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HomeMy WebLinkAboutNCD991278953_20021001_National Starch & Chemical Corp._FRBCERCLA C_Fact Sheets 1990 - 2002-OCR• • : ., , .. •·•;; .RE'.~~~~;:c ~c;& UPDATE FACT SHEET NATIONAL STARCH & CHEMICAL COMPANY SUPERFUND SITE ' Region 4 OCTOBER 2002 Salisbury, Rowan County North Carolina This fact sheet is not to be considered a technical document but has been prepared to provide the general public with a better ~ndcrstanding of activities that have been occurring at the Site. For technical information, please review documents in the lnfonnation Repository. INTRODUCTION The National Starch &Chemical Company (NSCC) Superfund Site is located on Cedar Springs Road, approximately 5 miles south of the City of Salisbury, in Rowan County, North Carolina. The goals of this Fact Sheet are to inform the public that: 1) construction activities associated with the Superfund clean-up effort are essentially complete at the Site; 2) NSCC is currently conducting a multi-year natural degradation treatability stlldy for contaminants in the soil; 3) NSCC is currently reassessing/re-evaluating the plume periphery extraction system associated with the Operable Unit #I Remedial Action; and 4) the Agency recently completed the Five-Year Review Study of tht: c11tire NSCC Site. SITE HISTORY In September 1968, Proctor Chemical Company purchased a 465- acre tract of land on Ced.1r Springs Ro.1d. Construction of the plant on Cedar Springs Road began in 1970. In January I 983, Proctor . Chemical Company was dissolved and its operations merged with NSCC. The pi'imary products of this facility are textile-finishing chemicals and custom specialty chemicals. Volatile and semi-volatile organic chemicals are used in the prodllction 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 rinse solutions. The NSCC facil_ity was proposed for inclusion on the National Priorities List in April 1985, re-proposed in June 1988, and fin.1\ized on the list in October 1989 with a Hazardous Ranking System score of 46.5 I. This 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. Since there has only been one owner/operator of this property after being developed into an industrial complex, no "Responsible Party Search" was performed. NSCC has been and remains the owner/operator of the facility. LI .. Figure 1 shows the layout of the NSCG: facility and points of interest. Due to the continued detection of contaminants in the streams, the original scope of work defined in I 986 has been expanded several times resulting in theNSCC facility being divided inio four (4) Operable Units. The Agency prepared a Record of Decision (ROD) for each Operable Unit (OU). A ROD is a public document the Agency prepares that explains and documents the cleanup technology to be used at a Superfund Site. The ROD is based on the Remedial Investigation, the Baseline Risk Assessment, and .the Feasibility Study. A Remedial Investigation gathers data needed to determine the types of contaminants present at a site. what are the concentrations of these contaminants, and how far these contaminants have migrated. ThC Baseline Risk Assessment assesses the information generated during the Remedial Investigation to determine if the types of contaminants present .1nd their reported concentrations will result in an unacceptable risk to either human health or the environment. The Feasibility Study looks at and evaluates the remediation technologies that can be applied at a site to.clean it up. Following the Agency's issuance of a ROD,,the cleanup alternative is designed and engineered as part of the Remedial Design phase. The Remedial Action (RA) is the next phase which involves in:iplementing the design and conducting the actual site clean-up activities . OU #1 focuses on the contaminated groundwater in the eastern portion of the NSCC facility. This contamjnated groundwater is discharging ·into the Unnamed Tributary. OU #2 examined the contaminated soils within the Trench Area which is the cause of the groundwater contamination studied in OU #1. OU #3 deals with the contaminated groundwater in the westerri portion of the NSCC facility. This contaminated groundwater iS discharging into the Northeast Tributary. OU #4 addresses the contaminated soils in ' Area 2 and the wastewater treatment lagoon area (i.e., the source of contamination in the groundwater studied' in OU #3). Area 2 includes the following features: Area 2 re.actor room, the tank room, raw material bulk storage, the warehouse, and an abandoned underground terra-cotta pipe line that ran from the Area 2 ~cactor room· to the wastewater treatment lagoons. The lag9on area includes three lagoons which wereoriginallyconstructed as unlined lagoons between 1969-1970. All lagoons are now lined with concrete. Please refer to Table I for the chronology of activities at NSCC as well as for the dates of important milestones .. The OU #1 RA included the following activi,ties: Install two groundwater extraction -ms: one to capture the leading edge of the plume, the plume periphery extraction system (PPES). and a second system to capture the heart of the plume (i.e., immediately downgradient of the Trench Area, the Trench Area Extraction System); Treat the extracted groundwater through a train of treatment technologies that includes: pH adjustment and air stripping to achieve a quality of water that can be discharged to the City of Salisbury POTW; Establish a monitoring program for groundwater and surface water/sediment; and • Conduct a supplemental RI (OU #2) to determine the source of contamination continually being detected in the surface waters. The OU #2 ROD included the following activities: No action ;emedy; Monitored•"natural attenuation; Monitor soils in the Trench Area on a quarterly basis; Deed restriction to 1) identify the area(s) of contamination, 2) prevent transferof property to an uninformed purchaser, and 3) limit future utilization of the property; and Conduct an RI (OU #3) to determine the source of contamination continually being detected in the surface waters in the Northeast Tributary. The OU #3 RA included the following activities: Install a groundwater extraction system in Area 2 (interception trench) and the bgoon area (extraction wells); Treat the extracted groundwater using air stripping and/or activated carbon filtration to achieve a quality of watt!r that it can be discharged to the City of Salisbury POTW; Vapor emissions from the air stripping unit are to be controlled · through catalytic oxidizing and scrubbing; Establish a monitoring program for groundwater and surface water/sediment; and Conduct FS (OU #4) to re-examine remediation options for the soils in this area of the NSCC facility. And the OU #4 ROD included the following activities: Perform a "Biodegradative Study" to (]) substantiate that natural degradation of contaminants of concern in the soil is occurring in the· OU #4 area, (2) identify where in the subsurface soils degradation is occurring, and (3)determine the rate of degradation; Develop and implement a for long term monitoring plan to monitor the biodegradative process until the performance standards are achieved; Implement institutional controls. Institutional controls include deed restrictions and maintenance of both the existing fence around the plant operations area and the paved areas around Area 2; • Develop a plan 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 ( 1,2-Dichloroethane ( 1,2-DCA) is the primary contaminant of concern in the soil); Conduct a fiv.lr Section 121(c); review in accordance with CERCLA In the event that the "Biodegradative Study" cannot substantiate the occurrence of significant natural degradation of 1,2-DCA and other contaminants of concern in the soil, or the study shows that degradation products increase the Site risks, the contingent remedy will be implemented. "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). The components of the contingent remedy include: • Install a soil-vapor extraction system above the water table to remove the volatile organic contaminants from the unsaturated zone and Treat the extracted contaminated air from Area 2 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 may 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. CURRENT ST A TUS Construction of the OU #1 RA was completed in March 1996. Figure I shows the location of the OU #1 RA components. Originally, the four PPES extraction wells were pumping at a combined average of 86 gallons per minute (gpm). In 1998. the average combined flow was reduced to 31 gpm. In 2000, the PPES · was shutdown to allow NSCC to conduct a hydrogeologic evaluation of this area. Currently, the PPES remains offline as the hydrogeologic evaluation continues. This evaluation is scheduled to be completed by April 2003. The combined pumping rate of the six Trench Area extraction wells is approximately 12 gpm. Construction of OU #3 RA was completed on February 18, 2000. On average, the combined tlov,' from the two bedrock extraction wells is 20 gpm and the extraction rate for the Collection Trench is 6 gpm. Figure I shows the location of the OU #3 components. The objectives of the OU #4 "Biodegradative Study" are highlighted above. Phase I of the OU #4 Natural Degradation Treatability Study was initiated in December 1996 and was completed in March 1998. Phase 11 was started in November 2001 and is anticipated to be completed in February 2007. This work is being conducted in accordance to the January 2000 Phase 11 Natural Degradation Treatability Study Work Plan. The primary objective of Phase II to is substantiate· biodegradation, collect sufficient data to establish a defensible degradation rate, and develop a long-term monitoring program. In r:sponse to the institutional contro •. , deed restrictions) requirements included in both the OU #2 and OU #4 RODs, a plot map was prepared and the restrictions were filed with the Rowan County Register of Deeds Office on June 12, 1997. The description can be found in Book 9989, page 179. Currently, NSCC is re-evaluating the hydraulic control of the OU #1 PPES. This was in response to detecting contaminants in a monitoring well, NS-31 (refer to Figure 1), on the opposite side of the Unnamed Tributary. According to the conceptual groundwater model for the Site, the Unnamed Tributary should be acting as a hydraulic barrier. This evaluation should be completed by April 2003. CONCLUSIONS OF FIVE-YEAR REVIEW REPORT Below is a short synopsis of the report. The portion of the Site remedy dealing with potential soil exposures is protective of human health and the environment-in the short- term. The Trench Area, Area 2. and the lagoon area remain covered and the deed restrictions are in place. At the conciuSion of Phase 2 of the Natural Degradation Treatability Study in 2007, a definitive answer should be made regarding long-term protectiveness of the remedy. In addition, the Agency will also determine whether to implement or eliminate the contingent remedy specified in the OU #4 ROD. There are no current onsite groundwater receptors and the nearest private, potable well is located approximately 2,700 feet north of Area #2. Since there is currently no indication of contaminated groundwater or surface wJter exiting the property, the remedy is considered protective in the short-term. Groundwater at the Site is not protective of humJn heJlth Jnd the environment in the long- term due to the following rcJsons: the current ground\Vater monitoring system is insufficient to determine if the plumes are being cJptured, groundwater is likely migrating to a degree and ' dischJrging to adjacent surf.lee water, groundwater performance standards are not being met throughout the plume, and groundwater is not currently ''restored'', as some Federal and State regulations are lower than the ROD standards. A copy of the 2002--Year Review Report has been placed in the NSCC Information Repository located in the Rowan County Public Library. The next Five Year review should be scheduled five years from the date of this Review, in:September 2007. Table 2 provides the recommendations made in the Five-Year Review Report. FOR MORE INFORMATION If you want further information on this Site or the Superfund program, please contact either of the individuals below: Jon K. Bornholm, Remedial Project Manager Diane Barrett, Community Involvement Coordinator U.S. EPA, Region IV North Superfund Management Branch Sam Nunn Atlanta Federal Center 61 Forsyth Street; SW Atlanta, Georgia 30303.3014 Phone: 1-800-435:9233, ext. 28820 or 28489 INFORMATION REPOSITORY Citizens are encouraged to visit the information repository to review the technical data covering all activjties that have occurred to date. · Rowan County Public Library 201 ,vest Fisher Street Salisbury, North Carolina 28144 Phone: (704) 633-55~8 Hours: Monday -Friday 8:00 a.m. -9:00 p.m. 5 (") ► -I ~ 0 .,, C/l ~ ~ .,, C: z 0 § 0 (") 0 3:: ""' ~ m z ;;j • - TABLE I •• CHRONOLOGY/MILESTONES FOR THE NATIONAL STARCH & CHEMICAL COMPANY SUPERFUND SITE .- EVENT I DATE EVENT DATE Proctor Chemical Company purchased the 465-acre tract September 1968 . OU #3 Proposed Plan Public Meeting August 3, 1993 Construction of facility 1970 Proposed Plan public comment period July 19. August 17, 1993 Proctor Chemical Company dissolved and merged with January l, 1983 Record of Decision for OU #3 signed, divided Site October 7, 1993 NSCC into 4 OUs, created OU #4 Site proposed for National Priorities List April I 985 OU #4 RI Report (used June 1993 OU #3 Remedial Investigation) June 1993 Special notice letter to conduct Remedial May 30, 1986 OU #4 Feasibility ·study Document June 20, 1994 Investigation/Feasibility Study Administrative Order on Consent signed December L 1986 Proposed Plan Fact Sheet for OU #4 July 8, 1994 Remedial Investigation/Feasibility Study (RI/FS) Work Plan December 1986 OU #4 Proposed Plan public comment period July 12 • August l l, 1994 Amended RI/FS Work Plan July 1987 OU #4 Proposed Plan Public Meeting July 26, 1994 Site re-proposed for Na~ional Priorities List June 1988 Record of Decision for OU #4 October 6, 1994 .. ,. First Remedial Investigation (RI) Report [for Operable Unit Unilateral Administrative Order for OU #3 and OU #4 September 29, 1995 (OU) #I l June 21-1988 RD/RA - First Feasibility Study (FS) Document (OU#!) September 8, 1988 ·initiated OU #3 and OU #4 Remedial Design October 1995 Proposed Plan Fact Sheet September 1988 Construction Completion for OU #l Remedial Action March 1996 Proposed Plan Public Meeting (OU#!) September 14, 1988 First Five-Year Review Report (for OU#!) June 18, 1996 Proposed Plan public comment period (OU#!) September 3 -24, _1988 Initiated OU #4 Natural Degradation Treatability December 1996 Study -Phase I OU #I Record of Decision (ROD) Signed, divided Site into September 30, 1988 First Explanation of Significant Difference June 10, 1997 • two OUs, created OU #2 Issued Special Notice Leiter to Conduct Remedial March 27, I 989 Completed OU #4 Natural Degradation Treatability March 26, 1998 Design/Remedial Action for OU# I Study -Phase I Unilateral Administrative Order issued to perform OU# I July 27, 1989 OU #3 Remedial Design Completed June 1998 Remedial Design/Remedial Action (RD/RA) Site finalized on National Priorities List October I 989 S~cond Explanation of Significant Difference November 4, 1998 Supplemental Remedial Invcstigntion Report for OU #2 May 1990 Initiation of OU #3 Remedial Action June 15, 1999 Initiation of OU #1 conslruction -building access roads to August 14, 1990 Initiation of OU #l + OU #3 Combined Pretreatment September 23, 1999 bedrock plume periphery extraction well locations System TABLE 1 •• CHRONOLOGY/MILESTONES FOR THE NATIONAL STARCH & CHEMICAL COMPANY SUPERFUND SITE EVENT DATE EVENT DATE Installation of four bedrock plume periphery extraction August 30 -November Completion of OU#! + OU #3 Combined · February I 8, 2000 wells 14, 1990 Pretreatment System -Proposed Plan for OU #2 July 1990 Construction Completion for OU #3 February 18, 2000 Proposed Plan public comment period July 30 · August 29, Initiated OU #4 Natural Degradation Treatability November 5, 2001 1990 Study. Phase II Supplemental Feasibility Study Document for OU #2 September I 990 First Site-Wide Five-Year Review Report July 2002 ROD for OU #2 signed, divided Site into three OUs, created September 28. 1990 Complete OU #I Plume Periphery Evaluation July 2003 OU#3 CD signed Augusl 1991. Implement Recommendations of OU #I Plume Consent Decree for OU #2 entered in FcJcr~l Court September 2003 . on July 20. 1992 Periphery Evaluation OU #3 Remedial Investigation Report June 2, I 993 Complete OU #4 Natural Degradation Treatability Anticipated February Study. Phase II· 2007 OU #3 Feasibility Study Document June 21, 1993 Accept Findings of Soil Degradation Treatability April 2007 Study or Implement Contingent Remedy ,, L ,. Proposed Plan Fact Sheet for OU #3 July 15, 1993 Second Site-Wide Five-Year Review Report I September 2007 !I Construction of trench area extraction wells+ pretreatment July I 993 -February Third Site-Wide Five-Year Review Report September 2012 system 1996 • TABLE 2 --SUMMARY OF RECOMMENDATIONS AND FOLLOW-UP ACTIONS ISSUE RECOJ\11\IENl>,\TIONS AND PARTY OYERSIGIIT MILESTONE FOLi.OW-UP ACTIONS RESPONSIBLE AGENCY How clean is clean for the soils in the Trench Arca Initiate discussions between regulatory agencies, NSCC, and EPA/NCDENR/ EPA September public to discuss this issue NSCC 2007 Complete OU #4 Biodcgradation Treatability Study Maintain communication with NSCC NSCC EPA February 2007 Complete assessment of PPES Maintain communication with NSCC NSCC EPA April 2003 Complete assessment of OU #2 Conduct soil sampling in conjunction with OU #4 NSCC EPA July 2003 Biodcgradation Treatability Study ' Effectiveness of Collection Trench in capturing Evaluate if Collection Trench is capturing plume NSCC EPA December plume 2003 Effectiveness of other groundwater extraction Determine if efficiency of existing groundwater extraction NSCC EPA September systems systems can be enhanced 2007 Are groundwater monitoring systems adequate? Determine if additional monitoring wells arc needed EPNNCDENR/ EPA December NSCC 2004 Arc contaminants leaving the Site via the Northeast Locate and sample new sampling point downstream of Sampling NSCC EPA December Tributary Location SW/SE -09 2003 The decision documents for the Site do not reflect Amend decision documents and NSCC deed recordation to EPA/NCDENR/ September cunent ARARs or subsCqucnt recordation EPA requirements and cleanup standards reflect current ARARs NSCC 2012 ft ~ Region 4 Official Business • U.S. Environmental Protection Agency 61 Forsyth Street, S.W. Atlanta, Georgia 30303-3014 Penalty for Private Use $300 S/F NSCC 109 'MR. DAVID MATTISON, ENVR. ENGR. SUPERFUND FEDERAL REMEDIATION BR. NC DEPTARTMENT OF ENVIRONMENT & NATURAL RESOURCES .,1601 MAIL SERVICE CENTER RALEIGH NC 27699-1601 I 276-=t9+i60i 0i 7 • £~, 2 . · 1111,11,,, I, II, ,I, I 11 I, I, 11,, 11, II 11 II 111111 Ill, 1111,1,, 11, Ill .. • • SUPERFUNDFACTSHEET-UPDATE JFD ELECTRONICS/CHANNEL MASTER SUPERFUND SITE Oxford, Granville County, North Carolina Remedial Action Completed - Operation & Maintenance Begins May 2002 This fact sheet is not to be considered a technical document but has been prepared to provide the general public with a better understanding of activities that have been and will be occurring at the Site. F6r technical information, please review documents in the Information Repository. INTRODUCTION The purpose of this Fact Sheet Update is to announce the completion of the Remedial Action phase and the initiation of the Long-Term Operation and Maintenance phase of the clean-up being conducted at the JFD Electronics/Channel iviastei" Site. BRIEF SITE HISTORY The JFD Electronics/Channel Master Site (the Site) is approximately 13 acres in size and is located at the corner of Industrial Drive and Pine Tree Road, approximately 2 miles southwest of Oxford, North Carolina. The Site was operated by JFD Electronics from 1961 to 1979 in the manufacturing of television antennas. The manufacturing processes involved a copper/nickel electroplating and chrome conversion coating of antenna parts. Wastes generated from the processes, primarily wastewater and sludge, contained a number of metals, including chromium, lead, and cyanide. Wastewater was treated in an on Site treatment plant. Sludge was disposed of in sludge drying beds along the southern property boundary and also in an unlined lagoon. · Channel Master owned the property from 1980 to 1984. They produced satellite antennas, amplifiers; and boosters. · The North Carolina Department of Environment and Natural Resources (NC DENR) conducted an inspection of the Site in 1987. As a result of their findings, Channel Master conducted a voluntary cleanup of the lagoon in 1987 and 1988. The Site was placed on the National Priorities List (NPL) in October 1989. EPA conducted a Remedial Investigation/ Feasibility Study (Rl/FS) during 1991 and 1992. The Record of Decision (ROD) was signed in September 1992 selecting the treatment remedy to be used to cleanup Site contaminants. In 1993 JFD Electronics/Channel Master signed a Consent Decree agreeing to implement the Remedial Design and Remedial Action (RD/RA) phase of the Superfund process. In January 1996, an Explanation of Significant Difference to the Remedial Action for the JFD Electronics / Channel Master Site was finalized, which altered the groundwater treatment method defined in the 1992 Record of Decision. It conditionally eliminated a few of the treatment steps due to results obtained during the Remedial Design. In May 1999, the ROD was amended to reflect a change in the soil/sludge remediation from on-site treatment and disposal to on-site treatment of metals-contaminated soils and off-site treatment • of cyanide-contaminated soils and sludges. Sampling conducted during May and July 2000, indicated a reduced quantity of soil/sludge that would need to be treated and removed from the Site. As a result, the ROD was changed through an Explanation of Significant Differences on July 19, 2000, to allow for all of the soils and sludges to be treated and disposed at an off-site facility. REMEDIATION ACTIVITIES Groundwater The groundwater remediation system was constructed during May -August 1998, to discharge treated groundwater to the nearby tributary to Fishing Creek. The treatment system consists of seven extraction wells (four deep and three shallow) which are piped to an air stripper which removes the volatile organic compounds in the contaminated groundwater. The Final Inspection was conducted by EPA and NC DENR in August 1998 and the system was started later that month. The first sample analyzed from the treatment system indicated cyanide concentrations greater than what was allowed to be discharged into surface waters. Therefore, the system was immediately shutdown. In March 2000, the discharge was rerouted from the tributary to the Oxford sewer system. The groundwater treatment system was started again in April 2000. Sampling was initially conducted weekly, and after the first three months it was reduced to monthly. Since April 2000 until the present, there have been no exceedances of . discharge criteria from the treated groundwater. The system is expected to continue operating until the contaminant concentrations have been reduced in the groundwater table to the concentrations listed in the ROD. It is expected to take several decades to achieve these results. Soil and Sludge Contractors brought personnel and equipment to the Site on July 24, 2000, and began soil/sludge remediation activities. Approximately 283 tons of metals-contaminated soil and approximately 3,282 2 • tons of cyanide-and metals-contaminated sludge and soil were transported to the Environmental Quality Company (EO) in Belleville, Michigan for treatment and disposal. The excavated areas were ·sampled to ensure all contamination had been removed prior to filling the holes with uncontaminated stone and soils. The remediated area was compacted and then hydroseeded. The Pre-Final Inspection was conducted by EPA and NC DENR on September 28, 2000, at which time only minor punch-list items were noted needing to be completed. The Final Inspection was conducted on October 23, 2000. In August 2001, contractors returned to correct a drainage problem near the Bandag building. FUTURE ACTIVITIES The remedial action for this site was documented as complete on May 2, 2002, in the Interim Remedial Action Report. This document marks the beginning of what is considered the Long- Term Operation & Maintenance phase, where the grouridwate·r treatment system will continue being operated and monitored. A five year review is scheduled to be conducted by September 30, 2005. INFORMATION REPOSITORY The Information Repository has been established to store a copy of documents developed during the process to be accessible to the public. The Information Repository is located at the: Richard H. Thornton Public Library Corner of Main and Spring Streets Oxford, North Carolina (919) 693-1121 \ ' • 3 • FOR MORE INFORMATION If you have questions or need more information, please contac_t either: or Ms. Samantha Urquhart-Foster Remedial Project Manager Waste Management Division North Site Management Branch US EPA, Region 4 61 Forsyth Street, SW Atlanta, GA 30303-8960 Phone: (404) 562-8760 or (800) 435-9233 email: UROUHART-FOSTER.SAMANTHA@EPAMAIL.EPA.GOV Ms. Diane Barrett Community Involvement Coordinator Waste Management Division Economic Redevelopment & Community Involvement Branch US EPA, Region 4 61 Forsyth Street, SW Atlanta, GA 30303-8960 Phone: (404) 562-8830 or (800} 435-9233 email: BARRETT.DIANE@EPAMAIL.EPA.GQV MAILING LIST Since you have received this fact sheet, your name is on the JFD Electronics/ Channel Master Site mailing list. If you have an address change or want your name deleted from this list, please complete this form and return it to us. If you know of someone that would like their name added to NAME ADDRESS the mailing list, please ask them to complete this form and return it to us: CITY, STATE, ZIP CODE ADDO CORRECTION 0 Return to: Ms. Diane Barrett Community Involvement Coordinator Waste Management Division DELETE 0 Economic Redevelopment & Community Involvement Branch US EPA, Region 4 61 Forsyth Street, SW, 10th Floor Atlanta, GA 30303-8960 . ' Region 4 • U.S. Environmental Protection Agency 61 Forsyth Street, SW Atlanta, Georgia 30303-8960 4 /v (r.-\ Y' \.. r,r,•J J · \ .... ., r: .. "(<...'.: ,~ .. -~o,:,:, .. , -u .. ~· --:::,,.....,"!;. • i. ( •· r"'/17 ?,, ,,,..,,.. \.lo • North Site Management;!;!ranch ,)111111° 0 -'l'" ussP00 .. ·· . · 3*· · Diane Barrett, Community Involvement Coordinator __ --.:.. ·. -..--:--'--·-, -~. I • f._,,.,._,~ ,---• i','t-';:"~· •· t ,., Samantha Urquhart-Foster, Remedial ProJect Manager H r3.,-.:.i·_,'...,q _ ~ ~/'-...,~":.,:_.-:,«' ;,~. l ------~--. -- Official Business Penalty for Private Use $300 S/F JFD MR. DAVID MATTISON. PROJECT MANAGER 151 NC DEPT OF ENVIRONMENT & NATURAL RESOURCES SUPERFUND SECTION 401 OBERLIN ROAD. SUITE 150 RALEIGH NC 27605 .• REMEDIAL DESIGN/fcMEDIAL ACTION UPDATE FACT SHEET·. OPERABLE UNITS ,#3~& #41 NATIONAL STARCH & CHEMICAL COMP.ANY' ,,. -r- November 1995 Salisbury, Rowan County, North Carolina Terms in bold face print are defined in a glossary locared st the end of this publication. This fact sheet is not to be considered a technical document but has been prepared to provide a better understanding to the public. INTRODUCTION The Record of Decision for Operable Unit #3 was signed on October 7, 1993 arid the Record of Decision for Operable Unit #4 was signed on October 6, 1994. Operable Unit #3 addresses the contaminated groundwater underlying Area 2 and the wastewater treatment lagoon area (refer to Figure 1) at the National Starch & Chemical Company (NSCC) Superiund Site in Salisbury, North Carolina. Operable Unit #4 addresses the contaminated soil in these same areas. The term "Operable Unit" is used when individual actions are taken as a part of an overall site cleanup. A number of operable units can be used in the course of a site cleanup. SITE BACKGROUND · The NSCC site was proposed for inclusion on the National Priorities List in April 1985 and finalized on the list in October 1989. The Site had a Hazardous Ranking System score of 46.51. Only Sites with a Hazardous Ranking System score of 28.5 or higher are eligible to be placed on the National Priorities List. The NSCC facility occupies approximately 465 acres on Cedar Springs Road five miles south of the City of Salisbury, North Carolina (refer to Figure 2). Presently, land use immediately adjacent to the Site is a mixture of residential and industrial developments. East and south of the Site are industrial parks consisting primarily of light industrial operations. The west and north sides of the NSCC property are bordered by residential developments. Refer to Figure 3 for Site location. Primarily, NSCC manufactures 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 waste stream from the manufacturing process includes wash and rinse solutions. 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. A fourth lagoon was installed in 1992 as part of the treatment system built to treat the contaminated groundwater being extracted from the aquifer as part of the Operable Unit #1 Remedial Action. As in the Remedial Design and Remedial Actions for Operable Units #1 and #2, the Potentially Responsible Party, NSCC, will perform and finance the Remedial Design and Remedial Actions for Operable Units #3 and #4. SCOPE AND ROLE OF OPERABLE UNIT WITHIN SITE STRATEGY As with many Supertund sites, the NSCC site is complex. Consequently, EPA divided the work into four manageable components called Operable Units (OU); they are: OU #1 • Groundwater in the western portion of the NSCC property OU #2 • Trench Area soils and surtace water/sediments in the Northeast Tributary OU #3 • Groundwater in Area 2 and the wastewater treatment lagoon area; surface water/sediments in the Northeast Tributary OU #4 • Soils in Area 2 and the wastewater treatment lagoon area. NEGOTIATIONS Following the signing of the Operable Unit #3 Record of Decision, the Agency decided to combine negotiation efforts for Operable Unit #3 and Operable Unit #4. Consequently, the Agency did not send a Special Notice Letter to NSCC until after the Record of Decision for Operable Unit #4 was signed. The Special Notice Letter, sent to NSCC on January 5, 1995, informed them of the time frame to be followed in negotiating the Consent Decree. NSCC informed the Agency on September 20, 1995 that lhey would not be willing to sign a Consent Decree with EPA. Consequently, EPA issued NSCC an Unilateral Administrative Order on September 29, 1995. The effective date of the Unilateral Administrative Order was October 6, 1995. On October 16, 1995, NSCC informed the Agency that they would comply with the Unilateral Administrative Order. · Below is the schedule for major milestones specified in the Unilateral Administrative Order. 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Submittal of Natural Degradation Treatability StudyWork Plan Submittal of Remedial Design Work Plan ~ovember 6, 199;· December 5, 1995 The timetable for the remaining milestones (i.e., completion of treatability study, submittal of the preliminary design, submittal of. prefinal/final remedial design, initiation of the remedial a~tio~s, etc.) will be highlighted in the Remedial Design Work Plan.· · OBJECTIVES FOR OPERABLE UNITS #3 & #4', ·· Prevent or mitigate the continued release of· hazardous substances, pollutants and contaminants at the Site to surface . water bodies and. sediments and to the shallow and bedrock aquifers; Eliminate or reduce the risks to human health associated with direct contact with or inhalation of hazardous substances, pollutants or contaminants within the Site; Eliminate or minimize the threat posed to human health and the environment from current and potential migration of hazardous substances in the soils and groundwater at the Site; . . Reduce concentrations of hazardous substances, pollutants and contaminants in surtace water, ground water, surtace and subsurface soil within the Site to levels specified by the Pertormance Standards; and Reduce the volume, toxicity and mobility of hazardous substance, pollutants or contaminants at the Site. CURRENT STATUS The dratt Natural Degradation Treatability Study was submitted to the Agency and the State of north Carolina Department of Environment, Health, & Natural Resources (NCDEHNR) on October 26. This document is currently being reviewed by both EPA and NCDEHNR. NSCC is presently dratting the Remedial Design Work Plan. This document is due to EPA and NCDEHNR by December 5, 1995. ADDITIONAL INFORMATION If you would like additional information on any of the work being performed at the National Starch Supertund Site, you can review the documents contained in the Information Repository which is located at the Rowan County Public Library, 201 West Fisher Street, Salisbury, North Carolina. Or if you have specific questions, you can call either Mr. Jon Bomholm, Remedial Project Manager, or Ms. Diane Barrett, NC Community Relations Coordinator, at 1-800-435-9233, or write U.S.E.P.A., Region 4, North Superfund Remedial Branch, 345 Courtland Street, NE, Atlanta, GA 30365. If you know of someone that wants to be added to the Site's mailing list, please notify Diane Barrett at the address shown in the previous paragraph. . GLOSSARY OF .S USED IN THIS FACT SHEET Aquifer: An underground geological formation, or group of formations, containing usable _amounts of groundwater that can supply wells and springs,:, ••• • • r Administrative Record: A file which is maintained and contains . aUiQformation,used by the lead agency to make its decision on the · selection of a method to be utilized to clean up/treat contamination at a Supertund site. This file is held in the information repository for public review. : Consent Decree: A legal document, approved by a judge, that formalizes an agreement reached between EPA and a PRP through which the PRP will conduct all of part of a cleanup action at a Supertund Site. The consent decree describes the actions the PRP will take and may be subject to a public comment period. Groundwater: Water found beneath the earth's surtace that fills pores between materials such as sand, soil, or gravel (usually in aquifers) which is otten used for supplying wells and springs. Because groundwater is a major source of drinking water there is growing concern over areas where agricultural and industrial pollutants or substances are getting into groundwater . Hazardous Ranking System /HRS): The principle screening tool used by EPA to evaluate risks to public health and the environment associated with hazardous waste sites. The HRS calculates a score based on the potential of hazardous substances spreading from the site through the air, surtace water, or groundwater and on other factors such as nearby population. This score is the primary factor in deciding if the site should be on the National Priorities List and, if so, what ranking it should have compared to other sites on the list. Information Repository: A file containing accurate up-to-date information, technical reports, reference documents, Technical Assistance Grant information, and any other materials pertinent to the site. This file is usually located in a public building such as a library, city hall or school, that is accessible for local residents. National Priorities List (NPL): EPA's list of the most serious uncontrolled 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. The list is based primarily on the score a site receives from the Hazard Ranking System (HRS). EPA is required to update the NPL at least once a year. Operable Unit: Term for each of a number of separate activities undertaken as part of an overall Supertund site cleanup. Potentially Responsible Parties /PRP): Any individual or company -including owners, operators, transporters, or generators -potentially responsible for, or contributing to, the contamination problems at a Supertund site. Whenever possible, EPA requires Potentially Responsible Parties, through administrative and legal actions, to clean up hazardous waste sites Potentially Responsible Parties have contaminated. Remedial Action Obfectives:These are .fie objectives which • are identified to protect both human health and the environment that take into consideration the environmental media contaminated (i.e., groundwater, soil, surface water, sediment, or air) and the contaminants present in each medium. The main goal of the objectives is to prevent exposure to contaminants in groundwater, soil, surface water, sediment, or air in excess of risk-based human health or environmental standards. · · · · · Remedial lnvestigation!Feasibility Study (RIIFS):The Remediai Investigation is an in-depth, extensive sampling and analytical study to gather data necessary to determine the nature and extent of contamination at a Superfund site; to establish criteria for cleaning up the she; a description and analysis of the potential cleanup alternatives for remedial actions; and support the technical and cost analyses of the alternatives. The Feasibility study also usually recommends selection of a cost-effective alternative. Record of Decision: A public document that announces and explains which method has been selected by the Agency to be used at a Superfund site to clean up the contamination. Semi-Volatile Orga,.mpounds (SVOCs): Carbon-containing chemical compounds that, at a relatively low temperature, fluctuate between a vapor state (a gas) and a liquid state. Special Notice Letter. Letter sent by the Agency to Potentially Responsible Parties providing them an opportunity to commit to conduct the necessary work. Unilateral Administrative Order. A directive issued by the Agency, requiring the Potentially Responsible Parties to undertake a response action. There must be imminent and substantial endangerment to the public health or the environment before such an order can be issued. Volatile Organic Compounds (VOCS): Any organic compound that evaporates readily into the air at room temperature. Water Table: The level below which the soil or rock is saturated with water, sometimes referred to as the upper surface of the saturated zone. The level of groundwater. MAILING LIST ADDITIONS If you are not already on our mailing list and would like to be placed on the list to receive future information on the National Starch & Chemical Company Superlund Site, please complete this form and return to Diane Barrett, Community Relations Coordinator at the USEPA, 345 Courtland St., NE, Atlanta, Georgia 30365 or call her at 1-800-435-9233. NAME: ADDRESS: CITY, STATE, ZIP CODE: PHONE NUMBER: ADDITION CHANGE DELETION , .-, f -,. ·• -- • , .. • U.S. Environmental Protection Agency 345 Courtland Street, N.E. North Superfund Remedial Branch Diane Barren, Comrn.mity Relations Coordinator Jon Bomholm, Remedial Project Manager Atlanta, Georgia 30365 Region 4 Official Business Penalty for Private Use $300 SUPERFUND SECTION :··· -----~-1 N~CC0158 1 S/F ASST~-~ PUBLIC l~~~~ND SECTION HEALTH ' N.C._ SUP ENVIRONMENT' .,. \ NC DEPT• OF RESOURCES f. NATURAL I \ • BOX 21681 NC Z160l-1681 lGH ._ . ~--_) ___ .:.....----- 111 11\i C...~i ... I 1, J, J J,,, J, JJ, 11n J j 111 I !J, 11 i 1 !l,, I,, i Ii,,, JI II i,i 111 iii,, ,i I i \ ~~S-·''~~-~f>o .. 5~ -/a,l,sr~ w# i.t.·vc!Vto , ~- So!id >Vasle RECORD OF DECISION FACT SHEET OCT 31 1994 : ·: .. ~ ·0PER.ABLE UNIT #4 ~.-1'.: ~ .. ~GfME~ ATIONAL STARCH 0&rCHEMICAL CO. Salisbury, North Carolina October 1994 This fact sheet is not to be considered a technical document, but has been prepared for the general public to pro·vide a better undersranding of the remedy and furure alllicipared activities. INTRODUCTION On October 6, 1994, the Deputy Regional Administrator' of the Region IV Environmental Protection Agency (EPA) signed the Record of Decision (ROD) selecting thsl remedial action to be implemented for Operable Unit #4 to treat contaminated soil in specific areas at the National Starch & Chemical Company facility in Salisbury. The North Carolina Department of Environment, Health and Natural Resources (NCDEHNR) has concurred with the selection. The selection. was based upon data obtained during the Remedial Investigation, Feasibility Study, subsequent sampling activities and public comments. The remedy chosen for Operable Unit #4 is Alternative S2: Natural Degradation and Institutional Controls as presented in the July 1994 Proposed Plan Fact Sheet. This remedy 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 reduce contaminant concentrations in the soil within two years of the date of this Record of Decision, the contingency remedy of Soil Vapor Extraction will be implemented. A more detailed de,cription of each of these remedies is explained in this fact sheet as well as a map indicating the areas of concern. The major contaminant of concern is 1,2- dichloroethane a chlorinated volatile organic compound. Other organic chemicals were detected in the soil and would also be effected and treated by the selected remedy _as well as the contingency remedy. SOIL Alternative S2: Natural Degradation and 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 :~e soil using the contaminants as an energy (food) source. Microorganisms, just like humans, eat and digest organic substances for nutrients and energy. Certain microorganisms can digest organic substances that a.re hazardous to humans. The organic contaminants degraje into harmless· products . consisting mainly of carbon dioxide and water. Where necessary, moisture, oxygen and nutrients can be added to the soil to enhance this process .. This remedy involves the following activities: A study will be conducted to substantiate that · natural degradation is occurring, where it is occurring in the subsurface soil, and ii this process will reduce contaminants in the soil within an expected time frame. A review of the data collected will be conducted • in two years to determine the progress of the remedy. In the -event that the concentration of 1,2-DCA does not decrease, the contingency remedy consisting of soil vapor extraction technology shall be implemented. Institutional controls will be implemented, i.e., maintaining fencing around property; repair and seal all cracks, seams and other areas where water carrying contaminants might enter the soil; periodic inspections of paved areas to ensure that the seal remains in tact;· a deed restriction to -,.,',.;. '. SBA2-15 SBA:>-13 6J(5.5) ~-;-;: ._,-7 ' ' --:--:;--,-1 · ,. . I , :: <. ND.■ SBA2-14 i ' I I I I I I I I I I I I SBA2-11 l.,i 3.J(O.OJ I I I I SBA2-10 l■I 2Jc1.01 I I I I I I I I I I I I I I I I I I '-I I -'-__ ---SBtA-13 16000(11.5) PARKING LOT SB'i:'6'31 SBlA 24 3.J/751 ~ • SBlA-22 ~=~-o;\sa~tl' \ __ , ",l'c\-"'" !s:s.r:'~i' , ,-SBlA-05 13(7 ) • ND 5J(5.5) SBlA-07 36(9.5) LAGOON 1 SBlA-19 ND SBtA-15 19000(7.5) LAGOON 2 SBlA-01 ■ 65(7.5) ■ SBtA-02 2J(1.5) ■ SBLA-03 23(7.5) SBLA-05 3!(1.5) • • SBlA-09 21(3.5) \ ;;2 no_J ,.~~3/ JO()'.~~i, CONTOUR, .. / LEGEND .·.7. SOIL BORING SHOWlNG 1.2·0CA CONCENTRATION ■· {ppti) AND (DEPTH {n)J OF MAXIMUM CONCENTRATION ----· 0 100 SOILS IMPAcrED BY 1,2·DCA (>100 ppb) APPROXIMATESCALE(ft) 200 300 400 500 ,. _________________________ .. ,_ _______ -'-____ .. 