this form and return to Diane Barrett, Community Relations Coordinator at the above address:
NAME:---------------------~--------
ADDRESS: ____________________________
_
CITY, STATE, ZIP CODE:-------------------------
PHONE NUMBER: __________________________
_
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G~OSSARY OF TERMS USED IN THIS FACT Sf!EET
• >, ;" Y, • .• )" AqlAfer: An underground geological for!llaliOn, or. Ql'Ol.ll. of lonnations, contairing usable amounts of groundwater that can , · · · supply wens and spr1rigs: · · ·
\
Actm/n/Sfraflve Recotd: A fie which Is rnalnlalned and contains al lnfonnalion used by the lead agency to make Its decision on the selection of a melhod to be utiized ti clean up/lreal conlamilalion at a ~ site.· This file Is held In the ilfonnalion repositoly for ptbic review. . '
Appllcab/11 or Relevant 111d Applopllata RBqunments (ARARsJ: The federal and state requirements that a selected remedy must-~. These r&qlkementS may vary anong sites and various alilmatiY8s.
Basellne RJslc Assesslllllllf: A means of estin~ lhe amoll1I of damage a Supeiuld site could cause to lunan hea1h and the envlrorment. Objecti'les of a ~sk assessment ara 10: help detennile the need for action; help detennine the levels of chemicals lhat can remail ori lhe site after dearq, and still protect health and Ile envf1011118111; and provide 8 basl.s for compMng ciflerent cleaf1l4) methods.
carcinog,i,: Any SLt>stirx:e that can cause or C0ltilul8 to lhe proooction of cancer; cancer-producilg.
Con¥Nehells/VII Environmental Response, Conpensatton and LIBblDty Act (CERCLA}: A federal law passed In 1980 and modified i"I 1986 by the &.perfund Ameooments and· Reaulhorization Ad (SARA). The Ads created a special tax paid by producers of various chemicals and ol produCls Iha! goes info a Trust Fund, commonly known as Supelfund. These Ads give EPA Ile 8111!"ooty to i"lvestigate and clean up abarooned or UllCOnllolled hazardous waste sites utilizing money from the Superfund Trust or by taking legal action 10 fOlt8 parties responsible for the contamination to pay for and clean up the site.
Feaslb/Uty Study: Refer to Remedial lnvestigatiorvfeasibiity Study.
Groundwater:. Water found beneath lhe earth"s Sl.llace that fiDs pores between materials such as sand. soB, or gravel (usually in aquifers) which Is often used for SIJR)lying wens and springs. Because grot.lldwater Is a major source of drinking water there Is growing concern over areas where agricultlral and lnduslrial pollutants or substances are getting Into groundwater.
Hazardous Ranking System {HRS): The principle scraening tool used by EPA to evaluate risks to public health and the erivirorvnent associated with hazard:>us waste sites. The HRS calc!Jates a score based on the potential of hazardous substances spreading from the site through the air, Sllface water, or groundwater and on other factors such as nearby · population. This score Is the primary factor In deciding tt the site shoul1fbe on the National Priorities List and, if so, what ranking It should have compared ID other sites on the list
lntonnaf/on Repository: A file containing aCCU'ate up-to~te lrnormation, technical reports, reference documents, information about the Technical Assistance Grant, and any other materials pertinent to the site. This file is usuany located in a public building such as a libra!y, city hall or school, that Is accessible for local residents. ·
National Pollutant Discharge Elimination System (NPDES): A provision of the Clean Water Act 'Mlich prohibits the discharge of pollutants Into waters of the linked States unless a special permit Is Issued by EPA, a state or (v.tiere delegated) a tribal government on an ln<fian reservation ailowing a controlled discharge of liquid after it has undergone treatment
Nations/ Prtorttles List {NPL): EPA's is! of the most sertous uncontroDed or abandoned hazardous waste sites identified for possible long-term remedial action under Superfund. A site must be on the NPL to receive money from the Trust Fund for remedial action. Theist is based primarily on the score a site receives from the Hazard Ranking System (HRS). EPA is requ~ed to update the NPL at least once a year.
Operable Unlt:Term for each ol a number ol separate activities under1aken as part of an overan Superfund site cieanup.
Potentially Responsible Parties (PRP): My individual or company• inclucfrng owners, operators, transporters, or generators -potentiaDy responsible for, or contributing to, the contamination problems at a Superfund site. Whenever possible, EPA requires Potentially Responsible Parties, tlYough administrative and legal actions, to clean up hazardous waste sites Potentially Responsible Parties have contaminated.
Remedial Action Obfectlves: These are specific objectives which ara ldentif1,edJo. J)!Olecl l!OIIJ~h\J!nan ~ and lhe . . .· envirorvnent that take Into consideration the environmental media contamlnal!li:I Q.e.; groandwal&r, sou, Sllface water, sediment, or air) and the contaminants present In each medun. The main goal of the objectives Is ID prevent expo!Ue ID contaminants In grounctNater, soil, surface water, sediment;or air kl excess of risk-based tunan heailh or'erivlrorimental standards. · .·
Remsdlal lnvBSIJgallon/Feaslblllty Study (RIIFS): The Reme<ial klvestigalion Is an in-deplh. e.~ sampling and analytical study ID gather data necessary ID delennine the nallr8 and extent of contamilalion at a &iperflrld site; to !!stablish c:riteria for cleaning up lhe she; a description 'arid analysis of lhe potential cieall.lp al1emalives for remediai actions; and support llie ' technical and cost analyses of the alternatives. The Feaslblllty study also usualy recommends selection of a cost-effective alternative.
Record Of Decision (ROD): A p!blic doMlent that 8111101rlC8S and explains wlt:ti'method has been selected by lhe h;}erq ID be used at a. Superfllld site ID ,clean up the contamination.
Responsiveness SUmmaty: A S1111111ary of oral and written p!blic comments received by EPA dlii1g a ·pc1)iic comment period and EPA's responses ID lhose comments. The responsiveness S1111111ary Is a key part of the Record of Decision.
~-Va/at/le Organic Conv,ounds (SVOCs): CarborKontanng chemical compounds Iha!, at a relatively low temperature, fluctuate between a vapor state (a ·gas) and a llqtid state.
Vadose Soll zone: Is lhe unsauated zone of sol starting at the Stlface and ending at the water table Q.e., lhe space between the son particles contains bolh water and al~.
Va/at/le Organic Conv,ouncts (VOCS): Any organic compound that evaporates readily Into the an:. afroom temperature.
Water Table: The level below Vtillch the soil or rock Is salurated wilh water, sometimes referred to as the upper surface of lhe saturated zone. The level ol groundwater. · · •
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U.S. Environmorul Proltctlon Agency
345 Courtland Strool, !i.E.
Atlanta, Georgia 30365
)ff,claJ Busin ...
1tnaly for Privllt UH $300
No!1h Suptm.l,d Rtrr.<lial Branch
Oiar.> Barnu, Camm.irily Rtlaliono C-.lllllor
Jon Bomholm, Romod'III Project Mt-
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I APPENDIX C
I RESPONSIVENESS SUMMARY
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RESPONSIVENESS SUMMARY
FOR THE
PROPOSED REMEDIAL ACTION
FOR OPERABLE UNIT #4
NATIONAL STARCH & CHEMICAL COMPANY SUPERFUND SITE
SALISBURY, ROWAN COUNTY, NORTH CAROLINA
Based on Public Comment Period
July 12 through September 9, 1994
Which Includes July 26, 1994 Public Meeting Held In
Agricultural Extension Center, Salisbury, North Carolina
Prepared by:
U.S. Environmental Protection Agency, Region IV
September 1994
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RESPONSIVENESS SUMMARY
OPERABLE UNIT #4 PROPOSED PLAN
NATIONAL STARCH & CHEMICAL COMPANY SUPERFUND SITE
TABLE OF CONTENTS
SECTION PAGE No.
