You are Invited to Comment on the Proposed Plan for Addressing

Groundwater at the Barber Orchard Superfund Site, Waynesville, NC

The Environmental Protection Agency (EPA or Agency) and the North Carolina Department of Environment and Natural

Resources (NCDENR) want to hear your views about the following proposed plan for addressing the groundwater and

surface water/sediment at the Barber Orchard Superfund Site (Site). You can comment on the Proposed Plan at a 7:00 p.m.

public meeting on Thursday, September 08, 2011 at the Saunook Fire Station located at 2908 Old Balsam Road, Waynesville,

North Carolina. Comments can also be submitted through the mail, via facsimile, or email (refer to the box below for

additional information). We have studied the Site and now believe that the following actions are needed to protect public

health and the environment.

This Proposed Plan presents:

• The proposed alternative of No Action with groundwater monitoring for the Barber Orchard Operable Unit 2 for the

groundwater underlying the Site and the streams (surface water/sediment) draining the Orchard.

You are encouraged to comment during the public comment period. You have until Thursday, September 29, 2011 to submit

written comments on the Proposed Plan or other material in the Administrative Record file. At the end of the comment

period, EPA and NCDENR will review the comments/suggestions and make a final decision about the Site cleanup. Your

input on this Proposed Plan is an important part of the decision-making process. We want to hear from you and will pay

serious attention to what you have to say.

Tell Us What You Think Submit Written Comments

Public Comment Period

August 31, 2011 through September 29, 2011

EPA will accept written comments on the

Proposed Plan during the public comment

period. You may submit written comments

three (3) ways:

MAIL Mr. Jon Bornholm

U.S. EPA - Region 4

61 Forsyth Street, SW

Atlanta, Georgia 30303-3104

EMAIL bornholm.jon@epa.gov

FACSIMILE 404-562-8788

Attend the Public Meeting

Public Meeting:

You are invited to attend a public

meeting sponsored by EPA to hear

about the Proposed Plan for Operable

Unit 2 (Groundwater and surface

water/sediment) for the Barber Orchard

Site. At the meeting you will be able to

voice your views about the proposed

actions.

The meeting will be held:

Thursday, September 09, 2011

at 7:00 - 9:00 p.m.

Location: Saunook Fire Station

2908 Old Balsam Road

Waynesville, NC

Locations of Administrative Record and

Information Repository

Haywood County Public Library

402 South Haywood Street

Waynesville, North Carolina

Phone: 828-452-5169

Hours: Mon-Wed, 9:00 a.m. – 6:00 p.m.

Thurs 9:00 a.m. – 7:00 p.m.

Friday 9:00 a.m. – 6:00 p.m.

Saturday: 9:00 a.m. – 5:00 p.m.

Sunday: Closed

EPA, Region 4's Information Center

61 Forsyth Street

Sam Nunn Atlanta Federal Center

Atlanta, Georgia 30303

404-562-8946

Hours: Mon – Fri, 8:00 a.m. – 5:00 p.m.

PROPOSED PLAN

BARBER ORCHARD SUPERFUND SITE

OPERABLE UNIT 2 (GROUNDWATER)

WAYNESVILLE, HAYWOOD COUNTY, NORTH CAROLINA

AUGUST 2011

Barber Orchard Site Proposed Plan Operable Unit 2

August 2011

2 INTRODUCTION

This Proposed Plan provides:

• a brief description and history of the Site;

• a summary of the nature and extent of

contamination;

• a summary of the Baseline Risk Assessment;

• presents to the public the Agency’s preferred

alternative for the groundwater (OU 2) at the Site;

• the public the opportunity to submit comments on

the proposed cleanup alternative; and

• a list of contacts and locations for more

information.

EPA is required by both the Superfund law

[Comprehensive Environmental Response, Compensation,

and Liability Act (“CERCLA”), Section 117(c), and the

National Oil and Hazardous Substances Pollution

Contingency Plan (“NCP”), Section 300.435(f)(2)] to issue

this Proposed Plan to the public. This document is issued

by the US EPA, the lead agency for the site, and

NCDENR, the support agency. EPA, in consultation with

NCDENR, will select a final remedy for the site after

reviewing and considering all information submitted

during the 30-day public comment period. EPA, in

consultation with NCDENR, may modify the Preferred

Alternative or select another response action presented in

this Plan based on new information or public comments.

Therefore the public is encouraged to review and comment

on all the alternatives presented in this Proposed Plan.