2 \ . • control future land use of the NSCC property. The restriction is to ensure that potable wells are not installed on Site, and potential buyers are made aware of the situation at the Site. Develop and implement a long-term monitoring plan to ensure that natural degradation continues to be effective until the cleanup has been achieved. Outside factors can effect this process, i.e., rain, snow, ice melting and filtering into the soil and carrying contamination into the groundwater; a change in soil chemistry could effect the natural degradation process; a spill of a chemical on Site. Because of these and other possible influences upon the process, it will be necessary to implement a continuing monitoring program of the process to ensure that it is working effectively. • If the selected remedy is working and nanJral degradation is occurring, the Agency will conduct 5 year reviews in accordance with the CERCLA requirements until the cleanup goals specified in the Record of Decision are achieved. The present cost for this remedy is estimated at $246,000 based on a 30-year period. The estimated time for the natural degradation process to accomplish cleanup levels would take over 30 years. !E the natural biodegradation is not effective, THEN the contingency alternative of Soil Vapor Extraction will be implemented. This alternative includes the following activities: • Volatile organic contaminants will be removed from the soil in Area 2 and the lagoon area through a system of numerous extraction wells drilled underneath the buildings, driveways and in ground surface around the lagoons. These wells will pull out the volatile organics in the soil by means of a vacuum. The action is similar to that of a vacuum cleaner. The air that is drawn out of the soil from Area 2 would be initially 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 further treated via vapor-phase activated carbon • adsorption filters. The extracted contaminated air from the lagoon area will be treated by using only vapor-phase activated carbon adsorption filters to remove the volatile organics prior to the air stream being released into the atmosphere. The carbon filters containing the contaminants captured by the vapor-phase carbon adsorption process will be destroyed through thermal regeneration of the used activated carbon at an off-site, commercial regeneration facility. • A review/assessment will be performed to verify that the soil vapor extraction system is operating as designed and is accomplishing reduction of contaminants to meet specific cleanup goals stipulated in the Record of Decision. The present cost for the contingency remedy of Soil Vapor Extraction is estimatdd at $5,281,000 based en a ?-year clean up period. FOR MORE INFORMATION ABOUT THIS REMEDY OR THE SITE, please contact: Jon Bornholm, Project Manger North Superfund Remedial Branch U.S.E.P.A., Region 4 345 Courtland Street, NE Atlanta, GA 30365 Phone: 1-800-435-9233 ext.4106 Citizens are encouraged to visit the information repository which houses all of the technical documents to find out more about this process and future activities. The repository is located in the: ~ rc ;i Rowan County Public Library 201 West Fisher Street A Salisbury, NC 28144 A > Phone: (704) 633-5578 ' -' - i( /, -,n ~ ~) ·• -If you know of someone that would like to be added to the NSCC Site mailing list or you need to change an address or delete a name from the list, please complete this form and mail to: i ,. Diane Barrett, Community Relations Coard. North Supert_und Remedial Branch U.S.E.PA, Region 4 345 Courtland Street, NE Atlanta, GA 30365 Phone: 1-800-435-9233 ext. 4111 ADDITION __ _ CHANGE OF ADDRESS ---DELETION __ _ J • ft U.S. Environmental Protection Agency ~,.-1345 Counland Street, N.E. ~ Atlar•a, Georgia 30365 Region 4 Official Business Penalty for Private Use $300 :-SI F NSCCO'i°53 I MR. WILLIAM MEYER, DIRECTOR : SOLID i,ASTE MANAGEMENT DIVISION 1 NC DEPT. OF ENVIRONMENT, HEALTH l & NATURAL RESOURCES I p. o. BOX 27687 I RALEIGH NC 27611-7687 I ) Ill lt11 t .. 1,11, .. t :it,,,, ,11,, ,Ill, .,t,11 .. 1 .. 1,1, "II, ,1,1 .. ,111 .. ,I ,, ·- National Starch talks olanned EPA plans to enter into neAions with . National Starch & Chemical c!!!r.-the only PRP -in October for groundwater cleanup of the National Starch & Chemical Corp. NPL site in Salisbury, N.C. In two years soil vapor extraction may also be required. A September 1993 ROD calls for pump-and- treatment with air-stripping and carbon filtering at operable unit 3 (OU-3). Treated water will then be discharged to a local sewage system. About 130 million gallons of groundwater in the shallow and bedrock aquifers are contaminated with 1,2-dichloroethane and acetone (Supe,fund Week, 71 9/93). Projected cost for the system is $8.2 million, most of which will be required for 30 years of operation and maintenance. The talks will also concern OU-3 and some 230,000 cubic yards of soil contaminated with 1,2- dichloroethane. A contingency ROD is scheduled for signature in September which will call for natural degradation of contaminants and monitoring. However. EPA says that if, after two years -the half-life of I .2-dichloroethane -the PRP cannot demonstrate significant progress of natural degradation, the agency will require the company to install a soil vapor extraction system. 8 The company is already paying groundwater cleanup in OU-I, which consisted of installing an air-stripping system to treat another contaminated plume. No action was chosen for ou.:2. Contacc Jon Bornlwlm. EPA project manager, 800-435-9233 or 404-347-7791; Ray Paradowski, National Starch & Chemical Corp. plant manager, 704-633-1731. EPA seeks oversight contractor EPA needs a regional oversight contractor for its Zone l National Program for Federal Facilities enforcement. The contract will be used to support the agency's oversight and enforcement of Superfund and RCRA activities in Regions 1, 2 and 3. Bidders must provide site-specific project management: help plan and monitor response actions at federal facilities; evaluate RCRA compliance of facilities and review pre-NPL preliminary assessments and site inspections. They must also prepare full Hazardous Ranking System documentation packages; oversee federal facility investigation and response activities; help monitor Rl/FS activities; provide technical review of design plans and selected remedies and provide technical support for negotiations. litigation/expert witnesses, community relations and sampling and analysis. Security clearances may also be required, said the Aug. 17 Commerce Business Daily. Contact: Charles Cavanaugh, 202-260-8526. Superfund Wuk-August 19, 1994 manufacturers and environmentalists over cleanup standards. · The EIRF plan wo,.low PRPs to recover from 20% to 60% of their cleanup expenses l.i, .. , an insurer-financed settlement fund, if the PRPs agreed not to file claims against their insurers .. Samuels said the new insurance proposal would split the burden of establishing the fund to 50% relrospective and 50% prospective over the JO-year life of the fund. "It's supponed by a significant segment of the insurance industry," including American International Group and Lloyds of London, he said. Samuels said that, besides the financing fonnula, a new wrinkle in the compromise is that the prospective fees will not apply to the first $5 million in annual premiums for each company. The original plan exempted the first $50 million from both the relrospective fees and prospective assessments for each company. The $50 million carve-out for relrospective fees is retained, he said. The new proposal also clarifies that the exemption amounts would apply to all "related" insurance companies. For instance, Lloyds of London would be able to exempt $50 million of its annual premium amounts from I 968 through I 985, rather than claiming $50 million exemptions for each of its subsidiaries. States' say in federal cleanups debated The administration has won new compromise language on state authority over federal facilities cleanups at state-delegated sites in the House's Superfund reauthorization bill. The compromise would hold the governor of each state directly accountable for remedy selection at state-delegated sites, instead of faceless state regulatory agencies. The reauthorization bill would give states remedy decisionmaking at sites EPA chooses to delegate to the states. It would blunt provisions in current CERCLA law under which EPA has the final say over remedies selection at all federal facilities. For this reason, some senators are wonied the adminislration- backed language gives states too much power and are pushing for more restrictive language in the Senate version of the bill. They want to strike existing Senate language calling for indepen-dent arbitrators to resolve state-federal disputes over remedy selection at federal facilities. Given too little authority, states can stall cleanups they don't like, but given too much they can break the federal bank. Either way, a change in state authority could radically alter the course of the federal facilities cleanup program. The issue is how to resolve remedy selection disputes at federal facilities where EPA delegates regulatory authority to states. Under existing law, EPA can let states take the lead at a site, but can't actually delegate regulatory authority, the way it does in its compliance pro-grams. But the extent to which states get con1rol over federal sites depends on the extent to which EPA delegates the sites to the states in the first place. The Senate bill (S. 1834), as amended by the Environment and Public Works Committee on Aug. 3, would allow an independent arbilrator to resolve disputes involving federal facilities undergoing state-controlled Superfund cleanups. However, sources said Senate Environment leaders realized -at the time the committee approved the bill -that such a concept would be unacceptable to the Defense and Energy departments, and they intended to revise the language on the Senate floor. The compromise proposal recently insened in the new House bill, H.R. 4916, was developed by DOD and DOE, state organizations and congressional staffers. Pasha Publicatioru, 1616 N. Fort Myer Drive, Suite 1000, Arlington, Va. 22209 u.&v1RONMENTAL PROTECTION ANcv REGION IV, ATLANTA, GEORGIA ANNOUNCES A 30-DAY EXTENSION TO THE PUBLIC COMMENT PERIOD ON THE NATIONAL STARCH & CHEMICAL CORP. SUPERFUND SITE PROPOSED PLAN FOR OPERABLE UNIT #4 • SOIL REMEDIATION The purpose of this notice is to inform citizens that the public comment period for Operable Unit #4 for the National Starch & Chemical Corporation Superfung Site in Salisbury has been extended. The Agency has received a request that the comment period be extended an additional 30 days. In response to that request, the original 30-day comment period ending on August 11th has been extended an additional 30 days to midnight September 9, 1994. Please submit all written comments to: Diane Barrett, Community Relations Coordinator North Superfund Remedial Branch Waste Management Division 345 Courtland Street, NE Atlanta, GA. 30365 A copy of all documents that have been prepared from the beginning of the Superfund process for the Site are available in the information repository located at: Rowan County Public Library 210 West Fisher Street Salisbury, North Carolina An" Announcement" of this action has been mailed to the public. For more information about this action or the Site, please contact either Jon Bornholm, the Remedial Project Manager, or Diane Barrett at the address provided above or call 1-800-435-9233. Th is notice will appear as a display ad in the Salisbury Post on August 11, 1994. This copy is being mailed to citizens on the Site's mailing list in an effort to keep the public informed of activities involving the Site. 'ii • U.S. Environmental Prote<:tion Agency 345 Courtland Street, ~.E. Atlanta, Georgia 30365 Official Business Penalty tor Priva1e Use $300 North Suporfund Remedial Branch Oiao Barrett, Comm.mity Relations Coordinator Jon Bomholm, RemediAI Project Manager • , " Region 4 • SUPERF.UNO· PROPteD PLAN FACT SHEET OPERABLE UNIT #4 •• SOIL REMEDIATION IN PLANT OPERATIONS AND TREATMENT LAGOON AREAS NATIONAL STARCH & CHEMICAL COMPANY July 1994 Salisbury, Rowan County, North Carolina Terms In bold fief print 118 dlltllllld In I glossary loclt9d It 11111 end of Ws publlcltlon. TIiis fact IIMllt Is not ID I» cons/dnd I technlcal docum6nt but his 1»1111 prepared ID provide I l»ttar undenlandln(I IO lht pub/le. INTRODUCT10N This Proposed Plan summarizes the June 20, 1994 Operable Unit #4 (OU #4) Feasibility Study and Identifies the preferred cleanup option for addressing the contaminated soil associated with Area 2 and the wastewater treatment lagoon area at the National Starch & Chemical Company (NSCC) Supertund Site in Salisbury, Nor1h Carolina. The tenn 'Operable Unir is used when individual actions are taken as a part of an overall site cleanup. A number of operable units can be used in the COtSSe of a site cleanup. This Fourth Operabie Unit is anticipated ID be the last Operable Unit for the NSCC site. The Proposed Plan Fact Sheet for Operable Unit #3 (OU #3), which addressed the contaminated groundwater underlying these same areas of the NSCC property, was distnbuted to the public in July 1993. The Environmen1al Protection Agercf (EPA), lead ~rr.y for Site · activities, prepared this Proposed Plan with the assistance of the Nor1h caronna Department of Environment. HealU1 and Natural Resources (NCDEHNR), the support agency. the data and infonnation presented in the Remacllll lnvestlgatlOn for OU #3 also supported the OU #4 FeaslblUty Study. EPA, in consultation with NCDEHNR, wiU select a ram9!!Y lof OU_#f,only after the,, public co.mrn~ period ends .and an ~il!Qd teJaPA , during this time has been re~,and consid!l@<li,,*, · , .., . , ... •); . ___ . . . EPA is issuing this Proposed Plan as part of its public participation responsibilities in accoidance with Section 117(a) of the Comprehensive Environments! P •~ LJISA, Canpensatlon, and UabHity Act (CERCLA).-also known as Superlund. Tlis Proposed Plan Fact Sheet Sllllmarizes i'lformation presented in the June 1993 OU #3 Piemedial Investigation Report, which includes the Baseline Risk Asses8ment, and the June 20, 1994 OU #4 Feasibitity Studydocr.rnent, and other documents contained in the lnfOmlatlon Reposlltiy/Admlnlstratlve Record for this Site. EPA and the State 8llCO\lag8 the pubic to review these documents to better llldersland the Site and the Supelfund activities conducted. The AdmiristralM! RecOld Is avaiabie for public review localy at the Rowan Pubic Library at 201 West Fisher Street, Salisbury, Nor1h Carolina. EPA, in consultation with NCDEHNR, may moclly the preferred alternative or select another response action presented in tlis Plan and the Remedial lnwstigation and the Feasibility Study Reports based on new Information and'or public comments~. Therefore, the public Is encotraged ID review and comment on al alternatives . discuSStid below. Tnis mposeci Flan: . . . ... 1. Includes a brief backgrotrrd of the Site and the principal findings of OU #3 Site Ptemedial Investigation and the recent hydrophobic dye tes~ 2. Presents the remedial (cleanup) alterna!M!s for OU #4. consi~ ~y EPA; . 3. Outlines the evaluation criilria 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 opporlllities for the pubic ID comment on the remedial alternatives and become Involved in the process. PROPOSED PLAN PUBLIC MEETING: DATE: July 26, 1994 LOCATION: Agricultural Extension Cenlllr XrrT Old Concord Road Salisbury, North carouna _ TIME: 7:00 PM • 9:00 PM PUBLIC COlrlrllENT PERIOD: July 12, 1994 • August 11, 1994 SITE BACKGROUND • The NSCC faci6ty occupies approximately 465 acres on Cedar Springs Road five miles south of the City or Salisbury, North Carolina (refer to Figure 1). Presently, land use immediately adjacent to the Site Is a mix1ure of residential and industrial developments. East and south of the Site are industrial parks consisting primarily of light industrial operations. The west and north sides of the NSCC property are bordered by residential developments. Refer to the Figure 2 for Site location. A · surface stream on the NSCC property, referred to as the Northeast Tributary, flows parallel to Cedar Springs Road and passes within 50 yards of lhe manufacturing area of lhe tacinty (re/er to Figure 2). Surface water runoff from the eastern side of lhe facility discharges into this lribulaly. The primary objective of Operable Units #3 and #4 was to delemline lhe source, nature, and extent of the contamination being continuously detected in this stream on the NSCC property. Primarily, NSCC marufactures textile-finishing chemicals and custom specialty chemicals. Volatfle and aeml•Yolatfle organic chemicals are used in lhe production process along with acidic and alkaline solutions. Acidic and alkaline solutions are also used in lhe cleaning processes. The waste stream from the manufacturing process inciudes wash and rinse solutions. Operable Units #3 and #4 focus on the areas of the facility referred to as Area 2 and the wastewater treabnent lagoons (refer to Fi{lllfB . 3). Arn~ 2 ennsis!!: of Im foPn>ving opem~on~: Arr<a 2 Reactor Room, lhe Tank Room, Raw Material Bulk Storage, and lhe Warehouse. The lagoon area inciudes three lagoons. A fourth lagoon was installed in 1992 as part of the traabnent system built to treal lhe contaminated groundwater being extracted from lhe aq\llfef as part of lhe Operable Unit #1 (OU #1) Remedial Action. As in Operable Units #1, #2, and #3, the work performed for OU #4 was financed by NSCC, lhe Potantfally Responslble Party. The NSCC site was proposed for Inclusion on the National Pr1Dlltfes List in April 1985 and finaized on the 6st In~ 1989, The Site had a Hazanlous Ranldng System score of 46.51. Only Sites with a Hazardous Rankilg System score of 28.5 or hipr are eligible to be placed on lhe National Priorities Ust. SCOPE AND ROLE OF OPERABLE UlfT WITHIN SITE STRATEGY As with many Superfund sites, the NSCC site is complex. Consequently, EPA divided lhe wol1! into four manageable components calJed Operable Units (OU); they are: OU #1 • Groundwater in lhe westem portion of lhe NSCC property OU #2 • Trench Area soils and surface water/sediments in lhe Northeast Tributary 2 • OU #3 • Grollldwater in Area 2 and Iha waSlewater teabnent lagoon area; SlJ1ace water/sediments In h Northeast Tributary OU #4 • Soils in Area 2 and the wastewater treatment lagoon area. RESULTS OF THE OU '3 REMEDIAL INVESllGAllON USED FOR OU "' FEASIBILITY STUDY As reported in previous Fact Sheets, contaminants have been lollld in the soils, groundwater, and surface water/sediment on the NSCC property. This contamination can be traced back to past chemical hardling and disposal practices ot lhe NSCC faciity. The sources of the contamination were Identified. The types and concentrations of the contaminants have been verified. The extent of contamination in the vadose soil zone has been defined. The vadose zone is comprised of subsurface soil lhal is not saturated with water. The interface between the vadose zone and the sa11.rated zone is commonly referred to as the water table. Fourteen diffeleol volatile organic compounds, one semi-volatile organc compound, and one pesticide wera de'leCled In the vadose soils. The primary SOIJ'ces of contamination in Area 2 were a_ buried, leaking terra-oitta (fired clay) pipeline and a solvent ~very · system. The terra-oitta pipeline transpol1sd iquid waste from Area 2 to the wastewater treabnent lagoons. Replacement of the terra-cotta pipeline with an overhead stainless steel . plpelne was completed in February 1994. Therefore, the terra-<:0tta pipeline .Is ne ~r In use. Sp!!s ~bd ~ ~~ng ths sct't'C~ .. · recovery system have been contained since 1988 when ii concrete containment structure was constructed around the solvent recovery system. Prior to this, material containing 1,2-dicljoroethane was spiDed d!reelly onto the ground. The S0llt8 of the contaminants detected in the wastewater treabnent lagoon area is the soil under and around the lagoons wlich wera contaminated prior ID the lagoons being lined with concralB. . The primary contaminant is 1,24chloroethane which is a chlorinated organic compollld that is typlcaly used as a solvent. · 1,2-Dichloroethan9 wlatiizes iaadify and is dassffled1as a probable human carcinogen. A cartinogen is any sabsllince that can cause or contribute to lhe de'191opment or cancer. Other organic chemicals wera detected. The chemicals of potential concern at the Site are (isted alphabetically}: acetone, bis (2· chloroethyi) ether, bis (2-ethythexyl) phthalale, 2-butanone, cadmium, carbon disulfide, chloroform, chloroethane, delta-BHC, 1.2· dichloroethene, di-n-bulyt phthalate, di-n-<>c\yl phthalale, ethyl benzene, methylene chloride, styrene, tetrachioroelhene, toluene, 1, 1,2-bichloroethane, trichloroelhene, vinyl chloride and total xylene. The following inorganics ~ also detec1Bd: alumnm, antimony, arsenic, barium, beryllium, clYomium, cobalt, copper, cyanide, lead, manganese, me!l:IIY, nickel, selenium, thalium, vanadium, and zinc. The only field work performed to support OU #4 activities in addition to the field investigation conducted as part of OU #3 was a 5"~ili!,;;. Z!l.zieii-i"1!!!"'!!!iseiiie;;;;;i~'eee zse 1se FIGURE 2 GRAPHIC SCALE, 1'•~1!0' / I :;i :i 1. ~ . I~~ ·~·,., ~~)~;: }\:~:~~~: .. '1 · .. ·-.1tg, '.-'~/'.: 'ii,· -~u. --../ ./ ~, ~ at--, ~ m ..... z . 11 t " .. w ~ cc ~ . I! ,.. . ::, 5 C, .c, u. ~ 11 "' 0 "' I I I ( 11 3 \ •' ,. I I ' I I , I I I I I I I , ' \ I I I I I I I I \ ,.0 \ \ I I ,, I " ' ' I I I I I \ \ I ' ' ' \ --, \ ' , T,BtNCH AREA I ' I I I I , , , , I I I I I I I I ' ' I I \ ' _, ' ' I I I ' I I I ' ' I ' ' I ✓ I I , , , ' I I I I I I I I I I I I I I I I I I I I I , I I I I I I I I I I I I I I I , I I I I I \ !if I I•• ':t ... •' PLANT OPERA TIO AREA [] I I ;,,---~----',, , I / I I I I I \ I I I \ I / -....... \ \ SOUTHMARK\ INDU$T~IAL PARK \ \ \ \ \ ' ' 4 I I ___, tJ1 0 ' I I I I I I I I I I I I . I I I I I I I I I \ \ ' ' ------ I ' I I \ \. \ \ \ I I +I,' I I ✓ , I ✓ I I I I FIGURE 3 I I I I I I hydrophobic dye test The hydl~ dye test was co~ to detennine ii 1,2-dichf0108thane existed as a liquid in the subsllface soils at the Site. 1,2-0k:hloroethane belongs to the family of chemicals lhat ff sufficient quantities of 1,2-dichloroethane are present, then the 1,2~thane will consoDdate in the subsurface environment and lonn pools of 1,2-dichloroethane. It was important to detennine ii 1,2-<flehloroelhane existed as a liquid in the subsurface envirorvnent as lhe Agency has found through experiences at olher Superfund sites lhat lhe presence of such a pool of contamination will act as a continuous source of contamination for many, many years. Consequentiy, lhe presence of such a pool of contamination would control Iha success or failure of lhe Site's cleanup as well as the cost of lhe cleanup. Once in lhe , subsurface, It is difficult if not impossible, to recover all of lhe trapped pooled contaminant from lhe ground. In a hydrophobic dye test. a soil or groundwater sample is mixed in a glass container lhat contains a solution of water and a dye lhat will attach ltseff to 1,2-dichioroethane. II no dye is found clinging to lhe sides of the glass container, lhen 1,2-dichloroethane does not exist as a free liquid In lhe sample tested. To insure lhe most useful lnlonnation was obtained, lhe six soH samples used in lhe hydrophobic dye test were collected from lhe area of lhe Site containing lhe highest soil concen1rations ol 1,2.<fichloroelhane. The results of lhe hydrophobic dye test (September 1993) on lhese six samples Indicate lhat 1,2.<fichloroelhane does not exist as a free liquid In lhe soils at the Site. .. ·-':';-~.,._-:;. -.... ,.._ . .:...,.~•-·-'"'--~''······. ·.,:i.··· .:: Replacement of tho terra-<:0tta pipeline wilh an overhead stainless . steel pipeline eliminated lhe release of 1,2-dichl0108thane to lhe .. soiis benealh Area 2 and; ultimately, to lhe undertying groundwater. The concrete flooring of lhe building o.e., lhe foundation) and lhe asphalt driveway lhat surrounds lhe building ad as an impervious cap. By replacing the leaking terra-<:0tta pipeline with lhe ovemead pipeDne, t.w goals were achieved. First lhe S0llte of contamination was eliminated. Second, water leaking from lhe tena cotta pipe comprised a driving force for the downward migration of 1,2.<fichloroelhane, W1d this driving force was .also eliminated. Therefore, It is not eXP8:d)ld lhat co~i~:pi~#tli~ jhiJ ~ ~ii, , adversely irnpad groundwater. · · All lhe metals Onorganics) detected iii tfe-.~, are' natiialy occurring. The dillerence in concentrations between the background sediment sample and on-site soil samples indicate lhe Site has not released inorganic contaminants Into the environment SUMMARYOFSITER~KS A goal of the Remedial lnvestigatiorVFeasibiilty Study process is to analyze and estimate the human health and envirorvnental problems lhat could result ff lhe contamination Is not cleaned up. This analysis is called a Baseine Risk Assessment. In calculating risks to a population if no remedial action is laken, EPA evaluates lhe reasonable maximum exposure levels under current and potential fub.Jre expos1X8 scenarios to Site contaminants. The risk scenarios evaluated In the Baseline Risk Assessment under current concitions Included trespassers on lhe NSCC Site as well as employees 5 working on ~-. The risk scenarios developed in lhe Baseline Risk Assessment for lubn concitions included a resident iving on the NSCC property and using a well installed in lhe contaminated groundwater as !heir S0\lt8 of potable water o.e., water used for drinking, cooking, bathing, etc.). In conci.lCling this assessment, EPA focuses on the adverse human health effects lhat could resut from long-tenn daily, direct exposure as a resut of ingestion, inhalation, or dennal contad ID ca-cinogeric chemicals (cancer causing) as wea as lhe adverse health effects lhat could result from long-tenn exposure ID non-carcinogenic chemicals present at lhe Site. EPA's goal at Superfund sites is to reduce lhe excess lffetime cancer risk due ID chemicals present at the Site. This means Iha! lhe chance of contracting cancer is between one in ten thousand and one in one million. In the exposure assessment, EPA considered Ingestion of soi, inhalation of soi vapor and/or particulates, and cirect contact as lhe likely exposure palhways for lhe human receptors. EPA concluded lhat under CIIT8nt conditions, the soil contamination associated wilh OU #4 does not pose an IJlaCCeptal:ile amen! risk to human health. There Is no current 111acceptable risk because there is no complete exposure palhway for lhe contaminants ., • reach lhe pubic at large. However, lhree future risk scenartos were . idenjified ~~~~to~ future risks as a resut of being exposea ID the chemical contamination at the Site. The fi'st scenario involves residents living in homes built on or near the Site . and using the contaminated groundwater as !heir source for potable · waler. The key exposure palhway in this scenario is the use ol lhe contaminated groundwater as a polable S0\lt8. . The second scenario lhat could result In anolher unacceptable lubJre risk is lhe expo5118 of a child to lhe surface water, sediment, and spring water. Currentiy, lhe potential for expo5118 1hrough tis palhway is significantly recklC8d because access to lhat portion ol lhe stream where elevated concentrations of contaminants an1 present is . encompassed .IWlhin lhe. fenced area of lhe ~~qc property. The .. thircl, po,!8!1!i1~ptable future risk involves exposilg inci'liduais to contamina11111 subslSface soil. This risk exists for bolh 'M!rkers · on-site as wel as lubn residents llving on-sile and digging into lhe subsurface soili -The womir iisi{s'caQ,)e graady·.~ by providing adequate personal protection. REMEDIAL ACTION OBJECTIVES The main goal of Remeclal Action OlljactlY89 is ID prated human heallh and lhe envirorvnent by preventing exposures to concentrations of contaminants above risk-based tunan heallh or environmental standards. Protecting human health may be achieved by eilher reducing exposure or reducing contaminant levels. Protection of the envirorvnent Includes protection of nallnl resources for lubn uses.· · In Identifying lhe Remedial Action Objectives, lhe findings of lhe Baseline Risk Assessment were used as wel as an examination of all potential federal and Slate environmental Applicable or Relevant and Approprlata Requlnimer,-ARARs). ARARs can be categorizedaschemicaJ.specific,locatioo-spedfic,oraction-specific. Chemical-specific ARARs are acceptable exposue levels 1D particular chemicals and Is lhe fimit lhat must be met for lhat contaminant within an environmental medium (I.e., water, soD, or air) at a specific compliance point Location-specific AAARs address site-specific aspects such as critical habitat upon which endangered species or threatened species depends, lhe presence of a wetiand, or historically significant features. Action-specific requirements are controls or. restrictions for particular activities related to lhe implementation of the proposed remedial alternative. In summary, lhe Remedial Action Objectives for soils In Plea 2 and lhe wastewater treatment lagoon area are: For Human Health: Prevent direct contact with soils having levels resulting in cancer risks above acceptable limits • For Human Health: Prevent release of contaminants from soil lhat could result in contaminant levels in excess of groundwater . cleanup objectives specified In the OU #3 Record of Decision • For Envirorvnental Protection: Continue containment of contamination. The objective of a Superfund Site cleanup Is to reduce lhe contamination to concentrations specified by • ARARs• or lhat is protective of human health. There are no Federal or State ARARs lhat govern lhe cleanup of contaminated soas that are not excavated. The following soi performance standards {cleanup goals) for 1,2-<flch!~roethane were based on (1) direct contact exposure and (2) leaching of 1,2-dichloroelhane lri!o the under1ying groundwater. Risk-based concentrations for 1,2-dichloroelhane were calculated for the following exposure scenarios: a worker exposed to contaminated soil and a future resident exposed to contaminated soil. The concentration protective of a worker is 63 miDigrarns per kilogram and for a Mure resident, 7 milDgrams per kibgiain. 'Based' on lhe data collected, no suiface soils at ttie Site exceeded !lie risk-baSed . value of7miir ', .. ~ plil'ktogram foiTidk;iioioe~'.1 'hieretoie;" igram ' . • . . .. .. surface soils do not pose an unacceptable risk b Iman healtn · · undercurrentorfulureexposurescenarloS: '· ...... ,, .. ,.,., · •· ..... . . . . . .. --~-.. : : '. ~ . ' .. Howewr, subsurface soils llldernealh Area 2 and lhe wastewater treatment lagoon area haw 1,2-dictioroethane concentrations of 1,600 miRigrams per kilogram and 19 m~ligrams per kilogram respectively, both exceeding 7 miDigrams per kilogram. H these soils should be exposed under a Mure residential scenarios (i.e., during digging or cons1rUction), lhey would pose an unaccepta.bfe health risk. The next step in establishing Sile cleanup goals Is ID develop soil cleanup levels ID protect groundwater. EPA detennines what concentration of contaminant can remain in lhe soi wi1hout leaching to groundwater in quantities lhat would be abow a protec1MI lewl for lhe groundwater. The estimated concentration of 1,2· dichloroelhane lhat could be left in the soi without increasing lhe ·6 • concentration of 1,2-dchloroelhane in grotnlwater abow lhe most stringent gl0llldwater quality concentation (NCAC 15-2L0202) for 1,2-dchforoelhane is 169 micro!,ams per kilogram. Based on lhe risk-based value of 7 miligrams per kilogram, lhe estimated volume of soil contaminated abow this concentration Is 35,940 cubic yards. The estimated volume of soil contaminated abow 169 micrograms per kilogram is O'lllf 231,300 cubic yards. SUMMARY OF REMEDIAL ALTERNATIVES The foUowing section summarizes lhe cleanup technologies and alternatives dewloped in lhe OU 14 Feasibiily Sludy document for addressing lhe soil contamination in Area 2 and lhe waSlll'#ater treatment lagoon area. Descriptions of lhe clean-up alternatives are summarized below. The cost Information below represents lhe estimated total present worth of each alternati'III. Total present worth was calculated by combining lhe capital cost plus the present worth of lhe amuaf operating and maintenance costs. Capital cost Includes construction, engineering and design, equipment, and sile development. Operating costs were cafculated for activities lhat continue after completion of construction, such as routine operation and maintenance of treatment equipment, and moritDli~ The present worth of an altematiw Is lhe arnOllll of capi1al ~ t> be deposited at lhe present time at a gi'l9n Interest ra1a ID yield lhe !Dial amo\111 necessary lo pay for iltial construction costs and Mure expenditxes, incklding operation and maintenance and future . rep!a::einent ".If ca!'ira! eq'J!pment. • · •· For more information about lhe Remedial Action Objectiws and altematiws for OU 14, please refer to the J1n120, 1994 Feasibility Study document and other dorunents available In lhe Information repository in lhe Rowan Public Library. REMEDIAL ALTERNATIVES TO ADDRESS SOIL COKTAMNATION'"'' , ... ,; :} " . ·:.,:,:,11·,.' ',·:;_,:[J' ' ' ,. ' , • ' \ , l ,, ,r ~• , " . ,...,, " " The tour alternatives for addressing cornalilinated solls include! ~ t, .,, -' , , 11 ', "'•-ii"~ · ,,, .. AJtemallve S1: No 'Action ..... Altemallve S2: Natural Degradation & lnsllblllonal Conlrols Alternative S3: Sall Vapor Extraction with Fume Incineration and Activated carbon Riter to Control Erisslona Altamatlve 54: Sol Vapor Extraction with Activated carbon Riter to Control Enuslons A description of each alternative follows: ALTERNATIVES1: No~ Capital Costs: Annual Operating & Mainlenance Costs First Year: Second Year: Third Year and Later: · Present Worth Operating & Maintenance Costs: Total Present Worth Costs for 30 Years: nme to Design: Construction nme: . Duration to Achieve Clean-up: $ 0 $16,000 $ 0 '$ 0 $199,000 $199,000 None None Over 30 years CERCLA requires that the 'No Action' alternative be evaluated at every Superfund Site to establish a baseline for comparison. No further activities would be conducted with Site soils under this alternative (i.e., the Site is left 'as Is'). Because this altemative neither removes nor destroys the contamination Q.e., contamination 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 will continue every five years until the dearup goals for the Identified contaminants in the soil ara achieved. If no action is taken migration of contaminants from the soil into the undertying aquifer in the vicinity of the wastewater treabnent lagoon AL TERNATl,S2: NATURAL DEGRADAroN AND /NST/TIJT,a/AL CONTFtJLS Capital Costs: . Annual Operating & Maintenance Costs First Year: Second Year: Third Year and Later: Present Worth Operating & Maintenance Costs: Total Present Worth Costs for 30 Years: nme to Design: Construction nme: Duration to Achieve Clean-up: $196,000 $ 4,000 $ 0 $ 0 $ 50,000 $246,000 3 months 1 month Over 30 years Natural degradation reties 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 2 chemicals at the Site, chloroethane and vinyl chloride, neither of which were used at this NSCC facility, is a strong Indication that t ,2-<lichloroethane is being transfonned via natural degradation process(es). The rate and effectiveness of the natural degradation process is dependent on a number of environmental factors, su:h as nutrient availability, soil moisture content, presence or absence of oxygen in the sol, etc. area win continue. This migration results from the natural movement Using published information, the following degradation rates were of precipitation (e.g., rain and melted snow) moving through the soils estimated: in less than 10 years, the concentration of 1,2-and carrying the contamination downward as the precipitation dichloroethane should decrease to the direct contad heal1h based recharges the aqu:fer. This migration force does not exist in Area 2 risk concentratil\n of 7 miligrams per kilogram; in less than 21 years as this araa is covered with concrete bulking founda~ons and ,,_,,,the .concentration of 1,2-dichloroetharie .E'1ould decrease to 169 -····" asphalt driveways. These S1ructures prohibit precipitation lroni' ., microgiamii" per kilogram, the concentration that can remain in the percolating Into the undertying soils. Therefore, al precipitation soil but not adversely Impact the quality of the undertying becomes surface runoff which is controlled by the slope of the groundwater above the performance standard for 1,2-dichloro-asphalt driveways and the curbs built around the asphalt driveways. ethane; and in approximately 35 years, the concentration of 1,2-Surface runoff is directed into sumps where the water is punped to clchloroethane in the soi should reach a concentration of 1 the wastewater treatment lagoons. Although Allernative S1 does not mlcrogam per kilogram. It estimated that It wil require over 130 aetlvely reduce or eliminate soil contamination, It is anticipated that years of punping the grollldwater, as required by OU #3, to the levels of 1,2-dichloroethane wii decrease over tine due to the remeciale the groundwater to the specified ARAR of 1 microgram process of natural degradation. per 11er. There are no initial capital costs for AltenialNe S1; Arinoal operating costs are based Ori coriductirig.,.peii&i\c ~mimiloni\g of Die soil in order to prepara the five year review every five years for a period of 30 years. As part of the five year review, soi samples win be collected for chemical analyses once every five years in both areas, Area 2 and the wastewater trea1ment lagoon area · 7 Aa part of this altemattve, a blodegradative study v.ill lie ~itducted. Tlil IIUdy will (1) confirm that natural degradation in the soB is oca.ntng and (2) ascertain n biodegradation will reduce the soil COiilamil ation during remedation of OU #3 groundwater to a level Iha! wll not cause an exceedance of the OU #3 groundwater cleln4> goal. In the event that natural degradation is occurring at • 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 addllk,11al contamination should be entering the sols beneath the A/98 2 buiding. Based on the degradation discussion above, a 8lbslanliaJ decrease in the concentration of 1,2-dichloroethane in the soil should be observed over the next several years. In the event that the concentration of 1,2-dichloroethane In the soi does not decrease as anticipated, a contingent remedy consisting of an active soil remeclation tecmology (SI.di as described in Alternative S3 or S4 below) shall be Implemented to achieve the reduction of contaminant levels that would Atectiw of the quaity of the. underlying groundwater. Institutional controls include using ·various controls and deed resb'ictions. The specific institutional controls considered for this alternative are 1) using and main1aining the existing fence around the plant operations area to imit access to the contaminated areas; 2) periodic inspection and maintenance of paved areas around Area 2 to insure the integrity of the cap over this area, and 3) a deed restriction to control future land use of the NSCC property. The deed restriction v.ill contain language to accomplish the follov.ing tour objectives: 1) to inform any potential buyer of the property of the contamination present, 2) restrict future land use which woukl decrease the Hkelihood of human exposure to contaminated soHs, 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 wor11ers. The suitable deed restriction shall be recorded in the appropriate county regis1rar's office. ALTERNATIVE S3: SOIi. VAPOR ExTRACTION WffH FUME INCINERATION AND ACTIVATED CARBON FLTER TO CONTROL EMISSIONS Capital Costs: Annual Operating & Maintenance Costs First Year: Second Year: Third Year and Later: Present Worth Operating & Maintenance Costs: : -Total Present Wortt: C-,sts ror 7 Yeari:: Time to Design: ConS1ruction Time: Duration to Achieve Clean-up: $2,887,000 $ 507,000 $ 416,000 $ 416.000 $2,394,000 $5,?.81,000 9 months 3 month Over 7 years This alternative will remove volatile organic contamiiiants by means of vapor extraction wens installed In the soil abow the water table. A preliminary design for Area 2 suggests a system of 10 horizontal • goals that wiU be stipulated In the Record of Decision. ALTERNATIVE S4: SOl VAPOR ExTRACTION wrTH ACTIVATED CARBON FILTER TO CONTFloL EMISSIONS Capital Costs: Annual Operating & Maintenance Costs First Year: Second Year: Third Year and Later: Present Worth Operating & Maintenance Costs: · Total Present Worth Costs for 7 Years: Time to Design: ConS1ruction Time: Duration ID Achieve Clean-up: · · $2,918,000 $3,353,000 $1,566,000 $ 475.000 $6,270,000 $9,188,000 - 9 months 3 month Over 7 years This alternative is Identical to Alternati\'9 S3 v.ith the exception that the extracted contaminated air from both areas woud be treated using vapor-phase activated carbon adsorption filters to remove the volatile organics prior to the ai' stream being released Into the atmosphere. As before, the contaminants capi.red by the vapor- phase carbon filters wo!Ml be destroyed at an off-site, commercial regeneration facility. CRITERIA FOR EVALUATING REMEDIAL ALTERNATIVES The selection of the preferred cleanup alternative for the NSCC OU #4, as described n this Proposed Plan, Is the resut of a comprehensive SCl8ening and evaluation process. The Feasibiity -Stud)· for Ol.l 1M -\YaS colldacted ID lde~!y and ara\,za the - alternati\'9s considered for addressing contamination in Area 2 and . the wastewater treatment lagoon area. The Feasibiity Study and other documents for the NSCC OU #4 site descri>e, In detail, the alternatives.considered, as wen as the process and criteria EPA used to narrow the list of the polential remedial alternatives ID address the sol contamination In this portion of the NSCC faciity. As stated previously, al of these cloa.ments are available for public ·-review in_ the ~rm~m-~~f~i.~~ ~r.,c ~-e:!0i"o~:~~:;qr~if~::@ cubic feet per minute of contaminated air. The ~mi.nartdesign !Qi: the wastewater treatment lagoon area suggests a system of seven ' ; Alternative ~ : Bio~ ~• ~t're= b' hi' detliled analysis . -vertical extraction wells removing a total of 20 cubic feet per niiriute of contaminated air. The extracted contaminated ai' from Area 2 would be treated using flJne Incineration ID destroy the volatile · organics prior to the air stream being released i1to the atmosphere and the extracted contaminated ai' from the lagoon area would be treated using vapor-phase activated carbon adsorption filters ID remove the volatile organics prior to the air stream being released into the atmosphere. The contaminants capiJr8d by the vapor- phase carbon filters woukl be destroyed through the thermal regeneration of the used activated carbon at an off-site, commercial regeneration facility. Remediation of the soi In Area 2 and the wastewater treatment lagoon area Is expected to be completed within 4 ID 7 years and 1 ID 2 years, respectively. A review/assessment in accordance to CERCLA Section 121 (c) would be performed ID verify that the soil vapor extraclion system Is proceedlng as anticipated or accomplished the specified cleanup . 