1.0 OVERVIEW . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-1
2.0 BACKGROUND . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-1
3.0 SUMMARY OF MAJOR ISSUES/CONCERNS/QUESTIONS/
STATEMENTS VOICED DURING PROPOSED PLAN
PUBLIC MEETING AND RESPONSES ......................... A-3
3.1 OU #1 GROUNDWATER EXTRACTION ................... A-4
3.2 NOISE LEVEL ASSOCIATED WITH THE SOIL VAPOR
EXTRACTION SYSTEM ............................... A-4
3.3 DEED RESTRICTION ..........•..................... A-4
3.4 REVISION OF OU #3 GROUNDWATER REMEDIATION
TIMEFRAME ....................................... A-5
3.5 AVAILABILITY OF JULY-AUGUST 1992 DRINKING
WATER DATA ............. ; : ....................... A-5
4.0 SUMMARY OF MAJOR ISSUES/CONCERNS/QUESTIONS/
STATEMENTS VOICED DURING PUBLIC COMMENT PERIOD ...... A-5
4.1 DISCONTENT WITH SELECTION OF ALTERNATIVE S2
AS THE PREFERRED ALTERNATIVE .................... A-5
4.2 CONCERN EXPRESSED ABOUT POTENTIAL ADVERSE
IMPACT ON GRANT CREEK WASTEWATER TREATMENT
PLANT IF COMBINED WATER TREATMENT NOT FULLY
ON-LINE .......................................... A-6
4.3 ELIMINATION OF THE NEED FOR INSTITUTIONAL
CONTROLS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-6
4.4 INTRINSIC BIOACTIVITY .............................. A-7
4.4 ANAEROBIC/AEROBIC BIOACTIVITY .................... A-8
4.5 POINT OF COMPLIANCE ............................. A-8
ATTACHMENTS
Attachment A -Transcript of Public Meeting
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RESPONSIVENESS SUMMARY
OPERABLE UNIT #4 PROPOSED PLAN
NATIONAL STARCH & CHEMICAL COMPANY SUPERFUND SITE
1.0 OVERVIEW
The 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 #4 (OU #4, OU#4, or OU4) 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
The Environmental Protection Agency (EPA) conveyed its preferred remedial alternative for OU #4 NSCC Superfund Site, located in Salisbury, North Carolina in the Proposed Plan Fact Sheet mailed to the public on July 8, 1994, and through an ad in The Salisbury Post newspaper. The ad was published in the July 12, 1994 edition of this newspaper. The public
meeting was held on July 26, 1994 at the Agricultural Extension Center in Salisbury, North Carolina. The purpose of the meeting was to present and discuss the findings of the OU #4 Remedial Investigation/Feasibility Study (RI/FS), to apprise meeting participants of EPA's preferred remedial alternative for OU #4, to respond to any questions or address any
concerns expressed during the public meeting, and to take their comments and make them a part of the official record. A copy of the transcript from the July 26 public meeting was placed in the Information Repository for public reading. The Proposed Plan Fact Sheet and the newspaper ad informed the public that the 30-day public comment period would ruri from July 12 to August 11, 1994. However, a request was made for a 30-day extension to the public
comment period. Consequently, the public comment period was extended to September 9, 1994.
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A-2
OU #4 National Starch & Chemical Company
Responsiveness Summary
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 news media attention when its 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.
A 1985 newspaper article indicated there were 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. 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. Five questions were asked during the public meeting. They related to:
Is it possible that the OU #1 groundwater extraction system is adversely effecting off-site potable wells?
How loud is the noise associated with the soil vapor extraction system?
Will the proposed deed restrictions pertain to off-site property?
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OU #4 National Starch & Chemical Company
Responsiveness Summary
• Why was the 30 year OU #3 RA duration revised to 120 years?
• Is the analytical data from sampling private potable wells in July-August 1992 available?
. A recount of the questions summarized above, the discussion that revolved around the questions asked, and the Agency's response can be found on pages 16-48 of the transcript of · the Proposed Plan public meeting (Attachment A).
3.1 OU #1 GROUNDWATER EXTRACTION SYSTEM
This issue had several facets, but to focus the following discussion, the question is summarized as follows:
Q: Can the OU #1 groundwater extraction system, which is now extracting
approximately 130,00 gallons per day, cause the water table off-site to drop and
if so, who is responsible for any adverse impact on off-site private potable wells?
A: Based on the data presented in the "Quarterly Report -First Quarter 1994 -
Operable Units One and Two", dated July 1994, the cone of influence created by
the extraction wells extends down to the Southwest Tributary but does not extend
beyond the stream. Since the wells are completed in fractured bedrock, it is
possible, due to preferred fracture flow, that the extractions wells are influencing
the off-site private, potable well. However, the potential is remote. The first
information to review are the construction details of the wells involved. If a
connection was determine, then the Agency or NSCC will need to consider taking actions to alleviate the situation.
I 3.2 NOISE LEVEL ASSOCIATED WITH THE SOIL VAPOR EXTRACTION SYSTEM
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Q: Will the noise created by the soil vapor extraction system be objectionable to homes 1,500 feet away?
A: Insufficient information was available to give a direct response to this question.
3.3 DEED RESTRICTION
Q: Will the proposed deed restrictions pertain to adjacent land?
A: The deed restrictions will only focus on the soils in those areas of Area 2 and the
wastewater treatment lagoon area that are contaminated (i.e., only to certain parcels of the NSCC property).
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OU #4 National Starch & Chemical Company
Responsiveness Summary
3.4 REVISION OF OU #3 GROUNDWATER REMEDIATION TIMEFRAME
Q: Why was the timeframe for the operation of the OU #3 groundwater extraction and treatment systems revised from 30 years to 120 years?
A: The 30 years was based on remediating the contaminated groundwater to the maximum contaminant level (MCL) for 1,2-dichloroethane (1,2-DCA) which is 5 parts per billion (ppb). The 120 years is the estimated timeframe to obtain the performance standard of 1 ppb specified in the OU #3 ROD. The 1 ppb is based on the State of North Carolina's groundwater protection regulations.
3.5 AVAILABILITY OF JULY-AUGUST 1992 DRINKING WATER DATA
Q: Will the Agency send a copy of it's analytical data for the samples collected from private, potable wells sampled in July-August 1992 to the well owners?
A: If available, yes. The State will also be requested to provide any analytical data the State may have for the groundwater samples collected in July-August 1992.
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 #4 NSCC Site can be grouped into the following areas:
Discontent with the selection of Alternative S2;
• Partial versus full operation of NSCC wastewater treatment system;
Elimination of the need for Institutional Controls;
• Intrinsic Bioactivity;
Anaerobic/Aerobic Bioaclivity; and
Point of Compliance.
Below is each written comment received and the Agency's corresponding response in italicized print.
4.1 DISCONTENT WITH SELECTION OF ALTERNATIVE S2 AS THE PREFERRED ALTERNATIVE
COMMENT #1: A citizen voiced disapproval with the selection of Alterative S2 but did not identify a preferred alternative.
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A-5
OU #4 National Starch & Chemical Company
Responsiveness Summary
RESPONSE: Of the four alternatives that remained after the screening and evaluation
process incorporated into the Feasibility Study, Alternative S2 is the most cost effective approach that will ultimately achieve a reduction in the toxicity, · mobility, and volume of contamination present at the Site. However, this approach relies on natural degradation which has not been substantially demonstrated as occurring at Site. It as been assumed natural degradation is occurring at the Site due to the presence of two chemicals in the
groundwater and soils that reportedly were never used at\the facility. The
process of natural degradation would result in the formation of these
chemicals. To prevent drawn out discussions in the future, a contingency
was incorporated into the ROD in the event that the process of natural
degradation cannot be substantiated within two years. If the bioremediation
treatability study fails to demonstrate that natural degradation is occurring at an acceptable rate, then an active remediation alternative (Alternative S3) will be implemented.
4.2 CONCERN EXPRESSED ABOUT POTENTIAL ADVERSE IMPACT ON GRANT CREEK WASTEWATER TREATMENT PLANT IF COMBINED WATER TREATMENT NOT FULLY ON-LINE
COMMENT #2: Concern was expressed about the circumstances surrounding the combined
operation of all the operable units and the impact on NSCC's pretreatment
system, and thereby the Grant Creek Wastewater Treatment Plant and
meeting its NPDES requirements.
RESPONSE: The Agency is aware of the City of Salisbury concern and has relayed that
concern on to NCDEHNR.
4.3 ELIMINATION OF THE NEED FOR INSTITUTIONAL CONTROLS
COMMENT #3: In addition to the institutional controls already in place (i.e., the existing
fence around the plant operations area and the paved areas around Area 2), NSC is currently, voluntarily placing deed restrictions on those portions of the property affected under OU#1, OU#2, OU#3, and OU#4. Such deed
restrictions will (a) prevent the utilization of groundwater for drinking water
purposes until the contaminated plumes meet drinking water standards, and (b) prevent future use of such property for residential purposes until such time as the CERCLA remedial activities conducted at the Site have rendered those portions of the property safe for such purposes. NSC anticipates that such deed restrictions will be in place by October 15, 1994.