This Proposed Plan summarizes and identifies key

information generated and/or collected through the

Remedial Investigation (RI) and Feasibility Study (FS)

phase of the Superfund process as well as the additional

groundwater data collected since the issuance of the 2004

OU 1 ROD.

All pertinent information supporting this Proposed Plan

can be found in greater detail in documents contained in

the Barber Orchard Administrative Record. The

Administrative Record and Information Repository can be

found in the Haywood County Public Library at 402 South

Haywood Street in Waynesville, North Carolina and in

EPA's, Region IV Information Center at 61 Forsyth Street,

Sam Nunn Atlanta Federal Center, Atlanta, Georgia.

SITE BACKGROUND/SITE CHARACTERISTICS

The Barber Orchard Site is a former commercial apple

orchard located off U.S. Highway 23/74 approximately 3

miles west of the city limits of Waynesville in western

Haywood County, North Carolina. The Site is

approximately 438 acres in size located on the northern

slope of a mountain in the Blue Ridge physiographic

province. Figure 1 is the Site Location Map. The Barber

Orchard Site was proposed for the National Priority List

(NPL) in the Federal Register (Vol. 66, No. 8, January

2001) and finalized on the NPL via the Federal Register

(Vol. 66, No. 178, September 2001). EPA’s identification

number is NCF FNO 406 989.

Topography across the Orchard varies. The parcels

located nearest to U.S. Highway 23/74 are relatively flat,

as they are located in the flood plain of Richland Creek.

To the southeast, the Orchard rises sharply as it nears the

Blue Ridge Parkway. Surface elevations across Barber

Orchard range from approximately 2,900 feet above mean

sea level (msl) along Richland Creek to around 4,000 feet

above msl near the Blue Ridge Parkway.

The Site is a former apple orchard that operated from 1908

to 1988. Apples were grown commercially and harvested

until bankruptcy closed the orchard. As with many

commercial agricultural operations, pesticides were

routinely used. The method of pesticide application at

Barber Orchard was somewhat unique, however, the

pesticides were mixed at one or more mixing stations,

drained downhill to a compressor and then pumped back

up into the orchard under considerable pressure (800

pounds per square inch), through an underground system

of pipes. The piping system had a number of standpipes

located among the apple trees. Orchard employees would

connect flexible hoses to these stand pipes and spray the

pesticide mixture onto the trees. Although not

documented, the depth of the underground piping is

assumed to be shallow. No diagrams showing the layout

of the piping system exists.

The pipes were routinely flushed to prevent clogging; any

pesticides present in the pipes were left to run onto the

ground. Reportedly, pipes would sometimes freeze and

rupture in the winter, causing them to leak. Pesticides

suspected of being used at the Site include: lead arsenate,

dichlorodiphenyltrichloroethane (DDT), lindane,

dichlorodiphenyldichloroethane (DDD), endrin, and

dieldrin. After bankruptcy, the former orchard land was

broken into 170 parcels of varying sizes and sold.

The former orchard now includes a mixture of the

following:

• Approximately 100 acres developed as residential

property

Barber Orchard Site Proposed Plan Operable Unit 2

August 2011

3

• Approximately 60 acres developed as agricultural/

commercial/cultural/light-industrial

• Approximately 10 acres unbuildable

• Approximately 268 acres orchard/pasture land.

Based on information obtained over the years, the Agency

is expecting that the majority of the undeveloped portion

of the Orchard will be developed as residential property.

The future make-up of the orchard is expected to look like:

• Approximately 358 acres developed as residential

property

• Approximately 70 acres developed as agricultural/

commercial/cultural/light-industrial

• Approximately 10 acres unbuildable

In early 1999, the Health Department of Haywood County

sampled a potable well at the residence of a concerned

homeowner in Barber Orchard. Pesticides were detected

in this sample, prompting a larger sampling effort by

NCDENR and the North Carolina Department of

Agriculture. Results of this sampling effort were

forwarded to the EPA for removal action evaluation in

June of 1999.

In 1999, EPA conducted additional testing of soils in

residential lawns and potable wells (drinking water) in

Barber Orchard. Results showed elevated concentrations

of arsenic, lead, and pesticides in soil from many of the

residential yards. In numerous locations, the arsenic

concentration exceeded EPA’s screening concentration of

40 milligrams per kilogram (mg/kg) which is based on

EPA’s 1 × 10-4

cancer risk level for arsenic. Groundwater

samples were collected from 55 potable water wells across

the Orchard area. Organochlorine pesticides including

alpha- benzene hexachloride (BHC), beta-BHC, and

gamma-BHC (Lindane) were detected in 21 of these wells.

