RECORD OF DECISION, REMEDIAL ALTERNATIVE SELECTION, CAPE FEAR … · 2019-06-07 · CAPE FEAR WOOD...

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RECORD OF DECISIONREMEDIAL ALTERNATIVE SELECTION

CAPE FEAR WOOD PRESERVING SITEFAYETTEVILLE, CUMBERLAND COUNTY

NORTH CAROLINA

PREPARED BY:

U.S. ENVIRONMENTAL PROTECTION AGENCYREGION IV

ATLANTA, GEORGIA

DECLARATION FOR THE RECORD OF DECISION

Site Name and Location

Cape Fear Wood PreservingFayetteville, Cumberland County, North Carolina

Statement of Purpose

This document represents the selected remedial action for this Site developedin accordance with CERCLA as amended by SARA, and to the extent practicable,the National Contingency Plan.

The State of North Carolina has concurred on the selected Remedy.

Statement of Basis

The decision is based upon the Administrative Record for the Cape Fear WoodPreserving Site. The attached index identifies the items which comprise theadministrative record upon which the selection of a remedial action is based.

Description of Selected Remedy

Prior to initiating any remedial action on-site, a site survey will beconducted to determine the presence of any endangered plant species on-site.If endangered plant species are encountered, then the Department of theInterior/U.S. Fish and Wildlife Service needs to be consulted prior toinitiating remedial action to decide how to proceed.

REMEDIATION OF HAZARDOUS MATERIALS, TANKS & PIPING

Off-site disposal of sodium dicromate - copper sulfate - arsenicpentoxide (CCA) salt crystals, the solidified creosote andasbestos-containing pipe insulation. The CCA crystals and solidifiedcreosote will be disposed of at a RCRA permitted landfill. Theasbestos-containing pipe insulation will be disposed of at the CumberlandCounty Solid Waste Facility pursuant to the facilities specifications.

The tanks and associated piping, above and below ground, will be emptied,flushed and cleaned, including triple rinsing, to render the metalnon-hazardous. The metal will then be cut and either sold to a localscrap metal dealer or disposed of at the Cumberland County Solid WasteFacility. For those tanks and/or piping that cannot be cleanedsufficiently to render them non-hazardous they will be transported to aRCRA permitted landfill for disposal.

The contents of the tanks and associated piping contains approximately50,000 gallons of 3 percent CCA solution and 15,000 gallons of CCAcontaminated wastewater. A buyer of the 50,000 gallons of 3 percent CCAsolution will first be pursued. If no buyer can be found, then the50,000 gallons of 3 percent CCA solution along with the 15,000 gallons ofCCA contaminated wastewater will be treated on-site through the watertreatment system set up for treating the pumped surface waters andextracted groundwater. All wastewater (i.e., cleaning equipment, etc.)generated by on-site activities will also be directed to the treatmentsystem.

SOURCE CONTROL (Remediation of Contaminated Soils)

The preferred alternative for the remediation of contaminatedsoils/sediment is soil washing. The alternate source control alternativeis a low thermal deaorption process to remove the organics contaminantsfrom the soil followed by either soil washing or a soilfixation/solidification/stabilization process to address the inorganics.The decision as to which source control alternative will be implementedwill be based on data generated by the soil washing treatability study tobe conducted during the remedial design.

Contaminated soils/sediment will be excavated, treated and placed back inthe excavation. All wastewater generated will either be reused ortreated on-site. Following completion of on-site remedial activities,those areas disturbed will be revegetated

MIGRATION CONTROL (Remediation of Contaminated Groundwater)

Groundwater extraction will be accomplished through the use of wellpoints in the upper (surficial) aquifer. Groundwater removal will beconducted in 10,000 square foot subareas at a time, until the entirecontaminated surficial aquifer is addressed. The well points will bemoved from one area to another for subsequential dewatering.

Due to local contamination of the lower aquifer, the lower aquifer willbe pumped following remediation of the overlying upper aquifer in thisarea. This will prevent potential contaminant drawdown to deeper depths.

A water treatment system will be established on-site. The system'sinfluent will include contents of the tanks and piping, all wastewatergenerated due to remedial actions implemented, pumped surface water, andextracted groundwater. The level and degree of treatment will depend on1) the level of contaminants in the influent and 2) the ultimatedischarge point of the treated water. There are two water dischargealternatives for the treated water. The optimal choice is the localsewer system. The other alternative is to discharge the effluent to asurface stream. The range of treatment for the contaminated waterincludes biological degradation, air stripping, filtration throughactivated carbon filter, and metal removal through flocculation,Bedimentation and precipitation. The point of discharge and the degreeof treatment will be determined in the Remedial Design stage. Theeffluents, including both discharged water and/or air, will meet allapplicable and relevant or appropriate requirements (ARARs).

Declaration

The selected remedy is protective of human health and the environment,attains Federal and State requirements that are applicable or relevant andappropriate, and is cost-effective. This remedy satisfies the preference fortreatment that reduces toxicity, mobility, or volume as a principal element.Finally, it is determined that this remedy utilizes permanent solution andalternative treatment technologies to the maximum extent practicable.

Date T YGreer C. Tidwelly Regional Administrator

SUMMARY OF REMEDIAL SELECTION

CAPE FEAR WOOD PRESERVING SITEFAYETTEVILLE, CUMBERLAND COUNTY

NORTH CAROLINA

PREPARED BY:

U.S. ENVIRONMENTAL PROTECTION AGENCYREGION IV

ATLANTA, GEORGIA

TABLE OF CONTENTS

PAGE NO.

1.0 Introduction .................................................. 11.1 Site Location and Description ............................ 11.2 Site History .............................................4

2.0 Enforcement Analysis ..........................................7

3.0 Current Site Status ........................................... 73.1 Hydrogeologic Setting ....................................73.2 Site Contamination ......................................113.3 Air Contamination ....................................... 113.4 Soil Contamination ...................................... 113.5 Groundwater Contamination ............................... 223.6 Surface Water and Sediment Data ......................... 333.7 Risk Assessment Summary .................................46

4.0 Cleanup Criteria .............................................494.1 Groundwater Remediation ................................. 494.2 Soil Remediation ........................................494.3 Surface Water/Sediment Remediation ...................... 52

5.0 Alternatives Evaluated ....................................... 525.1 Nine Point Evaluation Criteria for Evaluating

Remedial Action Alternatives .......................... 595.1.1 Overall Protection of Human Health and

the Environment ................................ 605.1.2 Compliance with Applicable and Relevant

or Appropriate Requirements (ARARs) ............ 605.1.3 Long-Term Effectiveness and Performance .......... 605.1.4 Reduction of Toxicity, Mobility, or Volume .......605.1.5 Short-Term Effectiveness .........................605.1.6 Implementability ................................. 745.1.7 Cost .............................................745.1.8 State Acceptance ................................. 745.1.9 Community Acceptance .............................74

6.0 Recommended Alternatives ..................................... 746.1 Description of Recommended Remedy ....................... 746.2 Operations and Maintenance ..............................766.3 Cost of Recommended Alternative .........................766.4 Schedule ................................................776.5 Future Actions ..........................................776.6 Consistency With Other Environmental Laws ...............77

7.0 Community Relations ..........................................818.0 State Involvement ............................................81

AppendicesAppendix A - Responsiveness SummaryAppendix B - Proposed Plan/Legal Notice

LIST OF FIGURESPAGE NO.

Figure 1. Map Showing Site Location ................................2Figure 2. Map Highlighting Area of the Site ........................3Figure 3. Map Illustrating Features of the Site .................... 5Figure 4. Map Depicting Groundwater Contour in Lower

Aquifer (Data Collected May 16, 1988) ...................9Figure 5. Map Depicting Groundwater Contour in Upper

Aquifer (Data Collected May 16, 1988) ..................10Figure 6. Map Identifying Surficial Soil Contamination

by Chromium Exceeding Cleanup Goal ..................... 14Figure 7. Map Identifying Surficial Soil Contamination

by Arsenic Exceeding Cleanup Goal ......................16Figure 8. Map Identifying Surficial Soil Contamination

by Polycyclic Aromatic Hydrocarbons (PAHs)Exceeding Cleanup Goals ................................ 17

Figure 9. Map Identifying Surficial Soil Contaminationby Benzene Exceeding Cleanup Goal ...................... 18

Figure 10. Map Identifying Surficial Soil Contaminationby Toluene ............................................. 19

Figure 11. Map Defining Horizontal Extent of ContaminationExceeding Cleanup Goals in Surficial Soils .............19

Figure 12. Map Locating Bore Holes .................................. 24Figure 13. Map Locating Groundwater Sampling Points .................29Figure 14. Map Specifying Total PAH Concentrations in

Upper Aquifer .......................................... 30Figure 15. Map Specifying Total BTX Concentrations in

Upper Aquifer .......................................... 31Figure 16. Map Specifying Total PAH Concentrations in

Lower Aquifer ..........................................32Figure 17. Map Specifying Total BTX Concentrations in

Lower Aquifer .......................................... 33Figure 18. Map Specifying Chromium in Upper Aquifer .................35Figure 19. Map Specifying Arsenic in Upper Aquifer ..................37Figure 20. Map Specifying Chromium in Lower Aquifer .................38Figure 21. Map Specifying Arsenic in Lower Aquifer ..................40Figure 22. Map Locating Groundwater Sampling Points .................46

LIST OF TABLESPAGE NO.