Inasmuch as this is new information that was not available to EPA during their selection of the preferred remedial alternative, NSC recommends that
EPA change the preferred remedial alternative to NO ACTION. This revision
is warranted due to the lack of any current or future risk to human health
under the scenarios defined in the OU#4 Feasibility Study, once the above deed restrictions are in place.
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OU #4 National Starch & Chemical Company
Responsiveness Summary
RESPONSE: Inasmuch NSCC has voluntarily initiated placing deed restrictions on those portions of the property affected under OU #1, OU #2, Ou #3, and OU #4, the deed restrictions will not be in place at the anticipated signing date for the OU #4 ROD. In addition, neither the Agency nor NCDEHNR has had an opportunity to review the language of the proposed deed restriction clauses. Other questions need to be addressed: What entity will enforce the restrictions? Where does the authority come from for enforcing these deed restrictions? What will be the penalties, if any, if the restrictions are not adhered to? In addition to the argument stated above, the institutional
controls as described in Section 10.0 incorporates other activities in addition to deed restrictions. Consequently, the Agency does not feel it is warranted to select the No Action alternative by removing the requirement for institutional controls from the selected remedy.
4.4 INTRINSIC BIOACTIVITY
COMMENT #4: Recent industry experience with intrinsic bioactivity of chlorinated aliphatics
indicates that it is an effective means of removing contamination from both
soil and groundwater. Field experience has also indicated that the success
of intrinsic bioactivity is a strong function of the ability to deliver nutrients to the target microbes in an manner that provides I.he microbes with a relatively constant supply. The ability to control the effectiveness of the delivery can be impacted by any of a number of factors, but the rate and direction of groundwater flow is a significant consideration.
The existing data base indicates that the constituents of concern are not likely to significantly migrate towards any potential receptors during the time interval required for evaluation of intrinsic bioactivity applicability. It is therefore recommended that the design for the Groundwater Treatment
System (GWT) identified in the ROD for OU#3 be developed to incorporate
any relevant data developed during the assessment of ongoing
biodegradation in OU#4. Inclusion of the data to be developed during the conduct of an intrinsic bioactivity precursor study into the design of a GWT for OU#3 is expected to yield significant benefits as the system could be designed to augment and supplement the intrinsic bioactivity at OU#4.
RESPONSE: The Agency concurs with the statement that the success of intrinsic
bioactivity is strongly associated with parameters identified in the comment.
ft is the Agency's opinion that additional field work will be necessary to
support the OU #3 groundwater extraction system design (i.e., better
delineation of the extent of contamination in the bedrock zone of the aquifer).
The Agency envisioned that the assessment of ongoing biodegradation will
be initiated with this OU #3 RD field work.
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A-7
4.4 ANAEROBIC/AEROBIC BIOACTIVITY
OU #4 National Starch & Chemical Company
Responsiveness Summary
COMMENT #5: NSC notes that there are differing processes of intrinsic bioactivity of chlorinated aliphatics. One process utilizes aerobic microbiological
populations to remediate constituents while a second is based on anaerobic processes. Based on discussions with various organizations having
experience in these areas, we have discovered that each process is most successful when appropriately applied. Aerobic processes appear to be restricted to remediation of impacted areas located above the water table (i.e., in the vadose zone). As there is significant data indicating that a large portion of the constituents of interest at this site are located in the saturated zone, it is unclear whether the Biodegradation Study Proposal presented in the FS for OU#4 is the optimum approach. NSC recommends that EPA
permit further evaluation of the various biological processes to ensure
selection of the most appropriate method (i.e., aerobic or anaerobic).
RESPONSE: The Biodegradation Study Proposal was just that, a proposal. The Agency is anticipating that a work plan along with the accompanying supporting
documents (e.g., Sampling Analysis Plan, etc) will be developed to direct this initiative on verifying and substantiating intrinsic bioactivity.
4.5 POINT OF COMPLIANCE
COMMENT #6: Based on the ROD for OU3, a cleanup level of 1 ppb for 1,2-DCA must be met throughout the groundwater plume. As we have previously commented,
it is doubtful that this cleanup level could ever be achieved, given the track record of pump and treat remedies in a fractured bedrock media and fate and transport modeling. In response to our comments, EPA cited 40 CFR 300.430(a)(1 )(iii)(F) that states "EPA expects to return usable groundwater to their beneficial uses wherever practicable, within a time frame that is reasonable given the particular circumstances of the site." Based on the
groundwater modeling presented in the OU3 FS report, it appears that the time required to reduce the level of contamination in groundwater to 1 ppb is approximately 150 to 200 years (optimistically). As we have indicated in earlier comments, we believe that a more realistic and practicable ARAR tor OU #3 of 5 ppb (which is the federal standard adopted by EPA pursuant to the Safe Drinking Water Act) should be adopted instead of 1 ppb in light of the time required to meet 1 ppb. In any case, if the requirement cited by EPA for beneficial uses implies reducing contaminants to the ARAR
throughout the contaminant plume, then the time frame is neither reasonable nor practicable. We believe that it is much more practicable to maintain a cleanup goal of 1 ppb at the plume boundary than by attempting to achieve a cleanup goal throughout the plume. As noted by EPA, the source of contamination has been eliminated, and it is not expected that contaminants
present in the soil will adversely impact groundwater.
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A-8
OU #4 National Starch & Chemical Company
Responsiveness Summary
RESPONSE: Technically, the source of contamination to the soil has reportedly been
eliminated, however, the same cannot be said for the groundwater. As long as contamination remains in the soil, this contamination can be termed a source of contamination for the groundwater. The selection of 1 ppb as the performance standard for 1,2-DCA in groundwater was not arrived at
arbitrarily. As stated in the Responsiveness Summary for OU #3 ROD, 40
CFR 300.400(g}(4) states, "Only those state standards that are promulgated,
are identified by the State in a timely manner, and are more stringent than federal requirements may be applicable or relevant and appropriate•. The state groundwater quality standard for 1,2-DCA, as specified in the North
Carolina Administrative Code (NCAC) 15-2L.0202(g}, is 0.38 µg/1. This is a more stringent standard than what is specified for 1,2-DCA in the Safe Drinking Water Act. However, NCAC 15-2L.0202(b}(1) allows the state groundwater quality standard to be raised to the detectable concentration.
Consequently, the Agency raised the groundwater performance standard for 1,2-DCA from 0.38 µg/1 to 1.0 µg/1 as 1.0 µg/1 is the detection limit for 1,2-DCA under the drinking water analytical protocols, EPA method 524.2.
Based on the Superfund Analytical Methods for Low Concentrations Water for Organic Analysis for the Contract Laboratory Program, dated June 1991, the quantitation limit for 1,2-DCA is set at 1 µg/1.
40 CFR 300.430{f)(1 }(ii)(C) provides the grounds for invoking a waiver.
Based on the Agency's evaluation on the request for a waiver to the State's
groundwater quality standard (NCAC 15-2L.0202), the Agency concluded
that the request does not satisfy any of the specified grounds for invoking a waiver.
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ATTACHMENT A
TRANSCRIPT OF PUBLIC MEETING
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NATIONAL STARCH AND CHEMICAL COMPANY
SUPERFUND SITE
7:09 P.M.
July 26, 1994
Salisbury, North Carolina
Agricultural Extension Center
2727 Old Concord Road
Salisbury, North Carolina
PROPOSED PLAN MEETING
OPERABLE UNIT ti
Ql~arlotte @our± 3Reporling. ]nc.
Jloat ©fflce 1lax 11£i2S
Ql[iiafutti. Nori.ft &ru11rui: Z82ZO
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i!aa Im (8Ul1) 456-9424
.-----------------=-2----,-------. I
A P P E A R A N C E S
Ms. Diane Barrett
Community Relations Coordinator
U.S. Environmental Protection Agency
345 Courtland Street, Northeast'
Atlanta, Georgia 30365
Mr. Jon Bornholm
Remedial Project Manager
U.S. Environmental Protection Agency
345 Courtland Street, Northeast
Atlanta, Georgia 30365
Mr. H.E Graulich
4 Waldon Road
Califon, New Jersey 07830
Mr. Ray Paradowski
Post Office Box 399
Salisbury, North Carolina 28145-0399
Mr. Mike Sturdevant
IT Corporation
312 Directors Drive
Knoxville, Tennessee 37922
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MS. BARRETT:
Thank you, Gentlemen, for coming. We appreciate
your time. I'm Diane Barrett; I'm the community relations
coordinator and Jon Bornholm is the remedial project manager
for.this site. And I .think just about everybody in here has
been to all the other meetings; right? Okay. So we should
have a lot of information. I will --let's see. The city
--city and county people, we welcome you, _Mr. Vest and Mr.