The concentration of Lindane exceeded its federal

maximum contaminant level (MCL) of 0.2 micrograms per

liter (µg/l) in 5 of the 55 potable wells sampled. The

concentrations of these 5 Lindane detection were 0.27

µg/l, 0.29 µg/l, 0.4 µg/l, 0.45 µg/l, and 1.7 µg/l. MCLs are

established under the Safe Drinking Water Act (SDWA)

(which can be viewed at the following website:

http://water.epa.gov/drink/contaminants/index.cfm). In

addition, two of these potable well samples contained a

concentration of lead above the federal MCL for lead

which is 15 µg/l. The concentrations of lead detected in

these two wells were 28 µg/l and 38 J µg/l.

Due to the elevated concentration of arsenic in the soil in

the landscaped portions of residential properties, a soil

removal action was initiated in October 1999 which was

completed in August 2000. This action removed surface

soils (the top foot) from 28 residential properties where

arsenic levels exceeded 40 mg/kg. The excavated areas

were backfilled with clean soil and landscaped. All home

owners in the Orchard were encouraged to install a

filtration system on their individual water supply system.

Although the former orchard occupies a parcel of land that

is approximately 438 acres, the RI expanded the study area

to the edges of the watershed which includes

approximately 725 acres. The boundaries of the watershed

are defined by the mountain top to the south, Richland

Creek to the north, and two unnamed tributaries to

Richland Creek, to the east and west. Included within the

watershed boundaries are several businesses, a fire

department, several churches, and a daycare center. This

725 acre area is drained by eight unnamed tributaries to

Richland Creek. Figure 1 shows the location of the

Barber Orchard Site along with these eight tributaries.

The subsurface geology at Barber Orchard consists of

unconsolidated soils and colluvium overlying bedrock.

The unconsolidated materials consist of saprolite

(weathered bedrock that contains relic structures), soils

(residuum created by weathering of bedrock), and

colluvium (poorly sorted soils, boulders and cobbles

deposited by gravity). This mantle of material overlying

the bedrock tends to be thinner on steep slopes and thicker

towards the valley bottoms. The colluvium is most

common in the lower lying areas. Surface soils at the Site

consist of fine- to medium-grained sands, silts and clays,

and silty sands that transition to saprolite.

Groundwater occurs in both the unconsolidated soils and

bedrock with no barrier between these two groundwater

zones. Groundwater occurrence is widespread in the

overburden but is restricted to fractures in bedrock.

Existing bedrock wells range in depth from approximately

100 feet below ground surface (bgs) to more than 700 feet

bgs. Groundwater in the overburden is used to a limited

extent as is indicated by a few hand-dug wells and springs,

while most of the groundwater used in the area is extracted

from bedrock wells. Groundwater recharge occurs through

surface water infiltration or precipitation. Groundwater

discharge occurs through seepage into area creeks. The

major surface water feature is Richland Creek which forms

the northern boundary of the Site. Seven tributaries to

Richland Creek flow across the Site and convey water

Barber Orchard Site Proposed Plan Operable Unit 2

August 2011

4 from the higher elevations and empty into Richland Creek.

At sporadic locations along some of these tributaries, a few

small ponds have been constructed.

To date, EPA has not identified any viable potentially

responsible parties. Therefore, the 1999-2000 emergency

response, the RI/FS, and the current, ongoing soil cleanup

have been funded by the Superfund.

Haywood County/Town of Waynesville received monies

from a number of sources to extend a municipal water

supply line into the Barber Orchard area. One of these

sources was a grant from EPA. Consequently, EPA

evaluated this grant under the National Environmental

Policy Act. In May 2003, EPA issued a "Finding of No

Significant Impact" which contained the following Special

Grant Condition – "The County must require all residential

sites in the Barber Orchard community to be sampled for

lead and arsenic contamination prior to construction of

those sites. If lead/arsenic levels are found to exceed

EPA’s remedial action level, the County must require (the

soil at) the sites to be remediated before construction on

those sites is permitted." The Commissioners of Haywood

County adopted this language which reduced the pace of

residential development within the Orchard.

In 2004-2005, Haywood County/Town of Waynesville

extended a municipal water supply line throughout the

Orchard and up to the North Carolina Department of

Transportation’s rest stop on US Highway 23/74. As of

June 2011, approximately half of the developed parcels

(32 parcels) in the Orchard have hooked up to the

municipal water line.