8 because this alternative does not provide any appreciable improvement in reduction of risk or other performance m8aSll8fllent over either Alternative S3 or 54. _ · '" · · EPA always uses the following nine criteria ID evaluate alternatives Identified in the Feasibiity Suty. The remeciaJ alternative selected for a Superfund site must aclieve the two threshold criteria as well as attain the best balance among the five evakJation aiteria. The nine criteria are as follows: THRESHOLD CRITERIA ' 1. Overall pro1BCtlon of Inman health and the environment The degree to which each alternative eliminates, reduces, or controls threats to pubic health and the environment through treatment, engineering methods or lnstiirtiOnal controls . 2. Cgllance With Ae or Relevant and Approprtate R8Clllrements IARARs): The alternatives are evaluated for compliance with all state and federal environmentll and public health laws and requirements that · apply or are relevant and appropriate to the site conditions. EVALUATING CRITERIA 3. Cost: The benefits of implementing a particular remedial alternative are weighed against the cost of Implementation. Costs Include the capital (up-front) cost of implementing an alternative over the long tenn, and the net present worth of both capital and operation and maintenance costs. 4. lmplernentablllty: EPA considers the technical feasibility (e.g., how difficult the alternative is to construct and operate) and administrative ease (e.g., the amount of coordination with other government agencies that is needed) of a remedy, including the availability of necessary materials and services. 5. Short-term effectiveness: The length of time needed to Implement each alternative Is considered, and EPA assesses the risks that may be posed to workers and nearty residents during construction and Implementation. 6. Long-tenn efl8cllveness: The alternatives are evaluated based on their ability to maintain reliable protection of public health and the envirorment over time once the cleanup goals have been met 7. Reduction of contaminant toxicity, moblllty, and volume: EPA evaluates each alternative based on how It reduces (1) the harmful nature of the contaminants, (2) their ability to move through the environment, and (3) the voil.lll8 or amount of contamination at the site. MODIFYING CRITERIA 8. State acceplanCt: EPA requests state comments on the Remedial Investigation and Feaslbitity Study reports, as well as the Proposed Plan, and must take Into consideration whether the state COl1CUIS with, opposes, or has no comment on EPA's prelarred alternative. 9. comm1111ty accep1ar,Ce: To ensure that the public has an adequate opportunity to provide input, EPA holds a public comment period and considers and responds to all comments received from the community prior to the final selection of a remedial action. EVALUATION OF ALTERNATIVES The following summary profies 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 to provide long-term protection for fiuman heallh and the • environment il COlplCtiOn with the OU #3 remeciaf action. However, Alternatives S2, S3, and S4 wil provide protedlon, more quickly, from exposures to contamilated subsu:iace soils. Of these three alternatives, Alternatives S3 and S4 wil afford the greatest protection to human health as they substantially reduce .the contaminants in the soil wittin 4-7 years of Initiation of the alternatives. Under Al1ematives S1 and S2, contaminant levels are anticipated to decrease as a resut of natural degradation. Alternatives S3 and S4 protect the envionment by remomg contaminants from the soil, thereby eliminating the potential for migration of contaminants to groundwater. In corjJnction with the OU #3 groundwater remedial action, Alternatives S1 and S2, wil also be protective of the environment. This protection stems from the folowinQ factors: 1) al comaminated soils are withil the groundwater plllll8 being remediated by OU #3, 2) the OU #3 remediation wiR prevent the spread of contaminants and remove contaminants from the grounctMlter, and 3) soil contaminants shoud be reduced by natural processes_Ylittin the timeframe required to complete the OU #3 groundwater remediation. Alternative S1 does not provide short term protection for human heallh, however, as discussed previously, the Site does not pose an l.flaCC8ptable risk under the current use scenario. Conplance with ARARI: As long as the sols are left il place (I.e., not excavated), no Federal or Stale ARARs for contaminants In sois are triggered. Alternatives S3 and S4 wil compy Wi1h action-specific and location-specific ARARs which Include opera lions at a hazardous wasts site, disposal of used activated cart,on as solid waste, and air emission controls. Alternative S2 wil comply with the locatiO!Hp!C,'fic t.'lAR relc:l&d to ojleratlons at a hazardous r:aste · site and there are no action-specific ARARs that apply to !tis alternative. . No AAARs were Identified for Alternative S 1 as no action is being taken. lona•tenn Effectiveness and Permanence: Alternatives S3 and S4 wil provide effective and permanent solutions for the contaminated soil. The chemlcals of concem wil be removed from the soi by the sol vapor extraction system and destroyed. Neither. alternative will leave any treainent residuals on Site. The reiability . of both AI\Bmatives S3 and S4 Is high because they rely on proven and applicable technologies and the extent of the contamination is relatively well defiled. The rellabiity of AIIBmative S4 is higher tlan Alternative S3 because of the mainlenance problems associated with the fume incinerator. Alternatives S1 and S2 do not directty remove, trea~ or isolate subsu1ace contaminan1s; therefore, they are comparable in terms of reducing poten1ial residual risks. However, contaminant levels should gradually decrease to levels that would be protective of groundwater quaity due to natural degradation processes. The time required to reach tis concenlration fals well within the OU #3 groundwater remediation timelrame (estimated to be 130 years). Alternative S2 ilvolves long-term Institutional controls to prevent fuue expoS118S to smsurlace soils as well as the use of the contaminated gr0111dwater beneath the NSCC facility. The projected adequacy and reiability of these controls depends on land use, but should be relatively high because the Impacted area Is small, within the plant boimaries, and land use Is not expected to change. Soll monitoring and periodic reviews at five-year intervals wiD be required for all lmle alternatM!s, but the duration of performing such l'8'lillws for ~s 1 and s2 is expected fD be ITIIJCh longer. The long tenn · ss and pennanence of Altermlmls s 1 and S2 are on the rate of degradation and eflectiveness of the OU #3 remedial action. Redll:llon of Toxicity. Mobility or Volume: Both Alternatives S3 and S4 actively reduce the toxicity and mass of con1aminants in the soil. This is accomplished lhrough the removal of the con1aminants from the soil via the soil vapor extraction system foDowed by fume incinerator or the thennal deslruction of con1aminants trapped on the carbon filter. Neither Alternative S 1 nor S2 <fuecUy reduce the toxicity, motimty, or volume of con1aminants through an engineered treatment process, but reduction due to natural processes is expected to occur wel within the time period required for, and in conjlllction with the OU #3 groundwater remediation. Short-term Ellectlveness: There are no short-time risks posed to site WOlkers, the general public, or the envirorvnent associated with either Alternative S1 or s2. There are minimal short-tenn risks associated with Alternative S4 which are primarily ciJe to general safety issues associated with the cons1ruction 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 handfng of hydrochloric acid generated by the scrubber associated with the incinerator. Potential risks could also exist during the operating period, especially won<ers exposure fD fugitive vapors. H EPA'S PREFERRED ALTERNATIVE either the carboldsorption or fume incilerafDr/scrubber systems ma'!unction, rary volatile organic emissions would be controlled and , dmized lhrough properly nstalled monitoring and control processes. Sooace runoff during construction, as for any conSINClion project, would be controlled fD protect nearby surface waters. lmplementablllty: Alternative S1 requ(es no implementation. Alternative S2 will be easy to implement because little ID no construction is 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. Cost: Total present worth costs for the sons alternatives are presented below: Alternative S 1 -No Action: $ 199,000 Alternative S2 -Natural Degradation and Institutional Controls: $ 246,000 Alternative S3 • Soil Vapor Extraction with Fume Incineration and Activated Carbon Filter to Control Emissions: $5,281,000 Alternative S4 -Soil Vapor Extraction with Activated Carbon Filter to Control Emissions: $9,188,000 Alter l;()ncwcting lhll abowi detailed analysis, Ei"" A is proposing the following aJtemati,11 tr, address the con1amin.;ted soil in Area · 2 and the wastewater treatment lagoon area. The EPA preferred soil remediation alternative is: ALTERNATIVE S2: NATURAL DEGRADATION AND INsrmmoNAI. CONl1loLs Based on current information, this alternatM! appears to provide the best balance of trade-offs with respect to the nine cri1eria that EPA uses to evaluate alternatives. EPA be6eves the preferred alternative wiD satisfy the staMory requrement of Section 121(b) of CERCL.A, 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 pennanent solutions and treatments to the maximum extent practicable. The selection of the above alternative is preliminary and could change in response to public comments. As this alternative reies on naturai degradation to dean the soils, NSCC wii be required to substlntiate that natural degradation Is occurring, identify wher8 In the subsurface the degradation is occurring, and detennine the rate of degradation. The collection of this data via the biodegradative study will begin after Record of Decision for OU #4 is signed. In the event that the biodegradallve study data cannot substantiate the occurrence of natural degradation a contingency remedy, such as Alternative S3 or S4, wil be inplemented. It is anticipated that this decision will be made within two years of the signing of the OU#4 Record of Decision. 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. NSCC will record, in the appropriate county registrar's office, a deed reS1riction in which NSCC, and any subsequent owner of the Site, would be prohibited from utifizing the groundwater for drinking water purposes until such time as the con1aminated plume meets drinking water standards. NSCC wiD also develop a plan that wiD protect any YtOl1\er in the event that the comaminated soils need to be dug into prior fD the levels of 1,2-<lichloroelhane reach the appropriate direct contact health based risk concentration. Maintaining the fence will reduce the ikelihood of trespassers gaining access to the con1aminated areas, and repairing cracks in the paved area will help prevent 1,2-dichloroelhane from leaching from the sons into the underlvim omundwater. 10 • • COMMUNITY PARTICIPATION EPA has developed a community relations program as mandated by Congress under Superfund to respond to citizen's concerns and needs for information, and ID enable residents and public officials to participate in the decision-making process. Public involvement activities undertaken at Supertund sites consist of interviews with local residents and elected officials, a community relations plan for each site, fact sheets, availability sessions, public meetings, public comment periods, newspaper advertisements, site visits, and TectV1ical Assistance Grants, and any other actions needed ID keep the community informed and involved. EPA is conducting a 30-day public conmant pe,locl from July 12, 1994 to August 11, 1994, to provide an opportunity for public Involvement in selecting the final cleanup melhod for this Site. Public input on all alternatives, and on the Information that supports the alternatives is an important contribution to the remedy selection process. During lhls comment period, the public Is Invited to attend a publlc meeting on August 3, 1993, at the Agricultural Extension Center Audltorf1111, 1m Old Concord Road, Slllsbury, Na!1h Csrollna beginning at 7:00 p.m. at which EPA wiU present the f'.emedial Investigation/ Feasibility Study and Proposed Plan describing the preferred alternative for lrearnent of the contaminated sou at the NSCC Superlund Site and to answer any questions Because tl>is Proposed Plan Fact Sheet provides only a summary description of the cleanup alternatives being considered, the public is encouraged ID consul the Information repository for a more detailed explanation. During this 30-day comment period, the public is invited ID review all site-related documentshoused at the Information repository located at the Rowan County Pubic Library, 201 West Fisher Stree~ Salisbury, Nonh Carolina and offer comments ID EPA either orally at 1118 public meeting or in written form during this time period. The actual remedial action could be different from the preferred al1Bmative, depending upon new information or statements EPA may receive as a result of public comments. tt you prefer ID submit written comments, please mail them posrnarked no later than midnight August 11, 1994 to: NC Conuoonlty RBlatlons Coordinator U.S.£P.A., Region 4 Nonh Rllmlldl,/~ Branch .,. 345 Couttland Stree~ NE Atlanta, GA 30365 All comments wiH be reviewed and a response prepared in making the final determination of the most appropriate alternative for · deanup.,1raarnent of the Site. EPA's final choice of a remedy will be issued in a Record of Decision (ROD). A document called a Responsiveness SWnmary summarizing EPA's response to all public comments will also be issued with the ROD. Once the ROD is signed by lhe Regional Administratcr It will become part of the Administrative f'.ecord (located at the Library) which contains al documents used by EPA in making a final determination of the best cleanup/lrearnent for the Site. Once the ROO has been approved, EPA wil begil negotiations with the Potenllally Responsible Parties to allow them lhe opportunity to design, inplement and absorb all costs of the remedy determined In lhe ROD In accordance with EPA guidance and protocol. tt negotiations do not result In a setUement, EPA may conduct lhe remedial activity using Superfund Trust mOlies, and sue for reimbursement of its costs with the assiSlanee of the Departnent of Justice. Or EPA may issue a unilateral administrative order or directiy file suit to force NSCC to conduct 1118 remedial activity. Once an agreement has been reached, the design of 1118 selected remedy wiD be developed and implementation of lhe remedy can begin. The preceding actions are lhe standard procedures utilized during 1118 Superfund process. 11 -. ' • As part of 1he Superfund progrfflPA provides affecied communities by a Superfund site with 1he oppom.rity to apply for a Teclncal Assistance Grant (TAG}. This grant of up to $50,000 enables the group to hire a teclvlical advisor or cor1Sldtanl to assist them In lnterpretilg or commenting on site findings and proposed remedial action plans. For more information concerning this grant program, please contact: II& Ros#nary Patton, Coard1Mlor NC Technical Asslstanc, GtllllS Waste Management DMslon U.S.E.P.A., Region 4 345 Courtland StrNt, NE Atlanta, GA 30365 (404) 347.2234 INFORMATION REPOSITORY LOCATION: Rowan County PubOc Ubraly 201 West Fisher Street Salisbury, North C&rollna 28144 Phone: (704) 633-5578 Hours: Monday • fl1day 8:00 Lm. • 9:00 p.m. Satunlay 9:00 Lffl. • 5:00 p.m. FOR MORE INFORMATION ABOllT SITE ACTMT1ES, PLEASE CONTACT: Mr. Jon Bormolm, Remedial Project Manager or Ms. Diane 8all'8tt, NC Colllnlr1lly Ralatlons Coanllnatar North Superfund Remedl.11 Brandl Wast8 Management Division U.S. Envlronmental Pratactlon Agency, Region IV 345 Courtland Street, NE Atlanta, Ga 30365 Toll Free No.: 1-800-435-9233 MAILING UST ADDITIONS If you are not already on our maiing 1st and woijd like to be placed on the 1st to receive future information on 1he Natlonal Starch & Chemical ~ SUperfund Site, please complete tlis fonn and return to Diane Barrett, Community Relations Coordinator at the above address: NAME: _____________________________ _ ADDRESS: ____________________________ _ CITY, STATE,ZIPCODE: ------------------------- PHONE NUMBER: __________________________ _ 12 · GLOSSARY OF TERMS .IN THIS FACT SHEET • Aquifer: AA underground geological formation, or group of fonnations, containing usable amounts of groundwater that can supply wens and springs. AdMnls1Tatlve Ricord: A life which is maintained and contains all infonnation used by the lead agency to make its decision on the selection of a method to be utilized to clean up/treat contamination at a Superfund site. This file is held in the infonnation repository for public review; Applicable or Relevant BIid ApproptfBIB Requll'llmllnts (ARARs): The federal and state requirements that a selected remedy must attain. These requirements may vary among sites and various alternatives. Baseline Risk Assessment: A means of estimating the amount of damage a Superfund site could cause to human heath and the environment. Objectives of a risk assessment are to: help detennine the need for action; help detennine the levels of chemicals that can remain on the site after cleanup and still protect health and the environment; and provide a basis for comparing different cleanup methods. Can:lnor,1111: My substance that can cause or contribute to the production of cancer; cancer-producing. Com,irehBns/VB EnvtrontntllltBI Responss, Colrf»nsa1/on BIid LJab/1/ty Act (CERCLA): A federal law passed in 1980 and modified 111986 by the Superfund Amendments and Reauthorization Act (SARA). The Acts created a special tax paid by producers of various chemicals and oU products that goes into a Trust Fund, commonly known as Superfund. These Acts give EPA the authority to investigate and clean up abandoned or unconuolled hazardous waste sites utilizing money from the Superfund Trust or by taking legal action to forte parties responsible for the contamination to pay for and clean up the site. Feasibility Study: Refer to Remedial lnvestigatiorvFeasibifity Study. GroundWBter: Water found beneath the earth's surface that fiDs pores between materials such as sand, soil, or gravel (usually in aquifers) which is often used for sUW!ying weDs and-springs. Because groundwater is a major source of drinking water there Is growing concern over areas where agricultural arvi industrial pollutarns or s,Jbstar.ces are getting into groundm1ter. HBZBrdous Ranking Sysl8m (HRS}: The principle scraening tool used by EPA to evaluate risks to public health and the environment associated with hazardous waste sites. The HRS calculates a score based on the potential of hazardous substances spreading from the site through the air, surface water, or groundwater and on other fae10rs such as nearby population. This score is the primary factor 11 deciding if the site should be on the Nalionai Priorities List and, if so, what ranking It should have compared to other sites on the lisl lntormatlon Repos/lDly: A file conlainlng 8CQ.1'818 up-to-<late infonnation, technical repons, reference documents, infonnation about hi Te<:lv1ical,AssiS!ane&&anl;andt111yother materials pertinent to the site. This ~le.!~)/~Y lo<:ated in a l)!/lllic .•. __ bt.ilding such as a llllrary, city hall-or school;'1hat Is accessible for local residents. · · National Polllllanf Dfschatge Ellmlllflon s,llwn (NPDES): A provision of the Clean Water Act which prohibi1s the discharge of pollutants into waters of the linked Slates unless a special pennit is issued by EPA, a state or (whe!e delegated) a b'ibal government on an Indian reservation allowing a comrolled discharge of liquid after it has undergone treatment. National Prtottti.s List (NP!.): EPA's 1st of the most serious uncontrolled 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. The 1st is based primarily on the score a site receives from the Hazard Ranking System (HRS). EPA is required to update the NPL at least once a year. -Operable Unit: Tenn for each of a number of separate activities undertaken as part of an overall Superfund site cleanup. PtifBll1/Bl}y Responslb/6 Parties (PRP): Any Individual or company -including owners, operators, transpor1ers, or generators -__ potentialy responsible for, or contributing to, the conlamination 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. 13 ' , • Remedial Action OlpCIIAse are Sl)eCific ~s which are identified ID protect both lunar! heal1h ard the envirorvnent that take Into C011Sideralion the environmental media contaminated Q.e., groundwater, soil, SLfface water, sedinent, or air) ard the contaminants present In each medium. The main goal of the objectives Is ID prevent expoSl.18 to contaminants in groundwater, soil, surtace water, sediment, or air in excess of risk-based human health or environmental standards. Remedial lnvesttgallon/Fflaslb//lty Study (RIIFS): The Remedial lnvestig,~tion is an in-depth, extensive sampling ard analytical study to gather data necessary to determine the nature ard extent of contamination at a Superfund site; to establish criteria for deaning up the she; a description ard analysis of the potential deanup allernatives for remedial actions; ard support the technical and cost analyses of the alternatives. The Feasibility study also usually recommends selection of a cost-efl8ctive alternative. Record at D9clslon (ROD): A public doaJment that announces and explains which method has been selected by the Agency to be used at a Superfund site to dean up the contamination. RespanslvBneSll SU/lfflBry: A summary of oral and written public comments received by EPA during a public comment period and EPA's responses ID those comments. The responsiveness summary is a key p._'111 of the Record of Decision. Sem/-Vo/aU/e Orr,anlc Compounds (SVOCs): Carbon-<:antaining chemical compounds Iha~ at a relatively low temperature, fluctuate between a vapor stale (a gas) ard a liquid state. VadOSf Soll Zone: Is the unsaturated zone of soi starting at the surtace and ending at the water table Q.e,, lhe space between the soil partides contains both waler and air). Vo/aU/e Orr,anlc Coff¥,Ounds (VOCSJ: Any organic compound that evaporates readily Into the air at room lemperature. Water Table: The level below which the soil or rock Is saturated with water, sometimes referred to as the upper surface of the saturated zone. The level of groundwater. · 14 ,,,,,' • • U.S. Envin>n .. ntal Pi"1octlon Agency 345 Courtland ~ ~.E. AUanta, Georgia 30365 Official Busin111 Penally lor Privllt Uee $300 I t~ .. E•:"·~~,: ':·:·~:iD ,, '\-· .· ILJf"l• z· -<GQ,1 o..; :__ l.Jv t I \ !3U?f-fl~:_.'1;•.i:_'__·~--~~~-=~?.i~--: t------- S/F NSCCOGll MR. SRUCE NlCriULSOi✓ ENVI:iUNM~r:TAL c~iG~., SUPi~Fu~0 SEClIJN N. C. OEP1-. U~ ~i~VlRU~JMENT, ~i~~Lf~i ~ NATU~AL ~ESOU~C~S P. u. ilOX c.7667 IK ~ 7 6 1 l -7 b 0 7 I,, I, II,,, I, 11, 11,, 11,,, 111,,, I, 11,, I,, I, I,,, 11,, I, I,,, Ii I,,, I .. Region 4 RECORD OF,ECISION FACT SHEET NATIONAL STARCH & CHEMICAL COMPANY s,~lisbury, Rowan County, _North Carolina INTRODUCTION On October 7, 1993, the Acting Regional Administrator of the Region IV U.S. Environmental Protection Agency (EPA) signed the Record of Decision (ROD) selecting the remedial actions to be implemented for Operable Unit #3 to treat the contaminated groundwater and surface water/sediment at specific areas at the National Starch & Chemical Company facility in Salisbury. [See Figure 1 for exact locations.] The North Carolina Department of Environment, Health & Natural Resources concurred with the selection. Comments received from the citizens during the public meeting and comment period, and all technical data developed during the Remedial Investigation/ Feasibility Study were used to make the selection. The alternatives selected are those presented on page 12 of the July 1993 Propcsed Plan fact sheet. The groundwater will be extracted and treated on-site with the treated water being discharged into the local publicly owned treatment works system. The selected remedy for Operable Unit #3 includes the following alternatives: GWP3/GWL3, GWP4NGWL4A for groundwater in the plant and lagoon areas and SW/SE-2 for the surface water/sediment in the Northeast Tributary. As there are no current unacceptable risks pcsed by the Site, this remedy addresses the future unacceptable risks pcsed by the Site to human health and the environment. Some of the contaminants of concern in the groundwater and soil/sediment that could pcse the future unacceptable risk that will be treated are: volatile organic compounds: 1, 1,2-Trichloroethane, 1, 1- Dichloroethene, 1,2-Dichloroethane, 1,2-Dichloropropane, bis(2- chloroethyl)ether, bromodichloromethane, vinyl chloride seml-volaHle organic compounds: bis(2-ethylhexyl)phthalate Inorganic compounds: antimony, arsenic, beryllium GROUNDWATER AltemaHve GWP3/GWL3 requires long-term monitoring of the contaminated groundwater and the implementation of a deed restriction on the National Starch & Chemical Company property as an institutional control to prevent the installation of pctable wells on their property. Alternative GWP4NGWL4A requires the installation of groundwater extraction wells and treatment systems downgradient of the "Plant" area and the wastewater treatment lagoon area. The groundwater will be extracted through wells and treated by air stripping to remove the volatile organics from the groundwater. Control of the air emissions from the air • "'-!• CAPTUP.£ ZONE IN. THE SAPROLITE D 1-,-------1 CAPTURE ZONE IN, THE SAPROL!TE October 1993 ! T • ..,._1, EXISTING UQN!TORINC '//£LL ~ SAPRCl.11( [>IR,.CIION W(LL Ell B(OROCK [XTRACfl()U W(LL GROUt.OWM(R HOW PATH .<PPROXll.l,lf[ [Xi[i.T CF CRQuNQWll(R CONIAl.'INATION Al If<( PL,V,ll _.RE,\ ,CAPTURE ZONE IN TK! BEDROCk AIR TO ATMOSPHERE strl'pper will be accomplished through vapor-phase carbon adsorption filters. Following treatment, treated groundwater will be combined with the groundwater from Operable Unit #1 for discharge to the Salisbury publicly · owned treatment works. Figure 2 provides a schematic of the remedy. ACTIVATED CARBON SPENT CARBON TO REGENERATION OR DISPOSAL Below are more specific details about the selected remedy: It is projected that a total of CONTAMINATED GROUNOWA TER EXTRACTION WELL SYSTEM STOfV,GE AND TRANSFER FIGURE 2 EXISTING UI PERMlffiO OUTFALL TRE.A.TED. WATER TO POTW ten (10) extraction wells will be necessary to capture the entire plume of contamination in the groundwater. These ALTERNATIVES GWP4A AND GWL!iA: AIR STRIPPING WITH EMISSION CONTROL BLOCK FLOW DIAGRAM extraction wells are anticipated to be arranged as follows: 2 in the saprolite (upper 20ne of the aquifer) and 2 in the bedrock downgradient of the active "Plant" area and 3 in the saprolite and 3 in the bedrock downgradient of the wastewater treatment lagoon area. Figure 1 provides the general location of the extraction wells downgradient of the "Plant" area and the wastewater treatment lagoon area. It is estimated that the extraction wells downgradient of the "Plant" will have a combined flow of 25 gallons per minute and the extraction wells downgradient of the wastewater treatment lagoon area will have a combined flow of 30 gallons per minute. These flow rates will accomplish the removal of the contamination from the aquifer as well as prevent further migration of the plume. It has been estimated that the volume of groundwater adversely impacted in these areas of the Site is 131 million gallons. The actual number, placement, depth, and pumping rate for each extraction well will be detern,ined in the Remedial Design phase. Extracted groundwater will flow into an equalization tank which will ensure that a constant flow of water moves into the air stripper for removal ol volatile organic compounds. The air stripper will be designed to achieve the pretreatment requirements which are to be determined by the City of Salisbury publicly owned treatment works (POTW) (i.e., the City's sewer system). It is anticipated that the air stripping tower will be cylindrical, approximately 2-3 feet in diameter and 28-31 feet in height. Contaminated water enters the stripping tower at the top and is evenly distributed through noules across internal packing media (filters). Clean air is introduced into the bottom of the tower below the packing media using a blower to force air up through the tower. As the falling contaminated water flows countercurrent to the 2 rising air stream, volatile organic compounds are stripped from the water and enter the air stream. Figure 3 provides an illustration of an air stripper. Specific details of the air stripper will be detern,ined in the remedial design. TYPICAL AIR STRIPPIHO TOWEA The treated water exiting from the bottom of the air stripping tower from Operable Unit #3 will then join and flow into the discharge system from Operable Unit #1 which discharges into the Salisbury POTW. Water flowing into the POTW must meet all federal and state requirements for discharge. The air stream from the air stripper; which now contains the volatile organic contaminants, flows from the air stripper to the vapor-phase activated carbon filters. The activated carbon filters remove the volatile organics from the air stream prior to the air being release into the atmosphere. !These filters work -on the same principal as the air filter in an automobile.J The used carbon filters may be regenerated (so that they can be reused), destroyed (i.e., incinerated), or disposed of in a RCRA approved facility (i.e., landfilled). The current estimated cost for Alternatives GWP3/GWL3 and GWP4NGWL4A covering ·a 15-30 yiiar period is $1,500,000 and $5,792,00, respectively. SURFACE WATER/SEDIMENT IN THE NORTHEAST TRIBUTARY Alternative SW/SE-2 requires long-term monitoring of the quality of the surface water and sediment in the Northeast Tributary. No active remediation of this stream is necessary as this stream does not pose a current unacceptable risk to either human health or the environment. Any future risk this stream may pose is eliminated by Alternative GWP4AIGWL4A as this alternative removes the source of contaminants being detected in the Northeast Tributary. The source of contamination is the contaminated groundwater discharging into the stream. • Alternative GWP4AIGWL4A prevents the migration of the contaminated groundwater into the stream; thereby removing the source of contamination for this tributary. The estimated cost for Alternative SW/SE-2 is $867,000 over 1_5· 30 years. In addition to ihEf efforts dejpribed above, a reviewlassessmenf · · of Site conditions will be· performed at 5-year intervals. The primary goal of this review/assessment is to insure that the implemented remedy remains protective. In the event the review/assessment determines that the remedy is no longer protective, the review/assessment will then detail the necessary changes warranted. SOILS The contaminated soils found in the 'Plant' area and the · wastewater treatment lagoon area will be addressed in Operable Unit #4. WHERE ARE WE IN THE PROCESS AND WHAT IS NEXT As can be seen in the following Superfund flow chart we are now moving into the Remedial Design for Operable Unit #3. This step involves preparation of every aspect involved in designing the treatment equipment to health and safety plans to be carried out during the Remedial Action phase as well as how this Operable Unit will interface with other Operable Units in the future .. The Remedial Design may take 6 to. 9 months to complete. After that, actual construction of the treatment process can begin on Site. Sit• Dl•c:ov•r-y Pub I re CO~nt NPL Llatlng A•madln1 F•n•lbl I Tty )---a-{ I nv••tlg•t rosl----.1 Study A•c:o.--d 01" Dec I• I on )-----{ A-mad I e. I 0.•lgn FOR IIORE INFORIIATION ABOUT THIS SITE EmtER WRITE OR CALL: · Jon Bomholm, Remedial Project llanager, or Diane Barrett, NC Community Relations Coordinator North Superfund Remedial Branch U.S.E.P.A., Region 4 ~ · 345 Courtland Street, NE '-9 Atlanta, Georgia 30365 Phone: 1-800-435-9233 3 Rerr.CI 1 e. I Action , .•..•..............•................•.........•.•..•.•••.•..•.....•....•..•.•..•• ;1 MAILING LIST ADDITION/DELETION If you know of someone that would like to be added to or deleted from the mailing list for the National Starch & .Chemical Company Superfund Site in Salisbury, North Carolina, please complete,the information below and return to Diane Barrett at the address shown above. Thank you. NAME------------------------------ ADDRESS _________________________ _ CITY/STATE/ZIP PHONE ___________________________ _ AFFILIATION (if any) ADD TO LIST__ DELETE FROM LIST __ L~------------ . ··-.. -.... , - .,.. •. ft ~ U.S. Environmental Protection Agency 345 Courtland Stree~ N.E. North Superfund Remedial Branch Diane Barrett, Commwilty Relations Coon! .. Jon Bomholm, Remedial Project Manager Atianta, Georgia 30365 Rtglon 4 Official Business Penalty for Private Use $300 S/F NSCCOOll M~. ht~UCE NlLhULSON ·ENVIRO~lNENTAL ~NGi{., SUl'~KFUNO SECfION N • C • L t t1 l • U F [NV l RUN i·l !:: N T , ri E 1\ L T H & NATUl(AL ~Es □uRCtS kALE!GH NC 27611-7667 : . :; i :: :: 'lj : ;· : : : :: : : : : ii !;;!;!],;;;1!11i;11l!1::li11ii!i;\:;\;;!;!:;:!!;l;;]:l1;!1r11:/ I!! •• •• NATIONAL STARCH & CHEMICAL COMPANY SUPERFUND SITE SALISBURY, ROWAN COUNTY, NORTH CAROLINA PROPOSED PLAN MEETING FOR OPERABLE UNIT #3 AUGUST 3, 1993 7:00 P.M. Agricultural Extension Center 2727 Old Concord Road Salisbury, North Carolina •• •• MEETING AGENDA I. Welcome & Introduction of Participants (Diane Barrett, NC Community Relations Coordinator) II. Meeting Purpose, Review of Community Relations Activities & Overview of Superfund Process (Diane Barrett, NC Community Relations Coordinator) Ill. Site Description, History, Results of Remedial Investigation, Baseline Risk Assessment, & Feasibility Study (Jon Bornholm, Remedial Project Manager) IV. Remedial Alternatives and EPA's Preferred Alternative (Jon Bornholm, Remedial Project Manager) V. Question and Answer Session (Jon Bornholm, Remedial Project Manager) VI. Closing Remarks/Adjournment ;; I 0 .l: I ~ ., "' "' "' ., ~ 0 • • 0 g I z ci a ., 0: 0 0. ~ i Ci 0 0: w g; 2 r "' V, :, -; a: . . " 15 :, ~ a j'; 0: 0. 0 u w r ~ 0. ci iii > . a, "' u "' r u u r u i ~ c:; 0: ~ > "' z ~ ! < 0 0 N 0 "' I N 2: I :i -V, i;! :::l ~ iii > " "' z 0: z ~ ~ V, 0 0: "' u E ,g-"' ,;; N .. '-N .:::. ., 0 ;:; ., "' "' ., 0 • •• •• --... t o..,0. ' 't ~ (,._ "o v'1?,. )"" ) " """' { DAVIDSON COUNTY -BAASER t f, 70 :=11 ~f:f· I l,lllL BRIOCE 150 NATIONAL /. STARCH SITE , , -~ ~ ,_ GfW{TS c,~ / / I I \ COUNTY ------7 KANHAPLOIS CABARRUS COUNTY I SCALE: - ---0 8 FIGURE 1-1 SITE LOCATION MAP NAnONAL STARCH ANO CHF:MICAL COAIPANY SALJSSUHY, NC ID IIITERNA'nONAL TECHNOLOGY COKPORAnON {N \ 16 Mil.ES , SITE BACKGROUND • 1968 -Proctor Chemical Co. Purchased Property • 1969 -NSCC acquired Proctor Chemical Co. • 1970 -Construction Of Plant • 1983 -Proctor Chemical Dissolved/Operations Merged With NSCC • • • • • April 1985 • June 1988 SITE HISTORY Site Proposed For National Priority List Site Reproposed For National Priority List • October 1989 Site Finalized On National Priority List • Hazardous Ranking System Score (HRS) (Sites With Score Above 28.5 Eligible For Placement On NPL) • Overall HRS Score -46.51 • Groundwater Pathway Exposure Score -80.46 • Surface Water Pathway Exposure Score -0.00 • Air Pathway Exposure Score -0.00 • • • • •• •• SUPERFUND SITE HISTORY • December 1986 Administrative Order On Consent Signed • OPERABLE UNIT #1 • December 1986 Remedial Investigation/Feasibility Study Initiated • Investigated Air, Sediment, Soil, Surface Water, And Groundwater • Proposed Plan Distributed In September 1988 • Proposed Plan Public Meeting Held On September 14, 1988 • 3 Week Public Comment Period Ended September 24, 1988 • September 30, 1988 -Record Of Decision (ROD) Signed ROD Split Site Into Two Operable Units • OU #1 Addressed Contaminated Groundwater West Of Trench Area/Required Additional Sampling Of Soils In Trench Area And Surface Water/Sediments In Surrounding Tributaries Operable Unit --The Term For Each Of A Number Of Separate Activities Undertaken As Part Of A Superfund Cleanup SUPERFUND SITE HISTORY • OPERABLE UNIT #2 • 1989 -Supplemental Remedial Investigation/Feasibility Study Initiated • Investigated Contaminated Soils In Trench Area And Surrounding Tributaries • Proposed Plan Distributed In July 1990 • Proposed Plan Public Meeting Held On July 30, 1990 • Public Comment Period Held From July 30, 1990 And Ended August 29, 1990 • September 30, 1990 -OU #2 Record Of Decision Signed ROD Required Another Operable Unit -OU #3 • OU #2 Addressed Contaminated Soils In Trench Area/Required Identification Of Source Of Contamination Detected In Northeast Tributary • • • • SUPERFUND SITE HISTORY • OPERABLE UNIT #3 • 1991 -OU #3 Remedial Investigation/Feasibility Study Initiated • Investigated Source Of Contaminants Detected In Northeast Tributary • Proposed Plan Distributed July 15, 1993 • Proposed Plan Public Meeting August 3, 1993 • Public Comment Period Began July 19, 1993 • Anticipate OU #3 Record Of Decision To Be Signed In Late September 1993 • OU #3 ROD Will Address Contaminated Groundwater Beneath Plant Area 2 And Treatment Lagoons • OU #3 ROD Will Require Another Operable Unit -OU #4 • OU #4 Will Address Contaminated Soils In Area 2 And Lagoon Area • • • • SUPERFUND SITE HISTORY • OPERABLE UNIT #3 Areas Investigated -Plant Area (Area 2) Area 2 -Includes Area 2 Reactor Room, The Tank room, Raw Material Bulk Storage, And The Warehouse Buried Terra Cotta Pipe Lines Used To Pump Wastewaters From Plant Area To Lagoon 2 • • • • SUPERFUND SITE HISTORY • OPERABLE UNIT #3 Areas Investigated -Lagoon Area Treatment Lagoon Area -3 Lagoons Originally Constructed As Unlined Lagoons In 1969 Lagoon 2 Used From 1970 To 1978 In 1978, Lagoon 1 Was Put Into Service, Lagoon 3 Was Lined With Concrete, And The Wastewater Stream Was Routed Through The Lagoons To The Local POTW In 1984, Lagoons 1 And 2 Were Excavated And Lined With Concrete Contaminated Soil Excavated From Beneath The Lagoons Was Removed And Disposed Of West Of The Plant Operations Area Saturated Soil Was Landfarmed And Then Used As Fill Material For Expansion Of Their Parking Lot Lagoon 4 Was Installed In 1992 For Pretreatment Of Contaminated Groundwater As Part Of The OU #1 RA • • • • + --j- AIRPORT ROAD - "' ~ .-"' ~--l "...., ' 250 750 GRAPHIC SCALE: 1'0 50'1' I j • • OU #3 REMEDIAL INVESTIGATION FINDINGS SOILS CHARACTERIZATION • 14 Different Volatile Organic Compounds --most frequently detected -acetone, 2-butanone, chloroform, dibromochloromethane, 1,2-DCA, toluene • 1 Semi-Volatile Organic Compound -bis(2-ethylhexyl)phthalate (230 mg/kg) • 1 Pesticide -delta-hexachlorocyclohexane (22 mg/kg) • 2 Metals Detected 2x Background Concentrations -copper + lead SOURCE Lagoons Prior to Being Lined with Concrete in the 1983 Terra-Cotta Piping EXTENT In and Around Sources • • • • SBA2-05 . -SBA2'07 ND ■ :' _: ■ 740(2(5) - -----------------------------------------~----;------ ------,., ' APPROXIMATE SCALE (ft) ----o 100 '~~~' 200 300 400 500 •oeeoe1os.12-~a2 111 cl)I SBA2-13 ND ■ 1()0 SBA2-15 6J(5.5j-SBA2-16 SBA2-14 . .-■ 540(3.5). ,.t-iD - ·SBA2-03 : 240(5.5) ~ LOADING DOCK ■ S_BA2-01 34000(3.5) ,:: ' : : ■ SBA2-17 ND \ j ) • SBA2-02 :: . 8300(3 5)'/ :: -., AREA 11.· ,6BA2-18 _4J(13.5) s · -PARKING LOT LEGEND ■ SOIL BORING LCX:AIION SHOWING MAXIMUM 1.2-DCA CONCENTHArlON (ppll) AND (DEPTH (ft)) OF MAXIMUM CONCENTRATION IC\:) 1,2-0CA CONCENTHATION (;C)NTOUA WASTE-WAI EA LINE. ARROW INDICATES • DIRECTION OF FLOW NOTE Conl11mat1011 data supplemented by sod screernng data FIGURE 4-7 DISTRIBUTION OF 1 ,2-DCA IN SOIL SAMPLES, AREA 2 NATIONAL STARCH ANO CHEMICAL COMPANY SALISBURY NC m INIEHNATIONAI. TECt1NOL.OGV COHPORA I ION ..-w -0 100 DRIVEWAY WASTE·WATEA COL.lECTION PIT--( ' SBLA-18 19000(7.5) LAGOON2 PARKING AREA ; SilLA-03 ·,_ ■ ;r-3(7.5) LAGOON 1 • SBL.A-09 APPROXIMATE SCALE (II) i __ l 200 300 ; I ---~ 400 500 SBLA-08 ■ 3J(1.5) 2J(3.5) ·,-:,: "' i g :;,: 1, LEGEND SOIL BORING SHOWING 1,2-0CA CONCENTRATION ■ (ppb) ANO (DEPTH (h)) OF MAXIMUM CONCENTRATION WASTE-WATER LINE. ARROW INDICATES DIRECTION OF FLOW ABANOONED LINE -·-, 1.2-0CACONCENTRATIONCONTOUA 10000--·· NOTE: ConlirmaUon dala supplemented by sod screening data FIGURE 4-8 DISTRIBUTION OF 1 ,2-DCA IN SOIL AT THE WASTE WATER TREATMENT LAGOONS NATIONAL STARCH ANO CHEMICAL COMPANY SALISBURY NC m INTEANA TlONAL TECt-tNOtOGY COAPOHA TION • • • •• •• CHAIN LINK FENCE -----NORTHEAST ____ \ I I , .... 1. I l TRIBUTARY S8A2-05 ........... 120 a ■ . 10---SBA2-07• 18DJ: · ■ 100--- 1000--.. SBA2-11 ■ SBA2-19 ■ ■ NO SBA2-15 10 SBA2·06 , 4000 SBA2·20 ■ NO S8A2-0B· ND . ... . --. N~ ■ S8A2-16 230~ 5.50 ■ \100 S8A2-10 • 240. ..• , S8A2-04 ■ S8A2-01 SBA2-09 : ND ,-650 .93 \ I i i SBA2-03 ■ ·,260 j :, I ! L.J-----I .. SBLA-13. ·· ·· ND SBLA-12 SBLA-04 NO ■ PAAKlNG AREA ■ SBA2-02 540; ■ SBA2-18· 150 , 1100 --\ S81.A-14 ,• . .\···. [No . ·· .. •· ··ssL:A-11 SBLA-23 SBLA:06 \:-. j ... .-: >·.·. ~ ■ 230/ ND . 51 :,,·.·.·.a·>SBLA-05 SBLA-10 SBLA-24 ■ ■ : •:.. ■: ·■ ·■ 230 .... ·· 1100 : ND ,•.-,■ • '. ~-■ .. • SBLA-01 , [J LEGEND SOIL BORING SHOWING ACETONE ■ CONCENTRATION {POI>) ·•.... ACETONECONCENTRATION 100--/" CONTOUR (ppc) APPROXIMATE SCALE (rt) ND !1. . ·• ; ■ SBLA-02 SBLA-22., I 'j . ' / . l . ,660 ·, I ', 3500 S81.A·0U ·,S81.A:1a, ·,, ·· I --24.J -1 I . 130 • 1· SBLA-03 ~ I LAGOON~ 150 • ~~~-09 1000---- 100---:--: ■ 10---.; •.seLA.es· '. 2200' .' FIGURE 4-13 DISTRIBUTION OF ACETONE IN SOILS, PHASE II OU3 RI NATIONAL STARCH AND CHEMICAL COMPANY SALISBURY N.C. o 100 200 300 ..., 500 [i] INTERNATIONAL TECHNOLOGY CORPORATION OU #3 REMEDIAL INVESTIGATION FINDINGS GROUNDWATER CHARACTERIZATION • 16 Different Volatile Organic Compounds most frequently detected -acetone, chloroethane, 1,2-DCA • 4 Semi-Volatile Organic Compound -phthalates • t Pesticide -delta-hexachlorocyclohexane (0.16 ug/I) • 9 lnorganics Detected 2x Background Concentrations arsenic, chromium, cobalt, copper, lead, manganese, nickel, zinc, and cyanide SOURCE Soils Contaminated Prior to Lagoons Being Lined with Concrete in the 1983 Terra-Cotta Piping EXTENT Underneath and DownQradient of Sources • • • • 700 ... I I ... 0 A ; . .... f J .. ,. N9·21 "l' ··r .. ,. 1 I _!.._,~~==::::::======:===---c-· '~-"--• ~-----· ~ __ JLJ __ .: •--;:---:::,. ~~-ll--:~,~---.... t£0ENO 'WIWT .. Owaclll V..-.Cal E.uggerllkin. 4X "'°" A' FIGURE 3-4 HYDAOGEOLOGIC CROSS SECTION A-A' NATIONAL SIARCHAND CHl."MICAJ. COMPANY SA.lJSlJURrN.C. rn .. ,,,._,,,,_ 110...;;,v,.,, COH.-ci,ul,,_ N 850 - •• ABANDONED RAILROAD SPUR .. 4J 3J-- ND ND .:_NO •• LEGEND NO GAOUNDW.ATE~ SCREE~ING :>Q1N"T Sf-OWING : 2•:X:A CONCEN,"q,A,7lQ~ 10000- •, 2-DCA CONCENTRAilON CONTOUR NOTE Ccnlirma11or, aata suoclemen:ec =,y groundwater screening Cata ; '' ' ' ND NSSO -~--__ -_-__ -_-__ -_-__ '-'_"' __ -_-__ -_-__ -_-__ -_-_ ,--'--.1-3-00---4~8-00--'c-. -,_-N-□---, ' ' N250 -' CHAIN LINK FENCE---~ . 200 N□"· 100>---1000-.-------------5-: ': 10000------------~---------, ·-~ · 420 ::30 ND-'-:. , 98000-'-''. t6000 . 