Lasa---Lasater, is that correct, and everybody else?
Okay.
The purpose of tonight's meeting is to discuss the
National Starch and Chemical Company operable unit 4 soil
remediation project. Thus far we've had four proposed
planned public meetings. One in '88, in 1990 and '93 and
tonight. Each public meeting has had a public comment
period; usually that's thirty days and has been extended
sometimes to sixty days. we have displayed --had display
ads published in our local news --in your local newspaper
advertising this meeting as well as mailing out fact sheets.
I hope you all received these in the mail or either if you
didn't in the mail, you can pick them up outside. And,
also, please sign in if you didn't. I think most everybody
has. These are just some of the ways that we keep people
informed through the community relations effort.
At --at the present time we are in step number 5,
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public comment period, for operable unit 4. All of the
other items that are on the screen here have been fulfilled
through the community relations efforts and will continue to
be updated.
Tonight there will also be a transcript made of
the meeting. Our court reporter here is --this is an
official meeting,· so the transcript, once it has been
completed, will be available in our information repository.
And for those of you that don't know, but I'm sure you all
do know, the repository is located at the Rowan County
Public Library at the reference center.
The public comment period time for this operable
unit 4 phase is July the 12th throug~ August the 11th. That
is the standard thirty-day public comment period. And if
the public requests, a thirty-day extension can be given and
will be given if --if the time is needed.
That, I believe, will pretty much complete my
section of the meeting, since most of you are familiar with
our process and have participated in previous meetings. I
do hope --we do appreciate your time and if --if at any
time that you need assistance, we have a 1-800 number which
is on page twelve of the fact sheet. Also, if you don't
want to look, it's 1-800-435-9233. So we will be glad to
receive your calls at any time. Feel free to call us.
Thank you for your attention. Now I will turn the meeting
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MR. BORNHOLM:
Our branch has got into the 21st century; we now
have voice-mail and my --my extension number is 4106 and
Diane's is 4111, so it keeps you from going through the
alphabet and pushing a lot more dials to get to us if you
need us.
One of the handouts on the --in the front, the
thick one, is basically just a --a copy of the overheads I
will be going through tonight. As most of you are familiar
with the site, I'll probably go I'll be going through the
first couple ones relatively quickly. Basically, the plant
operations started back in approximately 1970 and then have
been going on since.
The site was first proposed for the national
superfund site or national priorities list in April of '85
and it was finalized on the list in October of '89, and the
hazardous ranking scoring was 46.51 and basically we --we
use 28.5 as our cutoff score. Anything below that does not
--is not listed on the map in the priorities list.
Now, just to briefly look at the site, we are
working on operable unit number 4. I'll just go through,
because the next couple of sheets talk about the other
operable units as well. Operable unit 3 deals with the
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contamination associated with the trench area and the
contaminating ground water emanating from the trench area
that flows in a westerly direction, meaning th_e remediation
of that ground water is basically operable unit number 1.
The soils in the trench area are operable.unit number 2.
Operable unit 3 and 4 deal with plant area 2 which is right
here (indicating on screen) in the lagoon area. Operable
unit 3 deals with the_ground water in this area which is
basically flowing in --in this direction. The operable
unit 4, which I'm discussing tonight, deals with the
contaminated soils associated with area 2 of the --or the
plant operations area and the lagoon area. And, again, just
to swnmarize what operable unit was~-1 was, it's deal with
the contamination which they found on the site. This record
decision associated with this operable unit split the site
into what we call operable units, which are just basically
segregating the site into different manageable areas.
As a result of requiring a --well, as a result of
splitting the site into a second operable unit, National
Starch initiated additional studies of the site and looked
at the trench soils and then the record decision for
operable unit 2 was signed September of --of '90 and this
--because of continuing contamination being found in the
northeast tributary, the base·team, with --along with the
State, again split the site into an additional operable unit
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to try to identify the source of that contamination.
For operable unit 3 which we proposed to the
public back in July, September, August of last year,
identified the same alternative for the contaminated ground
water and again we split the site into a --a fourth,
appropriate, final operable unit and that fourth operable
unit, again, as I mentioned before is dealing with the
contaminated soils.
So basically we're here tonight with the proposed
planned public meeting. After the thirty-day public comment
period, if it's not extended, we'll end in --August 13th?
MS. BARRETT:
August 11th.
.MR. BORNHOLM:
--Aug---August 11th, and we anticipate having
the record of decision signed for this operable unit
sometime late September. And then, just to, again, just to
identify the areas we're talking about, area 2 is the plant
area and it contains the reactor room, the tank room, the
raw material storage area and warehouse and includes the
terracotta pipeline that led from the production area to
the lagoons and the solvent recovery operations. And just
to point them out here (indicating on screen), again, this
is area 2, terracotta terracotta pipelines basically
ran like this (indicating on diagram) and solvent recovery
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area was located up in this area (indicating on diagram).
And then for the lagoons, this overhead basically
identifies the history of the lagoons that were constructed
back in the early seventies. They were re-well, they
were excavated and lined with concrete back in '84 and
basically the contamination found associated with those
lagoons results from the contaminated soil that --from the
contamination entering the soil up to '84, before they were
excavated and lined with concrete.
Okay. Operable unit 4 feasibility studies built
on the operable unit number 3 remedial investigation. There
was suf---there was sufficient data generated during that
remedial investigation to be used as.part of --or to be
used as the feasibility study for operable unit 4. There
was one additional piece of fieldwork done as part of
operable unit 4 and that was a hy---hydrophobic dye test,
basically to answer the question whether or not we have a
dense aqueous liquid or what we term a Dinaphthol at the
site.
The primary contaminant which has been found
throughout the site in all the operable units and one that
oper_able unit 4 also concentrates on is the
1,2-Dichloroethane or 1,2-DCA, and basically this is a list
of organics detected in the soils and the --the range of
concentrations and the frequency of the number of times we
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encountered it in our samples.
Using this data, National Starch contoured the
concentrations of 1,2-Dichloroethane and this overhead shows
the --again, area 2, the plant production area, and then
the contours. Here's the most heavily contaminated area
(indicating on screen). And then this area down here is
associated with the terracotta pipeline and then plant
operations. And then the next overhead depicts the soil
contamination of 1,2-Dichloroethane associated with the
lagoon area. Again, it's very localized.
Okay. As part of the remedial investigation and
feasibility study effort, a risk assessment was performed
and basically.that's looking at the types of contaminants,
the concentration of contaminants present and determining
what risk the site poses to both the public and the
environment. Basically, it briefly identifies, first, in
order to be --in order for a risk to be there, first you
have to have a pathway for that contaminant to get to the
public, and secondly, the chemicals there have to be at a
sufficient concentration to have some degree of toxicity to
cause a health problem. And under superfund for
carcinogenic compounds, anything with any risk greater
than a 1 through -4, which is one out of every ten thousand
people or a hazard index of one, which really doesn't equate
to a ratio of one out of ten thousand.
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And, again, this is --this is based on the data
generated from operable unit 3, remedial investigation.
There is no current risk posed by the site and there is no
current risk because there is no complete pathway for
contaminants, but there are three, what we --as part of
that risk assessment, we look at future risk scenarios and ...
there are three unacceptable future risks, which means if
site conditions change, these are --these are
possibilities. And then these are the risks associated with
those scenarios and the greatest risk would be using the
ground water as drinkable water. And, again, the key term
here is an on-site resident. Right now, again, there's
the site doesn't cau~e --there is nQ unacceptable risk or
current risk associated with the site, but if site
conditions change and some people build homes on there, then
that risk changes and we would look at that. But, again,
thatis --that's a future potential risk.
Also as part of the risk assessment or risks --
risk process, we come up with cleanup goals or performance
standards. For this site we looked up three situations:
one, to protect the workers on site; second one, to protect
potential future --again, potential future residents, and
the last one is to be protective of the quality of the
ground water. And the agency has selected the more the
most stringent one, a cleanup goal, as the goal for operable
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unit number 4 as our cleanup goal for the soils or as our
target for the soils for 1,2-Dichloroethane at 169 parts per
billion.