SCOPE AND ROLE OF OPERABLE UNIT

EPA has organized the work at the Barber Orchard Site

into two operable units (OUs).

• Operable Unit 1: Contaminated soils

• Operable Unit 2: Contaminated groundwater,

surface water and sediment.

OU 1 – SOIL

EPA selected the remedy for OU 1 in a ROD signed on

September 29, 2004. The remedy included the excavation

and off-site disposal of soils contaminated with

organochlorine pesticides and metals (arsenic and lead).

The remedy is currently being implemented and it is

anticipated it will be completed by the end of September

2011.

OU 2 – GROUNDWATER

The second operable unit (OU 2), the subject of this

Proposed Plan, focuses on the contaminated groundwater

underlying the Orchard along with the surface water and

sediment in the streams that drain from the Orchard.

Although the Agency is proposing No Action for OU 2,

long-term monitoring of the groundwater underlying the

Orchard will be conducted to ensure that the soil cleanup is

effective and beneficially impacts the quality of the

groundwater. Monitoring wells and potable wells will be

monitored.

This OU is the final operable unit for the Barber Orchard

site as no further actions are necessary.

REMEDIAL INVESTIGATION

SUMMARY/NATURE AND EXTENT OF

CONTAMINATION

A RI is an in-depth study designed to gather data needed to

determine the nature and extent of contamination at a

Superfund site; support the Baseline Risk Assessment;

establish site cleanup criteria; identify preliminary

alternatives for remedial action; and support technical and

cost analyses of alternatives. The RI is usually done with

the FS. The FS identifies and analyzes appropriate

technologies/ alternatives for addressing the contamination

at the Site. The FS describes in detail the alternatives that

were considered, as well as the process and criteria used to

narrow the list of the potential remedial alternatives, to

address the contamination and risks at the Site. Together

they are usually referred to as the "RI/FS".

In January 2001, EPA conducted the RI/FS public kick-off

meeting. In May 2003, EPA held a public meeting to

share the findings of the RI.

EPA’s 2001-2002 RI involved the collection and analyses

of numerous soil samples, surface water and sediment

samples, and groundwater samples from newly installed

monitoring wells along with a number of private, potable

wells. The data collected and/or generated from these

efforts confirmed and documented that the quality of

surface and some subsurface soils as well as the

underlying groundwater have been negatively impacted by

past Site activities. Table 1 summarizes the 2001

Barber Orchard Site Proposed Plan Operable Unit 2

August 2011

5 monitoring well data and Table 2 summarizes the 2001

potable well data.

The soil data generated as part of the RI confirmed that

elevated levels of lead, arsenic, and organochlorine

pesticides were present within soils of the former orchard,

especially in areas where apple trees were planted or

currently growing. The majority of these contaminants

were found in the top foot of soil with an occasional

detection as deep as four feet. Organochlorine pesticides

were detected in monitoring wells, potable wells, and

springs. The primary contaminants in the groundwater

were the following organochlorine pesticides: alpha-BHC,

beta-BHC, delta-BHC, gamma-BHC (Lindane), endrin,

and endrin ketone.

Surface water and sediment samples were collected from

twelve streams during the RI. These streams can be

categorized as:

• streams that flow through or border the areas

where the apple orchard operated,

• streams that flow from the opposing hillside across

the valley and are not influenced by the orchard,

and

• Richland Creek, which is the largest stream in the

area, receives drainage from the other two types of

streams.

The surface water data is summarized in Table 3 and the

sediment data is summarized in Table 4. The highest

concentrations of contaminants in surface water were

detected in the streams that drained the Orchard. Lead and

organochlorine pesticides were detected in the water

column and arsenic, lead and organochlorine pesticides

were detected in the sediments. No concentrations of

contaminants were found in either the surface water or the

sediment above levels that would pose an unacceptable

risk to human health.

Figures 2 and 3 show the areal extent of contaminated soil

in the surface and subsurface zones, respectively. The

remediation of the soil contamination is anticipated to be

completed by the end of September 2011.

Figure 4 presents the groundwater sampling locations

used in the RI. The area/volume of groundwater beneath

the Barber Orchard Site was calculated based on the

following assumptions:

• porosity values in the saprolite were set at 40%;

fracture bedrock porosity was set a 5% (As a

simplifying assumption, overall porosity for the

rock column (saprolite/bedrock) is assumed to be

10%).

• the areal size was estimated to be a rectangle 3,000

feet by 3,000 feet or 9,000,000 square feet.