3400 .:_ . ; i i I I I i ' ! la I~ -----______ _l (/) c., APPROXIMATE SCALE {ft) 1 00 200 JOO .clO S00 ---------------z r i a: k I a.. (/) . 200. ·:NO :.:.... a: ~ w u FIGURE 4-4 1 ,2-DCA PLUME IN GROUNDWATER, PHASE II OU3RI NATIONAL STARCH AND CHEMICAL COMPANY SALISBURY N.C. m INTERNATIONAL TECHNOLOGY CORPORATION 1050 - 750 150 - -750 ! -850 <IOleea 08014¼93/dcti_,_nr,, • • NS-37 (1J) ABANDONED ____ __ RAILROAD SPUR .350 ... ---... ,. ,,. --' I .50 , ' I I \ \ / I \ I I I I NS-33 • (NO) I I 250 550 LEGEND • NS-13 (1700) 1.2.DCA CONCENTRATION CONTOUR IN PPB t.2·0CA CONCENTRATION IN PPB. GAOUNOWATEA SAMPLES FIGURE 4-5 1 ,2-DCA IN SAPROUTE GROUNDWATER SAMPLES, PHASE II OU3 RI NATIONAL STARCH AND CHEMICAL COMPANY SALISBURY N.C. [j] INlcJW,f,A,TICJHAI.. T'ECHNOLOOY CORPORA T10N 1050 - 750 - -750 I - • NS-24 • NS-38 (1J) (Not Sampled) ABANDONED RAILROAD SPUR_------ -350 ·50 ----s 250 •• NS-34 e (ND) I I 550 · LEGEND 1,2-0CA CONCENTRATION CONTOUR IN PPB t .z.QCA CONCENTRATION IN PPB, GROUNDWATER SAMPLES APPROXIMATE SCALE (ft) "' .,. - FIGURE 4-6 1 ,2-DCA IN BEDROCK GROUNDWATER SAMPLES, PHASE II OU3 RI NATIONAL STARCH AND CHEMICAL COMPANY SALISBURY N.C. [I] INTERNATIONAL TECHNOLOGY CORPORATION OU #3 REMEDIAL INVESTIGATION FINDINGS SURFACE WATER/SEDIMENT in Northeast Tributary CHARACTERIZATION • 2 Different Volatile Organic Compounds -acetone and 1,2-DCA • No Semi-Volatile Organic Compound • No Pesticide • 2 lnorganics Detected 2x Background Concentrations -copper and zinc SOURCE Contaminated Groundwater Discharging into Tributary EXTENT Adjacent to and Downgradient of Plant • • • • N 850 - •• TWP-13 (2400J) ABANDONED RAILROAD SPUR ____ __ TWP-12 (ND) SW-09 (150J) •• N 550 _;, ___________________ _J ___ _ SW-10 (1300J) -I I -i N 250 _, ' -r i I SW-16: i i ._______ l(1300JJ,, i -------~~~~~~~· TWP-11 'i'; 1 -AREA 2 (8300J) ,iJ TWP-10 -(790J) _ TWP-8 I 1!' (4800J) i TWP-9 ,z-i APPROXIMATE SCALE (ft) ,oo "' '°" ""' N-·.so:-:~"': _·:::: ._ ----------(6100J) SW-13 i ---(3200) ___ i_ --------------~ ,N-350 I PARKING LOT _____. 1SW-14f·,- TWP-7 ,j• ,--. -~ 1 (4J0) !-TWP-6 f -(ND) I NS-13 TWP-S '!'.j, (900) -(ND) TWP-4 .===--~ (ND) LAGOON 1 E-350 LAGOON 2 TWP-2 (ND) ====::::--a I l~S-1;' I ND I SW-12 (2J) E 250 E 5'1< i LEGEND ril TWP-8 -(4800J) •sW-14 (590) ■ NS-14 (ND) TEMPORARY WELL PO!NT ANO 1,2-DCA CONCENTRATION (ppo) SURFACE WATER LOCATION ANO 1,2-0CA CQNCENTRA TION (ppb) MONITORING WELL LOCATION AND 1.2-DCA CONCENTRA TlON (ppb) FIGURE 4-1 1,2-DCA IN WATER SAMPLES PHASE I OU3 RI NATIONAL STARCH AND CHEMICAL COMPANY SALISBURY N.C. m INTERNATIONAL TECHNOLOGY CORPORATION N 850 - N 550 I i -! I i _, •• ABANDONED RAILROAD SPUR 755 I 4 SE-09 (9J) •• SE-10 (610) ' I : ' APPROXIMATE SCALE {nl I i o , 00 200 300 -xl 500 I I ·----------------) : ' N 250 _II -I ' ' > -i . ---... ----I . . . ,,:~: ;..i::::::. '.-.·_ .. -.. -.... -.. -... -...... -.. ' PARKING LOT -----.,: iN-350 - Ii~ I LAGOON LAGOON 1 2 I .. 50 E-350 CHAIN LINK FENCE------~ AREA 2 SE-12 (ND) SE-11 (ND) E 250 SE-16 I i (61) 1 I I I I SE-13 ( .. (~~llJ_ ..... J SE-14 (1000) I I ' I I' l I LEGEND ASE-13 (290) STREAM SEDIMENT SAMPLE LOCATION AND 1,2-0CA CONCENTRATION {ppb) FIGURE 4-2 1,2-DCA IN STREAM SEDIMENT SAMPLES, PHASE I OU3 RI NATIONAL STARCH AND CHEMICAL COMPANY SALISBURY N.C. m INTERNATIONAL TECHNOLOGY CORPORATION •• •• Table 1-1 Ranges and Frequency of Detection of Organic Compounds Found In Investigated Media Phase I and II OU3 RI National Starch and Chemical Company Surtace Compound Soil Groundwater Water 1, 1-Dichloroethene 1-14 (3) 1, 1,2-Trichloroethane 11-17" (2)' 1-5 (10) 1,2 Dichloropronane 5 1,2-Dichloroethane 2-1600000 (42) 1-660000 ( 30) 2-3200 (7) 1,2-Dichloroethene 1-200 (4) 2-Butanone 3-42 (30) Acetone 22-4000 (40) 9-4200 (15) 18-52 (3) Bis(2-chloroethyl)ether 13-32 (2) Bis(2-ethylhexyl) phthalate 8 Bromodichloromethane 1-220 (7) 1 Carbon Disuttide 4-8 (3) Chloroethane 3-35 (6) Chloroform 2-900 (17) 7-8900 (2) Delta BHC 22 0.16 Di-n-butyl Phthalate 2-17 (2) Di-n-butyl Phthalate 2 Dibromocholorornethane 3-31 (5) Ethyl benzene 9-36 (2) Methylene Chloride 1-160 (5) Tetrachloroethene 2 1-7 (4) Toluene 1-3100 (12) 1-120 (3) Total Xylenes 1 2-90 (4) Trichloroethane 3 1-5 (4) Vinyl Chloride 32-190 (12) 1-120 (8) "Conoentration ranges are given in ppb. 'Frequency of detection is indicated in parentheses. KN/112&'WP1126. 1·1J0&.1M3'01 Sediment 9-1000 (5) 12~3(7) RISK ASSESSMENT In Order For There To Be A RISK, The Following Criteria Must Be Met: • Route Or Pathway Leading To An Exposure • Chemicals Exposed To Have Some Degree Of Toxicity A RISK Is Termed Unacceptable: For CarcinQQenic Cont~inants When The Calculated RISK Is Greater Than 1 x 1 o· For Noncarcinogenic Contaminants When The Calculated HAZARD INDEX Is Greater Than 1 • • • • OU #3 RISK ASSESSMENT CONCLUSIONS HUMAN HEAL TH Site Poses No Current Risks To Human Health Three Unacceptable Future Risk Scenarios Onsite Residents -Use Groundwater As Potable Water Carcinogenic Risk to CHILD due to Groundwater 2 x 10-3 Hazard Tndex (HI) to CHILD due to Groundwater 60 Carcinogenic Risk to ADULT due to Groundwater 2 x 10-3 Hazard Tndex (HI) to ADULT due to Groundwater 20 ExRosure Of Child To Surface Water1 Sediment, Or Spring Water Carcinogenic Risk to surface water 4 x 10-4 Hazard Tndex (HI) to surface water 0.1 Carcinogenic Risk to sediment 1 x 10-7 Hazard Tndex (HI) to sediment o.ooooge Carcinogenic Risk to spring water 1 x 1 a- Hazard Tndex (HI) to sediment 0.03 Exposure To Subsurface Soils Carcinogenic Risk to CHILD Hazard Index (HI) to CHILD Carcinogenic Risk to ADULT due to Groundwater Hazard Index (HI) to ADULT due to Groundwater AREA~ 2 X 10- 0.6 1 X 10-4 0.1 LAGOO~ 5 X 1 o· 0.02 6 X 10"6 0.003 • • • • OU #3 RISK ASSESSMENT CONCLUSIONS ENVIRONMENTAL ASSESSMENT Environmental Assessment - A semi-quantitative assessment of the possible hazards to environmental receptors was conducted as part of the Risk Assessment which included chemical, ecological 1 and toxicological testing. Assessment found adverse ecological impacts in areas of the stream where elevated levels of 1,2-DCA were detected. However, the assessment could not conclude that the contaminants originating from the Site, primarily 1,2-DCA, are the sole cause of this impact. There is a strong inaication that the naturally-limiting factors of the stream itself results in the diminished numbers of benthic (bottom-dwelling) organisms in this reach of the Northeast Tributary. • • • • OU #3 GROUNDWATER PERFORMANCE STANDARDS CONTAMINANT Acetone Bis 2-Chloroeth I ether Bromodichloromethane Chloroform 1 2-Dichloroethane 1 1-Dichloroethene cis 1 2-Dichloroethene trans 1 2-Dichloroethene 1 2-Dichloro ro ane Eth !benzene Meth lene Chloride . Tetrachloroethene Toluene Total X lenes RANGE AND FREQUENCY { ) OF DETECTION CONCENTRATIONS IN (µG/L) 1-660 000 30 1-120 FEDERAL ESTABLISHED PERFORMANCE STANDARD (MCL) (µGIL) 5 7 70 100 5 700 5 1 000 10,000 STATE ESTABLISHED PERFORMANCE STANDARD (µGIL) 0.19 0.38 7 0.56 29 5 7 1 000 400 SELECTED PERFORMANCE STANDARD (CLEANUP GOAL G/L SOURCE OF PERFORMANCE STANDARD CRQUState(bl CRQUState(bl MCUState CRQUState(bl State State MCL MCUState State • • • • OU #3 GROUNDWATER PERFORMANCE STANDARDS CONTAMINANT 11 2-Trichloroethane Trichloroethane Vin I Chloride UQ/1 -Micrograms per Liter RANGE AND FREQUENCY ( ) OF DETECTION CoNCENTRATIONS IN (µGIL) 1-5 1-5 1-120 14 FEDERAL STATE ESTABLISHED ESTABLISHED PERFORMANCE PERFORMANCE STANDARD STANDARD (MCL) (µGIL) (µGIL) 5 5 2.8 MCL --Maximum Concentration Limtt as Specified in the Safe Drinking Water Act OUl --Performance Standard Developed in September 30, 1988 Operable Untt #1 Record Of Decision 1 --Based on MCL for Trihalomethanes SELECTED PERFORMANCE STANDARD (CLEANUP GOAL GIL CR9li -Contract Required Quantitation Limtt State --Where the Maximum Allowable Concentration Of A Substance Is Less Than The Limit Of Detectability (15 A NCAC 2L.0202(b)(1) State -State Groundwater Quality Standards (NCAC 15-2L.0202) SOURCE OF PERFORMANCE STANDARD MCL State State • • • • OU #3 SURFACE WATER CLEANUP GOAL Ran~e of Concentrations EPA Region IV CONTAMINANT De ected in Northeast Chronic Screening Value Tributary (ua/1) (ua/1) 1,2-Dichloroethane 2-3,00 2,000 • • • • OU #3 FEASIBILITY STUDY EVALUATION PROCESS USED IN FEASIBILITY STUDY SCREENING PROCESS First Step Of Initial Screening Is Based On Technical Implementability Second Step Uses The Following Criteria To Evaluate All Technologies That Pass Step One • Institutional Implementability • Effectiveness • Cost • • • • I G"'ueral Response Action Conlalnmant ' ~ KN61Q2 ... XL.8,'0&-14-8\'KXI Technology TyPit --FlowConlrol I - I SU>ourfaoellran • I I On-SIio i Off.SIio Dlachlw,.. ~: i • Process o, 1 Assessment - Technical Implementability eon-lkx>alEx1racelonWall Enhanced Ex1lacllon Welle ln-lllrTranch lnlltrallon I I I I I f:::::::::::::::::::::::15 . ----. . :,:::::::::::::::::::,:1 ,i { POTW I H i SwlaceWaler~ I Comments Qirrenl supply nol llvaalanad. Nol app8cBble 'or s,ounct,,,a"". Nol ~ al deplhs required and beo'ocl< Is ~actured. Nol lJl)l)lcable al deplhs required and beo'ocl< Is ~actured. Nol "IJllOoahle al deplhs required and beo'ocl< Is ~actured. Ffactured be<tocl< Is already conlamlnatad. Ffacuad -la already conanlnalad. Too muc:t, net predpllatlon. Figure 2-6. Initial Screening of Technologies and Process Options for Groundwater • • • • C. •.• .oral Response Action I Co11W11uent/Traatment .._ l Technology Type -en,.,. Process O( Assessmen, - Technlcal lmplementablltty Exlr Wela Comments I ~i:':::::::::::::::::::GiJiill:I. -1:::::::::::::::::llllcicili: .. · ·-::::::::: ::::: ::::::1 Fractured -lo alnlady oonlarnlnal8d. :::::::::::::::1 Fracturad -lo anally oontmnlnalBd. -t I I Convanllonsl &Ir-Wela I r--=-,.,....-=-..,.....,,....,_.,,.,,.....-,, Nt Cllrbon 6laem Trencll I ~ apploeNe III dopCtw required. I I -:-:-:-:-:-:-:-::1 ---conotlllanla; not pradk:el IDr hliti-or orgonlce. · · · · ·:::::::::::::::::::::1 NolapplcetAe lDOfganlocontmn-. I Nol eppRc:etAe ID organic oontmnlnanla. Nol applcat:Ae ID Ofganlo oontmnlnanla . .,_,,-t.JO..MIO-,......., Figure 2-6 (Continued). Initial Screening of Technologies and Process Options for Groundwater • • • • c._ .... ral Response Ac:tlon Technology Type Processo1 , Assessmen, - Technlcal lmplemenlablllty Comments I L--~Qiemlcal==::..Tl!.reatman=="-1 _ __,• fr--==========, ::::::::::::<:::::::::::Pflil"""a::::::::::::::::::>::::1 No!appllcati4e"> DCA; ootav-. I ·::::::::::::::•:::::::::! No! appJcat,48., organic contamlnanta. ~ •-:-:-:-:-:-:-:-:-:· .. Tiliitniill'·•··········· . -~~~~~~- 1:.:-:-:-:-:::.:-:-:.:.:. :-:-:-:-:-:-:-:-:'.! Nol pracllcal lreatrnenlolgoundwata, wllh law levela ol_,.., :-:-:-:-:-:-:-:-:-:-:-:1 Nol pr-..s treatrnenl ol groundwalaf wllh law levela ol o,ganoe, -U "_,,.,, OU-1 Prelrealrnenl ""llllfn I Ony N conlarMlanl cc,-itrallona and llaw ralBa an, 8008plable. I I On-61• .. ,._ ___ ..,-=="'-----'' -:.:-:-:-:-:-:-:-:-:-::1 Too muct, net pradpllallon. POTW I StnlceWatarD I -••H.xur,oe.,....,. Figure 2-6 (Continued). lnltlal Screening of Technologies and Process Options for Groundwater • • • • I General Rasponaa Action NoAdlon lnllllullonelControl H H Technology Type N,IA -- Proc:eae Option H N,IA j H I ~ HVertlcal--AowCorwolH,__...,EJdradlorv11jOd=====-"W"'alls=-___, --~v-=--=-H :i{ Con---I I Eldracllon ---I I -Dru, TIWICII I -w' In-I I On-SIio J .......... I , • ,I • POTW I I On-SIio 4' --I Con---I ~ -.. EnhmlcodE,,hllCtll•·-I I -Dru, ~ TIWICII I I NI I i -T-. ~ c.bon I lllomn I 0Jddl6xt I I~ a-a!T,_ u I ~ t Pnmnrll OU.1 Pnllrealnad ... .._~ I I Traatnm -lllor-I lnstllutlonal lmplarnentablllty Eaelly in.,larranlabla Eallly~abla in,,lamonlabla ...., ... ,labia tr,.,...,.,tabla ...... ,.,table ·•~1tabla Nol~for- .....,.__wlllModonte Dltlbllty lu4A'1•1tabla .....,.__ will -Dltlbllly ~ will lltffloully •• ,.,table ........... Nol ~ ••• od for - Eaoly~-AIIE,1 ,. -Bo Controllod Ealy....,_ 1., ... ,.,tabla 1nip1e11 .. tlbla .,,,..,_ TedoiOlogy ~ will lltffloully ~wlh lltffloulty Effectiveness In Meatlng PRGa Not Ellecllva Sllghlly Effacllva Nol Effacllva • Waler - Tr&almanl lo Moot PR<le Ellocllve --..ie11ec11va Nol Effacllva • Waler - Troobnonl lo Moel PR<le Vwy Ellecllvo Vwy Ellecllva Nol Ellacllvo for C<in1>1oto Aqullor Vwy Ellacllvo Vwy EllocdVo Ellodlvo Ellacllvo U.pown Ellocllv-- ModonlJoly Ellacllvo Modo<alolyElloctlvo KNoftCl2-1'.x:L&Ot-1Ml30a Figure 2-7. Secondary Screening of Technologies and Proceu Options for Groundwater Coat Low Low Low to -• l.owlo-• High • -.ielyHlgh • --,High low loModll'llla Low -· High --,High ~High • -· • _....,,High High High High -toHlgh -toHlgh General Reapona.. Action I~ ' Technology Type l c:Jn-$1eD~ i Off.SIie .. , ________ .. ,. "'-OplJon~ • Procesa Option 1.l' In- II In- :if PClTW Lf su.-w ... lnslltutlonal Effectiveness lmplementablllty In Meeting PRGa I lrrc>--wlll -Dlllla,lly Ellilcllve I ~ ...... , .. lable Ellilcllvo I ~ wit, -Dlllla,ly Ellilcllve J ~able wllh Offllculy Ellilcllve ICHRla-1.nJlll».ll«M()I Figure 2-7 (Continued). Seeondary Screening of Tachnologlaa and Procaas Options for Groundwater Coat Low 10 Moderale Low .Moderalaly High High • • • • OU #3 FEASIBILITY STUDY EVALUATION PROCESS USED IN FEASIBILITY STUDY DEVELOPMENT OF REMEDIAL ALTERNATIVES First Step Combine Appropriate Technologies Into Remedial Alternatives To Address Contaminants In Each Environmental Media Second Step Evaluate The Remedial Alternatives Using The Following Criteria • Effectiveness • Implementability • Cost • • • • OU# ASIBILITY UDY EVALUATION PROCESS USED IN FEASIBILITY STUDY DETAIL EVALUATION OF REMEDIAL ALTERNATIVES Evaluate The Remedial Alternatives Using The Following Criteria THRESHOLD CRITERIA • Overall Protection Of Human Health And The Environment • Compliance With Applicable Or Relevant And Appropriate Requirements (ARARs) EVALUATING CRITERIA • Cost • Implementability • Short-Term Effectiveness • Long-Term Effectiveness . ·' • Reduction Of Contaminant Toxicity, Mobility, And Volume MODIFYING CRITERIA • State Acceptance • Community Acceptance THE REMEDIAL ALTERNATIVE SELECTED MUST ACHIEVE THE THRESHOLD CRITERIA AND ATTAIN THE BEST BALANCE AMONG THE EVALUATION CRITERIA ALTERNATIVE DESCRIPTION GWP1 /GWL 1 No Action GWP2/GWL2 Long-Term Monitoring Fence Portion of Northeast Tributary Long-Term Monitoring GWP3/GWL3 Institutional Controls Fence Portion of Northeast Tributary Groundwater Extraction GWP4A Air Stripping Vapor-Phase Carbon Adsorption POTW Discharge Groundwater Extraction GWP4B Air Stripping Fume Incineration POTW Discharge Groundwater Extraction GWL4A Air Stripping Vapor-Phase Carbon Adsorption POTW Discharge Groundwater Extraction PRESENT WORTH COST FOR 30 YEARS $227,000 $1,479,000 $1,500,000 $2,222,000 $2,274,000 $3,570,000 GWL4B Air Stripping $2,996,000 Fume Incineration POTW Discharge SW1/SD1 No Action $151,000 SW2/SD2 Long-Term Monitoring $867,000 EPA's PREFERRED ALTERNATIVE FOR OU #3 NATIONAL STARCH & CHEMICAL COMPANY SUPERFUND SITE Remedial Alternative Description Costs Alternatives GWP3/GWL3 Long-Term Monitoring $1,500,000 Institutional Controls Fence Portion of Northeast Tributary Alternatives GWP4B/GWL4B Groundwater Extraction $5,275,000 Air Stripping Fume Incineration POTW Discharge Alternatives SW2/SD2 Long-Term Monitoring $ 867,000 Total Present Worth Cost $7,637,700 • • • • I . •• ADDITIONAL ACTIVITIES TO OCCUR IN THE FUTURE • Initiation Of OU #4 • OU #4 Proposed Plan • OU #4 Proposed Plan Public Meeting • OU #4 Proposed Plan Public Comment Period • Negotiations With National Starch On Implementing Remedial Action Specified In Both OU #3 & OU #4 Record Of Decisions Documents NATIONAL STARCH & CHEMICAL COMPANY SUPERFUND SITE Salisbury, North Carolina GROUNDWATER REMEDIATION FOR OPERABLE UNIT #3 PROPOSED PLAN PUBLIC MEETING AGENDA August 3, 1993 Agricultural Extension Center Auditorium 2727 Old· Concord Road Salisbury, North Carolina AGENDA: Diane Barrett Welcome and Introduction Community Relations North Carolina Superfund Section Community Relations Coordinator Brief Site History, Results of Remedial Investigation, Feasibility Study, Alternatives Under Consideration and EPA's Preferred Alternative Jon Bornholm Remedial Project Manager Superfund Remedial Branch Panelists: Winston Smith, Groundwater Expert Question and Answer Period Closing Remarks SUPEr-' IND PROPOSED PLAN FACT SHF.t:T GROUNDWAT-REMEDIATION FOR OPERA" ~NIT #3 FOR THE NATIONAL STARCH & CHEMICAL COMPANY SUPERFUND SITE Salisbury, Rowan County, North Carolina July 1993 INTRODUCTION This Proposed Plan identifies the preferred options for addressing the contaminated groundwater and surface water/sediment associated with Operable Unit #3 at the National Starch & Chemical Company Superfund Site in Salisbury, North Carolina. The term "Operable Unir is used when individua actions are taken as a part of an overall site cleanup. A number of operable units can be used in the course of a site cleanup. (Terms in bold face print are defined in a glossary located at the end of this publication.) This document has been prepared and is being issued by the U.S. Environmental Protection Agency (EPA), the lead Agency for Site activities, and the North Carolina Department of Environmen~ Health and Natural Resources (NCDEHNR), tile support agency. EPA, in consultation with NCDEHNR, directed and oversaw the Remedial Investigation and Feaslblllty Study, and will select a remedy for Operable Unit #3 only after the public comment period has ended and all information submitted to EPA during this time has been reviewed and considered. EPA is issuing this Proposed Plan as part of its public participation responsibilities in accordance with Section 117(a) of the Comprehensive Environmental Response, Compensation, and Llablllty Act {CERCLA), also known as Superfund. This document summarizes information that is explained in greater detail in the Remedial Investigation Repo~ the Feasibility Study Report, and other documents contained in the Information Repository/Administrative Record for this Site. EPA and the State encourage the public to review these documents to better understand the Site and the Superfund activities that have been conducted. The Administrative Record is available for public review locally at the Rowan Public Library at 201 West Fisher Street, Salisbury, North Carolina. EPA, in consultation with NCDEHNR, may modify the preferred alternative or select another response action presented in this Plan and the Remedial Investigation and the Feasibility Study Reports based on new information and/or public comments. Therefore, the public is encouraged to review and comment on all alternatives identified here. A fourth Operable Unit will be developed to address the contaminated soils and source of contamination at the Site in the near future. nus PROPOSED PLAN 1. Includes a brief background of the Site and tile principal findings of Operable Unit #3 Site Remedial Investigation; • 2. Presents the remedial {cleanup) alternatives for the Site considered by EPA; 3. Outlines the criteria used by EPA to recommend a remedial alternative for use at the Site; 4. Provides a summary of the analysis of the remedial alternatives; 5. Presents EPA's rationale for its preliminary selection of the preferred remedial alternatives; and 6. Explains the opportunities for the public to comment on the remedial alternatives. DATE: LOCATION: TIME: PUBLIC MEETING: August 3, 1993 Agricultural Extension Center 2727 Old Concord Road Salisbury, North Carolina 7:00 PM · 9:00 PM PUBLIC COMMENT PERIOD: July 19, 1993 -August 17, 1993 AIRPORT RON> 'lti,~ "oc,~ '-... 70 150 "1U. BRIOC NATIONAL /. ST~CH S~ """"'~ ~ ) -·o· ,"- ~ DIMOSON ~= ,· KANNAPLOIS CASAARUS COUfo/TY :;:.c~-'-~·-·::~;._~:>'.:, ::~:: ____ ) ;~-.... ---- 500 0 500 1000 =1!""1-"5'" ..... ~--"""'5--"-"'== 250,. 750 GRAPHIC SCALE: 1'=500' ? .,. N .. ,.. __ . Fi.g1.p,e 1 '"I •.. ~. ., \ COUfo/TY 7 I ,I .I SITE BACKGROUND 41 The National Starch & Chemical Company (NSCC) facility occupies 465 acres on Cedar Spfings Road on the outskirts of Salisbury, North Garolina (refer to Figure 1). Presently, land use immediately adjacent to the Site is a mixture of residential and industrial developments. East and south of the Site are industrial parks consisting pfimarily of light industrial operations. The west and north sides of the NSCC property are bordered by residential developments. Refer to the Figure 2 for Site location. A surface stream, referred to as the Northeast Tributary, crosses the NSCC property parallel to Cedar Spfing 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 facility discharges into this tributary. The focus of the Operable Unit #3 Remedial Investigation was to determine the source, nature, and extent of the contamination entering this stream. Primarily, NSCC manufactures textile-finishing chemicals and custom specialty chemicals. VolaUle and sem~volaUle 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 waste stream from the manufacturing process includes wash and rinse solutions. 118 .···0:.-:.-:.-,.-.-.-, ~---,ii ~-~~Ill ! ! i I I,,c:·I·:.-::.-' . .-:: .. -=--................... 1 . ···-···· .• ' []~EJ • Operable Unit #3 focused on the areas of the facility referred to as Area 2 and the wastewater treatment lagoons (refer lo Figure 3). Nea 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. A fourth lagoon was installed in 1992 for pretreatment of contaminated groundwater as part of the Operable Unit #1 Remedial Action (RA). As the result of finding contaminants in groundwater and in the surface water/sediment of the Northeast Tributary, the original scope of work specified in the initial Remedial Investigation/Feasibility Study Work Plan has been expanded twice. The first Remedial Investigation and Feasibility Study resulted in the first Record of Decision (ROD) to be issued by the Agency on September 30, 1988 for the NSCC Superfund site. The findings of Operabie Unit #2 Remedial Investigation/Feasibility Study led to the second Record of Decision, rendered by the Agency on September 30, 1990. As in Operable Unit #1 and Operabie Unit #2, the work performed for Operabie Unit #3 is being performed by National Starch & Chemical Corporation, the Potentially Responsible Party (PRP). The engineering contractor hired. by the PRP to conduct Operabie Unit #3 work is IT Corporation .. The NSCC site was proposed for inclusion on the NaUonal Pr1011Ues Lisi in April 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 Ranking System score of 28.5 or higher are eligible to be placed on the National Priorities List SCOPE AND ROLE OF OPERABLE UNrr WITHIN SrrE STRATEGY As with many Superfund sites, the NSCC site is complex. Consequently, EPA divided the work into three manageable components called Operable Units (OU). These operable units 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/surface water/sediments in the areas of Nea 2, the lagoons, and the Northeast Tributary 91TB OP !'OR OPUABLB OUT tJ oPDABLB lll'IT tl Jlll'Ica&L 8TAltCB ' CRDICAL COIIPAJIY SUPDrU1ID SITI 3 RES UL TS OF THE REIi.. . INVESTIGATION FOR OU-3 · Three environmental media (soils, groundwater, and surface water/sediment) have been adversely impacted by contamination originating fiom the NSCC plant and from past chemical handling and disposal practices of the facility. The primary contaminant at the Site Is 1,2-dlchforoethane (1,2-DCA). This contaminant Is known as a chlorinated organic compound that volatilizes readily and Is classified as a probable human carcinogen. A carcinogen is any . substance that can cause or contribute to the development · of cancer. Other organic chemicals were also detacted. The chemicals of concern at · the Site are (listed alphabetically): acetone, bis (2-chloroethyl) ether, bis (2- ethylhexyQ phthalate, 2-butanone, cadmium, carbon disulfide, chloroform, chloroelhane, delta-BHC, 1,2- dichloroethene, di-n-butyt phthalata, di-n«lyl phthalate, ethyl benzene, methylene chloride, styrene, tetrachloroethene, toluene, 1, 1,2-trlchloroethane, trichloroethane, vinyl chloride and total xylene. The following inorganics were also detected: aluminum, antimony, arsenic, barium, beryllium, clvomium, cobalt copper, cyanide, lead, manganese, mercury, nicl<el, selenium, thallium, vanadium, and zinc. TheQU-3 soil investigation has generated ample information to characterize the contamination, determine the source, and define the extant of contamination in the vadose soil zone. The vadose zone Is comprised of subsw"face soil that is not saturated with water. The interface between the vadose zone and the saturated zone is commonly referred to as the water table. Fourteen different volatile organic compounds, one sem~volatile organic compound, and one pesticide were detected in the vadose sous. The primary source of contamination in Area 2 were buried, leaking tarra-cotta piping used to transport waste streams from the production area ID the treatment lagoons. The source of the contaminants detected in the lagoor. .;ea is the sou under . and around the lagoons 'MIich were contaminated prior to the lagoons being Uned with concrete. • OU-3 defined the nature of groundwater contamination (the contaminants present and their concentrations) but additional · work Is needed to completely define the extent of groundwater contamination, especially in the bedrock zone of . the aquifer. · The aquifer Is subdivided into two lntarCOMeCtad zones, the shallow zone and the bedrock zone .. Both of these zones have been adversely iripactad by activities at the NSCC plant. Sixteen different volatile organic compounds and four semi-volatile organic compounds were detected in the groundwater. Groundwaler in the shallow zone in the vicinity of the lagoons is flowing at an approximate speed of 80 feet per year. This rate slows to approximately 27 feet per year just east of the lagoon area. The highest concentrations of contamination detected in the Northeast Tributary were found just east of the plant. The levels of these volatile organics decrease downstream as these contaminants volatilize Into the atmosphere. Two samples, one surface water and one sediment were collected from the Northeast Tributary just prior to the stream leaving the NSCC property and flowing under Airport Road. No contaminants were detected in these samples which indicates that the Ukalihood of contamination leaving the Sita via surface water/sediment is minimal. The apparent source of the organics in this stream is the discharge of contaminated groundwater into the stream. lnorganics were detected in aB three of the envirorvnental media sampled (soils, groundwater, and surface water and sediment). Ail of the metals detected are naturally occurring and the variation In concentrations detected does not indicate the Sile is releasing inorganic contaminants into the environment L-.nd 8....-f'•c• Fr-o.ctur-ed Wee.thered Bedrock Bedrock: ,I 4 SUIIIIARY OF Sile RI. A task of the Remedial investigatiorvfeasibility Study is to ' analyze and estimate the human health and environmental problems that could result tt the soil, groundwater, and surface water/sediment contamination is not cleaned up. This analysis is call a Baseline Risk Assessment. In calculating risks to a population tt no remedial action Is taken, EPA evaluates the reasonable maximum exposure levels for currant and Mure exposure scenarios to Site contaminants. Scenarios were developed for residents living on or near to the Stte as weU as for employees wooong on the Site. In conducting this assessment, EPA focuses on the adverse human heallh effects that could result from long-tenn daily, direct exposure as a result of ingestion, inhalation, or dennal contact to carcinogenic chemicals (cancer causing) as well as the adverse heallh effects that could result from long-tenn exposure to non-carcinogenic chemicals present at the Stte. EPA considers a long-tenn resident beginning as a young child being exposed daily for 30 years to be a reasonable maximum exposure scenario for future exposure to the NSCC site. A goal of the f>(Jerv:, is to reduce the risk posed by a Superfund Site to fewer lhan one person out of 10,000 being at risk of developing cancer. This is the minimum risk the Agency will allow, typically the Agency aspires to be even more protective and strives to lower the risk so that at a minimum, only one person out of one million may be adversely impacted by lhe contamination found at a Superfund Site. EPA has concluded that there are no major current risks to human heallh at the Site. Exposure palhways evaluated in the Risk Assessment were ingestion, inhalation, and direct · contact to contaminants in lhe soil, groundwater, and surface water/sediment. The only reason groundwater does not pose a CUfTent risk is because lhe contamination in lhe groundwater has not migrated beyond lhe property boundary and consequenUy, has not impact any private, potable weU. There are no potable wells located on Stte. However, there are three unacceptable Mure carcinogenic risks associated wilh lhe contamination at the Site. The first scenario resulting in an unacceptable future risk is having residents Uving in homes built on or near the Site and using the groundwater as potable water. Another unacceptable future risk is the exposure of a child to surface 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 to lhe presence of noncarcinogenic chemicals in lhe groundwater. A semi-quantitative assessment of lhe Northeast Tributary was also conducted as part of the Risk Assessment This environmental assessment included chemical, ecological, and toxicological investigations of lhe surface water and sediment colle.om me Northeast Tributary. The data generated by lhe environmental assessment found adverse ecological impacts in areas of the stream where elevated levels of 1,2-DCAwere detected. However, lhe assessment could not conclude that lhe contaminants originating from the Stte, primarily 1,2-DCA. are the sole cause of this impact. There Is a strong indication that lhe naturally~imiting factors of the stream itself results in the diminished numbers of benthic (bottom-<lwelUng) organisms in this section of the Northeast Tributary. REIIEDIAL ACTION OBJECTIVES Remedial action objectives (RAOs} were developed based on lhe results of the Risk Assessment, an examination ol potential Appllcable or Relevant and Appropriate Requirements (ARARs}, and threats to groundwater and the Northeast Tributary. Action-, location-, and chemical-specific ARARs were examined. Chemical-specific ARARs for groundwater include maximum concentration levels (MCL.s} as specified in lhe Safe Drinking Water Act and North CaroUna Groundwater Standards. In summary, the Remedial Action Objectives are: FOR GROUNDWATER For Human Heallh: Prevent ingestion of water having concentrations of 1,2-DCA resulting in cancer risks above acceptable limits. For Environmental Protection: None, groundwater concentrations have not been found to represent an env~onmental hazard. FOR SURFACE WATER For Human Heallh: None, surface water is not a drinking water source. For Environmental Protection: None, surface water concentrations have not been identified as lhe sole cause for lhe limited benthic populations. FOR SEDIMENT For Human Heallh: Prevent direct contact with sediments having levels of 1,2-DCA resulting in cancer risks above acceptable limits. For Environmental Protection: None. The objective of a remediation is to obtain stringent health risk levels. For groundwater, all chemical-specific ARARs, which include MCLs and lhe North Carolina Groundwater Standards, will be achieved where the specified concentration is technically detectable. The estimated volume of contaminated groundwater requiring remediation is 131 million gallons. For more information about the~ial Action Objectives and alternatives for the NSCC ~ite, please refer to the June 21, 1993, FeasibiUty Study document and other documents available for review at the Administrative Record located at the Rowan Pubiic Library. SUIIIIARY OF REIIEDIAL ALTERNATIVES The following section provides a summary of the alternatives developed In the Feasibility Study (FS) Report. The primary objective of the Feasibility Study was to determine and evaluate alternatives for cleaning up the Site. Descriptions of the clean-up alternatives are summarized below. The Report contains a more detailed evalualionldescription of each alternative. The cost infonnation provided below for each alternative represents estimated total present worth (PW) of each alternative. Total present worth was calculated by combining the capital cost plus the present worth of the amual operating and maintenance (O&M) 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 groundwater monitoring. The present worth of an alternative Is the amount of capitai requ~ed 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 and Mure replacement of capitai equipment REMEDIAL ALTERNATIVES TO ADDRESS GROUNDWATER CONTAMINATION The groundwater remedial alternatives for addressing contaminated groundwater 'N9re considered separately for Area 2 and the lagoon araa. 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 •. ALTERNATIVES GWP1 AND GWL 1: No ACTION Capital Costs: Annual O&M Costs: Total PW Costs for 30 Years: nme to Design: Construction nme: Duration to Achieve Clean-up: $ 0 $ 22,000 $ 227,000 None None Over 30 years CERCLA requires that the "No Action" alternative be evaluated at every Superfund Site to establish a baseline for comparison. No further activities would be conducted with regard to the groundwater beneath the Site under this alternative ~.e., the Site Is left ·as is"). Because these alternatives do not entail contaminant removal or destruction, a review of the remedy would be conducted every five years r in accordance &rncLA Section 121(c). Operating costs are basedT'c;;;nducting this review every five years which includes monitoring the groundwater under the Site once every five yea,s for a period of 30 years. ALTERNATIVES GWP2 AND GWL.2: LONG TERM MONITORING, FENCIIG A PORT10H OF NOFm/EAST TRIBUTARY Capital Costs: Annual O&M Costs: Total PW Costs for 30 Years: nme to Design: Construction nme: Duration to Achieve Clean-up: $ 178,000 $ 138,000 $1,479,000 None None Over 30 years These alternatives are similar to Alternatives GWP1 and GWL 1, except under Alternatives GWP2/GWL2 additional monitoring wells would be installed, groundwater monitoring data would be collected amually instead of once every five years, and a portion of the Northeast Tributary would be fenced. ALTERNATIVES GWP3 AND GWL.3: I/IST1rt/T10NAL CONTROLS, FENCIIG A PoRl10N OF NORTIEAST TRIBUTARY Capital Costs: Annual O&M Costs: Total PW Costs for 30 Years: nme to Design: Construction T11ne: Duration to Achieve Clean-up: $ 198,000 $ 138,000 $1,500,000 None None Over 30 years These alternatives for groundwater contamination in Area 2 and the lagoon area are identical to Alternatives GWP2 and GWL2, except Alterative GWP3/GWL3 Includes institutional controls. No remediation activities would be conducted for groundwater: The additional costs are associated with preparing and fiUng deed restriction(s) and implementing the other institutional controls. The specific institutional controls to be Implemented include: using deed restrictions to control the installation of new 111'9Ils on both the plant property and adjacent property; track plume migration; and install fencing around the Northeast Tributary to limit access to contaminated surface water and sediment A "plume· is the discharge of a contaminant from a given point of origin in water or air, for example, smoke from a smokestack. These alternatives provide no reduction in volume, mobility or toxicity of the contaminants, however, they can reduce or eliminate direct exposure pathways and the resultant risk to the public. As part of these alternatives, the groundwater would be monitored on a yearly basis. As EPA may not have the authority to implement these institutional controls, the responsibility rests with the State of North CaroUna to ensure the institutional controls are In place, are reliable, and will remain in place after initiation of O&M. Therefore, the responsibility for implementing and enforcing institutional controls falls on the State of North Carolina. Groundwater monitoring and five year CERCLA reviews would be conducted for 30 years. The .cost is for both Area 2 and the lagoon area. ALTERNATIVE GWP4A: GROUNDWATER E.xTRACTION THROUGH WELLS AND TREATIIENT BY AIR SrnlPPING WITH V APOR-PIIASE CARBON ADsORPTIOH Capital Costs: Annual O&M Costs: Total PW Costs for 30 Years: Time to Design: Construction Time: Duration to Adlieve Clean-up: $ 648,000 $ 306,000 $2,222,000 1 year 6 months 15 to 30 years This alternative includes extracting groundwater by means of extraction wells downgradient of Area 2; volatile organics removal through air stripping; control of emissions to the atmosphere from the air stripper tlvough vapor-phase carbon adsorption; and combined discharge with treated groundwater from OU-1 to the Salisbury publicly owned treatment works (POlW). 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. The five year review CERCLA requ~ement would apply to this alternative. ALTERNATIVE GWL4A: GROUNDWATER E.xTRACTION WELLS, TREATIIENT BY AIR SrRIPPING WITH VAPOR-PHASE CARBON ADsORPTIOH Capital Costs: Annual O&M Costs: Total PW Costs for 30 Years: Time to Design: Construction Time: Duration to Adlieve Clean-up: $ 789,000 $ 434,000 $3,570,000 1 year 6 months 20 years This alternative is identical to Alternative GWP4A except this alternative addresses contaminated groundwater associated with the lagoon area. ALTERNATIVE GWP4B: GROUNDWATER E.xTRACTION WELLS, TREATIIENT BY AIR Sm/PP/HG WITH FUME IHCINERATIOH Capital Costs: Annual O&M Costs: Total PW Costs for 30 Years: Time to Design: Construction Time: Duration to Achieve Clean-up: $ 766,000 $ 299,000 $2,274,000 1 year 6 months 15 to 30 years This alternative is identical to Alternative GWP4A, except that the control of emissions to the atmosphere from the air stripper would be accomplished ttvough fume incineration. ALTERNATIVE GWL4B: GROUNDWATER E.xTRACTION WELLS, TREATIIENT BY AIR SrRJPP/11{; WITH FIIIIE INCINERATION 7 Capital CostiA Annual O&MWs: Total PW Costs for 30 Years: Time to Design: Construction Time: Duration to Achieve Clean-up: $ 913,000 $ 360,000 $2,996,000 1 year 6 months 20 years This alternative Is Identical to Alternative GWP4B except for this alternative addresses contaminated groundwater associated with the lagoon area. ALTERNATIVE GWP4C: GROUNDWATER E.xTRACTION WELLS, TREATIIENT BY LloUIO-PHASE CARBON ADsORPTION Capital Costs: Annual O&M Costs: Total PW Costs for 30 Years: Time to Design: Construction Time: Duration to Achieve Clean-up: $ 788,000 $ 432,000 $4,305,000 1 year 6 months 15 to 30 years This alternative includes extracting groundwater by means of extraction wells downgradient of Area 2; volatile organics removal ttvough iquid-phase carbon adsorption and combined discharge with treated groundwater from OU· I discharge to the Salisbury POTW. The treated effluent must meet permit limits set by the Salisbury POTW. Spent activated carbon would be regenerated. The five year review CERCLA requirement would apply to this alternative. ALTERNATIVE GWL4C: GROUNDWATER E.xT1IACTION WELLS, TREATIIENT BY LloUID-PHASE CARBON ADsORPTIOH Capital Costs: Annual O&M Costs: Total PW Costs for 30 Years: Time to Design: Construction Time: Duration to Achieve Clean-up: $ 987,000 $ 941,000 $8,375,000 1 year 6months 20 years This alternative is identical to Alternative GWP4C except this alternative addresses contaminated groundwater associated with the lagoon area. - ALTERNATIVE GWl5A: GROUNDWATER E.xTRACTION WELLS, TIIEATIEHT BY AIR STRIPPING WITH VAPOII-PHASE CARBON ADsoRPTION, lN-SmJ BIOREMEDIATIOH REQUIRING GROUNDWATER INJECTION OF NUTRIENTS Capital Costs: Annual O&M Costs: Total PW Costs for 30 Years: Time to Design: Construction Time: Duration to Achieve Clean-up: $1,093,000 $ 798,000 $7,477,000 1 year 6 months 15 to 30 years This alternative includes extracting groundwater by means of extraction weUs located downgradlent of the lagoons; volatile organics removal tlvough air stripping; control of emissions to the abnosphere .10 air stripper through vapor-phase carbon adsorption, bining a portion of the discharged groundwater with treated groundwater from OU-1 for discharging to the Salisbury POTW, polishing the remaining portion of the groundwater by air stripping to cleanup goals before injecting the treated groundwater along with nutrients into the conlaminated area to promote lrHlltu biodegradation of the conlaminants. 'In-situ' means to keep in place o.a., the treabnent is conducted in its original place). The treated. effluent being discharged to the Salisbury POTW must meet permtt timits set by the Salisbury POTW. Spent activated carbon would be regenerated. The five year review CERCLA requirement would apply to this alternative. ALTERNATIVE GWL.58: GROUNDWATER ExniACIJON WELLS, TREA TIIENT BY Ali STRIPPING WTTH FUIIE INC/HERA TION, IN-SITII BIOREIIEDIA TION REQUIRING GROUNDWATER INJEcnoN OF NIITRiENTS Capital Costs: Annual O&M Costs: Total PW Costs for 30 Years: Time to Design: Construction nme: Duration to Achieve Clean-up: $1,365,000 . $ 733,000 $7,000,000 1 year 6 months 15 to 30 years This alternative is similar to Alternative GWLSA except control of emissions of the vapor coming from the first air stripper would be accomplished through the use of a fume incineration. ALTERNATIVE GWLSC: GROUNDWATER ExnlAC110N THROUGH WELLS, TREATIIENT BY I.JoUID-PHAsE CARBON ADSORPTION, IN-SITU BIOREIIEDIATION REQUIRING GROUNDWATER INJEcnoN OF MITRJENTS Capital Costs: Annual O&M Costs: Total PW Costs for 30 Years: . nme to Design: Construction Time: Duration to Achieve Clean-up: $1,216,000 $ 1,631,000 $13,853,000 1 year 6 months 15 to 30 years This alternative includes extracting groundwater by means of extraction weUs located downgradient of the lagoons; volatile organics removal through liquid-phase carbon adsorption; combining a portion of the discharge with treated groundwater from OU-1 for discharging to the Salisbury POTW; the remaining portion of the treated groundwater would be re~njected, along with nutrients, back into the contaminated area to promote in-situ biodegradation of the contaminants. The treated effluent being discharged to the Salisbury POTW will meet permtt limits set by the POTW. Spent activated carbon would be changed out and sent to a commercial regeneration facility. The five year review CERCLA requirement would apply. The treated effluent must meet permtt limits set by the POTW. The five year review CERCLA requirement would apply to this alternative. 