And using that concentration, the next two
overheads depict the extent of soil contamination, lateral
soil --extent of soil contamination using that
concentration. Again, this is associated with area 2, the
plant operations.
MR. PARADOWSKI:
That's not included, Jon.
MR. BORNHOLM:
What's that?
MR. STURDEVANT:
It's the last two.
MR. PARADOWSKI:
Oh, I'm sorry.
MR. BORNHOLM:
I'm sorry.
MR. PARADOWSKI:
I didn't catch it.
MR. BORNHOLM:
And then the next --the next figure shows the
lateral extent of the contamination associated with the
lagoons that surpassed the --that performance standard.
Okay. Using this information, we'll go into the
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feasibility study and basically the feasibility study is
built on the process of elimination, starting with a broad·
base of technologies, and as you eliminat---eliminate
those technologies due to either implementability,
effectiveness or cost on the initial sweep through those
technologies, we start to narrow them down to a more
manageable number of technologies that we can do a detailed
evaluation on.
So the first step is to screen all --all
technologies using basically these three criteria. The
next step is try to put those technology technologies
together to form remedial alternatives, and once we've done
that, again, we use --then we use _tp.ese three criteria to
do an initial screening of those remedial alternatives,
again, try to eliminate those that are either duplicative of
one another or don't meet the needs of these criterias. And
after that process, then we take ~hat's remaining and
perform a detailed evaluation using basically these seven
criteria, the threshold criteria and the evaluating
criteria. The alternatives must pass the threshold criteria
and then these other evaluating criteria are used to
evaluate the alternatives against one another.
And then the last two are --is based on what the
community --the public comment period's about, at least for
the community's acceptance, as well as --and the-~ and the
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State's been involved all throughout the process.
These are the four alternatives that made it
through that screening process. By law, we're required to
keep the no action alternative, and that gives us a base
line to measure the other alternatives. On --the next
alternative is S2, natural degrad~tion and institutional
controls and the associated cost. Alternative 3S is soil
vapor extraction with fume incineration in the i~itial phase
-of that process when you're pulling out large quantities of
of contaminants, and then as that rate of --of removal
decreases, then we change the filtering method from fume
incineration to activated carbon filters to control the
the emissions from the process --from the soil vapor
extraction process. Then alternative S4 basically
eliminates the fume incinerator and we just use .activated
carbon. And the reason it's so much more expensive is
because you're going to be using a lot of activated carbon
in the initial start-up of the soil vapor extraction system.
And then what the agency has proposed, and the
State has given concurrence with some reservations, the
agency is proposing alternative S2, natural degradation with
institutional controls. Just the key points I want to make
to support the selection of this remedy is, one, if we go
back to the map of the site, most of the contamination with
the lagoons is --is in this area and the majority of --of
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contamina1:ion has alre.ady been --has already migrated into
the ground water here (indicating on screen). As far as
area two, most of --most of this area is already capped
with an impervious layer, either the building itself or the ' • y .
macadam driv7wa_y surrounding the area. So we.'re not
anticipating the contamination to migrate from the soil
down to the ground water in this area because of that
·· impervious cap·.
The other --the-second point is National Starch
has proposed that based on published literature,
1,2-Dichloroethane degrades with a half-life of two years,
which means that 7very two years the concentration of
' 1,2-Dichloroethane should decrease by one-half. And based
on those --on that rate of degradation, it's anticipated in
less than ten years that the concentration will fall to the
7,000 parts per mil~ion level which --where is that? Where
is the overhead? Here it is --which is --which would --
would be protective of of the public from germal contact.
And then in less than twenty-one years, we would --the
concentration would degrade down to this concentration. And
this --this process, the natural degradation process, is
accomplished through the --the activities of --of bac---
of bacteria microorganisms found in the soil.
And then the other points I want to --other
points other facts to point out which --let's put this
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one back up here. Operable unit 3 is --to extract
contaminating ground water, there will be extracti_on wells
located in this area (indicating on screen), general area,
to extract the contaminated ground water. So if there is
any migration of the contaminates from the soil down into
the ground water, we will be protecting both the environment
and public health through the use of those extraction wells.
And then the last point to make out .is, again, in
this area (indicating on screen) there is no current
unacceptable risk posed by the contamination presented in
this area because there is no direct link or exposure
pathway.
Okay. This is going to be a contingency ROD,
which basically means that if naturai degradation does not
pan out as anticipated, we are going to require National
Starch to go in and use an active remediation to remove the
volatile organics from the soil, which would be either
alternative S3 or S4, and basically we'd put a time frame to
that and propose a plan of two years from the signing of the
ROD to be able to show that natural degradation is occurring
and the rationale behind that is basically contamination has
been there, let's say, prior to 1980. If it's going to --
if natural degradation is occurring, we should see it now
because the last source of contamination was eliminated back
in February of --of this year when they completed the
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removal of that terracotta terracotta pipeline. So we
feel that within two years we should see substantial
decreases in contamination.
And that ends my prepa;=ed presentation. We will
--I'm happy to answer any questions that you may have. I
first ask that you please give your name --is that all?
MS. BARRETT:
{Nods head affirmatively)
MR. BORNHOLM:
That you give your name prior to asking a
question. Yes, sir.
MR. BARE:
Odell Bare. How much water are you pumping over
there now?
MR. BORNHOLM:
Mike?
MR. STURDEVANT:
About 130,000 gallons a day.
MR. BARE:
Well, we got a well across the creek that's going
dry. The water level is below the pump we put in there.
The --the bill usually runs about fifteen to twenty
dollars; it's seventy, eighty dollars.
MR. BORNHOLM:
Okay.
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MR. BARE:
The pump is below --the water is pulled below the
well.
MR. BORNHOLM:
I --National Starch just submitted a --
MR. STURDEVANT:
Quarterly report.
MR. BORNHOLM:
monitoring and a quarterly report that depicts
the contours of their cone of influence. I have not --it
was submitted --I got it Monday, so I have not looked at
it. But I talked to Mike and from what Mr. Sturdevant said,
the cone of depression does not go or reaches the stream,
does it not?
MR. STURDEVANT:
I think the cone of influence is approximately at
the southwest tributary. It runs on the backside of the
property.
MR. BARE:
Is it down to the branch?
MR. STURDEVANT:
It's --it's approximately down to the branch, in
there.
MR. BORNHOLM:
I don't know where you're --
.---------------------:.1!:<.B __________ I
1 MR. BARE:
2 Is it across from the bridge?
3 MR. STURDEVANT:
4 Not that --not that we're aware of. · In fact,
5 one's a downgradient monitoring well and I believe it's
6 NS~32 is artesian, and that's the one that's closest to the
7 --where you're talking about, as far as the --the wells.
8 MR. BARE:
9 Well, see --that's what they-~ it's lowering the
10 water level there; you're pulling the water out from under
11 that well and lowering the ground water there.
12 MR. STURDEVANT:
13 What I'm saying --what I'm saying
14 MR. BARE:
15 That well when it was put in, twenty-five feet was
16 ·water level, and that's below the well,
1 7 MR. STURDEVANT:
18 What I'm saying is
19 MR. BARE:
20 below the pump.
21 MR. STURDEVANT:
22 What I'm saying is the monitoring well that is
23 closest to your-~ the area that you're referring to is
24 artesian, whereas it has a head that is pushing water out of
25 the well. The water table elevation is actually above
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1 above the well.
2 MR. BORNHOLM:
3 Is that down at the branch?
4 MR. STURDEVANT:
5 Yes.
6 MR. BORNHOLM:
7 And that~-that's still artesian?
8 MR. STURDEVANT:
9 That's still artesian.
10 MR. BARE:
11 Is it running all the time?
12 MR. PARADOWSKI:
13 But that's a monitoring well, not a pumping well.
14 MR. STURDEVANT:
15 No; no. I know but I guess they're monitoring the
16 condition on that side of the creek.
1 7 MR. PARADOWSKI:
18 Right.
19 MR. STURDEVANT:
20 And it's an artesian creek well --
21 MR. BARE:
22 Is that running all the time?
2 3 MS • BARRETT:
24 Excuse me. Excuse me. Just say your name for
25 the record, please.
..-----------"-----£.!20L_ _____ ~I
1 MR. PARADOWSKI:
2 I'm sorry.
3 MS • BARRETT:
4 Say your name for the record.
5 MR. PARADOWSKI:
6 I'm sorry. I'm Ray Paradowski from National
7 Starch. But just to clarify that particular artesian well,
8 that's a monitoring well and there's no pump in that well.