Table 1. Surficial Soil Sampling Data Summary ....................12Table 2. Comparison of 1-Foot and 5-Foot Sampling Results ........21Table 3. Bore Hole Sampling Data Summary .........................25Table 4. Grace Parker Property Sampling Data Summary .............28Table 5. Groundwater Sampling Data Summary .......................41Table 6. Surface Water Sampling Data Summary ..................... 47Table 7. Sediment Sampling Data Summary ..........................48Table 8. Summary of Contaminated Media and Cleanup Goals .........53Table 9. Possible Remedial Technologies for Soil, Sediments,

Groundwater and Surface Water ..........................57Table 10. Retained Technologies, Applicable Media and

Contaminants Considered for Alternatives Developed .....58Table 11. Development of Remedial Action Alternatives for

Soils/Sediments ........................................ 60Table 12. Development of Remedial Action Alternatives for

Groundwater and Surface Water ..........................61Table 13. Development of Remedial Action Alternatives for

Hazardous Materials, Tanks, and Piping .................62Table 14. Summary of Remedial Alternatives Evaluation ..............64Table 15. Summary of Institutional and Land Use Restrictions .......71Table 16. Summary of the Public Health and Environmental

Effects Evaluation .....................................72Table 17. Implementability Evaluation .............................. 74Table 18. Summary of Present Worth Costs for Hazardous Waste,

Tanks and Piping ....................................... 75Table 19. Summary of Sensitivity Analysis for Soil and

Sediment Alternatives ..................................76Table 20. Summary of Sensitivity Analysis for Groundwater and

Surface Water Alternatives .............................77Table 21. List of Applicable and Relevant and Appropriate

Requirements ...........................................81

RECORD OF DECISIONSUMMARY OF REMEDIAL ALTERNATIVE SELECTION

CAPE FEAR WOOD PRESERVING SITEFAYETTEVILLE, CUMBERLAND COUNTY, NORTH CAROLINA

1.0 INTRODUCTION

The Cape Fear Hood Preserving (Cape Fear) Site was proposed for the NationalPriorities List (NPL) in June 1986 and was finalized in July 1987 as sitenumber 572. The Cape Fear Site has been the subject of a RemedialInvestigation (RI) and a Feasibility Study (FS), both of which were conductedunder the REM II contract. The RI report, which examined air, groundwater,soil, and surface water and sediment contamination at the Site and the routesof exposure of these contaminants to the public and environment was completedin October 1988. The FS, which develops, examines and evaluates alternativesfor remediation of the contamination found on site, was issued in final draftform to the public in February 1989.

This Record of Decision has been prepared to summarize the remedialalternative selection process and to present the selected remedialalternative.

1.1 SITE LOCATION AND DESCRIPTION

The Cape Fear Site is located in Cumberland County, North Carolina, on thewestern side of Fayetteville near Highway 401 (Figure 1). It includes aboutnine acres of a 41-acre tract of land near the intersection of latitude35*02'57"N and longitude 79*01'17"W. The site is adjacent to otherindustrial/commercial establishments as well as private residences. Fourhomes are located near the site. In addition, a subdivision named"Southgate" is located approximately a quarter of a mile south of the siteand houses approximately 1,OOO people. Figures 2 and 3 show the area andmajor site features.

Of the approximately 41 acres comprising the site, less than 10 acres weredeveloped by the facility. The remainder of the site is heavily wooded withconiferous trees with a small swampy area northeast of the developed area.The site is highly disturbed in the vicinity of the plant facilities. Thebuildings are currently abandoned and in various states of disrepair. Theswampy area consists of a seasonally flooded wetland dominated by rushes.The upland section of the site is sandy and well-drained. A site survey willbe required prior to initiating remedial action to determine if endangeredplant species exist on-site.

The terrain of the Cape Fear Site is predominantly flat, with drainageprovided by a swampy area on the northeast side of the site and a man-madeditch to the southeast that extends southeastwardly to a diked pond. Avariety of land uses exist around the Cape Fear Site. The properties to the

ft FEARWOOD PRESERVING

SEVENTY FIRST 1ELEU SCHOOL •

LOCATION MAPFIGURE NO.

1CAPE FEAR WOOD PRESERVING SITE

FAYETTEVILLE, NORTH CAROLINA

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AREA MAP

CAPE FEAR WOOD PRESERVING SITEFAYETTEVILLE, NORTH CAROLINA

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north include an undisturbed pine forest, a concrete plant, and a fewresidential properties. To the east is a continuation of the undisturbedpine forest, and to the west is farmland used for growing crops and raisinglivestock. To the south is another concrete plant as well as the Southgatesubdivision.

1.2 SITE HISTORY

Operations at the Cape Fear Wood Preserving Site commenced in 1953 andcontinued until 1983. The Cape Fear Wood Preserving facility producedcreosote-treated wood from 1953 until 1978 when demand for creosote-treatedproducts declined. Wood was then treated by a wolmanizing process usingsalts containing sodium dichromate, copper sulfate, and arsenic pentoxide.This treatment process is known as the copper-chromium-arsenic (CCA)process. The date the CCA process was initiated is unknown. Nor is it knownwhether the creosote and CCA processes occurred simultaneously or insuccession.

Both liquid and sludge wastes were generated by these two treatmentprocesses. Waste from the creosote process was pumped into a concrete sumpnorth of the treatment unit (Figure 3). As liquid separated from the sludge,it was pumped into a drainage ditch that lies southeasterly of the developedportion of the site and discharges into a diked pond. Stormwater runoff fromthe treatment yard also appears to drain into this ditch. Waste from the CCAtreatment process was pumped into a unlined lagoon north of the dry kiln andallowed to percolate into the ground.

In the summer of 1977, the site was determined to be contaminated withconstituents of coal tar and coal tar creosote. State authorities orderedthe owner/operator to comply with North Carolina law. As a result, theowner/operator changed operations to limit further releases, installed a newpotable water well for a neighbor west of the site, and removed 900 cubicyards of creosote-contaminated soil from the treatment yard and the drainageditch that parallels the railroad. The creosote-contaminated soil wastransported for land-spreading to property leased from Grace Parkerapproximately 2.5 miles south of the site. The soil on this property wassampled as part of the RI. Low levels of polycyclic aromatic hydrocarbons(PAHs) were detected.

Sometime between 1979 and 1980, a new closed-circuit CCA plant was installedand the old creosote and CCA facilities were decommissioned, the new CCAplant was regulated under the Resource Conervation and Recovery Act (RCRA) asa small generator until 1983, when the company went out of business. Thesite was subsequently abandoned until the summer of 1988 at which time SECo,Investment, Inc. purchased the property.

The Environmental Protection Agency (EPA) conducted a site reconnaissance andsite investigation in October 1984. Surface water, groundwater, soil andsediment samples were collected from the northeast swamp, diked pond, lagoon,

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drainage ditch and a domestic well west of the site (S.T. Jackson). PAHs,which are creosote-related compounds, and the CCA metals were detected in allsamples. Consequently, EPA conducted an emergency removal action at the sitein January and February 1985. This actions included:

* Removal of creosote sludge from the creosote concrete sump;

* Removal of sludge from the lagoon to a depth of 7 feet, andsolidification of the sludge with fly ash;

* Pumpage of lagoon water into storage tanks located south of the newCCA unit;

* Removal of contaminated soil from the drainage ditch that parallelsthe railroad tracks and at the culvert near Reilly Road;

* Removal of contaminated soils from a portion of the northeast swampand stained areas in the treatment yard; and

* Back filling with clean sandy soil of areas where contaminated soilhad been removed.

All contaminated soils and sludges removed were transported to the GSXhazardous waste landfill in Pinewood, South Carolina.

The NUS Corporation conducted an investigating of the site in May and October1985. Soil, sediment, surface water and ground water samples werecollected. Analytical results again showed that samples were contaminatedwith creosote-related compounds, arsenic, chromium and copper.

EPA conducted a second emergency response in September 1986 when site visitsrevealed that vandals had shot holes in a 3,000-gallon creosote storage tankspilling approximately 500 gallons of creosote on the ground. The cleanupoperation consisted of:

* Removal, solidification, and transport of approximately 10 cubic yardsof creosote-contaminated sludge to an on-site metal shed east of thenew CCA unit;

* Removal and transport of the creosote storage tank to the on-sitemetal shed;

* Excavation and grading of the area where the creosote tank had leaked;

* Pumpage of approximately 15,000 gallons of CCA waste water from theCCA recovery sump into on-site storage tanks located south of the newCCA unit; and

* Containment of the CCA recovery sump within an earthen dike.

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2.0 ENFORCEMENT ANALYSIS

Several Potentially Responsible Parties (PRPs) have been identified,including --he Cape Fear Wood Preserving Company (no longer active), Johnson fiGeddes Construction Company (no longer active), John R. Johnson, Doretta Ivey(wife of former president of the Cape Fear Hood Preserving Company —deceased), and Dewey Zvey, Jr. (son of the former president — deceased).Recently identified PRPs include SECO Investments, Inc. (SECO), SoutheasternConcrete Products, Inc. (SE-Lum), Southeastern Concrete Products ofFayetteville, Inc. (SE-Fay), Mr. Steve Floyd, Mr. Louis Lindsey, and Mr.James Musselwhite.

In December 1984, EPA issued notice letters to the PRPs informing them ofEPA's intention to conduct CERCLA remedial activities at the site unless thePRPs chose to conduct such actions themselves. The PRPs were sent noticeletters rather than an administrative order because of their presumedinability to pay for remedial action. On June 5, 1989, these PRPs were sentRD/RA notice letters informing them that the Agency was considering spendingFund monies if they no not or incapable of conducting the project themselves.

3.0 CURRENT SITE STATUS

The site was abandoned from 1983 until the summer of 1988 when it waspurchased by SECo, Investments, Inc. Presently, an area of approximately10,000 square feet of the site near the railroad tracks has been enclosed bya chained linked fence. Within the fence are some small earth-movingequipment and a concrete pad with a storage trailer on top. This area isrented to Southern Concrete Products, Inc.

In the fall of 1988 and at the direction of a Cumberland Countybuilding/construction inspector, the owner retrenched the majority of thedrainage ditch, dug several new drainage trenches and breached the dikedpond. Both the drainage ditch and the sediments within the drainage ditchand the diked pond and the sediments within the diked pond were areastargeted for remediation.