8 REMEDIAL AlcRNAllVES TO ADDRESS SURFACE~ATER AND SEDIIIENT CONTAIIINATlON ALTERNATIVE SW1/SD1: No AcnoN Capital Costs: Annual O&M Costs: Total PW Costs tor 30 Years: nme to Design: · Construction Time: Duration to Achieve Clean-up: $ 0 $16,000 $151,000 None None Over 30 years No further activities would be conducted on surtace 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 apply ID this alternative. ALTERNATIVE SW2/SD2: l.DNG-TERII Mo/lTORIIG Capital Costs: Annual O&M Costs: Total PW Costs for 30 Years: nme to Design: Construction Time: Duration ID Achieve Clean-up: $ 0 $92,000 $867,000 None None Over 30 years This alternative is similar to Alternative SW1/SD1, except under Alternative SW2/SD2, surtace water and sediment samples would be collected from the Northeast Tributary annually instead of once every five years. CRITERIA FOR EVALUATING REMEDIAL ALTERNATIVES EPA's selection of the preferred cleanup alternative for the NSCC OU-3 site; as described in this Proposed Plan, is the result of a comprehensive evaluation and screening process. The Feasibility Study for lhe Site was conducted to identify and analyze the alternatives considered for addressing contamination at the Site. The Feasibility Study and other documents for the NSCC OU-3 site describe, in detail, the alternatives considered, as weU as the process and criteria EPA used ID narrow the list to potential remedial alternatives to address the Site contamination. As stated previously, all of these documents are available for public review in the information repository/administrative record. Allernatives GWP4C, GWL4C, GWLSA, GWLSB, and GWLSC were not retained for the detailed analysis because the other alternatives would achieve the same degree of protection for human health and the envirorvnent but at a substantially lower cost EPA always uses the following nine criteria to evaluate alternatives identified in the Feasibility Study. The remedial allernative selectac for a Superfund site must achieve the two threshold critaria as well Aain the best balance among the five evaluation criteri~ nine criteria are as follows: THRESHOLD CRITERIA. 1. Overall protecUon of human health and the environment: The degree to which each altarnative eliminatas, reduces, or controls threats to public heallh and the environment through treabnent, engineering melhods or Institutional controls. 2. Compliance With Applicable or Relevant and Appropriate Requirements {ARARsl: The altarnatives are evaluatad for compliance wilh all stata and federal environmental and public heallh laws and requirements that apply or are relevant and appropriata to the site conditions. EVALUATING CRITERIA 3. Cost: The benefits of Implementing a particular remedial altarnative are weighed against the cost of implementation. Costs include the capital (up-fronQ cost of implementing an altarnative over the long tarm, and the net present worth of bolh capital and operation and maintenance costs. 4. Implementability: EPA considers the technical feasibility (e.g., how difficult the altarnative is to construct and operate) and administrative ease (e.g., the amount of coordination with other government agencies that is needed) of a remedy, including the availabiUty of necessary materials and services. 5. Short-term effectiveness: The lenglh of time needed to implement each alternative is considered, and EPA assesses the risks lhat may be posed l0 workers and nearby residents during construction and implementation. 6. Long-term effectiveness: The alternatives are evaluatad based on their ability to maintain reliable protection of public health and the environment over time once the cleanup goals have been met. 7. ReducUon of contaminant toxicity, mobility, and volume: EPA evaluatas each alternative based on how It reduces (1) the harmful nature of the contaminants, (2) their ability to move lhrough the env~onment, and (3) the volume or amount of contamination at the site. MODIFYING CRITERIA 8. State acceptance: EPA requests stata comments on the Remedial Investigation and Feasibility Study reports, as well as the Proposed Plan, and must take into consideration whether the 9 state concAith, opposes, cir has no comment on EPA"s p'!!lrerred alternative. 9. Community acceptance: To ensure lhat the pubiic has an adequate opportunity l0 provide input. EPA holds a public comment period and considers and responds to all comments received from the community prior l0 the final selection of a remedial action. EVALUATlON OF ALTERNA11VES The following summary profiles the performance of the preferred alternatives in terms of the nine evaluation criteria noting how it compares l0 the other altarnatives under consideration. The comparative analysis for the groundwater remediation alternatives Is as follows: GROUNDWATER REMEDIATION The following .altarnatives were subjectad to detailed analysis for migration control: Alternative GWP1 : No action with regard to the gioundwater in Area 2 Altemauve GWP2: Long-Term Groundwater Monitoring of In Area 2 wilh Fencing A Portion of Northeast Tributary Alternative GWP3: Institutional Controls wilh regard to the groundwater in Area 2 wilh Fencing A Portion of Northeast Tributary AltemaUve GWP4A: Groundwater Extraction Through Wells Downgradient of Area 2 and Treabnent By />Jr . Stripping with Vapor .Phase Carbon Adsorption wilh Combined Discharge to the Salisbury POTW AltemaUve GWP4B: Groundwater Extraction ~hrough Wells Downgradient of Area 2 and Treabnent By />Jr Stripping Wilh Fume Incineration wilh Combined Discharge to the Salisbury POTW AltemaUve GWL1: No Action wilh regard to the groundwater in the lagoon area AlternaUve GWL.2: Long-Term Groundwatar Monitoring of in the lagoon area wilh Fencing A Portion of Norlheast Tributary AltemaUve GWL3: Institutional Controls with regard to the groundwater in the lagoon area wilh Fencing A Portion of Northeast Tributary AltemaUve GWL4A: Groundwater Extraction Through Wells Downgradient of the Lagoon Area and Treabnent By Ne Stripping wilh Vapor-Phase Carbon Adsorption wilh Combined Discharge to the Salisbury POTW AltemaUve GWL48: Groundw• dction Through Wells Downgradient of the La~a and Treatment By Air Stripping With Fume Incineration with Combined Discharge to the Salisbury POTW Overall Protection: Alternatives GWP2, GWL2, GWP3, GWL3, GWP4A, GWL4A, GWP4B, and GWL4B provide adequate protection for human health by preventing ingestion of potentially contaminated groundwater and surface water. Alternatives GWP4A, GWP48, GWL4A, and GWL4B would afford the greatest protection to human health because tt would substantially reduce the contamination in the groundwater and prevent the potential for exposure through use of existing or future Pff w wells. Alternatives GWP4A, GWP4B, GWL4A, and GWL4B would also remediate the surlace water and sediment, which would eliminate the potential for exposure via ingestion of these media. These alternatives protect the environment by removing contaminants from groundwater, controlling the extent of groundwater contamination, and reducing the contamination in the tributary and downstream surface waters. Neither Alternatives GWP3 nor GWL3 would protect the environment because contamination would continue to migrate into the tributary through groundwater discharge. None of the Alternatives GWP1, GWL1, GWP2, or GWL2 wiU provide protection for either human health or the environment. Natural degradation/attenuation of contaminants in the subsurlace is not anticipated to prevent the potential migration of contaminants off w, although such processes may reduce the amount and concentration of contaminants. Compliance with ARARs: Alternatives GWP4A, GWP4B, GWL4A, and GWL4B would obtain performance standards for groundwater (MCLs and North Carolina Groundwater Standards), surlace water and sediment at the point of compliance. These alternatives would also comply with location-and action-specific ARARs related to the discharge to the POTW and air emission controls. Alternatives GWP1, GWL 1, GWP2, GWL2, GWP3, and GWL3 are not expected to meet performance standards at the point of compliance, however, Alternatives GWP3 and GWL3 would comply with the location-specific ARAR related to operations at a hazardous waste w. Long-term Effectiveness and Permanence: Alternatives GWP4A, GWP4B, GWL4A, and GWL4B would provide an effective and permanent solution for groundwater, surface water, and ·sediment because the chemicals of concern would be removed from the groundwater and destroyed. The reliabMy of these alternatives is high. These alternatives would not pose a human health or environmental risk at the point of compliance and no treatment residuals would be left on Stte. Alternatives GWP3 and GWL3 would prevent potential future risk by preventing the Installation of drinking wells in any areas exceeding MCLs or North Carolina Groundwater Standards. Alternatives GWP1, GWL1, GWP2, and GWL2 wiH not be protective of human health and the environment in the long term because these alternatives do not remove, trea~ or 10 isolate subsu. wntamination. Five-year CERCLA mandated revi iill be required for all of the alternatives. Reduction of Toxicity, Mobility or Volume: Alternatives GWP4A, GWP4B, GWL4A, and 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. Alternatives GWP1, GWL 1, GWP2, GWL2, GWP3, and GWL3 do not direcUy reduce toxicity, mobility, or volume of groundwater, surface water or sediment contamination. Short-term Effectiveness: All of the alternatives can be implemented without significant risk to the communtty or on-site workers and without adverse environmental impacts. lmolementability: None of the alternatives pose significant concerns regarding implementation. Cost: Total present worth costs (based on 30 years) for the groundwater alternatives are presented below: AltemaUves GWP1/GWL 1 -No action: $227,000 AltemaUves GWP2/GWL2 -Long-Term Monitoring with Fencing A Portion of Northeast Tributary: $1,479,000 AltemaUves GWP3/GWL3 -Institutional Controls with Fencing A Portion of Northeast Tributary: $1,500,000 AltemaUve GWP4A -Groundwater Extraction/Air Stripping/Vapor-Phase Carbon Adsorption/POTW Discharge: $2,222,000 AltemaUve GWP4B -Groundwater Extraction/Air Stripping/Furne lncineratior\lPOTW Discharge : $2,274,000 AltemaUve GWL4A -Groundwater Extraction/Air Stripping/Vapor-Phase Carbon Adsorption/POTW Discharge: $3,570,000 AltemaUve GWL48 -Groundwater Extraction/Air Stripping/Fume lncineration/POTW Discharge: $2,996,000 SURFACE WATER/SEDIMENT The following alternatives were subjected to detailed analysis for surlace water and sediment remediation: AltemaUve SW1/SD1: No Action AltemaUve SW2/SD2: Long-Term Monitoring Overall Protection: Under present conditions, both Alternatives SW1/SD1 and SW2/SD2 would be protective of human health, but may not be protective of the environment. If higher concentrations of cont:Jlllints are discharged into the stream from the groundw~n neither alternative may be protective of human heallh nor the environment. Compliance wilh ARARs: There are no Federal or State ARARs for the contaminants detected in lhe surface water or sediment Long-term Effectiveness and Permanence: Under current conditions, Alternatives SW1/SD1 and SW2/SD2, would be protective of human health but possibly not the environment. If higher concentrations of contaminants begin,discharging Into the b'ibutary, none of these alternatives may be protective of human heallh. Reduction of Toxicity, Mobility or Volume: Both Alternatives SW1/SD1 and SW2/SD2 could lead to a reduction of volatile contaminants in the b'ibutary, however, neither of these alternatives would result in the destruction of the volatile contaminants. These contaminants would be transferred from the tributary to the atmosphere through the process of volatilization. Short-term Effectiveness: All of the alternatives can be implemented without significant risk to the community or on-site workers and without adverse environmental Impacts. · 11 Im lementabili · · ne "' the alternatives pose significant plementation. Cost: Total present worth costs {based on 30 years) for the surface water/sediment alternatives are presented below: Alternative SW1/S01 -No Action: $151,000 Alternative SW2/SD2 -Long-Term Monitoring: $867,000 State Acceptance: The NCDEHNR has reviewed and provided. E~A wilh <;!)1!11)181l!s P11 1h41 ,:epo[IS al)d "3ta fro111 _ . the RI and lhe FS. The NCDEHNR has also reviewed this proposed plan and EPA's preferred alternative and presenUy concurs with EPA's selection. Community Acceptance: Community acceptance of the preferred alternative wil be evaluated after the public comment period ends and a response to each comment will be Included In a Responsiveness summary which will be a part of the Record of Decision (ROD) for the Site. • • EPA'S PREFERRED ALTERNATIVE After conducting a detailed analysis of all the feasible cleanup alternatives based on the criteria described in the previous sections, EPA is proposing a cleanup plan to address groundwater, surface water, and sediment contamination at the Site. The EPA preferred alternatives are: GROUNDWATER REMEDIATION . ALTERNATIVES GWP3B AND GWL3B: Long-Term Monitoring/Institutional Controls; ALTERNATIVE GWP4B: Groundwater Extraction Through Wells and Treatment By Air Stripping with Fume Incineration; and ALTERNATIVE GWL4B: Groundwater Extraction Through Wells and Treatment By Air Stripping with Fume Incineration and Combine Treated Groundwater with Groundwater from OU- 1 for Discharge to the Salisbury POTW At a cost of $1,500,000, $2,279,000, and $2,996,000. SURFACE WATER/SEDIMENT ALTERNATIVE SW2/SD2: Long-Term Monitoring Cost: $867,000 An active groundwater remediation 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. 12 • • COUUUNITYPARTICPATION EPA has developed a community relations program as mandated by Congress under Superfund to respond to citizen's concerns and needs for information, and to enable residents and public officials to participate in the decision-making process. Public involvement activities undertaken at Supertund sites consist of interviews with local residents and elected officials, a community relations plan for each site, fact sheets, availability sessions, pubiic meetings, public comment periods, newspaper advertisements, site visits, and Technical Assistance Grants, and any other actions needed to keep.the community Informed and involved. EPA Is conducting a 30-day publlc convnent period from July 19, 1993 W August 17, 1993, to provide an opportunity for public involvement in selecting the final cleanup method for this Site. Public input on all alternatives, and on the information that supports the alternatives Is an important contribution to the remedy selection process. During this comment period, the public is Invited to attend a public meeting on August 3, 1993, at the Agricultural Extension Center Auditorium, 2727 Old Concord Road, Salisbury, North Carolina beginning at 7:00 p.m. at which EPA will present the Remedial Investigation/ Feasibility Study and Proposed Plan desaiblng the preferred alternative for treatment of the contaminated groundwater at the National Starch & Chemical Company Superfund Site and to answer any questions. Because this Proposed Plan Fact Sheet provides only a summary description of the cleanup alternatives being considered, the public is encouraged to consult the information repository for a more detailed explanation. During this 30-day period, the public Is invited to review all site-related documents housed at the information repository located at the Rowan County Public Library, 201 West Front Street, Salisbury, North Carolina and offer comments to EPA either orally at the public meeting which will be recorded by a court reporter or in written form during this time period. The actual remedial action could be different from the preferred alternative, depending upon new information or statements EPA may receive as a result of public comments. H you prefer to submit written comments, please mail them postmal1<ed no later than midnight August 17, 1993 to: Dia/NI Barrett NC Community Fl8latlons Coordlnatar · U.S.E.P.A., Region 4 North Remedial Superfund Branch 345 COU111and Stree4 NE Atlanta, GA 303S5 All comments wiU be reviewed and a response prepared in making the final determination of the most appropriate allarnative for cleanup,teatment of the Sita. EPA's final choice of a remedy will be issued in a Record of Decision (ROD). A document called a Responsiveness Sunvnary summarizing EPA's response 10 all public comments wiU also be Issued with the ROD. Once the ROD is signed by the Regional Administrator ij wiU become part of the Administrative Record (located at the Library) which contains all documents used by EPA in making a final determination of the best cleanupMlatment for the Site. Once the ROD has been approved, EPA will begin negotiations with the PotenUally Responsible Parties (PRPa) ID allow them the opportunity to design, implement and absol1l all costs of the remedy determined 11 the ROD in accordance with EPA guidance and protocol. If negotiations do not result in a settlement, EPA may conduct the remedial activi1y using Superfund Trust monies, and sue for reimbursement of~ costs with the assistance of the Department of Justice. Or EPA may issue a unilalaral administrative order or directiy file suit ID force the PRPs to conduct the remedial activity. Once an agreement has been reached, the design of the selected remedy wUI be developed and implementation of the remedy can begin. The preceding actions are the standard procedures utilized during the Superfund process. As part of the Supertund program, EPA provides affected communities by a Superfund site with the opportumy to apply for a Technical Assistance Grant (TAG). This grant of up to $50,000 enables the group to hire a technical advisor or consultant ID assist them in interpreting or commenting on site findings and proposed remedial action plans. For more information concerning this grant program, please contact: Ms. Ros6mary Patton, Coordinator NC Technical Ass/stara Grants Waste Managem1111t Division U.S.E.P.A., Region 4 345 Courtland Stree~ NE Atlanta, GA 30365 (404/ 347-2234 13 • r, l INFORMATION REPOSITORY LOCATION: Rowan County Public Library 201 West Fisher Street Salisbury, North caro0na 21144 Phone: (704) 633-5578 Hours: llonday · Friday 8:00 a.m. · 9:00 p.m. Saturday 9:00 a.m. · 5:00 p.m. I I FOR IIORE INFORMATION ABOUT SITE ACTIVITIES, PLEASE CONTACT: Yr. Jon Bomholm, Remedial Project llanager or 11s. Diane Barrett, NC Comnullty Relations Coordinator North SUperfwld Remedial Branch Waste llanagemenl Division U.S. Enmlnmenlal Protedlon Agency, Region IV 345 Courtland S1reet, NE Atlanla, Ga 30365 Toll Free No.: 1-800-435-9233 GLOSSARY OF TERIIS USED IN THIS FACT SHEET Aquffer: Ari underground geological formation, or group of formations, containing usable amounts of groundwater that can supply weUs and springs. Administrative Rscord: A file which is maintained and contains all information used by the lead agency to make its decision on the selection of a method to be utilized to clean up,1reat contamination at a Superfund slta. This file is held in the information repository for public review. Appllcabls or Relevant and Appropriate Requirements (ARAJls): The federal and stata requirements that a selected remedy must attain. These requirements may vary among sitas and various alternatives. Base/Ins Risk Assllssment: A means of estimating the amount of damage a Superfund slta could cause to human heath and the environment ·Objectives of a risk assessment are to: help determine the need for action; help determine the levels of chemicals that can remain on the slte alter deanup and still protect health and the environment; and provide a basis for comparing different deanup methods. 14 •• • • Carcinogen: Any substance that can cause or contribute lo the production of cancer; cancer-producing. ComprehllllS/ve Environmental Response, Compensation and Liability Act (CERCLAJ: A federal law passed in 1980 and modified In 1986 by the Superfund Amendments and Reau1horization Act (SARA). The Acts created a special tax paid by producers of vartous chemicals and oil products that goes into a Trust Fund, commonly known as Superfund. These Acts give EPA the au1hority to Investigate and clean up abandoned or uncontroUed hazardous waste sites utilizing money from the Superfund Trust or by taking legal action to force parties responsible for the contamination lo pay for and clean up the site. · Grounctwatsr: Water found beneath the earth's surface that fills pores between materials such as sand, soll, or gravel (usually· in aquffers) which is often used for supplying wells and springs. Because groundwater is a major source of drinking water there is growing concern over areas where agricultural and industrial pollutants or substances are getting into groundwater. Hazardous Ranking System (HRS): The principle screening IDol used by EPA to evaluate risks to public health and the envirorvnent associated with hazardous waste sites. The HRS calculates a score based on the potential of hazardous substances spreading from the site through the air, surface water, or groundwater and on other factors such as nearby population. This score is the primary factor in deciding if the site should be on the National Priorities List and, ij so, what ranking~ should have compared to other sites on the ist. Information Repository: A file containing accurate up-to-oote Information, technical reports, reference documents, Information about the Technical Assistance Grant, and any other materials pertinent to the site. This file is usually located In a public buUding such as a library, city hall or school, that Is accessible for local residents. Maximum Contaminant Levels (MCLs): The maximum permissible level of a contaminant in water delivered to any user of a public water system. MCLs are enforceable standards. National Pollutant Discharge Elimination System (NPDESJ: A provision of the aean Water Act which prohibits the discharge of pollutants. into waters of the inked States uniess a special permit is issued by EPA. a state or (where delegated) a tribal government on an Indian reservation allowing a controlled discharge of liquid after ~ has undergone treatment. National Priorities List (NPL): EPA's list of the most serious uncontrolled 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. The list is based primarily on the score a site receives from the Hazard Ranking System (HRS). EPA is required to update the NPL at least once a year. Potsntlally Responsible Parties (PRPs): Any Individual or company -including owners, operators, transporters, or generators -potentially responsible for, or contributing to, the contamination problems at a Superfund site. Whenever possible, EPA requires PRPS, through administrative and legal actions, lo clean up hazardous waste sites PRPs have contaminated. Remedial lnvestlgatlM'Feaslb/Uty Study (R//FSJ:The Remedial Investigation is an in-<lepth, extensive sampling and analytical study to gather data necessary to determine the nature and extent of contamination at a Superlund site; to establish criteria for cleaning up the she; a description and analysis of the potential cleanup alternatives for remedial actions; and support the technical and cost analyses of the alternatives. The FeasibiUty study also usually recommends selection of a cost-effective alternative. Record of Decision (ROD): A public document that announces and explains which method has been selected by the Agency to be used at a Superfund site to clean up the contamination. Responsiveness summary: A summary of oral and written public comments received by EPA during a public comment period and EPA's responses to those comments. The responsiveness summary is a key part of the Record of Decision. 5eml-VolaU/e Organic Compounds (SVOCsJ: ~ntaining chemical compounds that at a relatively low temperature, fluctuate between a vapor state (a gas) and a liquid state. Vo/at/le Organic Compounds (VOCSJ: Any organic compound that evaporates readily into the air at room temperature. Watsr Table: The level below which the soil or rock is saturated with water, somtimes referred to as the upper surface f the saturated zone. The level of groundwater. 15 • • ----------, I I I I '· Rtglon 4 MAILING LIST ADDITIONS If you are not already on OIi' malling list and would like to be placed on the list to receive future lnfonnaUon on the Natlonal Starch & Chemcal Company SUperfund Sita, please complete this fonn and return to Diane Barrett, Convnunlty Relations Coordinator at the above address: NAME·;,._ ______________________________ _ ADDRESS;._·------------------------------- CITY, STATE, ZlPCODE: _________________________ _ PHONE NUMBER;._· __________________ .:..,... _______ _ i:;/ U.S. Envlronmonlal Proltclion Agoncy 345 Ccurtland St-, N.f. Adonla, Georgia 30365 Notth &Jporfund Romodlal Branch Dlant Barna, CcmmJnlty Rolalionl Co«d. Jon Bomholm, Rlmodlal Pn>jlct llanall" ; • • • j Offlclal e .. in- Ponalty for Prfvllo U,, $300 ~:SCCOOL 1 Mt,:,. Jr,UCi.: i~ lCtiUL'.)UN Ei•iVL~Jr~~\El•1l'AL ~NG~., SUPE~'.FUtJO SECTIOf~ ~-c. DtPT. UF E~VIkONMEN·r, HEALTH l ~ATUkAL kESOURCES P. J. r,LJ" 27bo7 RALt: ll.,ri t,C 27olL-7bi:i-l I I I I L,2-DICHLOROETHANE . . S. DEPARTMENT OF HEALTH & HUMAN SERVICES 1blic Health Service ~ency for Toxic Substances and Disease Registry omment Period Ends: ebruary 19, 1993 •" Federal Recycling Program t • Printed on Recycled Paper ..• ~ •• •• 1. PUBLIC HEALTH STATEMENT This Statement was prepared to give you infonnation about 1,2-dichloroethane and to emphasize the human health effects that may result from exposure to it. The Environmental Protection Agency (EPA) has identified 1,300 hazardous waste. sites as the most serious in the nation. These sites comprise the "National Priorities List" (NPL): Those sites which are targeted for long-tenn federal cleanup activities. 1,2-Dichloroethane has been found in at least 446 of the sites on the NPL. However, the number of NPL sites evaluated for 1.2-dichloroethane is not known. As EPA evaluates more sites, the number of sites at which 1,2-dichloroethane is found may increase. This infonnation is important because exposure to 1.2-dichloroethane may cause harmful health effects and because these sites are potential or actual sources of human exposure to 1 ,2-dichloroethane. When a substance is released from a large area, such as an industrial plant, or from a container, such as a drum or bottle, it enters the environment This release does. not always lead to exposure. You can be exposed to a substance only when you come in contact with it. You may be exposed by breathing, eating, or drinking substances containing the substance or by skin contact with it. If you are exposed to a substance such as 1,2-dichloroethane, many factors will determine whether harmful health effects will occur and what the type and severity of those health effects will be. These factors include the dose (how much}, the duration (how long), the route or pathway by which you are exposed (breathing, eating, _drinking, or skin contact}, the other chemicals to which you are exposed, and your individual characteristics such as age, gender, nutritional status, family traits, life-style, and state of health. 1.1 WHAT IS 1,2-DICHLOROETHANE? 1,2-Dichloroethane is a dear, man-made liquid that is not found naturally in the environment. It evaporates at room temperature and has a pleasant smell and a sweet taste. 1,2-Dichloro- ethane burns with a smoky flame. Its most common use today is to make vinyl chloride and several substances that dissolve grease, glue, and dirt. 1,2-Dichloroethane is also added to leaded gasoline to remove lead. In the past, it was also found in trace amounts in products that industry used to clean cloth, remove grease from metal, and to break down oils, fats, waxes. resins, and rubber. In the household, 1,2-dichloroethane was formerly a component of some cleaning solutions and pesticides; some adhesives, such as those used to glue wallpaper or carpeting; and some paint, varnish, and finish removers. Although large amounts of 1,2-dichloroethane are produced today, most is used to make other chemical products. Small amounts of 1,2-dichlorocthane released into water or soil evaporate into the air. 1,2-Dichloroethane does not stay in the air for _very long because it is readily broken down by the sun. 1 ,2-Dichloroethane that remains in soil from a spill or improper •-DRAFT FOR PUBLIC COMMENT,_ 2 •• 1. PUBLIC HEALTH STATE •• disposal can travel through the ground into water. The chemical may remain in water m soil for more than 40 days. Chapter 3 contains·'more chemical and physical information about 1,2-dichloroethane. Chapter 4 has more information on its uses, and Chapter .. 5 tells ahnut its presence in the environment. 1.2 WHAT HAPPENS TO 1,2-DICHLOROETHANE WHEN IT ENTERS THE ENVIRONMENT? 1,2-Dichloroethane can enter the environment when it is made, packaged, shipped. m used. Most 1,2-dichloroethane is released to the air, although some is released to rivers or lakes. 1,2-Dichloroethane could also enter soil, water, or air in large amounts in an accidental spill. 1,2-Dichloroethane evaporates into the air very fast from soil and water. In the air ii breaks down by reacting with other compounds formed by the sun. 1,2-Dichloroethane will stay in the air for 47-182 days. It may also .be removed from air in rain or snuw. Since it stays in air for a while, the wind may transport it over large distances. In water, 1,2-dichloroethane breaks down very slowly and most of it will evaporate tll the air. Only very small amounts are taken up by plants, fish, and birds. We do nllt know exactly how long 1,2-dichloroethane stays in water, but we do know that it stays lllnger in lakes than in rivers. In soil, 1,2-dichloroethane either evaporate~ into the air or travels down through sllil and enters underground water. Small living organisms in soil and groundwater may transform it into other less harmful compounds, although this happens slowly. If a large amount llf 1,2-dichloroethane enters soil from an accident, hazardous waste site, or landfill. ii may travel a long way underground and contaminate drinking water wells. More information on what happens to 1,2-dichloroethane in the environment can he found in Chapters 4 and 5. 1.3 HOW MIGHT I BE EXPOSED TO 1,2-DICHLOROETHANE? Humans are exposed to 1,2-dichloroethane mainly by brea.thing it or by drinking water that contains 1,2-dichloroethane. Human exposure usually happens where the chemical has been improperly disposed of, or spilled onto the ground. However, 1,2-dichloroethane has also been found in the air near industries where it is made ur used in manufacturing. Humans can be exposed 10· low levels of 1,2-dichlornethane -. through the skin or air by contact with old products made with l,2-dichluroe1hane. such · _. as cleaning agents, pesticides, and glued wallpaper and carpet. Such exposure is probably not enough to cause harmful health effects. 0 * DRAFT FOR PUBUC COMMENT*-* 3 •• PUBLIC HEALTH STATEMENT •• 1,2-Dichloroethane has been found in U.S. drinking water at levels ranging from 0.05 to 19 parts of 1,2-dichloroethane per billion (ppb) parts of water. An average amount of 175 ppb has been found in 12% of the surface water and groundwater samples taken at 2,783 hazardous wastes sites. 1,2-Dichloroethane has also been found in the air near urban areas at levels of 0.1-1.5 ppb and near hazardous waste sites at levels of 0.01-0.003 ppb. Humans may also be exposed to 1,2-dichloroethane through its use as a gasoline additive to reduce lead content, but these small levels are not expected to affect human health. As the use of leaded gasoline declines, fewer people will be exposed to 1,2-dichloroethane this way. Additional information on levels in the environment and potential for human exrmsure are presented in Chapter 5. 1.4 HOW CAN 1,2-0ICHLOROETHANE ENTER AND LEAVE MY BODY? 1,2-Dichloroethane can enter the body when people breathe air or drink water that contains 1,2-dichloroethane. Studies in animals also show that 1,2-dichloroethane can enter the body through the skin. Humans are most likely to be exposed in and outside the workplace by drinking water containing 1,2-dichloroethane or by breathing 1,2-dichloroethane that has escaped from contaminated water and soil into the air. Experiments in animals show that 1,2-dichloroethane that is breathed in or eaten goes to many organs of the body but usually leaves in the breath within I or 2 days. The breakdown products of 1,2-dichloroethane in the body leave quickly in the urine. Soil near hazardous waste sites probably does not have high amounts of 1,2-dichlornethane _because it evaporates quickly into the air. So exposure near a hazardous waste site occurs more often by breathing contaminated air rather than by touching contaminated soil. Further information on how 1,2-dichloroethane can enter and leave the hody is presented in Chapter 2. 1.5 HOW CAN 1,2-DICHLOROETHANE AFFECT MY HEAL TH? People who were accidentally exposed to large amounts of 1,2-dichloroethane in air or who accidentally or intentionally swallowed 1,2-dichloroethane often developed nervous system disorders and liver and kidney disease. They often died from heart failure. We do not know what levels of 1,2-dichloroethane caused these effects. Studies in experimental animals also found that breathing or swallowing large amounts of 1,2-dichloroethane produced nervous system disorders and kidney disease. Reduced ability to fight infection was also seen in experimental animals who breathed or swallowed 1,2-dichloroethane, but no evidence of this has been reported in humans. Longer-term exposure to lower doses also caused kidney disease in animals. Evidence •u DRAFT FOR PUBLIC COMMENT *** 4 •• 1. PUBLIC HEALTH STATE-• from animal studies suggests that 1,2-dichloroethane probably does not produce hirth defects or affect reproduction. Exposure to 1,2-dichloroethane has so far not been associated with cancer in humans. However, cancer was seen in laboratory animals who were fed large doses of the chemical. When 1,2-dichloroethane was put on the skin of k~oratory animals. they developed lung tumors. Breathing 1,2-dichloroethane may also cause cancer in anim,lls. In view of the cancer findings in animals, one cannot rule out the possihility of cancer in humans. The Department of Health and Human Services (DHHS) has determined 1ha1 l,2-dichloroethane may reasonably be anticipated to be a carcinogen. The lnternati"nal Agency for Research on Cancer (!ARC) has determined that 1,2-dichloroethane is possibly carcinogenic to humans. EPA has determined that 1,2-dichloroethane is a probable human carcinogen. 1.6 IS THERE A MEDICAL TEST TO DETERMINE WHETHER I HAVE BEEN EXPOSED TO 1,2-DICHLOROETHANE? 1,2-Dichloroethane has been found in the breath, blood, breast milk, and urine of exposed people. Because breath samples are easily collected, testing breathed-out "r exhaled air is now a possible way to find out whether someone has been recently exposed to 1,2-dichloroethane. However, tests that measure small amounts in human hreath. tissues, and fluids may not be available at your doctor's offices because they re4uire special equipment. Your physician can refer you to a facility where these tests are done. Although these tests can show that someone has been exposed to 1,2-dichloroethane. it 1s not possible to tell if you will experience any harmful health effects. Because 1,2-dichloroethane leaves the body fairly quickly, these methods are best for finding exposures that occurred within the last several days. Exposure to l,2-dichlori1ethane at hazardous waste sites will probably include exposure to other organic compounds at the same time. Therefore, levels of 1,2-dichloroethane measured in the hody hy these medical tests may not show exposure to 1,2-dichloroethane only. Other medical tests available at a doctor's office include x-rays, and lung-, liver-, and kidney-function tests: but these tc;sts look for damage that has already occurred from general chemical exposure and do not determine the cause of damage. Damage could also he the result of lifestyle ( e.g., alcohol consumption, smoking) or general exposure to environmental agents. Other ways to measure ·the effects of exposure to 1,2-dichloroethane (such as .abnormal enzyme levels) do not measure the effects of exposure to 1,2-dichloroethane only, but measure effects of other chemicals as well. 1.7 WHAT RECOMMENDATIONS HAS THE FEDERAL GOVERNMENT MADE TO PROTECT HUMAN HEAL TH? The federal government has developed regulatory standards and guidelines t" prntect people from .the possible health effects of 1,2-dichloroethane in air. The Occupati"nal Safety and Health Administration (OSHA) has set a limit of I part 1.2-dichlomethane per million (ppm, I ppm is 1,000 times more than I ppb) parts of air in the workplace for an 8-hour day, 40-hour week. The National Institute for Occupational Safety and *** DRAFT FOR PUBLIC COMMENT **" 1. PUBLIC HEALTH STATEMENT •• •• Health (NIOSH) recommends that a person not be exposed daily in the wmkrl:,ce t" more than 1 ppm 1,2-dichloroethane for a 10-hour day, 40-hour week. NlOSH Gills 1,2-dichloroethane a possible occupational carcinogen. EPA also calls the comruund a probable human cancer-causing agent, based on experiments in animals. The federal government has set regulatory standards and guidelines to protect peuple from the possible health effects of 1,2-dichloroethane in drinking water. EPA has set a limit in water of 0.005 milligrams of 1,2-dichloroethane per liter. EPA is considering lowering the levels at which accidentally spilled 1,2-dichloroethane must be reported tu the federal government. EPA is also measuring the levels of 1,2-dichloroethane found :It abandoned waste sites. 1.8 WHERE CAN I GET MORE INFORMATION? If you have any more questions or concerns, please contact your community or state health or environmental quality department or: Agency for Toxic Substances and Disease Registry Division of Toxicology 1600 Clifton Road NE, E-29 Atlanta, Georgia 30333 ( 404) 63 9-6000 This agency can also provide you with information on the location of occupational and environmental health clinics. These clinics specialize in. the recognition, evaluation, and treatment of illness resulting from exposure to hazardous substances. *** DRAFT FOR PUBLIC COMMENT 0 * •• IJ2-DICHLOROETHANE . . S. EPARTMENT OF HEALTH & HUMAN SERVICES 1blid Health Service ,gene~ for Toxic Substances and Disease Registry . I ~oI! ent Period Ends: i"eb ary 19, 1993 . ., Fedora Recycling Program t t Printed on Recycled Paper •• •• •• 1. PUBLIC HEALTH STATEMENT This Statement was prepared to give you infonnation about 1,2-dichloroethane and to emphasize the human health effects that may result from exposure to it. The Environmental Protection Agency (EPA) has identified 1,300 hazardous waste_ sites as the most serious in the nation. These sites comprise the "National Priorities List" (NPL): Those sites which are targeted for long-tenn federal cleanup activities. 1,2-Dichloroethane' has been found in at least 446 of the sites on the NPL. Howeve.r, the number of NPL sites evaluated for l.2-dichloroethane is not known. As EPA evaluates more sites, the number of sites at which 1,2-dichloroethane is found may increase. This infonnation is important because exposure to 1.2-dichloroethane may cause harmful health effects and because these sites are potential or actual sources of human exposure to 1,2-dichloroethane. When a substance is released from a large area, such as an industrial plant, or from a container. such as a drum or _bottle, it enters the environment This release does. not always lead to exposure. You can be exposed to a substance only when you come in contact with it. You may be exposed by breathing, eating, or drinking substances containing the substance or · by skin contact with it. If you are exposed to a substance such as 1,2-dichloroethane, many factors will detennine whether harmful health.effects will occur and what the type and severity of those health effects will be. These factors include the dose (how much}, the duration (how long), the route or pathway by which you are exposed (breathing, eating, drinking, or skin contact}, the other chemicals to which you are exposed, and your individual characteristics such as age, gender, nutritional status, family traits, life-style, and state of health. 1,1 WHAT IS 1,2-DICHLOROETHANE? 1,2-Dichloroethane is a clear, man-made liquid that is not found naturally in the environment. It evaporates at room temperature and has a pleasant smell and a sweet taste. 1,2-Dichloro- ethane burns with a smoky flame. Its most common use today is to make vinyl chloride and several substances that dissolve grease, glue, and dirt. 1,2-Dichloroethane is also added to leaded gasoline to remove lead. In the past, it was also found in trace amounts in products that industry used to clean cloth, remove grease from metal, and to break down oils, fats, waxes, resins, and rubber. In the household, 1,2-dichloroethane was fonnerly a component of some cleaning solutions and pesticides; some adhesives, such as those used to glue .wallpaper or carpeting; and some paint, varnish, and finish removers. Although large amounts of 1,2-dichloroethane are produced today, most is used to make other chemical products. Small amounts of 1,2-dichloroethane released into water or soil evaporate into the air. 1,2-Dichloroethane does not stay in the air for very long because it is readily broken down by the sun. 1,2-Dichloroethane that remains in soil from a spill or improper ••• DRAFT FOR PUBLIC COMMENT - 2 •• 1. PUBLIC HEALTH STATE~ • disposal can travel through the ground into water. The chemical may remain in w,Jter m · soil for more than 40 days. Chapter 3 contains more chemical and physical information about 1,2-dichloroethane. Chapter 4 has more information on its uses, and Chapter 5 tells ahout iis presence in the environment . . 1.2 WHAT HAPPENS TO 1,2-DICHLOROETHANE WHEN IT ENTERS THE ENVIRONMENT? 1,2-Dichloroethane can enter the environment when it is made, packaged, shipped, or used. Most 1,2-dichloroethane is released to the air, although some is released to rivers or lakes. 1,2-Dichloroethane could also enter soil, water, or air in large amounts in ,in accidental spill. 1,2-Dichloroethane evaporates into the air very fast from soil and water. ln the air it breaks down by reacting with other compounds formed by the sun. 1,2-Dichloroethane will stay in the air for 47-182 days. It may also be removed from air in rain or snow. Since it stays in air for a while, the wind may transport it over large distances. In water, 1,2-dichloroethane breaks down very slowly and most of it will evaporate to the air. Only very _small amounts are taken up by plants, fish, and birds. We do not know exactly how long 1,2-dichloroethane stays in water, but we do know that it stays longer in lakes than -in rivers. In soil, 1,2-dichloroethane either evaporates into the air or travels down through soil and enters underground water. Small living organisms in soil and groundwater may transform it into other less harmful compounds, although this happens slowly. If a large amount of 1,2-dichloroethane enters soil from an accident, hazardous waste site, or landfill, it may travel a long way underground and contaminate drinking water wells. More information on what happens to 1,2-dichloroethane in the environment can he found in Chapters 4 and 5. 1.3 HOW MIGHT I BE EXPOSED TO 1,2-DICHLOROETHANE? Humans are exposed to 1,2-dichloroethane mainly by breathing it or by drinking water that contains 1,2-dichloroethane. Human exposure usually happens where the chemical has been improperly disposed of, or spilled onto the ground. However, 1,2-dichloroethane has also been found in the air near industries where it is made or used in manufacturing. Humans can be exposed 10· low levels of 1,2-dichloroethane through the skin or air by contact with old products made with l ,2-dichloroeth,rne. such as cleaning agents, pesticides, and glued wallpaper and carpet. Such exposure is probably not enough to cause harmful health effects. 