9 There's no water being taken out of it.
10 MR. BARE:
11 Is it pumping water out all the time?
12 MR. PARADOWSKI:
13 Ya---well, except it's capped.
14 MR. BARE:
15 Well, that's probably lower than the well up on
16 the hill that we're talking about.
1 7 MR. PARADOWSKI :
18 As I said, no water is being taken out of that
19 well. It's strictly there as a test hole.
20 MR. BARE:
21 What about the other one? You drilled two· down
22 there, didn't you?
23 MR. PARADOWSKI:
24 Yeah, but those are --neither of-those wells are
25 being used for pumping water.
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MR. BORNHOLM:
But are they
MR. PARADOWSKI:
21
We're not pumping any water right now.
MR. BORNHOLM:
But are they showing drawdown, though?
MR. PARADOWSKI:
Pardon me?
MR. BORNHOLM:
Are they showing drawdown?
MR. STURDEVANT:
The --the extraction wells are upgradient from
the monitoring wells, which are down close to the creek. If
we had a map --I don't know if they'ye got a map over
there.
MR. BORNHOLM:
I don't.
MR. STURDEVANT:
I can sketch it.
MR. PARADOWSKI:
Let's see the report.
MR. BORNHOLM:
I'm not sure if the report goes into --but I
guess the point to be made or to reemphasize right now,
based on the information that National Starch has, the cone
1 of influence reaches the stream.
2 MR. BARE:
22
3 What's that? Were you talking to me?
4 MR. BORNHOLM:
5 Yeah. The --the extraction wells that they
6 installed on --on their property, the influence on the
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7 groundwater based --from the extraction of that·--of the
8 · water in through those wells has reached the stream. I
9 --and I don't --do not know where your well is located, so
10 I can't --
11 MR. BARE:
12 It's probably, what, three hundred feet,. four
13 hundred feet?
14 MR.· BORNHOLM:
15 Is it a --is.it drilled into bedrock or is it --
16 is it drilled into bedrock?
1 7 1-ffi • BARE :
18 The well?
19 MR. BORNHOLM:
20 Your well.
21 MR. BARE:
22 Yeah.
23 MR. BORNHOLM:
24
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It's in hard rock?
*·*******
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MR. STURDEVANT:
If you have a --a marker, I could draw a little
map up on the board there.
MR. BORNHOLM:
What type of marker is this? Erasable marker?
MR. BARRETT:
Okay.
(WHEREUPON, Mr. Sturdevant prepared a diagram
on the board.)
MR. STURDEVANT:
This is the trench area (indicating on diagram).
This is the southwest tributary down in this area. I
believe where you're talking about is the Little Acres;
right?
MR. BARE:
Yes, sir.
MR. STURDEVANT:
You're over here. I'm not sure whereabout in this
property that you have your well located, but from here down
to the stream, what would you say that is, approximately?
MR. BARE:
I'm not --I don't know exactly. I'd say four
hundred feet.
MR. STURDEVANT:
Yeah, I would say about four to five hundred feet
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there, directly here. We have monitoring wells 29, 30, 31,
and 1·think 32 is somewhere in this location. What we're
seeing in these monitoring wells is that we have a cone of
influence --we have these two extraction wells working all
the time. Extraction well --this is extraction wel_l 2;
this is extraction well 3. These are the two extraction
wells that are pumping water. We see
MR. BARE:
Are they pumped twenty-four hours a day?
MR. STURDEVANT:
That's right; that's right. The normal hydraulic
gradient across this area, of course, is down --right down
to the stream. When you have these wells operating, you see
a cone of influence something like this (indicating on
diagram). And what that means is that you're actually
having an influence of ground water in the downgradient
direction, actually reversing back towards these extraction
wells but at a limited distance. We're only affecting out
in this area, oh, about a hundred feet away from the well in
the downgradient direction. Okay. We're seeing decreases-
in concentrations of contaminants in the moni---
downgradient monitoring wells.
This particular monitoring well right here, NS-32,
the most downgradient well and closest to your property, is
what we refer to as an artesian condition. That means that
~•
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1 the hydraulic gradient is actually pushing up in this region
2 _so that once you tap into the bedrock aquifer at this point,
3 into the --into the aquifer at this --at this location,
4 you have a head of water that is above the surface water,
5 above --above the surface elevation.
6 MR. BARE:
7 Is that across the creek from the plant?
8 MR. STURDEVANT:
9 Here's your --here's your creek right here
10 (indicating on diagram). This is the southwest tributary.
11 Okay. So it's across the creek.
12 MR. BARE:
13 Is that contaminated over there?
14 MR. STURDEVANT:
15 No, never has been. It continually registers
16 non-detect. So your --your well is probably, if I was to
17 --to estimate, I would say it's at least fifteen hundred
18 feet, maybe two thousand feet away from this cone of
19 influence over here on the property.
20 MR. BARE:
21 Well, they built that high-rise prison over there
22 and they pump water like --
23 MR. STURDEVANT:
24 Well, that could be --
25 * * * * * * * *
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MR. BARE:
--it's going out of style. Now the water is
below the pump.
MR. STURDEVANT:
That could be your problem. If they're
withdrawing huge quantities of water from the prison, they
could be impacting the water in this area (indicating on
diagram).
MR. BARE:
You see, they don't use it no more.
MR. STURDEVANT:
Oh, okay. Well, disregard what I said.
MR. BARE:
Well, it's got a couple of trailers on it, but
it's going down below the --the pump; where the pump was
put in the ground, it was put down in --way down in the
water.
MR. BORNHOLM:
The other thing that we could look at if --if you
have information available, is look at the depth --the
depth of this well versus the depth of this well
(indicating on diagram).
MR. BARE:
Okay; okay.
* * * * * * * *
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MR. BORNHOLM:
And then if this well if these wells are above
the depth of this well, there's no way that you have
influence from that site.
MR. STURDEVANT:
Again, I'd like to point out, Odell, that the only
place.we're extracting ground water is out of the extraction
wells, the EX-2 or the EX-3. The --the monitoring well,
NS-32, we're not extracting any water out of that well
whatsoever; it's just monitoring the condition there.
MR. BORNHOLM:
Again, another thing we can look at is the depth
of --of this well (indicating of diagram), elevationwise,
com---compared to sea level and these wells here that --
could --will help answer any questions.
MR. BARE:
Well, that well sits higher than any of those --
that --that's on pretty high ground.
MR. BORNHOLM:
You know, I don't know the terrain around there,
so I can't respond to that.
MR. AREY:
My name is Javis Arey and I work with Mr. Odell
Bare and Mr. June Goodman in Little Acres Mobile Home Park.
We're responsible for the overall operation of the Little
28
1 Acres Mobile Home Park. We have numerous wells throughout
2 the development. There are 157 families, 157 mobile homes
3 in Little Acres tonight. Each of them are feeding different
4 .wells. My question is why, after eighteen months,
5 thereabout, of just pumping 120,000 gallons, which is
6 it'll go to 200,000, is that correct, per day? Will the
7 volume increase to 200,000?
8 MR, STURDEVANT:
9 That's the maximum amount that --that we have
10 designed for. Yeah. Whether we need to pump 200,000, based
11 on the results that we're seeing from our quarterly
12 monitoring program, I doubt it will have go that high.
13 MR. AREY:
14 All right. Where is the ground water
15 approximately eighteen months, speaking of today in
16 relationship to this ground water table before these
17 extractions started --before you started --started pumping
18 a hundred thousand --is the overall ground water table
19 dropping?
20 MR. STURDEVANT:
21 In that area of influence that --
22 MR. AREY:
23 Yes; right.
24 MR. STURDEVANT:
25 --I pointed out there?
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MR. AREY:
If it's 120,000 --130,000, it's got to come from
somewhere. Is it coming from --
MR. STURDEVANT:
Okay. All right.
MR. AREY:
Are you with me here?
MR. STURDEVANT:
Yeah. I sure am; I sure am. If I may again?
(WHEREUPON, Mr. Sturdevant approached the board.)
MR. STURDEVANT:
If you look at this whole region, the watershed
area begins up here at the top of the hill and extends way
back up, I guess, all the way up to Reynolds Aluminum plant
factory. Okay.
MR. AREY:
Right. Highway 29.
MR. STURDEVANT:
So you've got this huge regional aquifer that's
coming down through this area, through the southwest
tributary, and you have water, of course, that's flowing
down this direction from the top of the hill. So what
you're --what you're pulling out from these extraction
wells is the water that's coming down from the top of the
hill, under here and the water that's flowing down through
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this valley.