3.1 HYDROGEOLOGIC SETTING

The study area is underlain by two major stratigraphic formations: theTuscaloosa and the Black Creek Formations. The Tuscaloosa Formation appearsto rest directly on a basement rock complex and is mainly a massive clay unitcontaining interbedded layers of sand. The Black Creek Formation overliesthe Tuscaloosa Formation and typically consists of thin layers of brownish toblack clay alternating with thin layers of gray to white fine-grained quartzsand. The contact between the Black Creek beds and the Tuscaloosa clay isunconformable. In addition, the lithology of these formations is so similar,it is very difficult to differentiate between the formations based on visualinspection.

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The Tuscaloosa and Black Creek Formations are overlain by undifferentiatedBurficial sediments. In the study area, the surficial sediments have amaximum thickness of 30 feet. These beds generally consist ofunconsolidated, fine to medium-grained sand in a clay matrix.

Geologic logs recorded during monitor well and borehole installationsindicate that the site is underlain by intermittent beds of sands, clays, andsands in clay matrices. One distinct clay to silty, sandy claysemi-confining unit, however, was identified. This unit divides thesubsurface down to a depth of approximately 90 feet into two water producingzones.

The upper aquifer consists of unconsolidated sands and clays and isapproximately 25 feet thick. The lower aquifer also consists of sands andclays and is approximately 50 feet thick. Separating the aquifers is a clayto silty, sandy clay semi-confining unit, approximately 15 feet thick, whichacts as an aguitard. This unit is generally continuous across the site, butwas reporting missing in one location along the access road. Underlying thelower aquifer is a stiff clay unit of unknown thickness, which is assumed toact as an aquiclude or aquitard based on physical descriptions of thematerial. This unit appears to be continuous across the entire site.

It has been determined that the groundwater flow in the lower aquifer isgenerally southwestward at the site (Figure 4) while groundwater flow in theupper aquifer is radial, moving in all directions from the site (Figure 5).This radial flow pattern in the upper aquifer is probably due to acombination of two geologic conditions!

Most of the steams in the study area have flood plains. Some have terracesthat range in width from a few feet to several miles. Along each stream, thepresent flood plain width varies in response to geologic control, but thestream, flood plain, terraces, and valleys generally become widerdownstream. The site does not lie within a floodplain.

* The site is located at a topographic high point for the area and

* Sandy materials at the site facilitate higher rainfall recharge thanin the surrounding areas.

The southwestward flow pattern in the lower aquifer is probably in responseto the regional flow pattern for this aquifer.

The average horizontal groundwater velocity (based on Oarcey's Law forgroundwater flow) in the upper aquifer is approximately 9 feet/year and forthe lower aquifer, 16 feet/year. Therefore, in 35 years (the time since thebeginning of plant operations), the maximum contaminant migration in theupper aquifer would be expected to be in the order of 300 to 400 feet fromthe source and 500 to 600 feet in the lower aquifer. The analytical database supports this determination.

The average vertical groundwater velocity from the upper aquifer to the loweraquifer is estimated to be 3.0 feet/year.

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LEGEND

CLEARED MICA• 202.4 MEASURED WATER LEVEL

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Both aquifers underlying the site have been classified as Class IIA usingU.S. EPA Groundwater Classification Guidelines of December 1986.

3.2 SITE CONTAMINATION

Remedial Investigation field work centered on the developed area of the site,the swampy areas northeast and southwest of the developed area, the clearingeast of the developed area, and the drainage ditch and diked pond. Soil,groundwater, surface water and sediment samples were collected in and aroundthese areas. The soil samples analyzed in the on-site laboratory providedsufficient data to determine horizontal extent of contamination. The otherenvironmental samples (water and sediment) and 25% of the soil samples, weresent to a laboratory in the Contract Laboratory Program (CLP) and analyzedfor the compounds on the Target Compound List (TCL). Five groundwatersamples analyzed for hexavalent chromium (Cr ) and four soil samples wereanalyzed for dioxins.

The major contaminants are the organic compounds (polycyclic aromatichydrocarbons - PAHs) grouped under the general term of coal-tar basedcreosote and the the metals - copper, chromium and arsenic.

3.3 AIR CONTAMINATION

The most common sources of air contamination at hazardous waste sites are thevolatilization of toxic organic chemicals and the spread of airbornecontaminated dust particles. During the RI, site personnel used the HNuphotoionization analyzer to monitor the air while performing the designatedRI tasks. No airborne problems were encountered.

3.4 SOIL CONTAMINATION

The concentrations of contaminants detected in soil at the site aresummarized in Table 1. This table provides the frequency of detection, theranges of concentrations found in surficial soil at the site, and thebackground concentration ranges for those contaminants identified aschemicals of potential concern in Section 2.0 of the Risk Assessment(Appendix C of the FS) . Dioxins were not detected in any of the four soilsamples analyzed for this group of compounds.

Analyses of the soil samples indicate that in spite of previous removalactions, areas with high concentrations of inorganic chemicals and PAHs stillremain. In general, the most contaminated areas are in the process area, thenortheast seasonal swamp, along the access road to the back storage area, andalong the drainage ditch southeast of the process site.

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TABLE 1

SURFICIAL SOIL SAMPLING DATA SUMMARYCAPE FEAR WOOD PRESERVING SITEFAYETTEVILLE, NORTH CAROLINA

Frequency ofDetection

Concentration BackgroundRange Concentration

Range*

Inorganic Chemicals (mg/kg)

Aluminum 99Arsenic 68Barium 52Chromium 68Copper 69Iron 100Lead 39Magnesium 62

Organic Chemicals (ugAg)

Benzene 6Toluene 29

PAHs (mgAg)

Acenaphthene 12Acenaphthylene 16Anthracene 20Benzo(a)anthracene 12Benzo(b and/or k)fluoranthene 26Benzo(g,h,i)perylene 12Benzo(a)pyrene 17Chrysene 20Dibenzo(a,h)anthracene 5Fluoranthene 27Fluorene 18Indeno(l,2,3-cd)pyrene 12Naphthalene 11Pnenanthrene 15Pyrene 29

Total PAHs 53

ND-14000ND-15000ND-110ND-1300ND-610099-15000ND-270ND-530

ND-71ND-1100

ND-1300ND-244ND-24000ND-370ND-560ND-13ND-180ND-630ND-7.8ND-2600ND-4100ND-18ND-390ND-8100ND-2200

ND-37000

1600-2900ND

ND-212.6-5.2ND-11

1500-2400ND-70ND-210

NDND-390

NDNDND

ND-0.072ND-0.20ND-0.038ND-0.085ND-0.090

NDND-0.16

NDND-0.047

NDND-0.039ND-0.16

ND-0.89

ND - Not detected* - Based on the analytical results for the three background surficial

soil samples (BCK-1, BCK-2, and BCK-3).

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Figures 6 through 10 show the surficial soil analytical results for chromium,arsenic, total PAHs, benzene, and toluene, respectively. These chemicalswere used extensively in past wood preserving operations at the site andtherefore, are good indicators of the extent of site-related soilcontamination. Figures 6 through 10 also show areas of high and moderatecontamination compared to background levels.

As shown in Figures 6 through 7, chromium and arsenic metal contamination isfound mainly in the central process area and in the northeast seasonalswamp. Significantly elevated concentrations were also found along theaccess road and drainage ditch. The highest concentrations of chromium andarsenic (1300 and 15,000 mg/kg, respectively) were all found at grid pointC-5 which is just south of the creosote unit.

PAHs are mainly concentrated in the western process area as shown inFigure 8. Isolated occurrences of high concentration were also found alongthe access road and the drainage ditch. The western process area washistorically used to unload the creosote from the railroad cars which mayexplain the high concentrations of PAHs found in this area. The highestconcentration of total PAHs (37,000 mg/kg) was found at SS-2 near therailroad. The second highest concentration of total PAHs (11,000 mg/kg) wasfound at grid point D-9 which is located in the bed of the drainage ditch.This sample is essentially a sediment sample, but was taken when the ditchwas dry.

Results of the benzene and toluene analyses shown in Figures 9 and 10,respectively, indicate that volatile organics are not as widespread at thesite as the inorganics and PAHs, but they are still prevalent. Of the two,toluene is by far the more prevalent. Toluene is concentrated mainly in thecentral process area and in the northeast seasonal swamp. The highestconcentration of toluene (1100 mg/kg) was found at grid point C-5 which isjust south of the creosote unit. Benzene is concentrated mainly in thesouthern process area with the highest concentration (71 mg/kg) found at gridpoint D-B which is just east of the metal shed. It is believed that thesource of the benzene contamination is the underground gasoline storage tankburied at the west end of the metal shed.

A comparison of the indicator chemical analytical results for soil samplescollected at the surface and at depth (5 feet) is provided in Table 2. Asshown, the majority of contamination is found at the surface, particularlyaround the perimeter of the contaminated area. Therefore, a slopingcontaminated soil interface does not appear to be prevalent and the resultsof the surficial soil sampling program provide a valid determination of thehorizontal extent of contamination.

A composite of these areal extents is provided in Figure 11, which showssurface soil locations exceeding the cleanup goals for all contaminants ofconcern. This area encompasses approximately 150,000 square feet (3.4.acres).

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UN

A

FIGU

RE N

O.

-16-

BE

NZE

NE

CO

NC

EN

TRA

TION

S EX

CE

ED

ING

CLE

AN

UP

GO

AL IN

SU

RFIC

IAL SO

ILSC

APE FEAR W

OO

D PR

ESERVIN

G SITE

FAYETTEVILLE, NO

RTH

CAR

OLIN

A

FIGU

RE

NO

.

-17-

TOLU

EN

E C

ON

CE

NTR

ATIO

NS

IN S

UR

FICIA

L SO

ILS

CAPE

FEAR. W

OO

D P

RE

SE

RV

ING

SITE

FAY

ETTE

VILLE

, NO

RTH

CAR

OLIN

A

FIGU

RE N

O.

10

-18-

HORIZONTAL EXTENT OF CONTAMINATIONEXCEEDING CLEANUP GOALS IN SURFICIAL SOILS


FIGURE NO.