0 * DRAFT FOR PUBUC COMMENT""'* 3 PUBLIC HEALTH STATEMENT •• 1,2-Dichloroethane has been found in U.S. drinking water at levels ranging from ().(15 tll 19 parts of 1,2-dichloroethane per billion (ppb) parts of water. An average amount ,if 175 ppb has been found in 12% of the surface water and groundwater samples taken at 2,783 hazardous wastes sites. 1,2-Dichloroethane has also been found in the air near urban areas at levels .of 0.1-1.5 ppb and near hazardous waste sites at levels of 0.01-0.003 ppb. Humans may also be exposed to 1,2-dichloroethane through its use as a gasoline additive to reduce lead content, but these small levels are not expected to affect human health. As the use of leaded gasoline declines, fewer people will be exposed to 1,2-dichloroethane this way. Additional information on levels in the environment and potential for human exrmsure are presented in Chapter 5. 1.4 HOW CAN 1,2-DICHLOROETHANE ENTER AND LEAVE MY BODY? 1,2-Dichloroethane can enter the body when people breathe air or drink water that contains 1,2-dichloroethane. Studies in animals also show that 1,2-dichloroethane can enter the body through the skin. Humans are most likely to be exposed in and outside the workplace by drinking water containing 1,2-dichloroethane or by breathing 1,2-dichloroethane that has escaped from contaminated water and soil into the air. Experiments in animals show that 1,2-dichloroethane that is breathed in or eaten goes to many organs of the body but usually leaves in the breath within 1 or 2 days. The breakdown products of 1,2-dichloroethane in the body leave quickly in the urine. Soil near hazardous waste sites probably does not have high amounts of 1,2-dichloroethane because it evaporates quickly into the air. So exposure near a hazardous waste site · 'occurs more often by breathing contaminated air rather than by touching contaminated soil. Further information on how 1,2-dichloroethane can enter and leave the body is presented in Chapter 2. 1.5 HOW CAN 1,2-DICHLOROETHANE AFFECT MY HEAL TH? People who were accidentally exposed to large amounts of 1,2-dichluroethane in air or who accidentally or intentionally swallowed 1,2-dichloroethane often developed nervous system disorders and liver and kidney disease. They often died from heart failure. We do not know what levels of 1,2-dichloroethane caused these effects. Studies in experimental animals also found that breathing or swallowing large amounts of 1,2-dichloroethane produced nervous system disorders and kidney disease. Reduced ability to fight infection was also seen in experimental animals who breathed or swallowed 1,2-dichloroethane, but no evidence of this has been reported in humans. Longer-term exposure to lower doses also caused kidney disease in animals. Evidence •u DRAFT FOR PUBLIC COMMENT ... • 4 •• 1. PUBLIC HEALTH STATE •• from animal studies suggests that 1,2-dichloroethane probably does not produce hirth defects or affect reproduction. Exposure to 1,2-dichloroethane has so far not been associated ·with cancer in humans. However, cancer was seen in laboratory animals who were fed large doses of the chemical. When 1,2-dichloroethane was put on the skin of laboratory animals, they developed lung tumors. Breathing 1,2-dichloroethane may also cause cancer in anim,ils. In view of the cancer findings in animals, one cannot rule out the possihility of cancer in humans. The Department of Health and Human Services (DHHS) has determined that 1,2-dichloroethane may reasonably be anticipated to be a carcinogen. The International Agency for Research on Cancer (!ARC) has determined that 1,2-dichloroethane is possibly carcinogenic to humans. EPA has determined that 1,2-dichloroethane is a probable human carcinogen. 1.6 IS THERE A MEDICAL TEST TO DETERMINE WHETHER I HAVE BEEN EXPOSED TO 1,2-DICHLOROETHANE? 1,2-Dichloroethane has been found in the breath, blood, breast· milk, and urine of exposed people. Because breath samples are easily collected, testing breathed-out or exhaled air is now a possible way to find out whether someone has been recently exposed to 1,2-dichloroethane. However, tests that measure small amounts in human hreath. tissues, and fluids may not be available at your doctor's 6ffices because they re4uire special equipment. Your physician can refer you to a facility where these tests are done. Although these tests can show that someone has been exposed to 1,2-dichloroethane. it 1s not possible to tell if you will experience any harmful health effects. Because 1,2-dichloroethane leaves the body fairly quickly, these methods are best for finding exposures that occurred within the· last several days. Exposure to 1,2-dichloroethane at hazardous waste sites will probably include exposure to other organic compounds at the same time. Therefore, levels of 1,2-dichloroethane measured in the hody hy these medical tests may not show exposure to 1,2-dichloroethane only. Other medical tests available at a doctor's office include x-rays, and lung-, liver-, and kidney-function tests. but these tc;sts look for damage that has already occurred from general chemical exposure and do not determine the cause of damage. Damage could also be the result of lifestyle ( e.g., alcohol consumption, smoking) or general exposure to environmental agents. Other ways to measure the effects of exposure to 1,2-dichloroethane (such as abnormal enzyme levels) do not measure the effects of exposure to 1,2-dichloroethane only, but measure effects of other chemicals as well. 1.7 WHAT RECOMMENDATIONS HAS THE FEDERAL GOVERNMENT MADE TO PROTECT HUMAN HEAL TH? The federal government has develc,,ed regulatory standards and guidelines to protect people from the possible health effects of 1,2-dichloroethane in air. The Occupational Safety and Health Administration (OSHA) has set a limit of 1 part 1.2-dichloroethane per million (ppm, 1 ppm is 1,000 times more than I ppb) parts of air in the workplace for an 8-hour day, 40-hour week. The National Institute for Occupational Safety and ••• DRAFT FOR PUBLIC COMMENT "' 1. PUBLIC HEALTH STATEMENT •• •• Health (NIOSH) recommends that a person not be exposed daily in the workpl,1ce Ill more than I ppm 1,2-dichloroethane for a IO-hour day, 40-hour week. NIOSH calls 1,2-dichloroethane a possible occupational carcinogen. EPA also calls the rnmpllund ,1 probable human cancer-causing agent, based on experiments in animals. The federal government has set regulatory standards and guidelines to protect people from the possible health effects of 1,2-dichloroethane in drinking water. EPA has set a limit in water of 0.005 milligrams of 1,2-dichloroethane per liter. EPA is considering lowering the levels at which accidentally spilled 1,2-dichloroethane must be reported to the federal government. EPA is also measuring the levels of 1,2-dichloruethane luund at abandoned waste sites. 1.8 WHERE CAN I GET MORE INFORMATION? If you have any more questions or concerns, please contact your community or state health or environmental quality department or: Agency for Toxic Substances and Disease Registry Division of Toxicology 1600 Clifton Road NE, E-29 Atlanta, Georgia 30333 ( 404) 63 9-6000 This agency can also provide you with information on the location of occupational and environmental health clinics. These clinics specialize in the recognition, evaluation, and treatment of illness resulting from exposure to hazardous substances. ••• DRAFT FOR PUBLIC COMMENT *** • SUPERFUND UPDATE Fact Sheet NATIONAL STARCH & CHEMICAL COMPANY REGION IV Salisbury, Rowan County, North Carolina INTRODUCTION: The U.S. Environmental Protection Agency is pleased to provide a status report of activities to date at the National Starch and Chemical ,., ___ "_ .. "''S,..,,..,) "upc-" .. -" "'•e Th1"° Cort \..-V1Uf-1u.J.1J \l-i \..,\... u 1 J.U11U. uu. , u .., i. 1.-1,._, Sheet specifically will explain the current ac- tivities that have occurred in Operable Units 1, 2, and 3. SITE BACKGROUND AND HISTORY: The NSCC Site is located on the outskirts of the Salisbury city limits. Edward Proctor of Salisbury founded the Proctor Chemical Com- pany in 1938. In September 1968, Proctor purchased the 465-acre Cedar Springs Road property. Within the next year, Proctor Chemical was acquired by NSCC and operated as a separate subsidiary. Construc- tion of the Cedar Springs Road plant began in 1970. On January 1, 1983, Proctor Chemical Company was dissolved and its operations merged with NSCC. NSCC's Salisbury facility is primarily a manufacturing plant for June 1991 textile finishing and custom specialty chemi- cals. From 1971 to 1978, the NSCC conducted on- site disposal of approximately 350,000 gal- lons ofreaction vessel wash waters in trenches constructed in a 5-acre tract of land (the trench area) located west of the plant The corrosive wash water consisted predominantly of salt brines, sulfuric acid solutions, and solvents. The water was dis- posed in several trenches approximately 200 to 300 feet long and 8 feet deep. Liquid effluent from the plant production area flowed into the easternmost unlined pretreat- ment holding lagoon, and was pumped to the active trench area. Each trench was used until liquid no longer readily percolated into the ground. Afterwards the trench area was back- filled and seeded, and a new trench area was constructed. In 1976, eight monitoring wells were installed around the Site by National Starch to deter- mine if the trenching operations were impact- • ing groundwater quality. Four of these monitoring wells were installed adjacent to or within the trench area. Monitoring revealed that shallow groundwater immediately within and adjacent to the trench area was con- taminated. In June 1977; sampling by the North Carolina Department of Natural and Economic Resources, Division of Environ- mental Management (DEM) verified National Starch's earlier conclusion that some of the monitoring wells were contaminated. Based on analysis of samples taken at that time, DEM requested that National Starch cease on- site waste disposal activities at the Cedar Springs Road Plant. Since 1978, when the City of Salisbury installed a sewer line for the plant's usage, production plant process waters have been directed to a pretreatment facility, going through the sanitary sewer system. Three of the eight monitoring wells were sampled by DEM in January 1983. DEM found that the well located in the center of the disoosal area contained the metals cadmium, cirr'omium, copper, lead, and zinc. These · materials were not detected in the two wells adjacent to the disposal area. National Starch sampled the monitoring wells from September through October 1984. Sig- nificant contamination of the wells within and adjacent to the disposal area was found during the October 1984 sampling. The metals cad- mium, arsenic, chromium, copper, lead, nick- el, zinc, and silver were found in the well in the center of the disposal area, along with a variety of volatile and semi-volatile organic chemicals. The October 1984 sampling was followed by a DEM sampling in late October 1984, with similar findings. The North Carolina Division of Health Services (DHS) sampled private wells within 2 miles of the National Starch Site in October 1984. No volatile organic compounds were detected. The Rowan County Health Department • (RCHD) also sampled private wells in proximity to the National Starch Site. None of the chemical compounds sampled for were found. The NSCC Site was proposed for inclusion on the National Priorities List (NPL} in April 1985 with EPA assuming lead responsibility for the Site. Negotiations to allow NSCC to conduct the Remedial Investiga- tion/Feasibility Stqdy (RI/FS) activities were concluded with signature of an Administrative Order on Consent on December 1, 1986. These activities resulted in the issuance of the first ROD for the Site. 2 The first ROD addressed the remedy for the groundwater contamination at the Site. This ROD was signed in September 1988 and was ; termed Operable Unit 1. The ROD also . specified that soil contamination in the trench · area be further investigated to determine whether this area continued to be a major source· of groundv.,ater contanii~ation. The first ROD also required that analytical monitoring continue on contaminated surface water and sediments to further delineate the source of contaminants to the creek. Installa- tion of extraction wells began in August 1990 which constitutes the initial Remedial Action (RA) for Operable Unit 1. The second ROD addressed the soil con- tamination in the trench area as a source con- trol. This ROD was signed in September 1990 and was termed Operable Unit 2. The remedy selected for this Operable Unit was the no action alternative which will be described below. This ROD also outlined the need for a third Operable Unit to describe the extent of contamination in the Northeast tributary. ' Site Location Map National Starch and ChemiA::irporation Site . Rowan County, North Carolina 0 SCALE 1 inch equals 8 miles H 0 H H 5 NSCC SUPERFUND SITE \ . \ Nallonal \ Chemleal Corporation Starch and \ 00\ O·--"~-·~ CONTOUR INTERVAL 10 FEET 3 CURRENTSTATUSQFTHE SITE: Operable Unit 1 -This ROD required the development of a groundwater interception and extraction system to be installed downgradient of the contamination plume. Pretreatment for the extracted groundwater in- cludes air stripping, filtration through ac- tivated carbon, metals removal, and treatment through the company's existing lagoon sys- tem. Presently NSCC is negotiating with the Salisbury Publicly Owned Treatment Works (POTW) for the discharge of the treated water. A contingency plan for an alternative discharge point was included in the ROD if permit requirements for the POTW cannot be met. Operable Unit 2 -The second Remedial In- vestigation confinned very low levels of residual contaminants in this area. The Con- sent Decree for this ROD is anticipated to be signed in the summer of 1991. The ROD called for a no action alternative which would leave the contaminated soils in place. This will allow for the naturally occurring leaching or cleaning of the soil in conjunction with groundwater remediation. Leachate from the residual soil contamination would be ex- tracted and treated by the groundwater extrac- tion system. Infiltration to groundwater is the only route of migration and subsequent ex- posure potential. A deed restriction would be filed identifying the areas of contamination. The deed restric- tion will prevent property transfers to unin- formed purchasers and will limit future utilization of the property. These restrictions are easily implemented by processing the restrictions through a local attorney and the Rowan County or City of Salisbury Register of Deeds. • The trench disposal area itself does not present a direct health risk. As previously stated, the risk posed is through the migration from soils into groundwater; subsequent con- taminated groundwater consumption poses the principal Site threat. Therefore, access restric- tion to this area is not required. It should be noted that the trench area lies well within the NSCC property. Soil sampling was done on June 6, 1991. Soil samples will be collected for monitoring purposes periodically for several years to verify that soil remediation is progressing. Operable Unit 3 -This Operable Unit will ad- dress the contaminants in the Northeast tributary. The Supplemental RI included monitoring of the surface water and sediments in the Northeast tributary. This tributary was sampled in October and November of 1989, July 1990, and June 1991. Results of this tributary sampling confirmed surface water and sediment contamination. Therefore, the Northeast tributary is being addressed as a third Operable Unit to determine the source of . this contamination. 4 PUBLIC INVOLVEMENT: Community relations are vital to the Super- fund process. Citizen involvement is stressed in the Code of Federal Regulations governing Superfund site activities. Public meetings, fact sheets, and the establishment of an infor- mation repository are typical methods used to provide information to a S uperfund site com- munity. The repository will contain all relevant site documents prepared during this process which are available for public review. As indicated in the Superfund process flow- chart, we are between steps 6 and 7 on Operable Unit No. 1, and step 3 on Operable Unit No. 3. This fact sheet is provided not • • SUPERFUND PROCESS 1 REMOVALS 1-----------. * ENFORCEMENT 2 NPL Ranking LlatlnQ 3 Remedlal lnvaellgatlon 4 Feaelblllty Study 5 Publlc Commenta 6 Record ofDNlalon 7 Cleanup Plan 8 Long-Term Cleanup I .... ---------► I COMMUNITY RELATION8 I only to update the community on the current · activities of the Site, but also to encourage par- ticipation in the Superfund process. As part of the Superfund program, EPA is providing communities with the opportunity to apply for Technical Assistance Grants (TAGS). These grants (one per Site up to $50,000) are designed to enable community groups to hire a technical advisor or consultant to assist them in interpreting or commenting on Site findings and proposed remedial action plans. Citizens who are interested in the TAG pro- gram may obtain an application package by calling or writing the following EPA Region IV Technical Assistance Grants contact: Ms. Rosemary Patton N.C. Technical Assistance Grants Coordinator Waste Management Division U.S. Environmental Protection Agency 345 Courtland Street, N.E. Atlanta, GA 30365 (404) 347-2234 5 FOR FURTHER INFORMATION CONTACT: Barbara Benoy Remedial Project Manager Nurth Ren-1edial Superf-uiid Branch U.S. Environmental Protection Agency 345 Courtland Street, N.E. Atlanta, GA 30365 (404) 347 -7791 Ms. Diane Barrett Community Relations Coordinator North Superfund Remedial Branch U.S. Environmental Protection Agency 345 Courtland Street, N.E. Atlanta, GA 30365 (404) 347 -7791 • INFORMATION REPOSITORY: The Administrative Record is the official compilation of documents, data reports, and other infor- mation important to the status of and decisions made relative to a Superfund Site. Information for the National Starch & Chemical Corporation site is available for public viewing and copying at the local information repository: Rowan County Public Library 201 West Fisher Street Salisbury, NC 28144 Hours: Monday -Friday 9:00 am -9:00 pm Saturday 9:00 am -5:00 pm MAILING LIST ADDITIONS: If you know of others who would like to receive information on the National Starch and Chemical Superfund Site, please have them complete this form and mail to the address below. Name ______________________________ _ Address _____________________________ _ City, State, ZIP __________________________ _ Affiliation ____________________________ _ Phone ______________________________ _ Diane Barrett -Community Relations Coordinator North Remedial Superfund Branch U.S. Environmental Protection Agency -Region IV, 345 Courtland Street, NE Atlanta, GA 30365 6 UNITE STATES ' ENVIRONMENTAL PROTECTION AGENCY REGlo'N IV -North Remedial Brar.ch 345 CGURTLAND STREET ATLANrA GEORGIA 30365 OFFICIAL BUSINESS ' PENALifY FOR PRIVATE USE, $300 ,.:uri-~-= F'}1,1.,· :::::fr.:~\ 1-:H ,:---:r= :\/ c1 ( •• ~-:..~ :"': !' l"T ;· ,\J './ ~-(,'. U i,iH r· 87 • l,, l, 11,,, I, ll,,,,, I l,,, 111,,, I, 11,,,, I, 11,,, i,,, 111 . .. -.. - --~.-~. ::··•-_, ... ,. l -1"''.r, sr..,~ I · ft · EPA llll c:: 11G:JCJ {~) Regtn~,l;1,;)1i>R01>o~~~E~~f~ 0 ~~ NATIONAL STARCH & CHEMICAL CORPORATION SUPERFUND SITE Salisbury, Rowan County, North Carolina JULY 1990 INTRODUCTION The U.S. Environmental Protection Agency (EPA) is issuing a Proposed Plan concerning the contamination at the National Starch and Chemical Company (NSCC) Superfund site in Salisbury, North Carolina (see Figure 1). The Proposed Plan is provided in accordance with Section 117(a) of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) to provide opportunity for public review and comment on the remedial alternative selection for the site, specifically for soils in the area known as the trench a.,-ee_ (see Figure 2). The recommended cleanup plan includes allowing natural soil flushing by rainfall. This will be in conjunction with the groundwater pump and treatment system previously approved in the first Record of Decision (ROD) issued by the Agency in 1988. This Proposed Plan: (1. 2. Explains opportunities for the public to comment on the remedial alternatives; Includes a brief history of principal findings of the Remedial Investigation; the site and Supplemental ~~~~ijc Center . ·-·· \ 315 South Boundary Street Salisbury; North Carolina( . < (704) 638-3275 . · .. ::-.:-,. )~. \'::" -. -"i.,\ ~· ~ =~-------==-..,,,·-; ·~. ~-z~- 1",...----..l 3c:e.le: /1" • 2,000' figure 2 ~ INTI:RNATIONAL u.J ttiioNWoL National Starch and ChMnicat Corporation Area Hep ____________ __, 3. Outlines the criteria used by EPA to recommend a cleanup alternative for the site; 4. Provides a summary table (Table 1) for comparative analysis of the preferred alternative and other alternatives evaluated; and 5. Presents EPA's rationale for its preliminary selection of the preferred alternative. To help the public participate in reviewing the cleanup options for the site, this document includes information such as where interested citizens can fmd detailed descriptions of the remedy process and alternatives under consideration for the site. 2 BACKGROUND • The NSCC site is located on the outskirts of the Salisbury city limits. Edward Proctor of Salisbury founded the Proctor Chemical Company in 1938. In September 1968, Proctor purchased the 465-acre Cedar Springs Road property. Within the next year, Proctor Chemical was acquired by NSCC and operated as a separate subsidiary. Construction of the Cedar Springs Road plant began in 1970. On January 1, 1983, Proctor Chemical Company was dissolved and its operations merged with NSCC. NSCC's Salisbury facility is primarily a manufacturing plant for textile finishing and custom specialty chemicals. From 1971 to 1978, the NSCC conducted onsite disposal of approximately 350,000 gallons of reaction vessel wash waters in trenches constructed in a 5-acre tract of land (the trench area) located west of the plant. The corrosive wash water consisted predominantly of salt brines, sulfuric acid solutions, and solvents. The water was disposed in several trenches approximately 200 to 300 feet long and 8 feet deep. Liquid effluent from the plant production area flowed into the easternmost unlined pretreatment holding lagoon, and was pumped to the active trench area. Each trench w~ used until liq\\id no longer readily percolated into the ground. Afterwards the trench area was backfilled and seeded, and a new trench was constructed. In 1976, NSCC installed eight monitoring wells around the site to determine if trenching operations impacted groundwater quality. • Four of these monitoring wells were installed adjacent to or within the trench area. Sampling results revealed that shallow groundwater immediately within and adjacent to the trench area was contaminated. In lune 1977, sampling and analysis conducted by the State of North Carolina verified NSCC's results. The state subsequently requested that NSCC cease onsite waste disposal in the trench area. The NSCC site was proposed for inclusion on the Natlooal Priorities Ust (NPL) in April 1985 with EPA assuming lead responsibility for the site. Negotiations to allow NSCC to conduct the Remedial lnvestigadoo/Feaslbility Study. (RJ/FS) activities were concluded with the signature of an Administrative Order on Consent on December 1, 1986. These activities res-in the issuance of the first ROD for the site. The first ROD addressed the remedy for the groundwater contamination at the site. The ROD specified that residual soil contamination in the trench area be further investigated to determine whether the area still could be considered a major source of groundwater contamination. The first ROD also required that monitoring be conducted on the surface water and sediments adjacent to the site. Detection of contamination in the surface water would require a more focused study to determine the source. These two areas, the trench area· and the surface water system, are being addressed under what EPA bas termed Operable Unit 2. A separate ROD is . required for each Operable Unit. RESULTS OF THE SUPPLEMENTAL REMEDIAL INVESTIGATION EPA required that NSCC conduct additional soils sampling and analysis to determine the levels of contaminants in the trench area, the potential impact of the trench area on the groundwater, and to determine the leachability of the soils in the trench area. EPA also required collection and analysis of surface water and sediment samples in the adjacent stream to determine whether surface water was impacted. The findings of these activities are summarized below. Soil Quality: As directed by the first ROD, additional soil samples were collected in the trench area and residual contamination was confirmed. Significant levels of contamination was found approximately 18 feet below land surface. The only route of contamination migration at this depth is directly into the groundwater. The groundwater remedy was selected in 1988 (the first ROD). With the remedial design completed, construction on the system begins Fall of 1990. Surface Water Quality: Resampling was conducted in the surface water system adjacent to the site. Results detected low levels of contamination in both the surface water and the sediments. This sampling was conducted immediately after the Salisbury area was impacted by Hurricane Hugo and may be a result of excessive rainfall overflowing the runoff· containment system at the site. More extensive sampling was conducted during July 1990 to obtain 3 current data' the stream. Results of this sampling effort will provide adequate information to determine if contamination still exists in the surface water or sediments. U contamination is detected, the sam piing is designed to determine if contamination is from historical disposal of wastes or if runoff from current site operations is the prevailing problem. In the event that DO contamination is detected, the first ROD requires that monitoring of this stream continues on a periodic basis. ENDANGERMENT ASSESSMENT In the original' RI report, an endangerment assessment of exposure pathways was conducted for the site and specifically included the soils in the trench area. The purpose of the assessment was to determine present and future potential risks to public health and the environment posed by the site, and specifically the soils for this Operable Unit, based on existing conditions. EPA bas concluded that the major risk to public health and the environment would result from ingestion of contaminated groundwater. This risk was addressed in the first ROD through the remedy selected for groundwater. The second operable unit will not affect this scenario. SCOPE AND OBJECTIVES OF THIS REMEDIAL ACTION EPA addressed the immediate groundwater problem with the selection of the groundwater remedy under the first Operable Unit decision to stop the introduction of contaminated groundwater into the unaffected portion of the aquifer. The remedial action options presented in this Proposed Plan constitute the second Operable Unit for the site. The objectives of Operable Unit 2 arc to: ensure that cleanup standards for the site are developed for all appropriate media; implement a cleanup alternative that is protective of human health and the environment; and select a remedy that meets the above criteria in a cost effective manner. PUBLIC COMMENT PERIOD The distribution of this Proposed Plan is required by CERCIA, and is provided to explain the remedy selection process and encourage participation in this second part of the cleanup decision. EPA is conducting a 30-day public comment period, from July 30 to August 29, 1990 lo provide an opportunity for people to comment and ask questions concerning the site. Comments made at the meeting will be recorded, and a copy of the transcript will be added to the site Administrative Record available at the Rowan County Public Library. Additional questions or comments concerning the proposed alternative, or any issue concerning the cleanup of the NSCC site may be submitted in writing any time during this comment period. These comments may be delivered to EPA at the Public Meeting or mailed (postmarked .!!Q later than August 29, 1990), to: Barbara Benoy, Remedial Project Manager U.S. Environmental Protection Agency Region IV 345 Courtland Street, NE Atlanta, Georgia 30365 ( 404) 347-n91 and/or Suzanne Durham, Community Relations Coordinator . U.S. Environmental Protection Agency Region IV 345 Courtland Street, NE Atlanta, Georgia 30365 l404) 347-7791 As part of the Superfuod program, EPA is providing communities with the opportunity to apply for Technical Assistance Grants (TAGS). These grants ( one per site up to $50,000) are designed to enable community groups to hire a technical advisor or consultant to assist them in interpreting or commenting on site findings and proposed remedial action plans. Citizens who are interested in the TAG program may obtain an application package by calliog or writing the following EPA Region IV Technical Assistance Grants Contact: Denise Bland, Technical Assistance Grants Specialist Grants and Contracts Support Unit U.S. Environmental Protection Agency Region IV 345 Courtland Street, NE Atlanta, Georgia 30365 ( 404) 347-2234 4 • EPA'S REVIEW OF PUBLIC COMMENT EPA will review comments received from the public as part of the process of reaching a final decision for the soils included for this Operable Unit concerning the cleanup of the NSCC site. As with the first Operable Unit, EPA's final selection will be issued in a ROD for the site. A document, called a Responsiveness Summary, that summarizes EPA's responses to comments received during the public comment period will be issued with the ROD. Once the ROD is signed by the EPA Regional Administrator, it will become part of the Administrative Record, containing all documents used by EPA to choose a remedy for the site. ADDmONAL PUBLIC INFORMATION Because this Proposed Piao provides only a summary description of the NSCC site and the cleanup alternatives, the public is encouraged to consult the Administrative Record, which contains the RI, Supplemental RI, and FS reports, and other site documents, for a more detailed explanation of the site and all of the remedial alternatives under consideration. The Administrative Record will be available for review at the following· locations no later than July 30, 1990: EPA Record Center .345 Courtland Street, NE Atlanta, Georgia 30365 (404) 347-0506 Information Repository Rowan County Public Library 201 West Fisher Street Salisbury, North Carolina 28144 DEVELOPMENT OF EPA'S PREFERRED ALTERNATIVE EPA's selection of the preferred cleanup alternative for the NSCC site, as described in this Proposed Piao, is the result of a comprehensive evaluation and screening process. The FS for the site was conducted to identify and analyze the alternatives considered for addressing contamination at the site. The FS report for the NSCC site describes the alternatives considered, as well as the process and • criteria EPA in ust use to narrow the list down to the final alternatives being considered for soil remediation. EPA uses the following nine criteria to evaluate alternatives identified in the FS. While overall protection of human health and the environment is the primary objective of the remedial action, the remedial alternative selected for the site must achieve the best balance among the evaluation criteria considering the scope and relative degree of contamination. 1. Overall Protection of Human Health and the Environment addresses how an alternative as a whole will protect human health and the environment. This includes as assessment of how public health and environmental risks are properly eliminated, reduced, or controlled through treatment, engineering controls or institutional controls. 2. Compliance with Applicable or Relevant and Appropriate . Reguirements /ARARs) addresses whether or not a remedy complies with all state and Federal environmental and public health laws and requirements that apply or are relevant and appropriate to the conciitions and ·cieanup options at a specific site. If an ARAR cannot be met, the analysis of the alternative must provide the grounds for invoking a waiver. 3. Long-term Effectiveness and Permanence refers to the ability of a remedy to maintain reliable protection of human health and the environment over time once the cleanup goals have been met. 4. Reduction of Toxicity, Mobility or Volume looks at three principal measurements of the overall performance of an alternative. The 1986 amendments to the Superfund statute (SARA) emphasize that, whenever possible, EPA should select a remedy that uses a treatment process to permanently reduce the level of toxicity of contaminants at the site; the spread of contaminants away from the source; and the volume, or amount, of contamination at the site. 5 • 5. Short-term Effectiveness refers to the technical and administrative feasibility of an alternative, including the availability of materials and services needed to implement the alternative. 6. ~ includes the capital (up-front) cost of implementing an alternative, the cost of operating and maintaining the alternative over the long term, and the net present worth of both capital and operation and maintenance costs. 7. State Acceptance addresses whether based on the review nf the RI/FS and Proposed Plan, the state concurs with, opposes, or has no comment of the alternative EPA is proposing as the remedy for the site. 8. Community Acceptance addresses whether the public concurs with EPA's Proposed Plan. Community acceptance of this Proposed Plan will be evaluated based on comments received during the Public Comment Period. SUMMARY0FTHEREMEDIAL ALTERNATIVES A complete list of the remedial alternatives being considered for soils at the NSCC site is presented in Table 1. After screening and evaluation of these initial alternatives, the following five remedial alternatives remained under consideration for Operable Unit 2 soils. Alternative 1; Natural Soil Flushing /No Further Action) This alternative would allow for the naturally occurring precipitation (rainfall) to percolate into the trench area infiltrating into the groundwater and ultimately being extracted through the groundwater pump and treat system. This alternative effectively uses the same leaching process that was originally used for disposal of the waste waters. Oean water is allowed to filter through the subsurface soils into the groundwater. The groundwater remedy selected under Operable Unit 1 is designed to prevent further migration of the groundwater plume. Contamination will be reduced over time through blodegradatlon, leaching and natural volatilization of contaminants. • The contaminated soils in the trench area do not present a health risk through direct contact of surface soils since the significant levels of contamination are approximately 18 feet below land surface. The trench area soils are well within an area of the National Starch property. Access restriction is not required, however deed restriction will be filed identifying the areas of contamination and will prevent property transfers to uninformed purchasers and limit future utilization of the property. Periodic sampling will be required under this option to determine the effectiveness of the cleanup technology. Monitoring will be required at minimal intervals of every five years. This remedial action selection of natural soil flushing does not provide further mitigation to the soil contamination beyond the natural processes and will allow the manifestation of the soil contamination through the naturally flowing groundwater. As a result, this alternative constitutes a "No Further Action" alternative. CERCIA requires that the no action alternative be considered in all situations. Estimated Present-Worth Costs for operation and maintenance: $151,000 Alternative 2:.Site C:apping This alternative involves the capping of the trench disposal area. Caps are constructed of multiple layers that significantly reduce the infiltration of rainwater and therefore the migration of contaminants into the groundwater. This alternative does not provide further mitigation to the soil contamination in the trench area. Two types of caps would be retained for consideration. The first cap consideration is a Resource Conservation and Recovery Act (RCRA) cover which would meet all criteria defined by RCRA. This cap is constructed with a top vegetation cover, underlain by a "drainage layer" that is no less than 12 inches in thickness with additional permeability requirements as well as construction requirements. A final underlying layer with additional construction material requirements, thickness and permeability rates completes the design of a RCRA cap. The second cap under consideration is a soil cover that would meet North Carolina Solid Waste Regulations. This cover would consist of no less than 6 inches of top soil with vegetative cover, 6 • underlain by a low permeability clay layer no less than 18 inches thick. Permeability rates are carefully engineered with both types of caps. The rationale for capping is the reverse of the rationale considered under Alternative 1. This alternative does not enhance the groundwater pump and treat system for Operable Unit 1 and may result in a longer period of time for groundwater remediation. The capping alternative presented in the FS does not take into account the requirements identified for RCRA caps nor for the cover requirements defined by North Carolina's Solid Waste Regulations. The FS identifies a low permeability clay cap. · Therefore, costing information presented in the FS for this cap is only an estimate. Costing information is provided for a comparison basis, but must be considered as an underestimate. (Costs would probably be in excess of $1 million to meet RCRA and/or North Carolina Solid Waste Regulations.) Estimated Present-Worth Costs for construction and maintenance: $423,000 Alternative 3 · Io Situ Soil Flushing This alternative involves in-place flushing of the trench area soils during the groundwater remediation effort. Enhanced flushing can hasten the time for reduction of residual contamination on the soil. This alternative is essentially equivalent to Alternative l except that the introduction of water would be an active operation whereas Alternative l is a passive introduction of water. Estimated Present Worth Costs for construction, operations and maintenance, and monitoring: $781,000 Alternative 4; Excavation and Incineration This alternative involves onsite incineration of excavated soils from the trench area. The approximate volume of soils to be remediated is 250,000 cubic yards. The soil can be incinerated at rates up to 20 tons per hour. Emissions and effluents will be treated, monitored, and controlled to levels within current regulatory limits. \ • Incinerated material will be analyzed prior to replacement in disposal areas to ensure that remediation and ARAR levels have been achieved. After replacing the incinerated soils, the disposal areas will be covered with topsoil and revegelated. Estimated Present-Worth Costs for excavation, onsite mcmeratioo, disposal, operations and maintenance: $52,125,000 Alternative 5: Excavation and Offsite Disposal Io this alternative, 250,000 cubic yards of contaminated soil in the trench area would be excavated and transported to a RCRA permitted· landfill for disposal. The 250,000 cubic yards of contaminate soil only addresses the soil in the unsaturated zone; the contaminated soil in the saturated zone would not be excavated. Estimated Present-Worth Costs for excavation, transportation, disposal, and site restorations: $51,900,000 EPA'S RATIONALE FOR SELECTING THE PREFERRED ALTERNATIVE Based on current information and analysis of the RI/FS reports, and the original and supplemental investigations, EPA believes that the preferred alternative, Alternative I, Natural Soil Flushing (No Further Action), for the NSCC site is consistent with the requirements of the Superfund law and its amendments, specifically Section Ul of CERCLA and the National Contingency Plan (NCP). All of the alternatives presented in this Proposed Piao would provide overall protection of human health and the environment, including the No Further Action alternative. In EP A's analysis, the No Further Action alternative would achieve a balance of the nine selection aiteria. The soils in the trench area can orily contribute contamination to the groundwater. Groundwater remediation has been decided; the design stage has been completed, construction of the pump and treat system will start in the Fall of 1990. Remediation of groundwater takes many years to achieve the cleanup levels as defmed by existing environmental laws. The No Further Action alternative works in conjunction with the pump ._and treat system in a passive manner 7 without impacting either the schedule or the costs of the remedial action at the site. Any other alternative selection would introduce concerns including delays in the groundwater remediation, additional costs, waste handling, construction and implementation problems. The preferred alternative, Natural Soil Flushing: 1) provides short- and long-term protection of human health and the environment, 2) will attain Federal and state applicable and appropriate· public health and environmental requirements (ARARs), and 3) utilizes a permanent solution to the maxim um extent practicable. Glossary Administrative Order of Consent: A legal agreement between EPA and the potentially responsible parties (PRPs) whereby the PRPs agree to perform or pay the cost of a site cleanup. The agreement describes actions to be taken at a site and may be subject to a public comment period. Administrative Record: A file which is maintained and contains all information used by the lead agency to make its decision on the selection of a response action under CERCLA. This file is required to be available for public review and a copy is to be established at or near · the site, usually al an information repository. A duplicate ftle is maintained in a central location, such as a regional EPA and/or state office. Aquifer: Ao underground rock formation composed of material such as sand, soil, and/or gravel that can store and supply groundwater to wells and springs. Biodegradatlon: The breakdown and removal of contaminants by the use_ of naturally oceurring · microbial activities found in subsurface soils. Comprehensive Environmental Response, Compensation, and Llability Act (CERCLA): A Federal law passed in 1980 and modified in 1986 by the Superfund Amendments and Reauthorization Act. The Acts created a special tax that goes into a trust fund, commonly known as Superfund, to investigate and cleanup abandoned or uncontrolled hazardous waste sites. U oder the program, EPA can either pay for site cleanup when the responsible parties cannot be located or are unwilling or unable • to perform the work, or take legal action to force responsible parties lo cleanup the site or reimburse EPA the cost of the cleanup. · Endangerment Assessment: An assessment which provides an evaluation of the potential threat to human health and the environment in the absence of remedial action. Groundwater: Water found beneath the earth's surface that fills pores between materials such as sand, soil, or gravel. In an aquifer, groundwater occurs in sufficient quantities that it can be used for drinking water, irrigation, and other purposes. Groundwater Monitoring: The periodic evaluation of the hydrogeologic conditions and quality of groundwater underlying the site. Groundwater Monitoring Wells: A hole or shaft sunk into the earth which is periodically sampled to evaluate the hydrogeologic conditions and quality of groundwater underlying the site. Incineration: Burning of certain types of solid, liquid, or gaseous materials under controlled conditions to destroy hazardous waste. Information Repository: A file containing current information, technical reports and reference docu- ments regarding a Superfund NPL site. The information repository is usually located in a public building that is convenient for local residents, such as a public schoo~ city h~ or a library. As the site proceeds through the Superfund Remedial Process, the file at the information repository is continually updated. Leachabillty: The loss of soluble matter as a result of the filtering through of water. National Contlng,mcy Plan (NCP): The Federal regulation that guides the Superfund Program. Natlonal Priorities Ust (NPL): A listing of the most serious, uncontrolled or abandoned hazardous waste sites identified for possible long-term remedial response using Superfund monies. The list is updated yearly as required by the National Contingency Plan of CERClA. Sites are proposed for addition lo the NPL based on their HRS score. 