MR. AREY:
Yes, sir.
MR. STURDEVANT:
Okay. So that's where all this water's coming
from that you're pulling out of the extraction wells right
here (indicating on diagram). The water, I would --I would
assume that the water that you're seeing across here is
coming from an area up here, looking at, again, the --the
topography in the area. It looks like the watershed for
this zone is back up --
MR. BARE:
That well up there is about the peak of the hill.
MR. STURDEVANT:
Okay. So --
MR. BARE:
It's --it's about the peak.
MR. STURDEVANT:
The crown?
MR. BARE:
Yeah.
MR. STURDEVANT:
So you're probably --you're probably gathering
water from up in this area and also the water that's, again,
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running down through this valley.
MR; AREY:
31
Is the water table itself dropping any?
MR. STURDEVANT:
The water table in this area, this cone of
influence, we've seen it drop about --I believe it's two
feet --
MR. VEST:
That's not the point that he's asking, though,
Mike.
MR. STURDEVANT:
right --right around this well right here,
these wells. That's all. It's just a --a real shallow
zone.
MR. VEST:
I just want to make a point for Mike to make.
The point he's making is the four monitor wells, which are
outside the cone of influence, have you got the standing
MR. STURDEVANT:
Right.
MR. VEST:
--you got the standing elevation of those to show
that that has not changed --
MR. STURDEVANT:
That's right.
;.----------,-----~3~2 --------. I
1 MR. VEST:
2 --through the year --
3 MR. STURDEVANT:
4 That's right.
5 MR. VEST:
6 --of pumping? That's his question.
7 MR. STURDEVANT:
8 These --these wells down here, these --these •
9 monitoring wells, the elevation of the water in those
10 monitoring wells has not changed from this pumping action
11 here.
12 MR. VEST:
13 Which is on the other side of the creek where you
14 are.
15. MR. STURDEVANT:
16 We haven't seen any depression of --of the ground
17 water down in this area (indicating on diagram) whatsoever.
18 It hasn't been decreasing; the ground water elevation has
19 not decreased with these wells operating.
20 MR. BARE:
21 Well, what is --these wells that you're pumping,
2 2 how deep are they?
23 MR. STURDEVANT:
24 Approximately --let's see. I think --I think
25 they're 170 feet, I believe.
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MR. BARE:
Do they go down into the rock --
MR. STURDEVANT:
Yes.
MR. BARE:
--or do they just go down to the rock?
MR. STURDEVANT:
No. They go into the rock.
MR. BARE:
Into the rock?
MR. STURDEVANT:
That's right. The rock begins in this area,
(indicating on board) down near the X-02; the rock begins
around five, ten feet below the surface. So most of the
well is --
MR. BARE:
So you really --you really latched onto an
underground stream somewhere that you're pumping water off
of, a vein somewhere.
MR. STURDEVANT:
These are all --this is all fractured rock system
down through here.
MR. BARE:
So you could be pumping off a vein of --that runs
right across that hill to that other well, because when
34
1 I've drilled hundreds of wells; I know what I'm talking
2 about. When you hit a vein, then the water comes. Then it
3 --then it --the vein makes --you don't know which way
4 that vein is coming.
5 MR. STURDEVANT:
6 We have these monitoring wells at the same depth
7 as the extraction wells (indicating on diagram).
8 MR. BARE:
9 Well, the surface water there wouldn't --I mean,
10 the water level there wouldn't necessarily lower, but you
11 could --you could still maintain that surface there and be
12 pumping from another vein somewhere, pumping off another
13 vein, pulling another vein down. Yo~ don't pull that --the
14 area you're pumping, you don't know where that water's
15 coming from if you're down in the rock and not pumping
16 surface water.
17 MR. STURDEVANT:
18 We're we're pretty sure that, based on our
19 measurements, that we're not having an influence out in this
20 area, that the only influence we're having is right around
21 these two wells. That's all we see from all the data
22 measurements we've collected.
23 MR. BARE:
24 Well, how is that contamination getting down into
25 the rock? How deep is the well?
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MR. STURDEVANT:
About 170 feet.
MR. BARE:
So you --you hit rock at eight feet and it's got
to go 160 feet through rock before you can get it?
MR. STURDEVANT:
No; no. What we're doing is we're pulling
contaminants from the full depth of the contaminated
aquifer. What we found is from our initial investigations
here, is that the fractures in the rock pinch out, actually
decrease, to a point that you can't even see them any longer
after you get about 170 feet deep.
MR. AREY:
So, sir, you're saying that the actual ground
water table has not changed any in the overall area of,
like, two miles around Nation --National Starch?
MR. STURDEVANT:
I couldn't say that. If there's been other wells
placed in --in the area, that's, you know, --no; I can't
say that, not two miles.
MR. AREY:
I'm not trying to put words in your mouth. I'm
just --
MR. STURDEVANT:
Yeah; yeah. All I'm saying is locally right here
-·
.------------__.:3~6 -----~.I
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seen any changes in these downgradient monitoring wells.
MR. BARE:
We had another well down on Sidney Drive. there
that went dry last swnmer, the people --the --the lot that
we .sold, and they --they said their well was dry; there's
not enough water in it. Now, what would cause that? It's
been there
MR. AREY:
Eighteen years.
MR. BARE:
Ten or fifteen years.
MR. AREY:
Our problem is --our real question is if we had
one well tonight in trouble due to lack of production and we
have to --have --do we have --are each of the.other wells
a candidate for being the same thing one year from tonight?
MR. BORNHOLM:
And to answer that the best that we have --with
the data that we have is we're not influencing that area.
Again, the gentleman brought up a point that maybe there is
a vein across that runs that way. we don't know. We don't
know that.
MR. AREY:
Whose responsibility should it be to determine
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that?
MR. BORNHOLM:
It's going to have to fall on us. We're the --
the responsible parties. And, again, I think the first
thing we need to look at would be the depths of --of the
wells themselves.
MR. AREY:
Okay. Thank you.
MR. BORNHOLM:
Are there any other questions?
MR. AREY:
Yes, sir, please, and I don't mean to be
predominant. Again, Javis Arey, Little Acres Mobile Home
Park. Question: in relationship to how much noise will
these soil valve extractions make, will it be a terrific
vibration running twenty-four hours a day? How far will
that noise be extended?
MR. BORNHOLM:
You're going
MR. STURDEVANT:
What's that?
MR. BORNHOLM:
You're going up to where again that it --
MR. STURDEVANT:
Well, I think you're asking about the soil vapor
,.;..;..,
r---------,--,----_ ___:,:3~8 ------'--'----, I
1 extraction.
2 MR. AREY:
3 Yes, vapor extraction.
4 MR. STURDEVANT:
5 We're not proposing to put those wells in place.
6 MR. AREY:
7 You're not proposing to put them in?
8 MR. STURDEVANT:
9 That's right. The proposal is
10 control and natural degradation.
11 MR, BORNHOLM:
12 If we need to take --
13 MR. STURDEVANT:
14 If --yeah.
15 MR. BORNHOLM:
is institutional
16 If we need to move on to that step, my --my
17 memory serves me, they're semi-loud.
18 MR. AREY:
°19 All right. Would --would you and your --object
20 for you and your family to live, just, say, about 1500 feet
21 . from it on a constant basis?
22 MR. BORNHOLM:
23 I can't
24 MR. AREY:
25 ·You don't know?
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MR. BORNHOLM:
I --I really can't answer that, 'cause I don't
know. I don't know how loud they are. I've never been
around one. But the I'm assuming we might --if if
necessary, we'd have to muffle them somehow. I'm sure
there's technology there. First of all, we'd have --we're
going to have to control the emissions coming off of the
the blowers themselves to control the contaminants that
we're pulling out. So it's --it's going to be --the
sound's going to be dampened through that process anyway.
MR. AREY:
But that's strictly one of the potential
possibilities down the road?
MR. BORNHOLM:
Yes. And that decision
MR. AREY:
You're not going to meet it 'til it arises?
MR. BORNHOLM:
That decision will be made in two to three years,
MR. AREY:
All right.
MR. BORNHOLM:
--after we determine whether or not natural
degradation is or is not working. If it is not working,
, ...
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that's where we're headed; yes.