11

-19-

TABLE 2

COMPARISON OF 1-FOOT AND 5-FOOT SOIL SAMPLE RESULTSCAPE FEAR WOOD PRESERVING SITEFAYETTEVILLE, NORTH CAROLINA

ApproximateDepth Chromium Copper

Sample (ft) (tag/kg) (mgAg)

AA8-01AAB-05

A4-01A4-05

A6-01A6-05

A7-01A7-05

B3-01B3-05

B4-01B4-05

C2-01C2-05

C4-01C4-05

C8-01C8-05

D10-01D10-05

E2-01E2-05

G5-01G5-05

SS3-01SS3-05

15

15

15

15

15

15

15

15

15

15

15

15

15

2.32.4

18-

1108.6

240120

4.1. 7.1

1912

118.7

676.4

13-

22-

187.1

7.84.5

230240

2.3—

4.8-

27-

7832

3.3-

3.6—

4.82.2

13-

15-

_-

82.4

6.8-

206.5

Arsenic(mgAg)

J_u

—

9-

41-

5854_-

7.9-

9.6-

22-_-

_-

14-

8.9-

130180

TotalPAHs Toluene(mgAg) (ugAg)

^ «™

0.5

_ —

0.3

13001.6

120.52

_ _

2.0

9500 130210 150

420130

420 1301000

87- -

_ _- -

_ _— —

0.013 55- -

8.6 9002.3

Benzene(ugAg)

iml

—_-_—_-__—_———_-_—

_—_—_—

8-

-20-

TABLE 2(Continued)

ApproximateDepth Chromium

Sample (ft) (mgAg)

SS15-01SS15-05

SS28-01SS28-05

EXT21-01EXT21-05

EXT22-01EXT22-05

EXT27-01EXT27-05

EXT29-01EXT29-05

EXT31-01EXT31-05

EXT34-01EXT34-05

EXT41-01EXT41-05

DD9-01DD9-05

15

15

15

15

15

15

15

15

15

15

4.53.2

1.92.4

5.2

3.2

9

3.64.2

8.22.3

26

_

5620

TotalCopper Arsenic PAHs Toluene(mg/kg) (mgAg) (mgAg) (ugAg)

2.9 0.9- - 0.3 -

23 10 -- 0.4 -

1.20.5 - -

- - - -

8.8 77 4

6.4 1.5 - 272.1 - -

7.7 8 -- - 2.0 -

7.7 5 - 150

_ _ _ _

4.3 25 1.3 230'2.5 21 0.50

Benzene(ugAg)

_

—

—

_

-

_

-

-

_

-

- - Not Detected

-21-

Results of the vertical extent of contamination analyses (borehole samples -Figure 12) indicate that although the surface is highly contaminated inseveral areas, the subsurface below two feet is generally uncontaminated.Indicator chemical analytical results for the borehole samples, including thebackground borehole, are provided in Table 3. The only significantcontamination above background at depth is the PAH contamination found inBH-1 and BH-2. Moderate concentrations of PAHs were found down to a depth ofapproximately 23 feet in BH-1 and 46 feet in BH-2. BH-1 is located in thearea of the creosote unloading zone, and BH-2 is located in the area of thecreosote unit.

Since contaminated soils from the site were land farmed on property owned byGrace Parker, samples were collected here to insure that a health risk didnot exist due these past disposal actions. The Grace Parker propertyanalytical results for the chemicals of potential concern are shown inTable 4. As shown, the Grace Parker property has been contaminated with lowlevels of PAHs.

3.5 GROUNDWATER CONTAMINATION

Figure 13 locates the installed monitoring wells that provided thegroundwater samples and Table 5 summarizes the concentrations of contaminantsdetected in groundwater that were identified as chemicals of potentialconcern in the Risk Assessment (Appendix C, Section 2.0 of the FS document).The complete analytical results can be seen in Appendix A of the RI Report.

In general, analyses of the groundwater samples indicate low-levelcontamination by a variety of inorganic and organic chemicals includingseveral PAHs. The organic chemicals, however, are the only chemicals whichindicate any kind of plume pattern or area of contamination which can be tiedto the site. The inorganic chemicals do not show any kind of pattern and inmost cases, higher concentrations are found off-site than on-site.

Figures 14 through 17 show the analytical results of total PAHs and totalBTXs (benzene, toluene and xylene) in both the upper and lower aquifers.These contaminants are known to be site-related and for the most part are notnaturally occurring and therefore, are good indicators of site inducedcontamination. In addition, because BTXs do not generally become tied up inthe soil matrix, they are good indicators of the maximum extent ofcontamination. As can be seen in Figures 14 through 17, contaminant plumeshave been identified in both aquifers based on the analytical results. Theplume in the upper aquifer extends a few hundred feet in all directionsaround the wood preserving process area. The plume in the lower aquifercovers only a small protion of the process area and is located around wellEW-01. The plume in this aquifer could be the result of contaminantsmigrating through the semi-confining unit, but is more likely due to poorconstruction of well EW-01 (an old industrial water supply well) providingthe conduit for migration. Well EW-01 is screened in the lower part of thelower aquifer. If contaminants were migrating through the semi-confiningunit to the depth of EW-01, a greater extent of contamination would be

-22-

BOR

EHO

LE SAMPLIN

G LO

CATIO

NS

CAPE FEAR

WO

OD

PRESER

VING

SITEFA

YE

TTEV

ILLE, N

OR

TH C

ARO

LINA

FIGU

RE

NO

12

-23-

TABLE 3

BOREHOLE SAMPLING DATA SUMMARYCAPE FEAR WOOD PRESERVING SITEFAYETTEVILLE, NORTH CAROLINA

Sample

BH1-S12S13SIS2S354S556S7S859S10Sll514S15S16517S18519520521

BH2-S1S2S354S556575859510SllS12S13S14515516

ApproximateDepth(ft)

1357911131517192123253136414651566166

135791113151719263136414651

Chromium(mgAg)

_125.85.4

24121210388.528147.5273010_107.2—-

2149.88.213118.44.25.295.425208.56.99.65.5

Copper(mgAg)

5———10————————————2.62.82.42.5

32-2.32.62.8—7—_—_2.42.62.78.2

2-3

Arsenic(mgAg)

0.58——-18———————————0.80.60.92—-

16—-———2——————-4.7-


_0.67.50.32.0 8

2801.40.31.10.7- -8.2— —— —— —— —1.2— —- -- -— —

0.3- -- -

210670224.00.56.9 3002.120.16.50.713.68.2 700.096

Benzene(ugAg)

_-—-4--————--—--—---—

_-------17-------

-24-

TABLE 3(Continued)

Sample

S17S18S19

BH3-S1S2S3S4S556S7SBS9S10Sll512S13S14S15S16S17S18S19S20

BH4-S2S3S4S5S6S7S8S9S10SllS12S13S15SI 6S17S18S19

ApproximateDepth(ft)

566166

13579111315171924293133353944495459

357911131517192123252936414651

Chromium(mg/kg)

6.8—-_5.2—14161513131210—17326.5_8.94.6—4.87.6

_

66.86.3——__——_——20-5.410

Copper(mgAg)

112.610

w——2.52.9—_————2.3———_2.9—2.68.8

_

—

2.8—_——__——--2.9——-

Arsenic(rag/kg)

—-

1.10.680.627.70.550.75_0.58_——_——__—2.5—1.8

1.4_——_—__————_————


_ _- -

w _— —0.6

36— —0.3_ _— —0.30.8— —

10— —_ _— __ —_ _0.30.3- -

_ __ _— —1.8_ __ —_ _0.3_ _- _— —NAMANANANANA

Benzene(ugAg)

—-_—_—————_——_——_———-—

__—-——_—_————--—-

-25-

TABLE 3(Continued)

ApproximateDepth Chromium

Sample (ft) (ragAg)

S20S21

BHBCK1-S1S3S558SllS13S17S20S23S24S30

5661

1591521253339454759

152.8

11--4.9175.588—9.6—2.8

Copper Arsenic(mgAg) (ragAg)

3.1 4.2- -

9.1— —_ __ __ _— —3 1.6_ _

8.50.7

— —


25- -

"" D— —— -

110— —

3866

— —12

— —« __

Benzene(ugAg)

„-_————-————~~

- « Not detectedNA - Not analyzed

-26-

TABLE 4'

GRACE PARKER PROPERTY SAMPLING DATA SUMMARYCAPE FEAR WOOD PRESERVING SITEFAYETTEVILLE, NORTH CAROLINA

GP-1 GP-2 GP-3

PAHs (rag/kg)

- - Not detectedNA - Not analyzed

GP-4

Inorganic Chemicals (mg/kg)

AluminumArsenicBariumChromiumCopperIronLeadMagnesium

Organic Chemicals (ugAg)

BenzeneToluene

2100—8.54.12

1400—

250

_150

NA—NA—6NANANA

_—

NA—NA2.24.4

NANANA

53-

NA—

NA2.16.3NANANA

—

AcenaphtheneAcenaphthyleneAnthraceneBenzo (a) anthraceneBenzo (b and/or k) fluorantheneBenzo (g,h,i) peryleneBenzo (a) pyreneChryseneDibenzo (a,h) anthraceneFluorantheneFluoreneIndeno (1,2,3-cd) pyreneNaphthalenePhenanthrenePyrene

Total PAHs

- -0.0420.100.141.30.190.440.200.0680.12— —.35- -— —0.20

3.2

-- -— —— —

1.1- -

0.3- -— -

0.30.8

- -- -— -

1.8

4.3

-27-

LEGEND

250

- - - CLEARED AREA• SAMPLE LOCATION

GROUND WATER SAMPLING LOCATIONS


FIGURE NO.