• the average thickness of groundwater is 20 feet

and using a combined average porosity of 10%,

the volume of groundwater beneath the Site is

134,640,000 gallons.

The groundwater at the Site has been sampled numerous

times: 1999 by North Carolina, 1999-2000 by EPA, 2001-

2002 as part of the RI, August 2004, October 2007, March

2009, August 2010, and May 2011. The August 2004,

October 2007, March 2009, and August 2010 groundwater

sampling efforts focused on the monitoring wells. The

1999-2000 groundwater sampling efforts focused on

potable wells. The RI groundwater sampling effort

included both potable wells and monitoring wells. The

most recent groundwater sampling was conducted in May

2011 that included all fourteen monitoring wells and

fifteen potable wells. No concentrations of contaminants

were detected above federal MCLs or above levels that

pose an unacceptable carcinogenic or non-carcinogenic

risk to human health. An elevated concentration of lead

was detected in monitoring well MW-16 (16 µg/l);

however, this concentration of lead is attributable to the

turbidity of this sample and not the groundwater.

No groundwater “hot spots” have been identified;

however, the detection of pesticides is generally more

common in the western portion of the Site than the eastern

portion of the Site. This trend may be explained by the

development of the Orchard which also occurred from

west to east. The May 2011 analytical results for the 15

potable well samples were compared to the 1999-2001

results. Based on this comparison four observations were

made:

1) no contaminants were detected above federal MCL

in 2011,

2) concentrations of the organochlorine pesticides are

generally declining with time,

3) based on the conceptual hydrogeological model

for the Site, the contaminants are being slowly

diluted as the groundwater migrates northward

towards the primary groundwater discharge point -

Richland Creek, and

Barber Orchard Site Proposed Plan Operable Unit 2

August 2011

6

4) based on the 2001 RI data, discharges to Richland

Creek are not above Ambient Water Quality

Criteria and do not pose an unacceptable risk or

ecological receptors.

In addition, two soil removal efforts have occurred on the

Site. The first was EPA’s sponsored emergency response

action in 1999-2000 that removed contaminated soil from

28 residential yards. The second soil cleanup is currently

ongoing and is anticipated to be completed by September

30, 2011. The current soil cleanup includes removing the

top foot of soil from approximately 85 acres. The removal

of this contaminated soil will eliminate the source of

contamination to the groundwater. With the source

removed, the levels of detections in the groundwater

should continue to decline.

SUMMARY OF SITE RISKS

HUMAN HEALTH - Based on the results of the risk

characterization, chemicals of concern were selected from

chemicals of potential concern. At the Barber Orchard

site, it is known that pesticides, including arsenic and lead,

were historically used. The following chemicals were

identified as chemicals of concern in the various

environmental media:

• SURFACE SOIL - arsenic, lead, manganese,

thallium, DDD, DDE, DDT, aldrin, dieldrin, and

endrin ketone;

• HOMEGROWN PRODUCE (from surface soil) -

barium, manganese, thallium, DDD, DDE, DDT,

aldrin, dieldrin, endrin, endrin ketone, and

benzo(a)pyrene;

• SUBSURFACE SOIL - aluminum, arsenic, DDT,

aldrin, dieldrin, endrin, and endrin ketone;

• SUSPENDED PARTICULATES (from subsurface soil)

-aluminum, barium, and manganese;

• OVERBURDEN GROUNDWATER - aluminum,

barium, chromium, copper, iron, manganese,

vanadium, alpha-BHC, and lindane;

• BEDROCK GROUNDWATER - arsenic, chromium,

alpha-BHC, and lindane;

• FISH INGESTION (from Richland Creek surface

water) - DDT; and

• BEEF/MILK INGESTION (from surface soil) -

thallium, DDD, DDE, DDT, aldrin, dieldrin,

endrin, and endrin ketone.

WHAT IS RISK AND HOW IS IT CALCULATED?

The Superfund human health risk assessment estimates the

"baseline risk." This is an estimate of the likelihood of health

problems occurring if no cleanup actions were taken at a site.

To estimate the baseline risk at a Superfund site, EPA

undertakes a four-step process:

Step 1: Analyze Contamination

Step 2: Estimate Exposure

Step 3: Assess Potential Health Dangers

Step 4: Characterize Site Risk

In Step 1, EPA looks at the concentrations of contaminants

found at a site as well as past scientific studies on the effects

these contaminants have had on people (or animals, when

human studies are unavailable). A comparison between site-

specific concentrations and health-based concentrations helps

EPA to determine which contaminants are most likely to pose

the greatest threat to human health.