MR. AREY:
Thank you. A third question and, again, I don't
mean to be so predominant here, in the covenant restrictions
as I've read here in the communication, we have a tract of
land that is homogeneous with, common boundary line, with
National Starch that we have had for sale approximately two
and a half or three years. I read here that National
Starch's property, if it is ever sold, the deed covenant
restriction will be placed in there that it cannot be
developed or commercially produced. Now, are we going to
have to abide by_those rules? If we sold that property to
you, sixty-two acres, and we get a
MR. BORNHOLM:
Sold it to National Starch or --
MR. AREY:
Pardon me?
MR. BORNHOLM:
No; those covenants would --would zero in on
those areas that are --are contaminated --
MR. AREY:
Okay.
MR. BORNHOLM:
--are contaminated.
* * * * * * * *
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MR. AREY:
Are we allowed to disturb the soil?
MR. BORNHOLM:
On your property?
MR. AREY:
Yes, sir.
MR. BORNHOLM:
As --as far as I know you are. I mean, I --I'm
not sure where your property is, but I --there's no reason
for me to believe that it's even contaminated.
MR. AREY:
We have had different prospects for this tract of
land and once a potential buyer sees in the environment
there, speaking of National Starch, they don't become
interested. It's a valuable tract of land.
MR. BORNHOLM:
We would not --that covenant would not pers---
pertain to that certain tract of property.
MR. AREY:
We could give a --question: we could give a deed
in fee simple?
MR. BORNHOLM:
Yes. We --we don't have any say on your
property.
********
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MR. AREY:
You have no command of the property, period?
MR. BORNHOLM:
Correct, on your --
MR. AREY:
Would --would you have a command if once dirt
started being moved around, road construction started,
houses being built?
MR. BORNHOLM:
It does not pertain to the National Starch
superfund site; no.
MR. AREY:
Okay.
MR. BORNHOLM:
And even on parts of --even if National Starch
went out of business and sold their property, that covenant
would only pertain to those areas that are contaminated. So
there are no --and there --those tracts of --of National
Starch property that's not contaminated and I don't think
there'd be a problem with developing those as residences.
MR. PARADOWSKI:
Can we
have, Jon, to
MR. BORNHOLM:
can we put that one slide up that you
to illustrate that?
The area --the area we're talking about that --
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this deed of restriction would be associated with the
contamination around this area (indicating on screen) and
around this area only.
MR. AREY:
Only?
MR •. BORNHOLM:
Only. And there is
MR. AREY:
again,
The restrictions would be --
MR. BORNHOLM:
As far as I know, there's no contamination down
here and --and therefore there's no risk and therefore, you
know, the public is protected as far as we're concerned.
Now, what we'd say --you know, we would probably prevent or
the State would prevent construction of homes in this area
until the concentrations in the soil drop to a protective
level and then --
MR. AREY:
Which is only inside the fence?
MR. BORNHOLM:
Within the National Starch property, yes. Would
--I don't
MR. AREY:
Repeat that. I'm sorry.
********
,-------,-------------------"4_.4 __________ 1
1 MR. BORNHOLM:
2 The source --the source contamination is all
3 within the National Starch property.
4 MR. AREY:
5 Yes, sir.
6 MR. BORNHOLM:
7 You've got this area of contamination and this
8 area of contamination in the soils (indicating on screen),
9
10 MR. AREY:
11 All right.
12 MR. BORNHOLM:
13 which would prevent --you know, I --as a
14 homeowner, I wouldn't want to build a house there until I
15 was assured that there was no health associated with those
16 areas --health concerns associated with that area.
17 MR. AREY:
18 All right. Thank you. A fifth question, please,
19 and I apologize for the fourth time, why did your
20 organization go from a thirty-year plan to a 120-year plan
21 on the cleanup --or superfund plan? Pardon me.
22 MR. BORNHOLM:
23 The --there's a miscommunication here. Well, not
24 a miscommunication. It's been estimated to clean up the
25 ground water in this area is going to take over a hundred
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years and basically the thrity-year estimate was based on a
different cleanup criteria, was based on a perpetual cleanup
nwnber and we are forced to --to use the most stringent
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nwnber, which is the State's number, which requires more
extraction. The --the federal nwnber is five parts per
million.
MR. PARADOWSKI:
Per billion.
MR. BORNHOLM:
Per billion. Five parts per billion. That's the
federal cleanup goal, called the MCL. And that --and
that's contained under the safe drinking water act. The
State's cleanup number is • 8 or something like that.
MR. PARADOWSKI:
Point 3.
MR. BORNHOLM:
But we had to raise it --we had to raise it to
one part per billion because we can't test, we can't detect
below one part per billion. It's in the we just don't
have technology now. So going from five parts per bill-
per billion down to one part per billion increased the
amount of water that needed to be pumped and, therefore, the
length of time to clean up the ground water. So the
estimate of cleanup this contaminated ground water is now
approximately 120 years. That's where that 120 comes from.
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MR. AREY:
But that could potentially, possibility, be
extended again from 120.to 150?
MR. BORNHOLM:
In all likelihood, it will go on into infinity.
MR .. AREY:
Thank you. And my last --last question, please,
as I touched base with you for the meeting, I was with your
personnel and Raleigh's personnel on-site two years ago
approximately two years ago. Water samples were taken; they
were analyzed by National Starch Chemicals and Atlanta and
Raleigh. Unfortunately, I have never received any
communication pertaining to what those analyses were.·
MR. BORNHOLM:
I sent it to your --your partner.
letter to Mr. Odell.·
MR. AREY:
Oh, you sent it to him?
MR. BORNHOLM:
I sent that
Yeah. I don't know if he got it, but --and the
--the estimated time frame was in July of '92 that those
samples were
MR. AREY:
Yes, sir, '92, in July.
* * *· * * * * *
J
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MR. BORNHOLM:
,Okay. We need that to try to track that data
down.
MR. AREY:
Thank you. Mr. --Mr. Ray Paradowski did call me
and said that as far as they, National Starch, everything
was fine.
MR. BORNHOLM:
And is that about right, July of '92 --
MR. PARADOWSKI:
Yes.
MR. BORNHOLM:
--were --when the samples were collected?
MR. PARADOWSKI:
.That's correct.
MR. BORNHOLM:
tracking
MR. AREY:
Like I said, I'll find out. I've had difficulty
We will get a report, then?
MR. BORNHOLM:
I will send you the data.
MR. AREY:
Thank you.
********
48
1 MR. BORNHOLM:
2 Any other questions?
3 MR. PARADOWSKI:
4 Excuse me, Jon. Ray Paradowski. Could we get a
5 copy of that data, too?
6 MR. BORNHOLM:
7 Yes.
8 MR. PARADOWSKI:
9 Is that okay?
10 MR. BORNHOLM:
11 You never got it documented? If I can find it.
12 I've had difficulty looking, as I explained to the gentleman
13 in the back.
14 MR. AREY:
15 Arey.
16 MR. BORNHOLM:
17 I've looked at both under type of ground water or
18 type the sample was and the date and haven't found it yet.
19 MR. PARADOWSKI:
20 Mr. Arey said that National Starch's result, but
21 actual~y that was a --an outside certified laboratory. We
22 didn't do it ourselves.
23 MR. AREY:
24 Well, thank you. I --I thought you and your --
25 this is Javis Arey.
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MR. PARADOWSKI:
.f ,T,. 1.we; sent it off.
MR. GRAULICH:
We paid for it.
',_,, ,._j-'.,: ,;J.. i·c•,'''L; L\i,
MR. PARADOWSKI:
We paid for it, but it was an outside certified
'· -..
laboratory that did the analysis.
MR. AREY:
Tha~ you.
MR. BORNHOLM:
Are there any other questions? Well, thank you
for your --your time and attending our meeting.
(WHEREUPON, the hearing was adjourned at 8:09
P.M.)
* * * * * * * * *
-' STATE oF NORTH fuotim:-:;;;:"1""·:!""'"· •-. "• ,.i
) CE R·T,,I FICA T,E COUNTY OF MECKLENBURG )
I, Michelle A. Mitchell, Notary Public, do
hereby certify that the foregoing forty-nine (49) pages
constitute a verbatilll transcription of the said hearing. I
do further certify that the persons were present as stated.
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 9th day of August, 1994.
My c6mmiss1on Expires:
June 1, 1999.
~,<2~---
Michelle A. Mitchell ' ' , Notary, Public / : :' · , ·
. ) ; . . ; .. -_.: .·, .....
PLEASE NOTE that unless otherwise specifically requested in
writing, the tape for this transcript will be retained for
thirty days from the date of this certificate ..
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