13-

-28-

VLEGEND—— -CLEARED AREA \t

12 MEASURED CONCENTRATION IN u«/l X

NO HOT DETECTEDO ESTIMATED AREA OF COWTA** NATION

TOTAL PAH CONCENTRATIONS IN UPPER AQUIFERCAPE FEAR WOOD PRESERVING SITE

FAYETTEVILLE. NORTH CAROLINA

FIGURE NO

14

-29-

JLEGEND

-—— CLEARED AREA

12 MEASURED CONCENTRATION IN ug/lNO NOT DETECTED

O ESTIMATED AREA OF CONTAMIIJATION

230

TOTAL BTX CONCENTRATIONS IN UPPER AQUIFER

CAPE FEAR WOOD PRESERVING SITEFAYETTEVILLE. NORTH CAROLINA

FIGURE NO

15

-30-

LEGEND

12CLEARED AREAMEASURED CONCENTRATION

ND NOT DETECTEDO ESTIMATED AREA OF

250

TOTAL PAH CONCENTRATIONS IN LOWER AQUIFER


FIGURE NO.

16

-31-

- - - CLEARED AREA \

12 MEASURED CONCENTRATION IN ug/l V

NO NOT DETECTED

O ESTIMATED AREA OF CONTAMINATION

250

TOTAL BTX CONCENTRATIONS IN LOWER AQUIFER


FIGURE NO.

17

- 3 2 -

expected in the groundwater, at least out to MW-6. Since MW-6 is locateddowngradient of EW-01 and in the middle of the processing area with thescreen in the upper part of the lower aquifer, if contamination was migratingthrough the semi-confining layer, then it would be seen in MW-6.

The plume in the upper aquifer is consistent with the results of thehydrogeological analysis. The plume in the lower aquifer, however, is notconsistent with the hydrogeologic analysis results. Contaminants do notappear to be migrating through the semi-confining unit into the lower aquiferindicating that contaminants are probably not moving vertically asgroundwater moves. Retardation and/or decay processes in the upper aquiferand semi-confining unit have most likely kept the contaminants from enteringthe lower aquifer, to any significant degree.

Figures 18 through 21 show the analytical results for chromium and arsenic inboth the upper and lower aquifers. These contaminants are also known to besite-related and therefore could be indicators of site inducedcontamination. As can be seen in Figures 18 through 21, however, theanalytical results for these inorganic chemicals do not show any kind ofplume pattern which can tie the inorganic contamination to the site.

The inorganic contamination found in the study area likely exists for one oftwo reasons:

* Naturally occurring conditions or

* Small, local sources of contamination.

All the inorganic chemicals listed in Table 5 are naturally occurring in thesoils of the study area, and given the low pH of groundwater, most of theconcentrations measured for these chemicals are probably within the naturalvariation of concentrations expected. This is especially true consideringthat the samples are not filtered before being analyzed. Three wells,however, appear to have an unusually high concentration of one particularelement. These wells include MWS-1, MWS-9 and DW-14 which are far from thesite. Both wells MWS-1 and MWS-9 have unusually high concentrations ofchromium, while well DW-14 has an unusually high copper concentration. Thesewells have not exhibited any contamination in the past.

Of the five wells sampled and analyzed for hexavalent chromium (Cr ), onlyone showed evidence of Cr* . Well EW-02 had a concentration of 16 ug/1.The other four were below detection limits.

3.6 SURFACE WATER AND SEDIMENT

The concentrations of contaminants detected in surface water and sedimentsamples (sampling locations shown in Figure 22) are summarized in Tables 6and 7, respectively. The tables present the analytical results for thosechemicals identified as chemicals of potential concern in Section 2.0 of theRisk Assessment (Appendix C, Section 2.0 of the FS document). The completeanalytical results can be seen in Appendix A of the RI Report).

-33-

<JLEGEND

- - - CLEARED AREA.MEASURED CONCENTRATION IN UJ/I N \12

\s

NO NOT DETECTED

10

250

CHROMIUM CONCENTRATIONS IN UPPER AQUIFER


FIGURE NO.

18

-34-

>'\.

M\

—^— -—— - --— - v*12 MEASURED CONCENTRATION IN u«/l V

-——CUAftED AREA12 MEASURE) CONO NOT DETECTED

NO

250

ARSENIC CONCENTRATIONS IN UPPER AQUIFER


FIGURE NO

-35-

CHROMIUM CONCENTRATIONS IN LOWER AQUIFER

CAPE FEAR WOOD PRESERVING SITE______FAYETTEVILLE. NORTH CAROLINA

FIGURE NO.

20

——— CLEARED AREA12 MEASURED CONCENTRATION IN ug/lND NOT DETECTED

f» -- 2 >

250

ARSENIC CONCENTRATIONS IN LOWER AQUIFER


FIGURE NO.

21

- 37 -

TABLE 5

GROUND WATER SAMPLING DATA SUMMARYCAPE FEAR WOOD PRESERVING SITEFAYETTEVILLE, NORTH CAROLINA

COCOI

Inorganic Chemicals (ug/1)

AluminumArsenicBariumChromiumCopperCyanideIronLa adMagnesium

Organic Chemicals (ug/1)

Benzene2 , 4-DiroethylphenolEthylbenzeneStyreneToluenea , 1 , 1-TrichloraethaneXylenes

PAHs (ug/1)

AcenaphtheneAcenaphthyleneAnthraceneBenzol a (anthraceneChryseneDibenzofuranFluorantheneFluorene2-Methylnaphthd leneNaphthalenerhenanthronePyrene

ARARs

MCL

NA50

100050

lOOO(S)NA

300(5150NA

5NANANANA200NA

NANANANANANANANANANANANA

Other Guidance

MCLG3

MA50|p)

1500IP)UOIP)

1300IP)HAHA

20(P)HA

0NA

680(P)140IP)2000(P)

200<!40|P)

MANAMAMAHAMANANAHAHAHAHA

MH^l HW-2 »W-3

2/10/88 2/7/88 2/10/88

1BOOJ 33000 1300J_ _

22010J 98 11J17J 26 19J- - -

340J 24000 3100.122

640 4200 960

35140

- 242J20

2J- - 50

120- - 7J- _ _- - _-- - 82-

3598

- - 3824

- _ _

MW-4 MW-5

2/24/88 2/10/88

3600J 3500J2 12JN

5628JN 31J

11 65J40J

5400 2600J- —

970 1100

24-

40750

- -150

46-— ---

404J9J180

1200242J

HW-fi MH-7

2/12/88 2/10/88

1200J 1700J- _-

78J 9J170J

-5100J 12000J

- —800 520

— -.

5J11

-— —- -

12J

200131605J7J140501701409J16041

H4-8

2/25/88

31000J43210

120JH64-

63000J42

2900

_---—-—

_-2J-------3J—

JW-9

2/10/88

2900J___

44J-

9BOJ-

1100

_

------

„-—---------

Total PAHs 400 1500 1100

CO<ni

TABLE 5(Continued)


AluminumArsenicBariumChromiumCopperCyanideIronLeadMagnesium


Benzene2,4-Di»ethylphenolEthylbenzeneStyreneTo luena1,1 , 1-TrichloroethaneXylenes

PAHs (ug/1)

AcenaphtheneAcenaphthyleneAnthraceneBenzol a (anthraceneChryseneDibenzofuranFluorantheneFluorene2-Methy Inaphtha leneNaphthalenePhenanthrenePyrene

ARARs1

MCL

NA50

100050

lOOO(S)HA

300(3)50NA

5HANANANA200NA

HAHAHAHANANANAHAHAHAHAHA

Other Guidance

MCDG

NA50IP)

1500(P|120IP)1300(P)

NAHA

20(P)NA

0NA

680{P)110(P)

2000(P]200

440 (P)

NAHANAHAHAHAHAHAHAHAHAtlA

MW-10 MW-11 W-12 MW-13 MW-14 MW-15 IW-15D*

2/23/88 2/12/88 2/24/88 2/10/88 2/25/88 2/10/88 2/10/88

8400J 6000J 8000J 12000J 13000J 39000J 24000J2 4 8JN 14 - 9JN

116 - 84 - 10038JN 47J 23JN 44J 8UH 93J 59J

12 38J 14 33J 44 36J 32J- - - - - 3 0 J 9 0 J

11000J 9300J 21000J 16.000J 23000J 1600QJ 11000J4Q

1000 920 1600 1000 1500 1400 1100

« — ~» _ — . — —_ _ _ _ _ _ _- - - - - - -- - - - - - -_ _ _ _ _ _ _

11— - — — — — —

_ _ _ _ _ - -- - - - - - -- - - - - - -_ _ _ _ - _ —- - - - - - -_ _ _ _ — _ —_ _ _ - - _ -_ _ _ _ - - _- - - - - - -- - - - - - -_ _ _ _ _ _ _- - - - - - -

MW-16 EW-01

2/24/88 2/10/88

4000J289

32JN20 13J-

noooj noooj_ -

690 510

2J136

- -— —_

15J

33-3J

- -2J181219376802311

Total PAHs NA 840

OI

TABLE 5(Continued)

ARARs Other Guidance

Inorganic Chemicals (ug/l)

AluminumArsenicBariumChromiumCoppe rCyanideIronLeadMagnesium

Organic Chemicals (ug/l)

Benzene2,4-DimethylphenolEthylbenzenaStyreneToluene1 , 1,1-TrichloroethaneXylenes

PAHs |ug/l)

AcenaphtheneAcenaphthyleneAnthraceneBenzo ( a ) anthraceneChryseneOibenzofuranFluorantheneFluorene2-MethylnaphthaleneNaphthalenePhenanthrenePyrene

MO.2

NA50

100050

lOOO(S)NA

300(S)50NA

5NANANANA200NA


MCUT

NA5Q(P)

1500(P|120IP)

1300IP)NANA

20(P)NA

0NA

680(P)140IP)2000IP)

200•MO(P)