In Step 2, EPA considers the different ways that people might

be exposed to the contaminants identified in Step 1, the

concentrations that people might be exposed to, and the

potential frequency and duration of exposure. Using this

information, EPA calculates a "reasonable maximum

exposure" (RME) scenario, which portrays the highest level of

human exposure that could reasonably be expected to occur.

In Step 3, EPA uses the information from Step 2 combined

with information on the toxicity of each chemical to assess

potential health risks. EPA considers two types of risk:

cancer risk and non-cancer risk. The likelihood of any kind of

cancer resulting from a Superfund site is generally expressed

as a probability; for example, a "1 in 10,000 chance" or 1 ×

10-4

." In other words, the exposed individual would have an

excess cancer risk of one in 10,000 due to long-term exposure

to site contaminants. This excess risk would be over and

above the existing cancer risk for the individual. If the

accumulative excess cancer risk posed by the contaminants of

concern at a site is greater than 1× 10-4

(i.e., one out of

10,000), then the Agency typically implements a cleanup

action to reduce the overall risk. If the accumulative excess

cancer risk posed by the contaminants of concern at a site is

less than 1 × 10-6

(i.e., one out of 1,000,000), then the Agency

typically does not implement a cleanup action and may rely

on other activities to protect human health and the

environment. For non-cancer health effects, EPA calculates a

"hazard index" (HI). If the calculated hazard index is less

than 1, then no non-cancer health effects are expected. If the

hazard index greater than 1, then a non-cancer health effect

may occur do to the long-term exposure to Site contaminants.

In Step 4, EPA determines whether site risks are excessive for

people at or near the Superfund site. The results of the three

previous steps are combined, evaluated, and summarized.

EPA adds up the potential risks for each receptor.

Barber Orchard Site Proposed Plan Operable Unit 2

August 2011

7 The above chemicals of concern are associated with one or

more of the following receptors:

• CURRENT RESIDENT - overburden groundwater;

• FUTURE RESIDENT - surface soil, homegrown

produce, overburden and bedrock groundwater;

• CONSTRUCTION WORKER - subsurface soil,

suspended particulates, overburden and bedrock

groundwater;

• COMMERCIAL WORKER - overburden groundwater;

• SPORTSMAN - fish ingestion; and

• BEEF/MILK - ingestion.

Based on the concentrations detected in the May 2011

groundwater analytical data set, no concentrations of

contaminants were detected in the groundwater that

resulted in either an unacceptable cancer risk or an

unacceptable non-cancer risk. Refer to Table 5 for a

summary of the May 2011 groundwater data.

No RAO was developed for surface water as the only

unacceptable risk identified in the Baseline Risk

Assessment was under the sportsman fish ingestion

scenario for ingestion fish containing 4,4-DDT. However,

as documented in the RI, elevated levels were detected in

Richland Creek upgradient of the Orchard demonstrating

that Barber Orchard is not the sole source of 4,4-DDT

detected in Richland Creek.

ECOLOGICAL - The Screening-Level Ecological Risk

Assessment (SLERA) was unable to confirm that the Site

will have an adverse impact on the environment. The

current soil cleanup will eliminate future ecological

concerns.

REMEDIAL ACTION OBJECTIVES

OU 2

Since there are no risks associated with groundwater,

surface water and sediment, remedial action objectives

were not developed.

APPLICABLE AND RELEVANT AND

APPROPRIATE REQUIREMENTS

Remedial actions must comply with Applicable and

Relevant and Appropriate Requirements (ARARs) of

federal and state laws, statutes, and regulations. EPA's

Interim Guidance on Compliance with ARARs (EPA,

1988) and CERCLA Compliance with Other Laws Manual

Part II (EPA, 1989) establish how requirements of federal

and state laws are generally identified and applied to

remedial actions at CERCLA sites. However, since the

Proposed Plan for OU 2 does not propose any remedial

action, the development of ARARs is not applicable.

Although not identified as an ARAR, the Agency will

continue to monitor groundwater until the concentrations

of contaminants in the groundwater decrease to their North

Carolina Groundwater Quality Standard (15A NCAC 02L

.0202) (see Table 6). This long-term groundwater

monitoring will provide the necessary data to 1) ensure the

quality of the groundwater remains protective of human

health, 2) confirm that the soil remedy was effective in

preventing the contaminants in the soil from migrating to

the groundwater, and 3) demonstrate that the quality of the

underlying groundwater continues to improve with time.