8 • Net Pnsent-Worth: The sum of capital and operation and maintenance costs of a remedial alternative. Natural Volatilization: When a liquid evaporates under naturally occurring conditions. Operable Unit: An action taken as one part <if an overall site cleanup. A number of operable units can be used in the course of a site cleanup. Percolate: To pass (a liquid) gradually through small spaces or a porous substance. Proposed Plan: A public participation requirement of SARA in which EPA summarizes for the public the preferred cleanup strategy, the rationale for the preference, reviews the alternatives presented in the detailed analysis of the remedial investigation/feasibility study, and presents any . waivers to cleanup standards of § 121( d)( 4) which may be. proposed. This may be prepared either as a fact sheet or as a separate document. In either case, it must actively solicit public review and comment on all alternatives under Agency consideration. Pump and Treat System: A method for treating contaminated groundwater where the groundwater is drawn from wells drilled in the aquifer and treated in a surface treatment system. Record or Decision (ROD): A public document that explains which cleanup alternative will be used at a National Priorities List site and the reasons for choosing that cleanup alternative over other possibilities. Remedial Alternatives: A list of the most tech- nologically feasible alternatives for a remedial strategy. Remedial Investigation and Feasibility Study (RI/FS): Two distinct but related studies, normally conducted together, intended to define the nature and extent of contamination at a site (RI) and to evaluate appropriate, site-specific remedies necessary to achieve final cleanup at the site (FS). Resource Conservation and Recovery Act (RCRA): A Federal law that established a regulatory system to track hazardous substances from the time of • generation to disposal. The law requires safe and s«urc procedures to be used in treating. transporting, storing. and disposing of hazardous substances. RCRA is designed to prevent new, uncontrolled hazardous waste sites. Responsiveness Summary: A summary of oral and/or written public comments received by EPA during a comment period. Superfund: The common name used for CERCIA, also referred to as the Trust Fund. Supplemental Remedial Investigation: Additional field studies conducted to define the nature and extent of contamination at a site. • 9 Tiiblc 1. Na1ion11I SIAffh on,.J Chcmirnl Corpornlion Screening Con1n1I ·1·cl·hm,1t1gic~ f11r S<,il (:unt11minntiun Soil General Remedial Technology Pnxess Option Efrectiveness Implementability Cost Status No Fun tier Action Natural soil 0ushing N/A N/A N/A; will likely require long-tenn LowO&M Retained monitoring lrulitulional Actions Acceu ratrictions Deed re&trictions Etrectivc in limiting use of trench area Legal requirements Negligible Retained Fencing •Dismissed Containment Cap Oay and soil Effective a§ainst vertical leaching of rontaminants Easily implemented; restriction on future lo!-' capital, low Retained into groun water; susceptible to cracking land use maintenance Mullilaycred cap Effective; least susceptible to crncking Easily implemented; restriction on future Moderate capital, Retained land USC low maintenance Vertical barriers Slurry wall Not reasible because ~undwall!r is Dirlicuh to verify continuity or ,lurry or H~ capital, low Dismissed contaminated within e fractured bedrock backfill 0 M · • Grout curtain Nol effective because of fractured bedrock [?iffjcull. to vcrjfy continuity of wall; must llih capital, low Dismissed tie into 1mpemous zone . 0 M Sheet pile Not eHectivc because of fracturt!d bedrock Difficult to key to bedrock; no e:1cavation lljh capital, low Dismissed required; limited to 50 feet 0 M Excavation/frcat-Removal Exarvation Effective for removal of contaminants in soil, but Readily i~plemepted. with conventional H~ capital, low ment Action require, disp:>&BI construction equipment . 0 M Rclained Physical treatment Soil Wllhing Water can be effective since volntiles of concern l':£lemented usin~ commercially Hig.1_1 cacital, •Dismissed arc highlr lOluble. Re~uircs excavation and lhe a i_lable mining a d chemical proce.s5ing Modera e O&M trcatmcn or water. Clayey soil can hinder equipment removal erficiencies. Poor track record; may not treat to dcsircd levels Soil farming Effectiveness is dependent on ambient Easily implemented. ~uira excavation H:fh capital. high •Dismissed temro_raturcs, precipitation and wind. May not of contaminated soils an ,prcading over 0 M con onn to air release regulations for volatile large area with ,urface water control. compounds. Solidification/-Not an effectlVC method for organic compounds. Readily implemented. bJ; excavating and Moderate capital, •Dismissed rtx.ation mixing soil with the ad itive lowO&M In ,itu treatment Subsurface Effectiveness is dependent on sc,il unifonnity (i.e. Readily im'r!f mented by horizontal Moderate caEital, Dismissed bioredamation grain size, poro&ity, pH, etc.) irritfnt1on. ay require bench-scale moderate O M tes mJi P90r t~ck records for this type of geo ogtc selling Soil Dushing Effectivcne55 is dercndent on soil uniformity and Not rcadily,imtlemented in clayey soils Moderate cagital, Retained • ability lo capture t e leachate would refiu1rc umerous moderate O M injection extraction wells and lCVCral years or ushing Soil venling Not an effective method for tight clayey soils Not readily.implemen!ed ln_c~~y ~ils, Moderate cattal, •Dismissed would require prc56urized air mJcct1on moderate O M Thermal treatment Rotary kiln incinerator ~~ectivencss is dependent on operation of Qayc(h soils D)ay require trir.r · residence High catal, low Retained incinerator time ercby mcreasinff O& . mOOera e or high AvailabilitY. of incinera ors is O&M questiona61e. Thermal desorption Effective on volatile organic compounds Implementation may require testing Jlig!' cafcital, •Dismissed mOOera e O&M Excavation/-OH-sile disposal RCRA facility Effective and reliable, but requires transportation Permits required H1h capital, high Retained Disp:>SBI Action 0 M •Rauonale for dJsmJssal Is discussed In the FS Report located at the Information Repository. • r------------------------------------------------------------------------ ' ' ' MAIUNG LIST ADDmONS To be placed on the mailing list for the National Starch and Chemical Corporation Site please complete this form and mail to: Ms. Suzanne Durham Community Relations Coordinator, U.S. EPA, Region IV 345 Courtland Street, NE, Atlanta, GA 30365 Name ____________________________________ _ Address---------------------------------- : Affiliation------------------------------------ 1 Telephone----'----------------------------------, ' L----------------------------------------------------------------------- United States Environmental Protection Agency Official Business Penalty for Private Use $300 Governor James G. Martin 116 West Jones Street Region 4 345 Courtland Street, NE Atlanta, GA 30365 IS :S IW 9Z l@;;.Dfi.gh, North Carolina 27611 GOVERNOR'S OFFfCE Remedial Investigation/ Feasibility Study Fact Sheet National Starch and Chemical Corporation Site Rowan County, North Carolina The U.S. Environmental Protection Agency (EPA) is ,preparing lU implement a Remedial lnvcstigati()[l and Feasibility Study (Rl/FS) of die National Starch and Chemical Corporation sire in Rowan County, North Carolin:1. For this site, the RI/ FS will be performed by National Siarch and Chemical Corporation (National Starch). EPA and irs contractors will oversee National Starch's work and ensure all tasks are performed in . accordance with EPA guidelines, standards and policy. This face sheer briefly describes the sirc, the nature of the H.1/FS, public involvement in rhe Rl/FS acrivirics, and the future acriviti<.:s EPA \viii conduce pertaining co che sire. SITE DESCRIPTION The National Starch and Chemical Corporation (National Starch) owns a 465 a.ere industrial site known as the Cedar Springs Road Plant. The Cedar Springs Road Plant is located approximarely five miles south of Salishury, in Rowan Cou,uy, North Carolina (Figure I). Hazardous waste \Vas reportedly <lisposcd of on an approximate rwo acre'arca of the Cedar Springs Road Pbnt. This two :1cre an.:a was identified as an uncontrolled hazardous wa.sre <lisposal sire by EPA and proposed for inclusion on rhe National Priorities List (NP!.) in 1\pril 1985. National Starch produces tt.:xtile finishing chemicals and custum specialty chemical products for a variety l_)f industries at thl' Lumbl'r Strel't Plant ·in downtown Salisbury, and at the Cedar Springs Road Plant. Production of these chemicals occurs on a batch basis and varies according m demand. Property for the Cedar Springs Road Plam w:1s acquired in 1968 by Proctor Chemical and Gll1St rucrion bl'g:in ·in 1970. Proctor Chl'!Tlical was acquired by National Starch in 196:) and was opl'rated as a wholly owned subsidiary until 198.1,, when Procwr Chemical was !iquid:m:d and its operations merged with Nacional Search. THE PROBLEM Between 1971 and 1978, National Starch, forml'rly Proctor Chl'mical, disposed of pl:1nr dflucnr genl'ratl'd from rank cleanings, floor washings and rhc like on the Cedar Springs Road Plane property. This effluent consistl'd predominantly of salt hrinl's, sulfuric acid solucions, and su!fonaring fats and ()ils fr()rn both their Lumber Strl'l't and Cedar .Springs H.!lad Plants. Wastl'S Wl'tT disp(;st.:d of in ~EPA Region IV February 1987 trenches, 6-8 feet deep, 2 feer wide :rnd approximately 300 feet long. The area where these trl'nches were constructed is approximare!y two acres in size and is located ro the west, behind rhe exisri_ng produccion area. In 1976, eight monitoring wells were installed around che sire by National Starch rn determine if the trenching operations were impacting ground water quality. Four of these monitoring wells were installed adjacent co or within the trench :1rea. i\fnnilOring revealed rhat shallow ground water immediately within and adjacent to the trench arca was contaminated. In June 1977, sampling by the North Carolina Deparrmenr of Natura! and Econon1ic Resources, Di\'ision of Environmental Management (DEM) verified National Starch's earlier conclusion that some of the monitoring wells were contaminated. Ba~ed on analysis of samples taken at that time, DEM requested that National Starch cease onsite waste disposal :Ktivicies at the Cedar Springs Road Pbnc. Since 1978, when the city of Salisbury Site Location Map Nacionnl Starch and Chemical Corporarion Sire Rowan County, North Carolina - 1 ~-'1 V;$ \,_· SCALE Cov. ' 1 inch equals 8 miles -i\l,ry, H Fl H 5 BARBER 8 COUNTY ~) I 6Q1 G ~o-"'(, ~ ~ .. SPt:~CER - NATIONAL STARCH, . ;r\1 SITE ~~-~S~ENCE,R ··-8'~,;Yj(,ALISBURY~HIGH ROCK MILL /f: .6:,-:0WMJ~ ~LAKE BRIDGE (5 @,MILLS '! , GRP..N15/ /J/ GRANITEt\le ' ✓I QUARRY l' :.-2 ,iJiil.,~ /Hl'I' GROVE •~:OCKWELL Jg'.,y ____ ~o~co~~ KANNAPOLIS CABARRUS COUNTY/ installed a sewer line for the plant's usage, production plam process waters have been directed to a pretreatment facility, going through pre-settling and surface· aer:_1rion bdore being discharged inco the Salisbury saniury sewer syst(:m. The monitoring wells have been sampled by National Starch on a quarterly.basis since their installation. Three of the cighc monitoring wclls were sampled by DEM in January 1983. DEM found that thc well l0i.:aced in the c.enter of che disposal area contained the menlis cadmium, chrnmium, copper, lead and zinc. These metals were not detected in che two wells ;1djacem to the disposal area. In June 1984, DEJ\-1 again sampled the three wells and found water from the well in the center of the disposal area was very :icidic and that xylene and possibly other organic chemicals were present in one of the wells adjacent to the disposal area. DE~:1 then requested National Starch to conduct a complete chemical analysis of each onsite ,noniroring well. National Starch sampled the ·moniroring wells from September through October 198/i. Significant contamination of the wells within and adjacent co the disposal area was found during the October 1984 sampling. The metals cadmium, arsenic, chromium, copper, !ead, nickel, zinc, and silver were found in the well in the center of the disposal area, as \Veil as a variety of volacile and semi- volatile organic chemicals. The October 1984 sampling was followed by a DEM sampling in !are October 1984, with si;11iliar findings. The North Carolina Divisiu1i of Health Services (DHS) sampled priv_ace wells \\:ithin 2 miles of the National Srnrch site in Occober 1984. No volatile organic compound~ were measured. The Rowan County Health Department (RCHD) also sampled private wells in proximity ru the National Srnrch site. None of rhe chemical compounds sampled for were found. During 1984, approximately 2000 cubic yards of conraminated soil were removed during construction of a concrete liner in the holding lagoons on the south side of the Cedar Springs Road Plant. The .soil was stored in a diked-off section on the plane sire near the former trenching area. The RI/FS will also address any potential environmental in1pacr caused by the placement of such soil in this area. WHAT IS REMEDIAL INVESTIGATION' At sites like National Starch, EP,\ typically conducts an extensive investigation and srndy (Rl/FS). A condensed description of the Superfund prucess · is presented as Exhibit A 011 the back cover of chis fact sheet. Thl' Remedial investigation (IU) is the first seep in the process. In the RI, decenninations arc made of the type and extent of on.site conrnmination, the imeraction between ground and surface water and the contamination, and the degree of contamination in the soil. To do chis, National Srnrch or their concrac(()r, will take samples of soil and water at v:1rious locarions in and :1round the rwo-acre disi~osal are:1 ~ind the la,1:;oon area as well as che general site area. These samples will be sent ro EPA approved laborarories to be analyzed for various cunurninants such as heavy metals and selected organic chcmicds. The.: area will also be srndied to determine if the concaminancs have: ·moved from the disposal area, where they might go, and what sensitive areas might be affected by the contaminants. Based on the information from this srudy, the potential imp.act of these contaminants on human health and the environmem \vill be assessed .. Before any srndics could be initiated by National Starch, a plan of their work was submitted to EPA for review and was approved. This \X1ork Plan, as it is called, is the basis for EPA ro oversee the studies conducred by National Starch and ttJ ensure th:1t che srndies and analyses conducted by National Starch are in accordance with EPA guidelines and requirements. National Search will begin studies early in 1987 WHAT IS A FEASIBILITY STUDY' The information frnm rhe Rcm(:dial lnveStigation (RI) is used as rhe basis fur developing different methods for dealing with comaminarion at a site. Each of the methods arc evaluated based on certain factors or criteria. This process is known as :1 Feasibility Study (FS). The FS presems different methods (alternatives) for deJ.ling with the contamination at a site, as well as an evaluation of each method. At least om: alternative will be developed that addresses each of the following criteria (alternatives may address more than one criteria): • AlLernaLivcs which a/lain applicable and/or're!evant federal srandards on public health and the environment: • A lternaLives which exceed applicable and/or relevant federal srandards on public health and the environment; • Alrcrnarives which do not attain applicable or relevant fr:deral standards on public health or environment, but will reduce the likelihood of present or furnre thrt.!at from hazardous chemicals; • Alternatives that involve off-site treatment or disposal; and • Alternatives that involve raking "no action". As part of the FS process,each of these alternative methods \vii! be evaluated on the following criteria: • Technical feasibility (reliability, ease of implementation, and quality of performance); • Impact on the environment during and after the · cleanup operation; • lmpao on public health; • • Instirnciona! considerations (acc<.!ptablc un<lcr f edcral, .stare, and local rcgu lations, ord i na nccs, codes, and standards); and • Cost-effectiveness ( cypc or k:vel of ckanup justify the cost). The results of the evaluation arc presented in the FS in terms of how the alrcrnarivc rll<.!thods rate according rn rhi; criteria presented above. The FS may also contain a recommendation on which alternative or several altcrna'tivcs arc the best solution ·rn the problem. The alternative chosen will be protective of human health and the environment, cost effeccive, and will utilize permanent solution and alrcrnarive crearment technologies to the maximum extent practical. A remedial investigation/ feasibility srndy may take from one to two years to complete. HOW DOES THE PUBLIC GET INVOLVED? The FS is released to the public upon complcrion and reviewed by EPA. A public commenc period (minimum duration of three weeks) will be held t0 allow citizens co comment on the alternative methods proposed and evaluated in the FS. During the comment period a public meeting will be held. EPA will present a suminary of the RI/FS process and explain the proposed altern:nivcs. Citizens arc encouraged to voice their concerns and ask questions regarding the RI/FS. Questions and answers will be recorded to assist in the preparation of a report (Responsiveness Summary) that summarizes cmzen comments and EPA responses. Followic:ig the conclusion of the comment period on the study, a formal decision document will be prepared that summarizes the decision process and rhe alternative selec~ed. This dorument will include the Responsiveness Summary and will be submitted to the EPA Regional Administramr for approval. Upon approval, the design of the selected alternative will be developed and the process can begin. Designing the cleanup plan may take six months, implementing the plan -actually beginning activities at the sire -may t:ike from one to three yeu:-:ind longer if groundwater is involved. HOW DOES THE PUBLIC GET MORE INFORMATION? Prior to initiacion of the RI/FS, the EPA prepared a Community Relarions Plan, in which members of che co1.ninunity were interviewed, their concerns noted, and a mailing list of citizens developed. Citii.cns who indicated che\• would like to be placed on the mailing list will recievc additional information as it becomes available widwuc any additional effort. Citizens who were not contacted or who would now like to be placc:d on the mailing list should fill out and send the Mailing List Addition Form found in this fact sheet tu tht: EP/\ at the address indicated. Information, such as Draft RI/FS reports and otht:r public documents pertaining to die sire, will be a vailab!e to the public in an i'nformarion repository. The information repository will be located ac: Rowan County Public Lihrary 201 \Xie.st Fisher Street Salisbury, North Carolina 28144 (704) 633-5578 Questions and requests for additional information should be directed to either of the following: Giezclle S. Bennett Enforcement Project Manager U.S. EPA, Region IV }'15 Courtland Street Atlanta, GA 30365 (404) 347-2930 H. Michael Henderson Community Relations Coordinator U.S. EPA, Region IV 345 Courtland Streec At!ama, GA 30.l65 (404) 347-3004 ------------~---------------------,----- \ MAILING LIST ADDITIONS I I I I I ! Name: H. i\1 ichacl Henderson Community Relations Coordinator U.S. EPA, Region IV :,SliS Courtland Street 1\danta, Gt\ 30365 Address:---------------------------------- Affiliation: Phone: I I I I I I ______ J Exhibit A SUPERFUND PROCESS Site Discm·tr)'. NPL Rankin!i/ Li~1in!i lmmediall' Rtmo,·al COMMUNITY RELl.TIONS es RemeJi~I lnn·srigaiion In 19~0, Congress enacted the Comprehensive Environmental Response, Compensation, and Liability 1\et (CERCLA, more commonly known as "Superfund"). This act aurhorizes EPA w respond ro releases or threatened releases of hazardous substances that z:nay endanger public health or welfare, or the environment. This exhibit provides a simplified explanation of how a long~term Superfund respon?e works ac sites like rhe National Starch and Cheinical Corporation sire. 1. After a site is discovered, it is inz:estigated, usually by ihe Stare. 2. The Stare then ranks the site using a system that takes imo accounr: • Possible healrh ro rhe human population. • Potential hazards (e.g., from direct contact, inhalation, fire, or explosion) of substances ac the site. • Potential for the substances ar rhe site to conraminace drinking water supplies. • Porenria! for the substances ar rhe site w pollure or otherwise harm the environment. If the problems at a sire are deemed .serious by the Srate and EPA the sire will be !isrecl on the National Priorities Lisi (NPL), a roster of the nation's worse hazardous waste sites. Every site on th·e NPL is eligible for federal Superfund money. 3. lf a site or any portion thereof poses an imminent threat to public health or the environment at any time, EPA may conduce an emergency response rdcrn.:d to as an inn11edl,uc removal action. 4. Nexr, EPA usually conducts a remedial investiP,ation (RI). The RI assesses how serious the contamination is, what kind of contaminants are present, and characterizes porential risks w rhe community. As part of the Rl, EPA typical!y conduets an endangerment assessmcnt thai t'ea~ihilin Stud} , 6$¥G&iYii Cleanup Plan/ l)c\i,lin # COMMUNITY RELATIONS ' [,;m;.:•Tl·rm (lt.'anup describes the problems at chc site and the potential health and t:nvirnnmental consequences if no further acriun is taken. ac the site. 5. Following completion of the RI, EPA performs a jetJSibility stud)' ( FS) which examines various cleanup alternatives and evaluates them on the basis of technical feasibility, public health effects, environmental impacts, institutional concerns (incl'uding compliance with sDte and local laws), impact on the communic·y, and cosr. The findings are presented in a draft FS report. 6. 1:ollowing completion of the draft fS report, EPA holds a public comment period to receive citizen cornmems concerning the recommended alternatives. Citiztns may provide comments either orally at public meetings or through wriccen correspondt:nce.to EPA. 7. After public commems have been received, EPA then chooses a specific cleanup plan. 8. Once 1he design is finished, the acrual remedial acti\'ities at the si1e caq begin. The time nccessary to cornpletc e~ICh of these steps \'arics wich every sicc. In genera!, a remed;al inr·estig,ition//euJihilitJ' study wb.:.s from one to two years. Designing the cleanup plan mny rake six months. lmplemcnting the remedy -the actua! conrainmcnc or removal of che waste -may take from om: to three years. If ground wa!cr is involved, the final cleanup may cake many more years. Onf-:oin~ community relations 1JCti11itie.r during a cleanup include public mecrings and ochn activities inrendcd 10 keep citizens and officials informed and to encourage public participation. Thcse activities are scheduled throughout cht: course of the remcdial cleanup process. Spc:cific anivities vary frnm sitt: to site depehcling on the level and naturc of concern. The range of communiry relations acciviries rh:n can occur is descrilx·d in EPA's C.ommuniry Rcbtiuns Pbn for the si1e. UNl,cO ST,.C,TES ENVlr<O~:MENT,.;L FRO,E::TIO~I AGENCY REGION IV .;IJ~ COl..:RTLA:,iO $TR':;E"f. N ~- AT:.,.o,.NTA. GFQRGIA 30J,)5 FAX COVER SHEET PLEASS COHTACT 404/3~7-7?91 if any problems occur with thi.9 trar1smlttc11..l. F.:i.O!-~: Sa:t.·Q;=.r::?. P.. S_~!1.2>' Re:,m~~~~aJ '?.:::>je,:-:_t M...1.nager Rec i,:;::~ IV E?A -----~·----__ _, ~fi@-U ::....,__;:,_-=--.. -- IA~ Jul 14 ,90 14 ::24 }' •• SUPERFUND PRL PROPOSED PLAN FACT St~ ·~ NATIONAL STARCH & CHEMICAL CORPORATION SUPERFUND SITE>. Salisbury, Rowan County, North Carolina JULY 1990' '. )NTRODlJ(,,"TION The U.S. Environmental Protection Agency (EPA) is issuing a Proposed Plan concerning the contamination at the National Starch and Chemical Company (NSCC) Supcrfund site in Salisbury, Nor.th Carolina (see Figure J), The Proposed Plan is provided in ac,:ordance with Section 117(a) of the Comprehensive Environmental Response, Com~nsatlon, and Liability Act (CERCLA) to provide opportunity for public review and comment on the remedial alternative selection for the site, specifically for soils in the area known as the trench area ( see Figure 2), The recommended cleanup plan includes allowing natural soil flushing by rainfall. This will be in conjunction with the groundwater pump and trestmrnt Slstem previously approved in the first Record or Dedslon (ROD) issued by the Agency in 1988, This Proposed Plan: 1. Explains opportunities for the public. to comment on the remedial alternatives; 2, Includes a brief history of principal findings of the Remedial lnHstlgatlon; the site and Supplemental F1,i:1, r,: I Si«" Locaiion Map National 5[arch and Chemical Corpor.trion Sitt Rowan Coun1}', North Carolin.:i •• ·,,· ' ,: ~: f \ : r ; ' }-~ ':, -' . ' • ,I • ~cale: l'' • 2,000' I Fiaura 2 Jiational Sttirch at.d rn INURNATINAL TECHNOL Y CO~J'ORA ·N pem1cal Corporation At~A M•p ------------------ 3. Outlines the criteria used by EPA to recommend a cleanup alternative for the site; 4. Provides a summary table (Table 1) for comparative analysis of the preferred altc.rnalivc. and other altern&livcs cvahrnted; and S. Presents EPA's rationale for its preliminary se.lection of the preferred alternative. To help the public participate in revic11.fog the ckanup oplions for .the site, 1his document includes · infoimalion such as where inlcrc.sted citizens can find detailed descriptions of the remedy pr=,s and alternatives under consideration for the site. 2 Jul 24,90 14:24 No.010 P.03 •• BACKGROUND The NSCC •ite is loc~tcd on the outskirts of the Salisbury city limits. Edward Proc1or of Salisbury founded 1he Proctor Chemic.al Company in 1938. In Seplemb.;r 1968, Proctor purchased the 465-acre Cedar Springs Road property, Within the ne>1 year, Proctor Che.mica! was acquired by NSCC ·and operated as a separate subsidiary. Construction of the Ce<lar Springs Road plant began in 1970. On January 1, 1983, Proctor Chemic~! Cornpany was dissolved and its operations merged with NSCC. NSCC's Sali.sbury facility is primarily a manufacturing pl•nt for textile finishing and custom specialty chemic.als. From 1971 to 1978, the NSCC conducted on.site disposal of approximately.350,000 gallons of reaction vessel wash waters in trenches constructed in a 5-acre tract 9f land (the trench area) located west of the plant. The corrosive. Wash waler c,_)nsistcd predominantly of s;,lt brines, sulfuric acid solutions, and solvents. The waler was disposed in several trenches approximately 2J'.lO 10 300 fee.( long and 8 feet deep. Liquid effluent from the plant production area flowc.<l into the easternmost unlined pretrcatmC:nt holding lagoon, and was pumped to the active trench area. Each trench was used until Liquid no longer readily percolaled into the ground. AfterW;,rd, the trench area was backfilled and seeded, and a new trench was constructed. In 1976, NSCC installed eight monitoring wells around the site to determine if trenching operations impacted groundwater quality. Four of these monitoring wells were installed adjacent to or within the trench area. Sampling results revealed that shallow groundwater immediately within and adjaccat lo the trench area was contaminated. In June 1977, sampling and analysis conducted by the State of North Carolina verified NSCC's resulls. The state subsequently requested that NSCC c.:ase onsite waste disposal in the trench area. The NSCC site was prnposcd for inclusion on the National Prlorltles List (NPL) in April 1985 with EPA a.s.,uming lead responsibility for the site. Neg()tialions to alJow NSCC to conduct the Remedial lnvestleatlon/Feaslblllty Study (Rl/FSJ activities were conclu<lcd v.ith the signature of an Administrative Order on Consent on December 1, •• 1986_. These activities resulted in the issuance of the 1"1tst ROD for the site. The first ROD addressed the remedy for the grouodwater contamination at the site. T~e ROD specified that residual soil contamination in the trench area be further investigated to determine whether the area still could be considcrc·d a major source of groundwater contamination. The i1tst ROD also required th.I! monitoring be conducted on the surface water and sedime.nt, adjacent to the ~te. Detection of contamin;1tion in the surface water would require a more focused study to dclcrminc the source. These two areas, the trench area and the surfaC<' ·water system, are being addressed under what EPA has termed Operable Unit 2. A separate ROD is required for each Operable Unit. RESULTS OF THE SUPPLEMENJ:6L BEMEDlAL INVESTIGATION EPA required that NSCC conduct additional soils sampling and analysis to determine the levels of contaminants in the trench are.a, the potential in1pacl of the trench area on the groundwater, and to determine the leachabllity of the soils in the trench area. EPA also required colle,ction and analysis of surface water and sediment sampks in the adjacent stream to determine whether surface water was imp;,c·tcd. The findings of these activities are summarized below. Soil Quality: As directed by the first ROD, additional soil samples were collected in the trench area and residual contamination was confirmed. Significant kvels of contamination was found approximately 18 feet below land surface. The only route of contamination migration at this depth is directly i.nto the groundwater. The groundwater remedy was selected in 1988 (the first ROD). With the remedial design completed, construction on the syslcn1 begins Fall of 1990. Surface Water Quality: Re.sampling was conducted in the surface water system adjacent to the site. Results detected low levels of contamination in both the surface water and the sediments. This sampling was conducted immediately after the Salisbury area wa.~ impacted by Hurric;,,ne Hugo and may be a result of excessive rainfall overflowing the runoff containment system at the site. More extensive sampling was cun<lucted during July 1990 to obtain 3 Jul 24,90 14:24 No.010 P.04 current data on the stream. Results of this sampling effort will provide adequate information to dc.tc-rminc if contanltnation still exists in the surface water or sediments. If contamination is detected, the sampling is designed to determine if contamination is from historical disposal of wastes or if runoff from current site operations is the prevailing problem, In the event that no contamination is detected, the first ROD requires that monitoring of this stream continues on a periodic basis. ENDANGERMENT ASSESSMENT In the original RI report, an endangerment assessment or expc,sure pathways was conducted for the site and speciJk;,,lly included the soils in the trench area. The purpose of the assessment was 10 determine present and future l'('tential risks to public health and the envirt,nmcnt p<>sed by the site, and specifically the soils for this Operable Unit, based on existing conditions. EPA has concluded that the major risk to public health and the environment would result from ingestion or contaminated groundwater, This risk was addressed in the first ROD through the remedy selected for groundwater. The second operable unit will not affect this scenario. SCOPE AND OBJECTIVES OF THIS REMEDIAL ACTION EPA addrcs-scd the immediate groundwater problem with the selection of the groundwater remedy under the first Operable Unit decision to stop the introductioo of contaminated groundwater into the unaffected portion of the aqulrer. The remedial action options presented in this Proposed Plan constitute the secood Operable Unit for the site. The objectives of Operable Unit 2 are to: ensure that cleanup standards for the site are developed for all appropriate. media; imp)ement a cleanup alternative that is protedive of hnman health and the environment; and select a remedy that meets the above criteria in a cost effective manner. PUBLIC COMMENT PERIOD The distribution or this Proposed Plan is required by CERCLA, and i.s provided to explain the remedy selection process and encourage participation in this second part of the cleanup dedsion. EPA is j C n ',_._, . ""T r,,;_,-,1,,,7 'i i:..L: •• conJucting a 30-day public comment period, from July 30 lo August 29, 1990 to provide an opportunity for people lo comment and ask questions concerning the site. Comments made at the meeting will be recorded, and a copy of the transcript will be added to the site Admlnlstrutl,e Reeord available at the Rowan County Public Library. Additional questions or comments co11ccrning the proposed alternative, or any issue concerning the cleanup of the NSCC site may be ~ubiuiu,d ill wi'itiug &.0y tiru,. during tlii! eon1ni.nt period. These conimcnts may be delivered to EPA at the Public Meeting or mailed (po~trnarkcd l1Q later th;1n August 79, 1990), to: Barbara Benoy, Remedial Project Manager U.S. Environmental Protection Agency Region IV 345 Courtland Street, NE Atlanta, Georgia 30365 (404) 347-7791 and/or Suzanne Durham, Community Relations Coordirlntor U.S. Environmental Protection Agency Region IV 345 Courtland Street, NE Atlanta, Georgia 30365 (404) 347-7791 As part of the Superfund program, EPA is pro,iding communities with the opportunity to apply for Technical Assistance Grants (TAGS). These grants (one per site up to $50,000) are designed to enable community groups to hire a technical advisor or consultant to assist them in interpreting or commenting on site findings and proposed remedial action plans, Citizens who are inlcrcstcd in the TAG program may obtain an applic.ation package by calling or writing the following EPA Region JV Technical Assistance Grants Contact: Denise Bland, Technical Assistance Grants Specialist Grants and Contracts Support Unit U.S. En,1ronmcntal Protection Agency Region IV . 345 Courtl~nd Street, NE Atlanta, Georgia 30365 ( 404) 347-2234 4 Jul 24·,90 14:24 l~o .010 P.05 •·· EPA'S REVIEW Of PUB! IC COMMENT EPA will review comments received from the public as part of the process of reaching a final decision for the soils included for this Operable Unit concerning the cleanup of the NSCC site. As with the first Operable Unit, EPA's final selection will be is.sued in a ROD for the site. A document, c.allcd a Responsiveness Summary, that summarizes EPA's responses to comments received during the public . t.:-ru111(.nt ~ri,:,d will Ix i.1w,d w;th tl.G ROD. Once the ROD is signed by the EPA Regional Administrator, it· will become part of the Administrative Rernrd, containing all docume.nts tL<ed by EPA to choose a remedy for the site. ADDITIONAL PllBLIC INFORl\tATION Be«rnse this Proposed Plan provides only a summary de.scription of the NSCC site and the cleanup alternatives, the public is encouraged to consult the Admini.<trative Record, which cont a ins the RI, Supplemental RI, and FS reports, and othc.r site documents, for a more detailed explanation of the. site and all of the remedial alternatives under considc.ration. The Administrative Record will be. available for review at the following locations no later than July 30, 1990: EPA Record Center 345 Courtland Stree.t, NE Atlanta, Georgia 30365 (404) 347-0506 Inrormatlon Repository Rowan County Public Library 201 West Fisher Street Salisbury, North Carolina 28144 DEVELOPMENT OF EPA'S PREFERRED ALTERNATIVE EPA's selection of the preferred cleanup alternative for the NSCC site, as described in this Proposed Plan, is the result of a comprehensive evaluation · and screening process. The FS for the site wa.s conducted to identify and analyze the alternatives considered for addressing contamination at the site. The FS report for the NSCC site describes the alternatives considered, as well as the process and criteria EPA must use to narrow the list down lo the final alternatives beu,g considered for soil remediation. EPA uses the follov.ing nine criteria to evaluate alternatives identified u, the FS. While overall protection of humun health and the eovironnwnt is the primary objeclivc of the remedial action, the remedial alternative sclccicd for the site must achieve the bes! balance among the evaluation criteria considering the scope and relative degree of contamination, 1. Overall Protection of Human Health and the £n1.,~ronme,nt addrc.s.sc.s how an alternative as a whole "'ill protect human health and the environment. This u,cludes as asse"mcnt of how public health and cnvuonmenlal risks are. properly eliminated, reduce.ct, or controlled through treatment, engineering controls or inst it utiunal controls. 2. Com pliancc ""th Applicable or Relevant and Apl?ropri~te. Requirements {ARARs) addres..ses whether or not a remedy complies with all slate, and Federal environmental and public health laws and requirements that apply or are relevant and appropriate to the conditions and cleanup options al a specific site. If an ARAR unnot be. met, the analysis of the. alternative musl provide the grounds for invoking a waiver. 3, Long-term · Effectivene~s and Permanence. refers to the ability of a remedy to maintain reliable protection of human health and the environment over time once the cleanup goals have been met. 4. Reduction of Toxicity Mobj!ity. or Volume looks at three principal measurements of the overall performance of an alternative, The 1986 amendments to the Supcrfund statute (SARA) emphasiu tbat, whenever possible, EPA should select a remedy that uses a treatment process lo permanently reduce the level of toxicity of contaminants at the site; the spread of contarnu,ants away from the source; and the volume, or amount, of contamination at the site. 5 Jul 24,90 14:24 No.010 P.06 •• 5. ShorHerm Effectiveness refers to the technical and administrative feasibility of an alternative, including the availability of materials and scr.kes needed lo implement the alternative. 6. ~ includes the capital (up-front) cost of implementing an alternative, the cosl of operating and mainti'.iin.ing the.:. alternative over the long term, and the net present worth of both capital and operation and maintenance NSls. 7. Stale Acceptance addre;.ses whether based on lhe review of the RI/FS and Proposed Plan, the state concurs with, opposes, or has no comment of the alternative EPA is proposing as the remedy for the site. 8. Community AcceptilnC~ addresses whether the public concurs mth EPA's Proposed Plan. Community acceptance of this Proposed Plan \\111 be evaluated based on comments re<.eived during the Public Comment Period. SUMMARY OF THE REMEDIAL ALTERNATIVES A complete list of the remedial alternatives being considered for soils at the NSCC site is presented in Table 1. After screening and evaluation of these in.itial alternatives, the follo"1ng five remedial alternatives remained under consideration for Operable Unit 2 soils. Ahcrn~tive 1: Natural Soi) Flushing (No Further Action) This altcrnativ.e would allow for the naturally occurring pre<.ipitation (rainfall) to percolote into the lrcocb area infiltrating into the groundwater and ultimately being extracted through the groundwater pump and treat system. This alternative effectively uses the same leaching process that was originally used for disposal of the waste waters. Clean water is allowed to filter through the subsurface soils into the groundwater. The groundwat,,r remedy seleeled under Operable Unit 1 is designed to prevent further migration of the groundwater plume. . Contamination will be reduced over time through l,iodei;radatlon, leaching and naturul volatflizalion of contaminants. J. ,, ,, __ ....... -,,;_;-;,, ... l .