EW-02 MWS-1 H4D-2 MHS-3 MHD-4 HHS-S MHD-G

2/12/88 2/8/88 2/8/88 2/9/88 2/24/88 2/9/88 2/8/88

29000J 4200J 24000J 3000J 650J 4600JBJN 6JN 3

5116J 220J 26J 99J 25JN - 25J68J 50J 24J 38J 16 16J 28J

120J 170J 120J - 10J 30J40000J . 9000J 1400J 24000J 6200J 380J 1000 OJ

_ _ _ _ _ _ _690 1900 1000 520 550 - 780

_ — _ — — — —_ _ _ _ _ _ __ _ _ _ _ _ __ _ _ _ _ _ _2J - - U_ _ _ _ _ _ _- - - - - - -

_ _ _ _ _ _ __ _ _ _ _ _ __ _ _ _ _ _ __ _ _ _ _ _ _

-_ _ _ - - _ -_ _ _ _ _ _ __ _ _ - - - -_ _ _ _ _ _ _4J 3J

- -— — — — — — —

WS-7

2/9/88

1100J---

26J-

6100J--

530J120

76 OJS50JN

--

2300J

350J23619J-

20070200-

21000180

—

MHD-8

2/23/88

1900J562

38JN20-

laoooj-

570

_----—-

_----—-----—

Total PAUs NA 22000

TABLE 5(Continued)

ARABS Other Guidance


AluminumVitsenicBariumChromiumCopperCyanideIronLeadMagnesium


Benzene2 , 4-DimethylphenolEthylbenzeneStyraneToluene1,1,1-TrichloroethaneKylenes

PAHs (ug/1)

AcenaphtheneAcenaphlhyleneAnthraceneBenzol a 1 anthraceneChryseneDibenzoCuranFluorantheneFluorene2-MethylnaphthaleneNaphthalenePhenanthrenePytene

MCL2

HA50

100050

1000(5)HA

300(S|50HA

5HAHAHANA200HA

HAHAHANAHAHANANANANANAHA

MCLG3

NA50(P)

1500(P)120IP)

1300IP)HAHA

20(P|HA

0HA

680(P)140(P)

2oao(p)200

440IPI

HAHAHAHAHAHANAHAHAHANANA

MWS-9 MHD-IO H4S-11 MHD-12 DW-9 OH-11 DW-13 DH-14 DW-15

2/8/68" 2/8/88 2/9/88 2/12/88 2/9/88 2/9/88 2/9/88 2/9/88 2/9/88

12000J 210J 5700J 1300J - - 130J 200J_ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _

930J 27J 24J 24J - - - - -fi7J 20J 46J 41J 16J 24J 31J 330J 24J

IOJ - - - - - 10J 10J190J 640J 1900J 1900J - 300J 1200J

_ _ _ _ _ _ _ _ _520 390 500 440 - 930 750 620 490

_ _ - . _ — — — — _- - - - - - - - -- - - - - - - - -_ _ _ _ — _ — - _ •_ _ _ _ _ _ _ 4 J -_ _ _ _ _ _ _ _ _— — — — — — — — —

_ _ _ - - - - — _- - - - - - - - -- - - - - - - - -_ _ _ _ _ - - - _- - - - - - - - -— — — — — — — — —_ _ _ - - - _ - _- - - - - - - - -- - - - - - - - -- - - - - - - - -— — — — — — — — —- - - - - - - - -

Total PAIIs HA HA

TABLE S(Continued)

ARARs

no.

Other Guidance

MCtG

DW-16 Ot-lfiD Hew Will

2/25/88 2/25/88 2/9/BI


AluminumArsenicBariumChromiumCopperCyanideIronLeadMagnesium


Benzene2,4-DimethylphenolEthylbenzeneStyrenaToluene1,1,1-TrichloroethaneXylenes

PAHs (ug/1)

AcanaphtheneAcanaphthylenaAnthraceneBenzo (a) anthracenechrysaneDibenzofuranFluorantheneFluorena2-Me thyInaphthalaneNaphthalenePhananthrenaPyrene

Total PAHs

HA50

100050

1000(5)HA

300(5)50NA

5NANANANA200NA

NANANANANANANAHANANANANA

NA

NA50(P)

ISOO(P)120(P|

HANA

2 0 ( P )NA

0NA

680(P|140<P|

2000(P)200

440(P)

HANAHAHANANANAHAHAHAKANA

HA

11J39J

15000J

12 J37J

22000J

4700

16J

£40

RRRR

123NA(P)(S)

Applicable or Relevant and Appropriate Requirements (sea Risk Assessment)Federal Maximum Contaminant Level (see Risk Assessment)Federal Maximum Contaminant Level Goal (see Risk Assessment)

= Not Available; criterion has not been developed (or this chemical.= Proposed= Secondary MCL based on taste and odor

Concentration Footnotes— = The conpound was analyzed for but not detected.J = This number is estimated. The qualitative analysis ia acceptable, but the value cannot be considered as accurate.H = Presumptive evidence of presence of material. There is evidence that the material is present, but for some reason or combination of reasons, it has

not been confirmed.R = Data are rejected and are totally unusable.JN 3 The identification is tentativa and the value is istimated.* a Duplicate Sample.

LEGEND

250

SURFACE WATER/SEDIMENT SAMPLING LOCATIONS


FIGURE NO

22

-43-

TABLE 6

S1TB FACE WATER SAMPLING DATA SUMMARYCAPE FEAR WOOD PRESERVING SITEFAYETTEVILLE, NORTH CAROLINA


AluminumArsenicChromiumCoppe rIron

PAHs (ug/1)

AnthraceneDenzo ( A ) anthraceneChryseneFluoranthenePyrene

Total PAHs

SW-1 SW-2 SW-3 SW-4

AHARs 2/7/88 2/7/BB 2/7/88 2/7/88

NA - 500J 410J 700J50 - 39050 - 67J15 14J 21J 150J 160J

1,000 130J 2.400J 1.200J 340J

NA -NA -NA -NA -NA -

NA -

SW-5 SW-5D* SW-« SW-7 SW-8 SW-9

2/7/88 2/7/88 2/7/88 2/7/88 2/7/88 2/7/88

4.200J 990J 1,OOOJ 950J 930J170JN 170 310 21094J 43J 55J 39J79 J 57 J 70J 42J 20 J

4.600J 1.200J 2.600J 2.100J 610J

28J - - - -1J3J1J3J

36

800J_

59J22J

1EOJ

_----

-

- Applicable or Relevant and Appropriate Requirements (see Risk Assessment).

Footnotes= The compound was analyzed for but not detected.

J = This number is estimated. The qualitative analysis is acceptable, but theN = Presumptive evidence of presence of material. There is evidence that the i

of reasons, it has notR = Ddta ace rejected andJT1 = The identification is* = Duplicate sample.NA = Mot available; has not

been confirmed.are totally unusable.tentative and the value is estimated.

been developed for this chemical.

value cannot be considered as accurate.•aterial is present, but for some reason or combination

TABLE 7

SEDIMENT SAMPLING DATA SUMMARYGATE FEAR WOOD PRESERVING SITEFAYETTEVIliE, NORTH CAROLINA

45.tni

SD-1

2/1/s a

Inorganic Chemicals (ing/kg)

Aluninum 9SArsenic -Chroniun -Coppe r 28Iron 160Magnesium • -

PAHs (ug/kg)

Acenaphthene —Acenapthylene -AnthraceneBen 20 (a 1 anthracene -Benzo(b and/or k ) f luoranthene -Benzo(a)pyrene -Chrysene -DibenzofuranFluoranthene -Fluorene -2-Methylnaphthalena Rnaphthalene -Phenanthrene -Pyrene -

Total PAHs

Footnotes

SD-2 SD-3

2/7/88 2/1/88

22,000 2,80025JN 4.6JN660 9.4830 9.6

16,000 1,7004700

_ _-- -_- ---— —-_

25J R-

— -25J

50

SD-1

2/7/88

1,40090JN22083

810-

13J16J60J-

730J220J310J

-370J12JR--

350J

2,100

SD-4D*

2/7/88

1,500120JN330110910-

„-

<UJnoj320J130J330J

—380J

-R--

410J

1,800

SD-5 SO-S

2/7/88 2/7/88

13,000 7,500130JH160 1230 7.3

4,000 9,800160

_ _- -

720J4.500J

- —_

6.900J- —

36,000-

R R_ _— -

32,000

80,000

SD-7

2/7/88

1,500100JN11012750-

14,000-

12,0006.2QOJ

—-

8,OOQJ11,00050,00025,0001.700J790J

62,00041,000

230,000

SD-8

2/7/88

8,60016JN28IS

9,800230

_-

S3---

54J—

51J-R-—

43 J

160

SD-9

2/7/88

15,0005.8JN

171,00012,000

260

—

-—-----

40J-R--

17J

57

- = The compound was analyzed for but not detected.J = This number is estimated. The qualitativeN = Presumptive evidence of presence of uteri

of reasons, it has not been confirmed.R = Data are rejected and are totally unusableJN = The identification is tentative and the va* = Duplicate Sample.

analysis is acceptableal. There is evidence

lue is estimated.

, but thethat the

value cannot be considered asmaterial is present, but for so

accurate .•a reason or combination

Although SW-2/SD-2 samples were intended to be background samples, theanalytical results indicate otherwise. Highly elevated levels of someinorganic chemicals and the detection of PAHs, particularly in the sedimentsample, indicate that this surface water has been influenced by some sourceof contamination. It is very unlikely the source of this contamination issite-related since the SW-2/SD-2 sampling point is approximately a quarter ofa mile from the site. Because of the uncertainty associated with thesesamples, however, the analytical results were dropped from consideration asrepresenting background concentrations.

In general, analyses of the surface water and sediment samples indicatecontamination by PAHs and a few inorganic chemicals. The greatest concernslie with the drainage ditch and diked pond to the south, and the seasonalswamp to the northeast where elevated levels of aluminum, arsenic, chromium,copper, iron and PAHs were found. Elevated levels of these contaminants werealso found in the former water supply pond, the drainage ditch to the westand the concrete plant discharge pond to the southeast, but contamination inthese surface water features is not as significant.

The elevated levels of arsenic, chromium, copper and PAHs found in thesurface water and sediment samples taken near the site are most likelysite-related since these chemicals were used extensively in past woodpreserving operations at the site. Aluminum and iron contamination, however,is not expected to be site-related. The elevated concentrations of thesechemicals are most likely due to natural conditions at the site. Thesechemicals are typical components of the soils in the study area and the lowpH of surface water and groundwater in the area is probably causing them toleach from the soils into the water system where they can be easilytransported. Field measurements of pH of natural waters at the site rangedfrom 3.7 to 7.9 and averaged 5.3.