PREFERRED ALTERNATIVE FOR OU 2

OU 2 – No Action

Cost:

Estimated Capital Cost: $0

Estimated Annual O & M Cost:$53,000 (

Estimated Construction Timeframe: 0 years

The annual operations and maintenance (O&M) cost is

associate with the long-term monitoring of the

groundwater.

Based on the information provided above no risks have

been identified for groundwater, surface water and

sediment. As such, the preferred alternative for OU 2

(groundwater, surface water and sediment) is "No Action".

The Agency is confident that the ongoing soil cleanup will

have a positive impact on the currently improving quality

of the groundwater.

STATE ACCEPTANCE

The North Carolina Department of Environment and

Natural Resources supports the Preferred Alternative for

OU 2.

COMMUNITY PARTICIPATION

You can comment on the Proposed Plan at a 7:00 p.m.

public meeting on Thursday, September 08, 2011 at the

Barber Orchard Site Proposed Plan Operable Unit 2

August 2011

8 Saunook Fire Station located at 2908 Old Balsam Road,

Waynesville, North Carolina.

EPA and NCDENR provide information regarding the

cleanup of the Barber Orchard Site to the public through

Fact Sheets, public meetings, announcements in The

Smokey Mountain News, and the Administrative Record

file for the site. EPA and the NCDENR encourage the

public to gain a more comprehensive understanding of the

Site and the Superfund activities that have been conducted

at the Site. Information regarding the public comment

period, public meeting and the locations of the

Administrative Record files, are provided on the front page

of this Proposed Plan.

For further information on the Barber Orchard Site, please

contact:

Jon Bornholm

Remedial Project Manager

(404) 562-8820 or (800) 435-9233

e-mail: bornholm.jon@epa.gov

or

Angela Miller

Community Involvement Coordinator

(404) 562-8561 or (800) 435-9233

e-mail: miller.angela@epa.gov

at

US EPA Region 4

61 Forsyth Street, SW

Atlanta, GA 30303-8960

DOCUMENT INFORMATION

The Administrative Record contains all the information

used by the Agency to select a Remedial Action. Copies

of the Administrative Record are kept at:

Haywood County Public Library

402 South Haywood Street

Waynesville, North Carolina

Phone: 828-452-5169

Hours: Mon-Wed, 9:00 a.m. – 6:00 p.m.

Thurs 9:00 a.m. – 7:00 p.m.

Friday 9:00 a.m. – 6:00 p.m.

Saturday: 9:00 a.m. – 5:00 p.m.

Sunday: Closed

and at

U.S. Environmental Protection Agency

Region IV - Records Center

61 Forsyth Street, SW

Atlanta, Georgia 30303-3104

404-562-8820

Hours: Monday - Friday 8:00 a.m. - 5:00 p.m..

Table 1 – Summary of Analytical Results for Groundwater Samples Collected from Monitoring Wells in the RI

Analytes Number of Detections Range of Concentrations MCL NC 2L

Organic Chloride Pesticides

alpha-BHC (α-BHC) 2 out of 15 0.078 – 0.099 NA 0.02

beta-BHC (β-BHC) 2 out of 15 0.03 – 0.036 NA 0.02

delta-BHC (δ-BHC) 2 out of 15 0.43 – 0.077 NA 0.02

gamma-BHC (Lindane) 4 out of 15 0.017 – 0.25 0.2 0.03

Endrin 5 out of 15 0.014 – 0.058 2 2**

Metals

Arsenic 2 out of 15 5.9 – 13 10 10

Lead 7 out of 15 3.4 – 72 15* 15

All concentrations reported in micrograms per liter (µg/l) or parts per billion (ppb). NA – Not available * - The action level for lead is 15 µg/L. ** - Endrin, total (includes endrin, endrin aldehyde, and endrin ketone)

Table 2 – Summary of Analytical Results for Groundwater Samples Collected from Potable Wells in the RI

Analytes Number of Detections Range of Concentrations MCL NC 2L

Organic Chloride Pesticides

alpha-BHC (α-BHC) 5 out of 33 0.004 – 0.036 NA 0.02

beta-BHC (β-BHC) 4 out of 33 0.003 – 0.038 NA 0.02

delta-BHC (δ-BHC) 2 out of 33 0.01 – 0.014 NA 0.02

gamma-BHC (Lindane) 8 out of 33 0.004 – 0.12 0.2 0.03

Endrin 9 out of 33 0.006 – 0.12 2 2**

Endrin Ketone 8 out of 33 0.007 – 0.17 NA 2**

Metals

Arsenic 0 out of 33 0 10 10

Lead 6 out of 33 2.8 – 19 15* 15

All concentrations reported in micrograms per liter (µg/l) or parts per billion (ppb). NA – Not available * - The action level for lead is 15 µg/L. ** - Endrin, total (includes endrin, endrin aldehyde, and endrin ketone)