- The contaminated soils in the trench area do not present a health risk through direct contact of surface soils since the 'signilicant levels of contamination are approximately 18 feet below land SUrface. The trench area soils are well within an area of the Nation.ii Starch property. Access restriction is not required, however deed restriction will be filed idcntif)ing the areas of contamination and will prevent property transfers to uninformed purchasers and limit future. utilintion of the property. Periodic sampling will be required under this option to determine the effectiveness of the cleanup technology. Monitoring will be required at minimal intervals of every five years. This remedial action selection of natural · soil flushing does not provide further mitigation to the soil contamination beyond the natural processes and will allow the manife.station of the soil contaminatinn thn•ugh th,, naturally flowing groundwater. As a result, this alternative constitutes a "No Further Action• alternative. CERCLA requires that the no action allcrnative be considered in all situations. Estimated Present-Worth Costs for operation and maintenance: $151,000 This alternative involves the c~pping of the trench disp,.,sal area. Caps arc constructed of multiple layers that significantly reduce the infiltration of rainwater and there.fore the rnigralion of contaminants into the groundwater. This alternative docs not provide further mitigation to the soil contamination in the trench area. Two types of caps would be retained for consideration. The first cap consideration is a Resource Conservation and RC<'overy Act (RCRA) cover which would meet all criteria deftned by RCRA. This cap is constructed with a top vegetation cover, underlain by a "drainage layer" that is no less than 12 inches in thickness with additional permeability requirements ll5 well as construction requirements. A final underlying layer with additional construction material requirements, thickness and permeability rates completes the design of a RCRA ,;,p. Tbe second cap under considcralion is a soil cover that would meet North Carolina Solid Waste Regulations. This co,·er would consist of no less than 6 inches of top soil with vegetative oover, 6 Jul 24,90 14:24 No.010 P.07 •• underlain by a low permeability day layer no less than. 18 inches thick. Pcrm·eabiliry rates are careful!)' engineered with both types of caps. The rationale for capping is the reverse of the rationale conside.rcd unJ,;r Alternative 1. This alternative docs not enhance the groundwater pump and treat system for Operable Unit 1 and may result in a longer period of tin1e for groundwater remediation. The capping alternative presented in the FS does not take into account the requirements identified for RCRA caps nor for the cover requirements defined by North Carolina's Solid Waste Regulations. The FS identifies a low permeability clay cap. Therefore, costing information presented in the FS for thi, c,ip is only an estimate. Costing infc.)rmation is provided for a comparison basis, but must be considered as an underestimate. (Costs would probably be in excess of $1 million to meet RCRA and/or North CaroLJna Solid Waste Regulations.) Estimated Present-Worth Costs for construction and maintenance: $423,000 .6!)i;rn11t i,·c 3 -In Situ Soil F1ushin~ This alternative iavolws in-place flushing of the trench area soils dUring the groundwater remediation effort. Enhanced flushing can hasten the time for re.duct ion of residual contamination on the soil. This alternative is essentially equivalent to Alternative 1 except that the introduction of water would be an active operation whereas Alternative 1 is a pa;..1ivc introduction of water. Estimated Present Worth Costs for construction, operations and maintenance, and monitoring: $781,000 Alternative 4: Excavation and Incineration This alternative involves onsite incineration of exuvated soils from the trench area. . The approeimate volume of soils to be remcdiated is 250,000 cuhic yards. The soil can be incinerated at rates up to 2() tons. per hour. Emissions and efnue11ts will be treated, monitored, and controlled to levels within current regulatory limits. :::..r n -~---·. --. ~, ~n1,: n •• Incinerated material "ill be analyzed prior to replacement in disposal areas to ensure that remediation and ARAR levels have been achieved. After replacing the incinerated soils, the disposal areas will be _covere.d 'Nith topsoil and rcvcgdatcd. Estimated Present-Worth Costs for excavation. on.site incinuation, disposaJ, operations and maintenance: $52,125,000 e,ltcrnative 5· Excavation and Offsite Disposal In this alternative, 250,1)()() cubic yards of contaminated soTI in the !reach area would be excavated and transported to a RCRA permitted landfill for disposal. The 250,000 cubic yards of contaminate soil only addresses the soil in the unsaturated 7.(mc; the contaminated son in the saturated zone would not be excavated. Estimated Present-Worth Costs for cxca.vati,on, tran.)portation, dispos.11, an<l site restorations: $51,900,000 EPA'S RATIONALE FOR SEl.i:cCJlNG THE fREFERRED l?,LTF,RNATIVE Based on current informati0n and analysis of the RI/FS report1, and the original and supplemental investigation.,, EPA believes that the preferred alternative, Alternative I, Natural Soil Flushing (No Further Action), for the NSCC site is consistent with the requi.reme.nts or the Superfund law and its amendments, spccific<1lly Section 121 of CERCLA and the National Contlnsency Plan (NCP). All of the alternatives presented in thi< Proposed Plan would provide overall protection of hunian health -and the environment, including the No Further Action alternative. In EPA's analysis, the No Further Action alternative would achieve a balanc<; of the nine selection criteria, The soils in the trench area can only contribute contamination to the groundwater, Groundwater remediation has been decided; the design stsge has been completed, construction of the pump ;ind treat system v.ill start in the Fall or 1990. Remediati,,n of groundwater takes many years to achieve the cleanup levels as defined by existing environmental laws. The No Furthc.r Action alternative work$ in conjunction \1/ith the pump arid treat system in a p.issive manner 7 Jul 24,90 14:24 No.010 P.08 •• without impacting either the S<:hedule or the costs of the remedial action at the site, Any other alternative selection would introduce concerns including delays in the groundwater remediation, additional com, waste handling, construction and implementation problems. The preferred alternative, Natural Soil Flushing: 1) provides short-and long-term protection of human health and the environment, 2) will attain Federal and slate applic.ihle and appropriate public health and environme.ntal requirements (ARA.Rs), and 3) utilizes a permanent solution to the maximum extent practicable. Clossao Administrative Order or Consent: A legal agreement between EPA and the potentially responsible parties (PRPs) whereby the PRPs agree to perform or pay the cost of a site deanup. The agreement describes actions to be taken at a site and may be subject to a public comment period. Admlnlstn,th·e Record: A file which i.s maintained and contains all information used by the lead agency to make its decision on the sele<"tion of a response action under CERCIA This file is requi.red lo be available for public rc,iew and a copy is to be established at or near the site, usually at an information repository. A duplicate file is maintained in a central h)cation, such as a regional EPA and/or state office. Aquifer: An under&,round rock formation composed of material such as sand, soil, and/or gravel that can store and supply gr,,undwater to wells and springs. Biodegl"llda!lon: The breakdoWn and removal of contaminants by the use of naturally occurring microbial activities found in subsurface soils. Compreb,nslve Environmental Response, Comp,.nsatlon, and LlabllitJ Act (CERCLA): A Federal law passed in 1980 and modified in 19&i by the Superfuad Amendments and Reauthoriz;,(ion Act. The Acts created a special tax that goes into a trust fund, commonly known as Superfund, to investigate and cleanup abandoned or uncontrolled ha7.ardous waste sites. Under the program, EPA can either pay for site cleanup when the responsible parties cannot be located or are unwilling or unable (J) TMJo6ie l. National S1an:h and ('.h<=mic11J Corporal ion Srtt,ening 0 Control Tet·hnoJ°tP,o; rur Sojf Conlaminalion LI... Sci! General R<medwT~ P= Option Ef(ccti=>ess Implementability Cost Status •:::) ~ ,:::) No Purtllcr Action Natural ,o,1 nuwng N/A N/A r-.·; A; .,,,;11 likdy ""!uite long-mm LowO&M R,tained D mowooru,g z lmtilwtionalActioo< .AcccQ; ratriction5 Deed 1eatJ.iC'..tioo.s El!caivc in lialiting ~ o{ t:rcncb area "-1 ""I-Negligi)lc -"'=T ~ncing •Diml.i.s5ed (_"-J c:.p Oayaoosou flf~ ~J'ttClll :leaching of COfltamina.nU Easily impleane.nted; =trictioo <lll futuro ~ capilAl, low °"'-Rctamed ~T into· tcr; nisccp<ibJe to cn.cbog land use mwn- ~ Muhila;rerod cop :eJfective; ie&st susceptible ro cn,d,i:ing: Eas.ilv irnpl.e:me.nted.; m..trictioc oa. fu.rurc Mode~te c11pita~ Rctao>ed ,:::) land ·use . low IlUlOtcnan.::e ,Jo Vertical barricn Slunywall Not feasible because 6Jroundwa1er is. Difficult to~ cootimity of duny or !:Ji!Rt'"pial, low Diomiaed rontaminated within e fraccured bedrock backfill 7" •-:-'-l • Gro1111 c:wuin 1'«>t. cffectnot-bccalA-C of hacn.iRd bcdrod: (?iff~h. 10 -..ctjfy cooti,:wuy of waJJ; mu&i: ~rap;uu, low Dismisocd ne mto i,m_pc;r¥'JOIJ5 rone :, Sbect pie Not cffectM:. l)ecausc of fractured bedtoct Difficult ~io bc:drod£; ao acavalion ~capital, k:,w Diuni5ood ,-) ~~/fteal- n,quucd; . . to 50 feet Rcn>CMI! ExaM!tioo Eifectiv-e. for removal of rontaminMIS in iOt.l, but Readily i~pkme_oled ir.nh COO"lo'C.atioaa ~ capital, low mall .Actiri& rc:,q_ui:re;s~I t:'Ofntrumoo. cqUJpment R,tair,ed Phygcal b'elltmcnl Soil-.lung Water can tic effccti\•c :-ini.."'IC ~a tiles of ronccm [m['\emcnted using oommc1riaUy lli~f.lBI, -~ are highly r.()lublc. Rpiuircs c>."C-3\'"".ttion and the .avaa_la.bte min.mg ai-ad cbemic&l ~ M a e O&M treatment of wa[cr. Cbvcy soil can hinder -removal efficicncic.. POOr tr-de.I. record; may »ot treat to desired k::Ycls T Soil I""""'& Flf«fr.,,:n,ess is dependent on ambient ~ implemented. R~uira cn"li!Yatioo ~~C"lpital.lu~ "Dismissed temfuJ.r-Jture.-., prcctpt"tation ao_d wi(!d. May_not of contam:in.otcd SOil& a.n 5,pru.Jing oYeJ" T coo o.rm to .11.lT K~ regulauons to1 \'Olatilc large uca With iW'fa.cc 11t"ilct coot.rol ,r oompound<. I Solidificatioo /-1'--bt an crfcctive method for organic-rompounds.. !f:i~~ly~~~~aod :\ioderatc a.pilal, "Dismi.s<cd ·r flllltioo lowO&M ,") I In ~[u U'Catment Subsurface Eff~~n,ess ~ (,lependcnr on soil uniformity (i.e.. Readilv im~menled by horizonu/. Moderate -c-atkal., Dirmjg,:d t t»ottclamatioo gn,n MLC, J>OIUl'Y, pH, etc.) irrigatton. r ~Wre beoch-.sqtl.e mode.rate 0 ~~~~foe tu type ,j. Sail n&.<d>in& r:.ifo::-tivcoess is dt~ndenr on '°11 ua"onmty IOd Not readily_ iraplcmec.t-ed io dq::y 50ik Modentc caffl1, R<uiacd abitity to capture t leachate wouJd ~u1re numcrou.s modcralc 0 injection., e.,-u-ac-ttOll wells -1.Dd 5CYC3'al ye= of fluming • Sod vcutin,g Not an effectivt: method for tight clayey roils :"lot radily_implcmen~ed in yli;tyey-':')tl:... Moderate caEJi• "Di,missed would re.quire~ au lill,cctKMli lllodeJ'alc () Thermal treatment Rowy km inaae"""" ~ectivcnc::u is dcp1mdeot on opcratKXl o( Clo)<:\ soils may =tuirc kl"l(r =idcD<c ~bghca~,low R<tau>cd [ maneratoc 11mc t erebyi~ m6Jcra e or high Av.a.tlal>ilii,) of incioc.ra is · O&M q uc.sti ooa le. Thermal daorpt:ioo EtTectiYe oo ><>!able O<ga,,j< compounds lmplema11abou may n,quite t=ing fugh ""t:"l . =-mo.:kra O&M e.av.tK>n/-Di,pooal Anioo 00-4itedi<po<a) RCRA facility Effcct_ivc a&d reliabk:. but rcquirr.:s 1.ntnsportatioo. PeC1IUu. ~uired 15t'i.tcapital, high R<<aincd -AadoneM tor d:5-mlssal ts di~ tn the rs Report located at the !~CN"rna-Uon Repository. ,-__:. _______ ___: ______ ~10 ___ _:_____ ____ ----+-~-----:--•' ,-'---,-, • SUPERFUND UPDATE .. . rr1:c°l::1 .. Fact Sheet JUz o ,-. 11E(J Sl/pf.HF/1, n J 189; NATIONAL STARClfc& CHEMICAL COMPANY Salisbury, Rowan County, North Carolina INTRODUCTION: The U.S. Environmental Protection Agency is pleased to provide a status report of activities to date at the National Starch and Chemical Company (NSCC) Superfund Site. This Fact Sheet specifically will explain the current ac- tivities that have occurred in Operable Units 1, 2, and 3. SITE BACKGROUND AND HISTORY: The NSCC Site is located on the outskirts of the Salisbury city limits. Edward Proctor of Salisbury founded the Proctor Chemical Com- pany in 1938. In September 1968, Proctor purchased the 465-acre Cedar Springs Road property. Within the next year, Proctor Chemical was acquired by NSCC and operated as a separate subsidiary. Construc- tion of the Cedar Springs Road plant began in 1970. On January 1, 1983, Proctor Chemical Company was dissolved and its operations merged with NSCC. NSCC's Salisbury facility'"is priml¢ly a manufacturing plant for June 1991 textile finishing and custom specialty chemi- cals. From 1971 to 1978, the NSCC conducted on- site disposal of approximately 350,000 gal- lons of rcaCtion vessel wash waters in trenches constructed in a 5-acre tract of land (the trench area) located west of the plant The corrosive wash water consisted predominantly of salt brines, sulfuric acid solutions, and solvents"> The water was dis- posed in several trenches approxin:iatel y 200 to 300 feet long and 8 feet deep. Liquid effluent from the plant production area flowed into the easternmost unlined pretreat- ment holding lagoon, and was pumped to the active trench area. Each trench was used until liquid no longer readily percolated into the ground. Afterwards the trench area was back- filled and seeded, and a new trench area was constructed. In 1976, eight monitoring wells were installed around the Site by National Starch to deter- mine if the trenching operations were impact- ing groundwater quality. Four of these monitoring we]Js were installed adjacent to or within the trerich area. Monitoring revealed that shall.ow groundwater immediately within ruid adjacent to the t,renc~ area was con- taminated. In June' 1977, sampling by the North Carolina Department of Natural and Economic Resources, Division of Environ- mental Management (DEM) verified National Starch's earlier conclusion that some of the · monitoring wells were contaminated. Based on analysis of samples taken at that time, DEM requested that National Starch cease on- site waste disposal activities at the Cedar Springs Road Plant. Since 1978, when the City of Salisbury installed a sewer line for the plant's usage, production plant process waters · have been directed to a pretreatment facility, going through the sanitary sewer system. Three of the eight monitoring wells were sampled by DEM in January 1983. DEM found that the well located in the center of the disposal area contained the metals cadmium, chromium, copper, lead, and zinc. These materials were not detected in the two wells , adjacent to the disposal area. National Starch sampled the monitoring wells from September through October 1984. Sig- nificant contamination of the wells within and adjacent to the disposal area was found during the October 1984 sampling. The metals cad- mium, arsenic; chromium, copper, lead, nick- el, zinc, and silver were found in the well in the center of the disposal area, ilong with a variety of volatile and semi-volatile organic chemicals. The October 1984 sampling was followed by a DEM sampling in late October 1984, with similar findings. The North Carolina Division of Health Services (DHS) sampled private wells within 2 miles of the National Starch Site in October 1984. No volatile organic compounds were detected. The Rowan County Health Department • (RCHD) also sampled private wells in proximity to the National Starch Site. None of the chemical compounds sampled for were found. The NSCC Site was proposed for inclusion on the National Priorities List (NPL) in April 1985 with EPA assuming lead responsibility · for the Site. Negotiations to allow NSCC to conduct the Remedial Investiga- tion/Feasibility Study (Rl/FS) activities were concluded with signature of an Administrative Order on Consent on December 1, 1986. These activities resulted in the issuance of the first ROD for the Site. 2 The first ROD addressed the remedy for the groundwater contamination at the Site. This ROD was signed in September 1988 and was termed Operable Unit 1. The ROD also specified that soil contamination in the trench · area be further investigated to determine · whether this area continued to be a major source of groundwater contamination. The first ROD also required that analytical monitoring continue on contaminated surface water and sediments to further delineate the source of contaminants to the creek. Installa- tion of extraction wells began in August 1990 which constitutes the initial Remedial Action (RA) for Operable Unit 1. The second ROD addressed the soil con- tamination in the trench area as a source con- trol. This ROD was signed in September 1990 and was termed Operable Unit 2. The remedy selected for this Operable Unit was the no action alternative which will be described below. This ROD also outlined the need for a third Operable Unit to describe the extent of contamination in the Northeast tributary. Sice Locacion Map National Starch and Chemic-rporation Site Rowan County, North Carolina SCALE NSCC SUPERFUND SITE \ \_ Nallonal ' Chemical Corporal Ion r:---.::;,::s· . ~ ·. ---;:=;;:·~~, , :·~:.. \ ~··.·. . . . /Ctj .--. r , SCALE 1:24 000 ,-l l 0 \ '"<l \ --------m• '--!_.' ' """'"' CONTOUR INTERVAL 10 F(CT 0 Sta,ch and \ 00\ t) .... _,,_,.\" 3 CURRENT STATUS OF THE SITE: Operable Unit 1 -This ROD required the development of a groundwater interception and extraction system to lie installed downgradient of the contamination plume. Pretreatment for the extracted groundwater in- cludes air stripping, filtration through ac- tivated carbon, metals removal, and treatment through the company's existing lagoon sys- tem. Presently NSCC is negotiating with the Salisbury Publicly Owned Treatment Works (POTW) for the discharge of the treated water. A contingency plan for an alternative discharge point was included in the ROD if permit requirements for the POTW cannot be met.• Operable Unit 2 -The second Remedial In- vestigation confinned very low levels of residual contaminants in this area. The Con- sent Decree for this ROD is anticipated to be signed in the summer of 1991. The ROD called for a no action alternative which would leave the contaminated soils in place. This will allow for the naturally occurring leaching or cleaning of the soil in conjunction with groundwater remediation. Leachate from the residual soil contamination would be ex- tracted and treated by the groundwater extrac- tion system. Infiltration to groundwater is the only route of migration and subsequent ex- posure potential. A deed restriction would be filed identifying the areas of contamination. The deed restric- tion will prevent property transfers to unin- formed purchasers and will limit future utilization of the property. These restrictions are easily implemented by processing the restrictions through a local attorney and the Rowan County or City of Salisbury Register of Deeds. 4 • The trench disposal area itself does not present a direct health risk. As previously stated, the risk posed is through the migration from soils into groundwater; subsequent con- taminated groundwater consumption poses the principal Site threat. Therefore, access restric- tion to this area is not required. It should be noted that the trench area lies well within the NSCC property. Soil sampling was done on June 6, 1991. Soil samples will be collected for monitoring purposes periodically for several years to verify that soil remediation is progressing. Operable Unit 3 -This Operable Unit will ad- dress the contaminants in the Northeast tributary. The Supplemental RI included monitoring of the surface water and sediments in the Northeast tributary. This tributary was . sampled in October and November of 1989, July 1990, and June 1991. Results of this tributary sampling confinned surface water and sediment contamination. Therefore, the Northeast tributary is being addressed as a third Operable Unit to determine the source of this contamination. PUBLIC INVOLVEMENT: Community relations are vital to the Super- fund process. Citizen involvement is stressed in the Code of Federal Regulations governing Superfund site activities. Public meetings, fact sheets, and the establishment ofan infor- mation repository are typical methods used to provide information to a Superfund site com- munity. The repository will contain all relevant site documents prepared during this process which are available for public review. As indicated in the Superfund process flow- chart, we are between steps 6 and 7 on Operable Unit No. 1, and step 3 on Operable Unit No. 3. This fact sheet is provided not • SUPERFUND PROCESS REMOVALS I---------~ I ENFORCEMENT 2 3 4 5 6 7 8 NPL RanklnQ Publlc Record Cleanup Plan Ll9tlno Aemedlal lnvoellgatlon Foaelblllty_ Study Commenta of D.clelon Cleanup IL ----------1►• I COMMUNTTYRELATION8 \ only to update the community on the current activities of the Site, but also to encourage par- ticipation in the S uperfund process. As part of the Superfund program, EPA is providing communities with the opportunity to apply for Technical Assistance Grants (TAGS). These grants (one per Site up to $50,000) are designed to enable community groups to hire a technical advisor or consultant to assist them in interpreting or commenting on Site findings and proposed remedial action plans. Citizens who are interested in the TAG pro- gram may obtain an application package by calling or writing the following EPA Region IV Technical Assistance Grants contact: Ms. Rosemary Patton N.C. Technical Assistance Grants Coordinator Waste Management Division U.S. Environmental Protection Agency 345 Courtland Street, N.E. Atlanta, GA 30365 (404) 347-2234 5 C FOR FURTHER INFORMATION CONTACT: Barbara Benoy Remedial Project Manager . North Remediai Superfund Branch U.S. Environmental Protection Agency· 345 Courtland Street, N.E. Atlanta, GA 30365 (404) 347 -7791 Ms. Diane Barrett Community Relations Coordinator North Superfund Remedial Branch · U.S. Environmental Protection Agency 345 Courtland Street, N. E. Atlanta, GA 30365 (404) 347 -7791 INFORMATION REPOSITORY: The Administrative Record is the official compilation of documents, data· reports, and other infor- mation important to the status of and decisions made relative to a Supei-fund Site. Infonnation for the National Starch & Chemical Corporation site is available for public viewing and copying at the local information repository: Rowan County Public Library 201 West Fisher Street Salisbury, NC 28144 Hours: Monday -Friday 9:00 am -9:00 pm Saturday 9:00 am -5:00 pm MAILING LIST ADDITIONS: If you know of others who would like to receive information on the National Starch and Chemical Superfund Site, please have them complete this form and mail to the address below. Name _______________________________ _ Address _____________________________ _ City, State, ZIP ____________________________ _ Affiliation ______________________________ _ Phone _______________________________ _ Diane Barrett -Community Relations Coordinator North Remedial Superfund Branch U. S. Environmental Protection Agency -Region IV, 345 Courtland Street, NE Atlanta, GA 30365 6 UNI ED STATES ' ENVIRONMENTAL PROTECTION AGENCY REGION IV -North Remedial Branch ' 345 COURTLAND STREET ' ::i:: :~:::: 30365 PENALTY FOR PRIVATE USE, $300 87 ~.-I ;~ ., I l j-: ;-~ ~ •• •• UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION IV AUG 2 8 1989 4WD-SFB 345 COURTLAND STREET, N.E. ATLANTA. GEORGIA 30365 CERTIFIED MAIL RETURN RECEIPT REQUESTED Katherine L. Rhyne, Esquire King and Spalding 2500 Trust Company Tower Atlanta, GA 30303 RE: National Starch RD/RA Salisbury, NC Dear Ms. Rhyne: In response to your letters of August 10, 1989 and August 15, 1989, the Agency is revising the deliverable due dates in Section V, Paragraph D of the Unilateral Administrative Order dated July 27, 1989, Docket No. 89-32-C. The following is the new schedule for deliverables: DELIVERABLE Conceptual Design -30% Complete EPA Comments Draft Final Design EPA Comments Final Design Report Preconstruction Activities Begin Draft O&M Plans EPA Comments Final O&M Plans Start-up Activities Begin DUE DATE October 25, 1989 November 28, 1989 January 8, 1990 February 12, 1990 March 14, 1990 April 16, 1990 April 16, 1990 May 14, 1990 June 13, 1990 July 2, 1990 If you have any questions, please contact Ms. Giezelle Bennett at 404/347-7791 or Mr. Reuben Bussey at 404/347-2641. Sincerely, ~h1T~ Patrick M. Tobin Director Waste Management Division cc: Charles H. Tisdale, Jr., Esquire Alex Sampson, NSCC Hank Graulich, NSCC Ray Paradowski, NSCC 345 COURTLANC STREET. N.E. JAN O 5 1990 4WD-SFB CERTIFIED MAIL RETURN RECEIPT REQUESTED A. M. Samson, Jr., Esquire ATLANTA. GEORGIA 30365 Counsel, Regulatory Affairs National Starch & Chemical Corp. 10 Finderne Avenue Bridgewater, NJ 08807 RE: National Starch RD/RA Salisbury, NC Dear Mr. Samson: JAN 161990 SUPERFIJNO SECTION In response to your December 20, 1989, the Agency will grant the six week extension on submittal of the draft final design report that you requested. Therefore, the draft final design report will be due to the region no later than February 19, 1990. If you have any questions, please do not hesitate to call me at 404/347-7791. Sincerely, dJ/ -ik-x! 8/M (__ Gi:;{elle' S .· Bennett Remedial Project Manager cc: H. Graulich, NSCC R. Paradowski, NSCC M. Sturdevant, IT T. Eggert, COM Ul t!I :J \ l·\1-\\, l1C,\:ht: OJ'°ill '.,Uqua •• •• MEMORANDUM SUBJECT: •• •• UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION IV 345 COURTLAND STREET, N.E. ATLANTA. GEORGI A 3036 5 National Starch RD/RA Salisbury, North Carolina DATE: fEB 2 7 1990 FROM: TO: Barbara H. Ben~ Remedial Project Manager Review Team Doug Lair, ESD Wade Knight, ESD Rutherford Hayes, Water John Lank, RCRA Jack Butler, NC DEHNR Tim Eggert/ Joe Claypool Attached is the Draft Final Design Report for the Remedial Design at the National Starch Site in Salisbury, NC. Please review and send any comments that you may have to me no later than March 23, 1990. If you have any questions, please give me a call at x7791. .. - /. f~ ~.: .... Ni_i~·.·. CHAIRMAN Julia C. Howard VICE-CHAIRMAN David Springer SECRETARY Ruth Phillips TREASURER Wayne Mabry EXECUTIVE SECRETARY Joe C. Matthews EXECUTIVE COMMITTEE John Barber Davie County Sherman Cook Davidson County Glenn Deal, Jr. Alexander County W. E. DeJamene Alexander County Julia C. Howard Davie County Ed A. Listerman Stanly County Wayne Mabry Stanly County David Morgan Stanly County Albert L. McAuley Montgomery County Robie Nash Rowan County Ruth Phillips Forsyth County David Springer Davie County Hall Steele Rowan County Thomas Wooten Yadkin County •• •• Yadkin-Pee Dee River Basin Committee 280 S. Liberty Street (919) 722-9346 September 4, 1990 Mr. R. Jack Butler Environmental Engineer Superfund Section Environmental Protection Agency P.O. Box 27687 Raleigh, NC 27611-7867 Dear Mr. Butler: SE:P 6 1990 I have enclosed for your consideration, and that of other officials, a copy of a resolution passed by the Yadkin-Pee Dee River Basin Committee in a meeting in Rowan County on Saturday, September 1. Your careful consideration of this resolution will be greatly appreciated. If you have any questions, please feel free to let me know. ~{:-~ Julia C. Howard cc Federal, State and Local Officials cc Board of Directors, Yadkin-Pee Dee River Basin Committee .' ~.. .. ;~~ I' . -.w'f!t~c 1-..... ,:~ · ~Ji~ifl CHAIRMAN Julia C. Howard VICE-CHAIRMAN David Springer SECRETARY Ruth Phillips TREASURER Wayne Mabry EXECUTIVE SECRETARY Joe C. Matthews EXECUTIVE COMMITTEE John Barber Davie County Sherman Cook Davidson County Glenn Deal, Jr. Alexander County W. E. OeJarnette Alexander County Julia C. Howard Davie County Ed A. Listerman Stanly County Wayne Mabry Stanly County David Morgan Stanly County Albert L. McAuley Montgomery County Robie Nash Rowan County Ruth Phillips Forsyth County , David Springer Davie County i Hal! Steele Rowan County Thomas Wooten Yadkin County •• •• Yadkin-Pee Dee River Basin Committee 280 S. Liberty Street • (919) 722-9346 • RESOLUTION Winston-Salem, N.C. 27101 FAX (919) 725-1598 WHEREAS, the Yadkin-Pee Dee River Basin Committee opposes in principle the use of the state's lakes and rivers as the receiving basins for cleanup of hazardous waste. NOW THEREFORE, be it resolved by the Yadkin-Pee Dee River Basin Committee: ( 1) ( 2) ( 3) That the Committee opposes the Environmental Protection Agency's allowing the use of lakes and rivers in North Carolina as receptors of inadequately treated waste. That the Committee insists that the EPA act in a timely manner in devising and implementing plans for cleanup of hazardous waste sites and that it do so with full compliance of all federal, state and local standards. That factors other than cost of cleanup be of paramount consideration in devising and implementing remediation plans. NOW, THEREFORE, BE IT HEREBY RESOLVED by the Yadkin- Pee Dee River Basin Committee, at the annual scheduled meeting on the 1st day of September, 1990, that we do strongly approve the foregoing recommendations; and BE IT FURTHER RESOLVED that a copy of this resolution be forwarded to R. Jack Butler, with the North Carolina Superfund Branch of EPA, and all other officials who should receive a copy of this resolution. ia C. Howard, Chairman adkin-Pee Dee River Basin Committee ,·. STATE & LOCAL •,, 2 .---- .. , ... ,---. --. -............ , . ' ,. 'f,. •I Group Questions Waste-Dump.Cleanup Pia~:{ .! • By Terry Martin · · river basins in cleanups of hazardous• cleansing before It is discharged Into:.":· ,.· JOURNAL REPORTER waste contamination. . Grants Creek and enters the lake. •.,.d 1 .,· .. . . MILL BRIDGE "We don't have a vendetta Mary Apperson Davis, •·committee Thesiteisoneof23Superfundsitcsln·:••.· : '' · r . Federal plans to discharge billions of • · member from Davie County, said, "We North Carolina that the EPA lists as ns· ,r.; : gallons of treated water from a hazardous-against National Starch; it just don't have a vendetta against National tional prtorttles because of extensive.' I waste cleanup into High Rock Lake drew seems that EPA has a basic Starch; It just seems 'that EPA has a basic chemical contamination and threats to the ..... ; questions and calls for caution yesterday policy of locking the barn after the horse environment and public health. , .' ;0,, from an 18-county river-support group. policy of locking the barn after has rim away, and this is something that But Paradowski told the group,. "The , ,, The directon of the Yadkin~Pee Dee • our children and our grandchildren arc acvcrlfy ofthis sire ls rather mlniJ!W com#•·:,, River Basin Committ"" took luue with . the horse has run away .... " going to have to live with." pared to many others In North Carolina.", . plans by the U.S. Environmental Protec-_ Mary Apper9on Davia Ray E. Paradowski, the general manager John C. Vest, the director of utilities for ,,: tion Agency to let a company pipe up to of the National Starch plant, told the Salisbury, told the group that, under cur-.-;, 200,000 gallons a day of treated industrial Committee member group that all significant collccnttatloris of rent construction plans, the discharges ,i:: wastewater Into the northern end of the· -~--~----------chemicals In the water -which federal would not begin until the spring of 1992 ... lake. . . . 350,000 gallons of chemicals that National · records show to contain 11 cancer-causing He said that all the wastewater would -,., The wastewater would be the byprod-Starch and Chemical Corp. buried In compounds -would be removed at a 'undergo 20 days of treattnent and that the~ :; µct of an effort to clean up a five-acre open trenches from 1971 -78 at one of its treatment plant that his company ls build-pumps could be cut. off at any time if'. . waste dump south of Salisbury. Rowan County planta. · ·: lng at the site. problems are detected. -:rc~ The project -which would take· 30 The boarcl, meeting In Sloan Park just · That treated water would then be piped "They're basically nor 110tng to be send· '.; ·: years -is intended to remove contaml-eight miles west of the site, adopted a to the Grant.I Creek waarewater-rreat----------------· nated groundwater that 15. 1ullied by resolution opposing the USC of lake and ment plant near Salisbury for additional ... CLEANUP, Pace C3 ·-~ .1 I I I I tni ~s ilnythtna that they hnen't . been tcndln11, us for. yevo, but they.' will be upgrading their system," Vest . said. . . . .... . .. _., , ,. _,,· D. Reid Stnlc Jr., the chalriniri of· the Davidson County commission- , '"J• said that the gtoup wants more · : assurances. , · ·,' . 11 From rriy COUrfrY's 'exptrieiiCt,· they certainly do not mohltor the· sewage that High Point· is putting out into our streams/' Sink said. "What we'ie saying here ls we WB.rit to be · tertaln."· · ·· : · ·. · ·.: . . Joe c. Matthews; the ~.Ri.itive di-, recioc of the committee, said that·; copies of the. resolution .will be .,at to the EPA, state regulators and the· ( N. C. Environmental Management Commisaion. ., . _ . . , · ,·. "We've had 1ome oerious f,lob-·1.,;;,, In North Carofina and the na-~: tlon because people have . riot b<oti; enforcing the ·regulations,.· and wt.! want to be otl record that 1treami l and lakes should not used ln these cleanups." · · , The EPA's plan, authorized Iii! ,:. September 1988,.came after federal: •authorities rejected as too expensive!' a $51.9 million proposal to pump out· the contaminated water and haul it· by truck to a lwardous-wute treat-! ment plant. · . . · .•· . t YADKIN-PEE DEE R .. SIN COMMITTEE BOARD •• ECTORS-PRIVATE Mr. John Barber P.O. Box 928 Bermuda Run, NC 27006 Mr. J. David Brendle II 119 West Brenhaven Drive Elkin, NC 28621 Mr. James Lacie Buie Route 7, Box 606 Thomasville, NC 27360 Mrs. Terri Lee Burnham Route 10, Box 785-C Salisbury, NC 28144 Mr. Sherman Cook 622 Cardinal Drive Lexington, NC 27292 Mrs. Joanna Cornwall 412 West Street Winston-Salem, NC 27101 Mr. Victor Crosby Route 2, Box 47 Harmony, NC 28634 Mr. Judson S. Davis 747 Sylvan Road Winston-Salem, NC 27104 Mrs. Mary A. Davis Route 4, Box 569 Mocksville, NC 27028 Mr. W.E. DeJarnette P. 0. Box 46 Stoney Point, NC 28678 Mrs. Jamima DeMarcus 501 Main Street China Grove, NC 28023 Mr. Vance Eller 550 ·Fox Hollow Road Salisbury, NC 28144 Mr. Jack Errante 416 Windsor Drive Salisbury, NC 28144 Honorable Charlotte Gardner 1500 W. Colonial Drive Salisbury, NC 28144 Mrs. Lib Grubb Route 5, Box 483 Lexington, NC 27292 Mrs. Mary Harviel P.O. Box 184 Spencer, NC 28159-0184 Honorable Julia C. Howard 203 Magnolia Avenue Mocksville, NC 27028 Mr. James E. Lambeth P.O. Box 308 Thomasville, NC 27360 Honorable Brad Ligon Member, NC General Assembly Route 12, Box 460 Salisbury, NC 28144 Mr. Ed Listerman Route 1, Box 237 Richfield, NC 28137 Mr. Wayne Mabry 720 Avondale Avenue Albemarle, NC 28001 Mr. Dale Martin Hiddenite, NC 28636 Mr. Albert McAuley Mount Gilead, NC 27306 Mrs. Drane McCall 928 Goodwood Road Winston-Salem, NC 27106 Mr. Robie L. Nash 232 Richmond Road Salisbury, NC 28144 Mr. Michael'L:.Pate Route ·2, Eox-849 Hamptonville, .NC'' 27020 Dr. Ruth Phillips 490 Avalon Road Winston-Salem, NC 27104 Mr. Henry Shore P.O. Box 70 Boonville, NC 27011 YADKI! DEE RIVER BASIN COMMitEtl BOARD OF DIRECTORS-PRIVATE (ypdbodp) Mr. Glenn Simmons City-County Planning Board P.O. Box 2511 Winston-Salem, NC 27102 Mr. David Springer The Point Farm Route 4 Mocksville, NC 27028 Mr. Hall Steele Route 2, Box 28 Mount Ulla, NC 28126 Mr. Kenneth Wommack 465 Doub Road Lewisville, NC 27023 Mr. Cecil Wood Wilkes County Office Bldg. Wilkesboro, NC 28697 Mr. Jack Kepley P.O. Box 1146 Salisbury, NC 28145 Mr. Richard 0; Tillis Box 504 Rockingham, NC 28379 .----. •• The signatures listed are people that 1· ~ndt~r~ dee~ly concerned about articles'~~a~~ an~haround High Rock Lake th or arol1na's most toxic sites is g . ting ~t water from one of e lake water. oing O possibly be dumped into .. h··· u?-£ ;J}Ly-r0 ~~ ~ w_(VftA &i£ Mt/4£± 2)~pz/t?~ d/JcJ [). J~~l( . 0,~ t:V~~ . P~r tdc::f .//\_,<.A.L,-~~ l (~?)•• •• ' . ' •• •• ·.'I. 1' .J .. ·: i ' ·J . ) ' '. •• •• •• ---1 · .. -,\ \ ... i....: ... ' _, .. -· .. _· ....... _ \ \• \ \ .. ,. ·----~:-.. ' .. --' ...... \.. I---- • '·1 -, : I ....... _,. __ _ \ •• •• The signatures listed are people that live on and around High Rock Lake and are deeply concerned about articles stating that water from one of North Carolina's most toxic sites is going to possibly be dumped into , :the I ake water. ·"·· ... ~ .. •• •• •• I '""\ • t ! ... I ' •• •• The signatures listed are people that live on and around High Rock Lake and are deeply concerned about articles stating that water from one of North Carolina's most toxic sites is going to possibly be dumped into the lake water. W.G. (BILL) HEFNER 8TH DISTRICT, NORTH CAROLINA 2161 RAYBURN HOUSE OFFICE BUILDING WASHINGTON, DC 20S\5 1202) 225-3715 FAX (2021 225-4036 COMMITTEES: •• ~ongrcss of the ilnitcd ~tatcs "!A.oust of 1Rtprrsrnrnti\lts DISTRICT OFFICES P.O. BOX 385 101 UNION STREET, SOUTH CONCORD. NC 28025 j704] 933-1615 OA 786-1812 P.O. BOX 4220 HOME SAVINGS ANO LOAN BLDG 507 WEST INNES STREET, SUITE 225 SALISBURY. NC 28144 !704) 636..0635 COMMITTEE ON APPROPRIATIONS SUBCOMMITTEE ON DEFENSE CHAIRMAN: SUBCOMMITTEE ON MILITARY CONSTRUCTION goshin_gton, 1)1[ 20515 ·Htt.Gt.lVE D S[p 13 1990 P.O. BOX 1503 230 EAST FRANKLIN STREET ROCKINGHAM, NC 28379 (9191997-2070 September 10, 1990 Mr. R. Jack Butler Environmental Engineer Superfund Section EPA P.O. Box 27687 Raleigh, NC 27611-7867 Dear Mr. Butler: SUPERFllND SECTION I am in receipt of the enclosed copy of a letter to you from the Honorable Julia C. Howard, Chairman, ~adkin-Pee Dee River Basin Committee. I hope that you will give the resolution sent to you by Mrs. Howard every consideration. With kindest regards, I am BH:bm Enclosure Sincerely yours, /1µi/~ BILL HEFNER Member of Congress • I • ' • ' 1·i,; , .. ::. ::,:c,:.,:;;, ·(: \!". •• ( Cieanup:~.t·i Company pledges to 'do whatever it takes' Continued frcim page .1 C ~ so there·s no telling what's in the water or the ground," said Mary Stamper, another Airport Road resident. "They should do something." Dozens of residences are near the plant, including the Kings For- est and Stonybrook subdivisions. More homes are likely to be bui!t on attractive land nearby, and that means children could be exposed to contaminants in surface water sediment or soil that will eventu- ally spread from the company's property. the EPA says. Retired prison teacher Charles Cunningham's home is a mile away from the plant. and he's relieved to hear of the cleanup plans. "You learn when you·re a little kid that if you make a mess, you clean it up," Cunningham said. "That's what should happen here." The EPA targeted the National Starch site for cleanup in I 989, when the site was added to its "superfund" list or toxic waste sites. The EPA and the company have reached a tentative agreement in which the company will take re- sponsibility for the cleanup. Bar- rett said. "National Starch is looking at it from the standpoint that it's on our property, and we'll do whatever it · takes to clean it up," said Ray Paradowski, operations manager · for the plant. "We· want to be a responsible company." . To remove the pollutants, the EPA proposes pumping out and treating 131 million gallons of groundwater. The chemicals would be removed from the water and incinerated; the wastewater would be released to Salisbury's municipal wastewater treatment plant. The EPA plans to monitor sur- face water and sediment by con- ducting annual tests for chemicals. Cleansing the groundwater should reduce the contaminants in the suriace water and sediment to the point they are no longer a hazard, Barrett said. The approved cleanup plan for the groundwater and stream sedi, ment should be announced by the end of the month. Barrett said. EPA will announce the next step, its plan to treat the contaminated soil, later this year or early in 1994. · Canada is pleased about the proposed cleanup, but she's not satisfied. "We want to save up enough to move," she said. "We want a nicer -place to live. I'm glad they want to l(\ean (t up .. but we'd also like to get :~m the plMit " - rFP139J t :"'..'/1:.,~., !ft/~~):,11f!ltt·lht.l; Jl-1,,:j, L.., ( J T:. ~JI_-S8.l-a· '7,-3Y>t'Z.r+::1• .. ·•.f.':;;·l.·};·";;1pjj' ,,, -·.. e_··.'·•,•f ··hb . ~/ ·.· a . .· s~i:,~t1~wmrr1es ne1g ·. ors . Plan,#f.µ/R!:1,~:nup only a start, residents say By JIM WRINN ,.::,}\ ··· :: : i: !~;; , · ,-------------7 Chemical solvents and acids c 0 ;:~1;~~•~Y ..::'ti~)ie: ~l~a-da, Want to comment?. ~~~;,';,mth~h1ia~~n~a~~r~~i;~.ect a' 3 • · To comment, or for more infor- , p_lays in· the backyard: dirt, matlon about this "suporfund" densely wooded property, th scooping it up with his_ tiny hands 8 said. The soil and the st ., project. write 10 Diane arrett, and watching it spill to the grOund. community relations coordlnalor, contain harmful chemicn\s ;rnd Across the road' is National North Superfund · Remedial heavy metals such as ethyl bcn• Starch & Chemical Co.'s properly,· Branch, Waste Management Dlvi• zene, cadmium, chloroform and where poisonous chemicals taint slon, 345 Courtland St. N.E., Al· others. The plant is no longer. the soil behind a dense stand ol lanta. Ga. · 30365, Or call dumping the chemicals onto the trees blanketed with "no trespass· \-800-435-9233. Comments property. · • · should be received by Thursday. mg· signs. · ·. · : Because \he chemicals haven't Charlie's mother, Carol Canada, s h' .is worried that soon the soil be-" C d d yet seeped, oil National tare s up, ana a sai • property, they aren't a health hind their trailer won't be safe for a The EPA says the cleanup will threat now, said EPA spokesper- ,i /4 ,,. youngster to play in. keep cancer-causing chemicals son Diane Barrett. But the situation ,_ ;1:1, ... ' N That's why the_ Environmental and heavy metals that lace the soil ·1 , will become dangerous 1 .. some· 1~ ;j;~?1,))-;, , Protection Agency is prodding the groundwater lrom draining oil the thing isn't done. · :11'"' ,;'ll','ii , · 0 company to launch a massive company's properly and seeping ·r,i/I''tf/l/~tte ===--m'0 $7.6 million, 30-year cleanup of into nearby wells and spreading "II scares me _ sometimes a a,J· ·I' Mn., the Airport Road property. . . into the dirt. The public can com• terrible .. odor comes lrom~hB lant [• .. ... . . GEORGE BREISACHERIS,alf "II there's something over there ment on the proposed cleanup '-.---'-that's bad, they ought to clean it plan thr~ugh Thursday. Please see Cleanup/pa > clean il ll\J, · .... -..... ---• :_ · \ "That's what should happen here. The EPA targeted the National. Starch site for cleanup tn 198.9, when the site was added to ,ts "superlund" list of toxic waste sites. h ve The EPA and the compan:,r .,a ... ---. -··h· d " tentative agreemerh in reac e l• . k which the company ..,,nil la e re- sponsibility lor the cleanup, Bar- rell said. · · · t 't "National Starch is loo~mg a 1 from the standpoint lhat it son ou_r property, and we_'\\ do .'."'hatever it takes to clean tl up, said Ray Paradowski, operations manager for the plant. "We w.~nl to be a rrsnonsih\e com,pa~~~11 .. 1c..ntc:. lhe V JOURNAL V/INSl0;<,5AlEM, - JUL 31 90 1rtes1dents Wondering '\Vhy EPA 1. Is So Slow; By Terry Marlin ,:;,1."",<l II•<{<::." 01:llt~U SALISBURY Hi:..:h R,irk Lak,: could soon be receiving up r,, ~\'!;\:\./J g;1ll,ms a day of formerly cont:imi• n.nL·J 11,·,1kr (ruin on..: of North Carolina's ~,.,;r r,ixic ch•imi..:JI dumps. · · The U.S. Eiwironmi:ntal Protection Agen• u plans by Im: Si:ptember to have tainted ~r01111dw:.ncr pipcJ om of an aquifer south of S:iliih;,iry, trcJtcd by National Starch and Ch.,mkal Corp:, sent through one,of Salis· \ bury's scw::ige plants, :md emptied into the nnnhcrn end of the lake. Ofr1d:ils s:iid bst night th::it groundwater (r,,111 lhc siri:, whid1 is unc of the 22 Super· fund sii::s in North Carolina, may have to be· \'\l!ll)kJ out :ir the rate of 200,0Xl gallons a day (.,1 "I' r., ),"\ y,:.,r~. Conlinued From Page 17 is in d:mger. Thi.s is called a· run- around." Barbara Benoy, the EPA's rcmed al project manager, said that federal officials do not support an alternative proposal to spend $51.9. million to remove 250,000 cubic yards of t::iint· cd dirt. . "The problem we have of exova;:- ing soil is nm only that lt's costly, but it poses other hazards," she said. "And costs muH be· a pan of the decision." · The deanu? plan that the EPA staff is recommendini to Greer C. Tidwell, the agency's regional admi('!· istrator in Ailanta, calls for 10 extrac• tion wells tha(would draw the con• taminated groundwater as we\\ as rainwatei' through the soil to remove th~ ·chemicals. National Starch would then build iu own treatment plarit to ·process the water before sending it to Salisbury. · · "What we're doing here, is lenlrig nature take its course fqr what rcsid· ual soil coritamination we. have le1 out there,". Mu:a said. . I Public_comm_cnt on the plan wi\j) be acccPted through Aug. 29. _/ -·--- JUL 28 90 •