3.7 RISK ASSESSMENT SUMMARY

The chemicals of potential concern identified for the site are inorganiccompounds, polycyclic aromatic hydrocarbons (PAHs) and benzene. Theinorganic compounds include chromium and arsenic.

Due to the uncertainty of land use in and around the site, several differentland use scenarios were evaluated. The exposure pathways identified undercurrent land use conditions (keep undeveloped with minimal industrialization)are the following:

* direct contact with contaminated surface soils by childrentrespassing on the site,

* inhalation of fugitive dust originating from contaminated soil areasby site trespassers and nearby residents, and

* contact with contaminated sediments by children wading on-site inthe diked pond and drainage ditch.

-46-

Additional human exposure pathways are relevant if the future use of the siteand surrounding area becomes either more industrial or residentiallyoriented. These additional exposure pathways are:

* direct contact with contaminated surface soils by future residentsand workers,

* inhalation of fugitive dust originating from contaminated soil areasby future workers, and

* ingestion of groundwater from the upper and lower aquifers.

Because "applicable and relevant or appropriate requirements" (ARARs) are notavailable for all chemicals in all environmental media, risks were alsoquantitatively assessed for the identified exposure pathways. For lifetimeexposures (70 years), risks were estimated assuming exposure concentrationsremained constant over time. v

Estimates of risks under current land use conditions are as follows. Fordirect contact with surface soils for children trespassing onsite, thelifetime excess upper bound cancer risk is less than 1 person out of1,000,000 under the average case and 1 person out of 200,000 under theplausible maximum case. Risk under the plausible maximum case is due tocarcinogenic PAHs. For inhalation of fugitive dust by onsite trespassers,individuals of the Jackson residence and residence in the Southgatesubdivision, the lifetime excess upper bound cancer risk is less than 1person out of 1,000,000 under average and plausible maximum cases. Forchildren wading in onsite surface water and exposed to chemicals of potentialconcern in sediments, the lifetime excess upper bound cancer risk is lessthan 1 person out of 1,000,000 under average cases and 1 person out of100,000 under a plausible maximum case. No carcinogenic chemicals ofpotential concern are detected in the residential wells, therefore ingestionof drinking water by current residents with residential wells, the lifetimeexcess upper bound cancer risk is less than 1 person out of 1,000,000.

Estimates of risks under hypothetical future land use conditions are asfollows. For potential exposure associated with direct contact with the soilat the site by future residents, the lifetime excess upper bound concern riskis 1 person out of 3,000,0000 under the average case and 1 person out of1,000 under the plausible maximum case. Risks under both cases are dueprimarily to carcinogenic PAHs; under the plausible maximum case, the risk isdue to arsenic is 1 person out of 200,000. Foe direct contact with soils byfuture workers onsite, the lifetime excess upper bound cancer risk is lessthan 1 person out of 1,000,000 under average case and 1 person out of 200,000under the plausible maximum case. Risk under the plausible maximum case isdue primarily to carcinogenic PAHs; the risk from arsenic under the plausiblemaximum case is 1 person out of 3,000,000. The risk associated with exposureto chemcials at the maximum detected sample concentrations would result inlifetime excess cancer risks of 1 person out of 8,000. For inhalation offugitive dust by future workers onsite, the lifetime excess upper boundcancer risk is less than 1 person ou£ of 1,000,000 under the average and

-47-

plausible maximum cases. Ingestion of groundwater from the upper aquifer byfuture residents, the lifetime excess upper bound cancer risk is 1 person outof 4/000 under the average case and 1 person out of 6,000 under the plausiblemaximum case. And ingestion of groundwater from the lower aquifer by futureresidents, the lifetime excess upper bound cancer risk is less than 1 personout of 20,000 under the average case and 1 person out of 2,000 under theplausible maximum case.

Potential environmental impacts of the chemicals of potential concern at thesite were also evaluated. Plant and animal species potentially exposed tothe chemicals of concern at the site were identified based on a knowledge ofthe site and surrounding habitat. Risks were assessed by comparing thereported environmental concentration or the estimated dose with the selectedtoxicity value. Absolute conclusions regarding the potential environmentalimpacts at the Cape Fear Site cannot be made because there are manyuncertainties surrounding the estimates of toxicity and exposure.

The maximum concentrations of arsenic, chromium, copper and lead found in thesoils of the site exceed levels known to be phytotoxic in at least somespecies. The geometric mean concentrations of arsenic and chromium in thesoils from the processing area are close to the levels toxic to some speciesand are possibly at concentrations that are toxic to species which occur inthe area of the Cape Fear Site. Conclusions regarding adverse impacts toplants at the site are supported by the lack of vegetation across large areasof the site. Portions of the site that remain without vegetation offerlittle value as wildlife habitat and thus, the habitat value of the area isreduced.

Small mammals and deer that potentially use the surface water of the CapeFear Site as a drinking water source do not appear to be at increased risk ofadverse impacts, as the estimated intakes are well below those estimated tobe associated with toxic effects. Birds ingesting water from the northeastswamp, ditch-diked pond area, and concrete plant discharge pond may be atincreased risk of adverse impact from chromium as estimated intakes areapproximately equal to the derived toxicity value. This may be of particularconcern for red-cockaded woodpeckers, an endangered species potentiallyoccurring in the area, a loss of even a single individual could adverselyaffect reproduction (and thus, the population) of this already stressedspecies. There are, however, many uncertainties surrounding the derivationof the toxicity values and the estimated intakes and therefore, absoluteconclusions cannot be made.

Adverse impacts may also be occurring in the surface waters of the site. Theconcentrations of arsenic in the northeast swamp and the ditch-diked pondarea exceed the acute and chronic Ambient Water Quality Criteria (AWQC) forthis chemical. Chromium concentrations in the northeast swamp, theditch-diked pond area and the concrete plant discharge pond exceed the acuteand chronic AWQC. Copper concentrations exceed the acute and chroniccriteria in the water supply pond, the northeast swamp, and the ditch-dikedpond area. Aquatic species most likely impacted are insects, otherinvertebrates, and aquatic plants. It is difficult to determine the impact

-48-

of these adverse effects on the aquatic populations of the area. However,the observed levels of contaminants in some of the surface waters at the siteprobably result in an exclusion of aquatic life in these waters, or a shiftin community structure towards species more tolerant of high metalconcentrations.

4.0 CLEANUP CRITERIA

The extent of contamination was defined in Section 3.0, Current Site Status.This section examines the ARARs associated with the contaminants found onsite and the environmental medium contaminated. In the cases where nospecific ARAR can be identified, a defendable remediation goal wasgenerated. Table 8 provides a summary of the environmental mediumscontaminated , the clean-up goals for the contaminants of concern in eachmedium, and a rationale for each specified clean-up goal.

4.1 GROUNDWATER REMEDIATION

In determining the degree of groundwater clean-up, Section 121(d) of theSuperfund Amendment and Reauthorization Act of 1986 (SARA) requires that theselected remedial action establish a level or standard of control whichcomplies with all ARARs, be cost-effective and achieve a clean-up level thatis protective of human health and the environment. Finally, the remedyshould utilize permanent treatment technologies to the maximum extentpracticable.

For those contaminants found in the groundwater at the site, Table 8 presentsthe remediation levels the migration remedial alternative will achieve, at aminimum.

4.2 SOIL REMEDIATION

The Public Health and Environmental Assessment in the RI (Chapter 4),determined that risks to human as a result of exposure to on-sitecontaminants via inhalation, ingestion and dermal contact are very low underpresent Site conditions. For potential future use scenarios, the risk isslightly higher. Therefore, remediation and institutional controls will benecessary to assure that an increased risk to human health is not posed inthe future.

Table 8 presents clean-up remediation levels that the source remediationalternative will achieve.

-49-

TABLE 8

SUMMARY OF CONTAMINATED MEDIA AND CLEANUP GOALSCAPE FEAR WOOD PRESERVING SITEFAYETTEVILLE, NORTH CAROLINA

Media

Site Related ContaminantsExceeding ARARs, RiskAssessment Values, or Clean UpEnvironmental Criteria Goals

Rationalefor Clean Up

Goals

Ground Water BenzenePAHs (carcinogenic)PAHs (noncarcinogenic)

Surface Water ArsenicChromiumCopper

(total)

Soil

Sediment

ArsenicBenzene - Leachate CaseChromium (total) -Leachate Case

PAHs (carcinogenic)PAHs (total)

PAH (total)ArsenicChromium (total) -Leachate Case

ug/liter

510

14,350

ug/liter

121114

mgAg

940.005

882.5

100

mgAg3.094

88

abc

dde

c, fb

gc, hi

k

(a) ARAR - Maximum Contaminant Level (MCL).

(b) The Contract Laboratory Required Quantitation Limit (CLRQL) isproposed since the calculated risk assessment value is below analyticaldetection limits. Should the CLRQL reduce with time as analyticalprocedures improve, the new (lower) CLRQL would become the cleanupgoal.

(c) Value derived using reverse risk assessment techniques.

-50-

TABLE 8{continued)

(d) ARAR - Ambient Water Quality Criteria.

(e) The goal epresents background conditions since the Ambient WaterQuality Criteria Concentration (6.5 ug/1) is below background.

(f) The future use worker scenario is used since this is the more likelyfuture land use and arsenic is not posing a significant risk undercurrent use conditions.

(g) The goal represents site background conditions (maximum of the rangeobserved) since the calculated risk assessment value is belowbackground levels.

(h) The value listed represents a current use scenario since this is moreconservative than the levels derived for the future use workerscenario.

(i) Value is based on typical background concentrations (from theliterature) since the calculated level necessary to preventfuture leachate from exceeding a hazard index of 1 in ground water(60 mg/kg) is less than representative background conditions.

(j) Concentration researched by EPA to be protective of aquatic biota.