Table 3 – Summary of Analytical Results for Surface Water Samples Collected During the RI

Analytes Number of Detections Range of Concentrations

Organic Chloride Pesticides

alpha-BHC (α-BHC) 0 out of 19 0

beta-BHC (β-BHC) 1 out of 19 0.043

delta-BHC (δ-BHC) 0 out of 19 0

gamma-BHC (Lindane) 0 out of 19 0

Endrin 2 out of 19 0.08 – 0.15

Endrin Ketone 1 out of 19 0.12

4,4-DDT 1 out of 19 0.91

Metals

Arsenic 0 out of 19 0

Lead 4 out of 19 1.9 – 4.7

All concentrations reported in micrograms per liter (µg/l) or parts per billion (ppb).

Table 4 – Summary of Analytical Results for Sediment Samples Collected During the RI

Analytes Number of Detections Range of Concentrations

Organic Chloride Pesticides

alpha-BHC (α-BHC) 1 out of 19 0.35

beta-BHC (β-BHC) 2 out of 19 0.018 – 0.15

delta-BHC (δ-BHC) 2 out of 19 0.0038 – 0.01

gamma-BHC (Lindane) 2 out of 19 0.0034 – 0.02

Endrin 11 out of 19 0.0023 – 0.43

Endrin Ketone 7 out of 19 0.0056 – 0.092

4,4-DDT 13 out of 19 0.0028 – 1.4

Metals

Arsenic 15 out of 19 1 – 48

Lead 19 out of 19 6.5 – 150

All concentrations reported in milligrams per kilogram (mg/kg).

Table 5 – Analytical Data from Groundwater Samples Collected in May 2011 from Both Potable Wells and Monitoring Wells Showing that No Unacceptable Carcinogenic or Non-Carcinogenic Risk Action Level has been Exceeded. All concentrations in micrograms/liter (µg/l).

Excess Cancer risk or hazard quotient based on

maximum detection

Health based drinking water MCL/Action level

POTABLE WELLS MONITORING WELLS

Detection Frequency Detection Range Detection Frequency Detection Range

Organic Chloride Pesticides

alpha-BHC (α-BHC) Risk = 1 × 10-5 NA 5 – 15 0.003 – 0.16 1 – 14 0.016

beta-BHC (β-BHC) Risk = 2 × 10-6 NA 5 – 15 0.006 – 0.059 1 – 14 0.038

delta-BHC (δ-BHC) Risk = 1 × 10-6 NA 2 – 15 0.004 – 0.037 1 – 14 0.02

gamma-BHC (Lindane) Risk = 8 × 10-7 0.2 10 – 15 0.008 – 0.051 2 – 14 0.013 – 0.039

Endrin HQ = 0.1 2 4 – 15 0.002 – 0.1 1 – 14 1.5

Endrin Ketone HQ = 0.02 NA 8 – 15 0.004 – 0.19 2 – 14 0.071 – 0.23

Metals

Arsenic Risk = 9 × 10-5 10 0 – 15 NA 2 – 14 1.3 – 3.9

Chromium HQ = 0.07 100 3 – 15 1.2 – 5.2 5 – 14 1.4 – 5.7

Lead < action level 15 3 – 15 1 – 12 3 – 14 1.4 – 6 16*

* – This was a very turbid sample. Elevated level of lead attributed to this turbidity and not considered to be in the water column. NA – Not Available

Table 6 – North Carolina Groundwater Standards for North Carolina Administrative Code (NCAC) Title 15A Subchapter 2L. All standards are in microgram per liter (µg/l).

Contaminants 2L GROUNDWATER STANDARD

Organic Chloride Pesticides

alpha-BHC (α-BHC) 0.02

beta-BHC (β-BHC) 0.02

delta-BHC (δ-BHC) 0.02

gamma-BHC (Lindane) 0.03

Endrin 2*

Endrin Ketone 2*

Metals

Arsenic 10

Lead 15

* - Endrin, total (includes endrin, endrin aldehyde, and endrin ketone) The North Carolina 2L standards can be viewed at the following website: http://portal.ncdenr.org/web/wq/ps/csu/gwstandards