(k) The same value proposed for soils is applied due to a similar humanexposure route, and low expected impact to surface water on avolumetric basis.

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4.3 SURFACE WATER/SEDIMENT REMEDIATION

The following areas have been targeted for remediation: the water supplyroad, the northeast seasonal swamp, the drainage ditch south and west of therailroad tracks, the diked pond and the drainage ditch. The level ofclean-up for the surface waters and sediment are also stated in Table 8.

5.0 ALTERNATIVES EVALUATED

The purpose of the remedial action at the Cape Fear Site is to minimize, ifnot mitigate contamination in the soils, groundwater, and surface waters andsediment and to reduce, if not eliminate, potential risks to human health andthe environment. The following clean-up objectives were determined based onregulatory requirements and levels of contamination found at the Site:

* To protect the public health and the environment from exposure tocontaminated on-site soils through inhalation, direct contact, anderosion of soils into surface waters and wetlands;

* To prevent off-site movement of contaminated groundwater; and

* To restore contaminated groundwater to levels protective of humanhealth and the environment.

Table 9 provides a list of possible remedial technologies applicable at theCape Fear Site knowing the environmental media affected, the type ofcontaminants present and the concentration of each contaminant in eachenvironmental medium. Table 10 lists those technologies retained after theinitial screening. This initial screening evaluates the technologies on thefollowing technical parameters:

* implementability,

* reliability and effectiveness, and

* previous experience.

These technologies address soils/sediments, surface water and groundwater andthe hazardous material, tanks and piping and best meet the criteria ofSection 300.65 of the national Contingency Plan (NCP).

Following the initial screening of the individual technologies, thesetechnologies were combined to form a number of remedial action alternatives.These alternatives address the contaminated soils and sediments, surfacewater and groundwater, and hazardous materials, tanks and piping, and arelisted in Tables 11 through 13, respectively. These remedial actionalternatives are than screened and analyzed in relation to the nine pointcriteria.

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TABLE 9

POSSIBLE REMEDIAL TECHNOLOGIES FOR SOILAND SEDIMENTS AND GROUNDWATER AND SURFACE HATER

Response Action Technology

SOIL AND SEDIMENTS

Removal ExcavationSediment Dredging and Dewatering

Treatment AttenuationWashingFlushingImmobilizationBiodegradationThermal ProcessingIncineration

Containment/ CappingMigration Control On-site Encapsulation/Landfill

Solidification/StabilizationVitrificationSubsurface BarriersOff-site Landfill

GROUNDWATER AND SURFACE WATER

Collection Extraction WellsSubsurface Drains

Treatment Air StrippingSteam StrippingAerationSpray IrrigationVacuum ExtractionFlocculation, Sedimentation, FiltrationActivated Carbon AdsorptionPrecipitationIon ExchangeReverse Osmosis

-*

Disposal Discharge to Surface WaterPublicly Owned Treatment Works PlantAquifer Recharge

-53-

TABLE 10

RETAINED TECHNOLOGIES, APPLICABLE MEDIA, ANT) CONTAMINANTSCONSIDERED FOR ALTERNATIVES DEVELOPMENT


Media

Soil/Sediraent

Response Action

Removal

Containment

Remedial Technology

Excavation

Dredging

Capping

Applicable to

Soils > cleanup goals.

Sediments > cleanup goals.

Soils and dewatared sediments, all contaminants of interest:

Treatment Washing

Thermal Processing

Solidification/stabilization

As, benzene, Cr, PAIIs.

Soils and sediments, all contaminants of interest:As, benzene, Cr, PAHs.

Soils and sediments, organic contaminants: benzene and PAHs.

Soils and sediments with As and Cr contamination.

Ground water/surface water

Removal

Treatment

Discharge

Well Paints

Deep Well

Pumping

Flocculation, sedimentation,and filtration

Carbon Adsorption

Air Stripping

Precipitation

To surface water

To POTW

Upper aquifer, extraction of ground water > cleanup goals.

Lower aquifer, extraction of ground water > cleanup goals.

Transfer of ground water and surface water > cleanup goals.

Particulate removal in ground water and surface water inassociation with other treatment technologies (carbonadsorption, precipitation).

Removal of organic and some inorganic constituents in groundwater and surface water.

Removal of volatile organics (benzene) from ground water.(

Removal of metals {As, total Cr, Cu) from surface water andonsite wastewater.

Treated effluent.

Pretreated effluent.

TABLE 10(Continued)

Media Response Action Remedial Technology Applicable to

Icneni

Hazardous Materials,Tanks, and Piping

Removal

Containnent

Treatment

Disposal

Excavation

Containerization

Offsite Transport

Solidification/stabilization

Reduction

Precipitation

Offsite Landfill

Scrap Metal

Pipelines and the underground fuel tank.

Apparent CCA crystals, assumed asbestos insulation, creosote-contaminated solidified sludge, CCA solution.

CCA solution.

Creosote-contaminated solidified sludge.

CCA solution and CCA wastewater, Cr treatment if necessary.(Reduction of Cr to Cr .)

CCA solution, CCA contaminated wastewater, and surface watertreated onsite.

Apparent CCA crystals, assumed asbestos insulation, creosote-contaminated solidified sludge, CCA solution, CCA contaminatedwastawater, tanks and piping.

Tanks and piping.

As = ArsenicCr g = Chromium (total)Cr = Hexavalent chromiumCu = CoppperPAH = Polycyclic aromatic hydrocarbons

TABLE 11

DEVELOPMENT OF REMEDIAL ACTION ALTERNATIVESFOR SOILS/SEDIMENTS


Alternative Technologies Employed

IS* No actionNatural flushing

2S Excavate isolated areas of soil contaminationExcavate/dredge sedimentsDewater dredged sedimentsCap soils and dewatered sediments

3S Excavate/dredge soils and sedimentsWash excavated materials onsiteWater supply source:

A. Purchase from Fayetteville Public Works Commissionand truck to the site.

B. Purchase from a private water company and pipeto the site.

C. Install an onsite well outside the contaminantplume area.

Redeposit washed soils/sediments in the excavated area

4S Excavate/dredge soils/sedimentsDewater dredged sedimentsThermal process excavated materialsSolidify/stabilize processed soils/sediments andredeposit in the excavated area.

S denotes remedial alternative for soil/sediment.

-56-

TABLE 12

DEVELOPMENT OF REMEDIAL ACTION ALTERNATIVESFOR GROUND WATER AND SURFACE WATERCAPE FEAR WOOD PRESERVING SITEFAYETTEVILLE, NORTH CAROLINA


1W* NO actionLong-terra ground water monitoring

2W Ground water extraction by well points and a deep wellFlocculation, sedimentation, and filtration(surface and ground water)

Activated Carbon Adsorption (surface and ground water)Discharge treated effluent to surface water (western ditch)

3W Ground water extraction by well points and a deep wellFlocculation, sedimentation, and filtration(ground water and surface water)

Air stripping (ground water)Activated carbon adsorption (surface and ground water)Discharge treated effluent to surface water (western ditch)

4W Ground water extraction by well points and a deep wellGround water treatmentFiltrationAir StrippingActivated carbon adsorption

Surface water treatmentPrecipitationFlocculation, sedimentation, and filtration

Discharge treated effluent to surface water (western ditch)

5W Ground water extraction by well points and deep well(s)PretreatmentPrecipitation, (surface arid ground water)Flocculation, sedimentation, and filtration (surfaceand ground water)

Discharge to POTW

W denotes remedial alternative for ground water or surface water.

-57-

TABLE 13

DEVELOPMENT OF REMEDIAL ACTION ALTERNATIVESFOR HAZARDOUS MATERIALS, TANKS, AND PIPING


Material Alternative Technologies Employed

Apparent CCA Crystals

Asbestos Insulation* *(Assumed)

Solidified Sludge

CCA Wastewater and/orCCA 3% Solution

Tanks and Piping

1C

1A

1SS2SS

1L

2L

3L

1T/P + 2T/P

1T/P

2T/P

Offsite landfill (hazardous).

Offsite landfill (nonhazardous)

Onsite disposal.Offsite landfill (hazardous).

Treat wastewater and solutiononsite for Cr*6.

Treat wastewater and solutiononsite with surface waters-

Treat wastewater and solutionoffsite.

Transport CCA solution offsite.

Locate (Piping)Empty (Tanks)Excavate (UST and Piping)Drain/Purge (Piping)Clean (Tanks and Piping)Cut (Tanks and Piping)

Dispose of as:Scrap metal

at an offsite landfill(nonhazardous)

*C denotes Crystals (apparent CCA)A denotes Asbestos (assumed)SS denotes Solidified SludgeL denotes Liquid (CCA Wastewater and/or CCA 3% Solution)T/P denotes Tanks/Piping

Based on visual characterization. These materials were not sampled.

UST - Underground Storage Tank.

-58-

5.1 NINE POINT EVALUATION CRITERIA FOR EVALUATING REMEDIAL ACTIONALTERNATIVES

Each alternative was evaluated using a number of evaluation factors. Theregulatory basis for these factors comes from the National Contingency Plan(NCP) and Section 121 of SARA. Section 121(b)(l) states that, "Remedialactions in which treatment which permanently and significantly reduces thevolume, toxicity or mobility of the hazardous substances, pollutants andcontaminants as a principal element, are to be preferred over remedialactions involving such treatment. The offsite transport and disposal ofhazardous substances or contaminated materials without such treatment shouldbe the least favored alternative remedial action where practicable treatmenttechnologies are available."

Section 121 of SARA also requires that the selected remedy be protective ofhuman health and the environment, cost-effective and use permanent solutionsand alternative treatment technologies or resource recovery technologies tothe maximum extent practicable.

Based on the statutory language and current U.S. EPA guidance, the ninecriteria used to evaluate the remedial alternatives listed above were:

1. Overall Protection of Human Health and the Environment addresseswhether or not the remedy provides adequate protection and describeshow risks are eliminated, reduced or controlled through treatment,engineering controls, or institutional controls.

2. Compliance with ARARa addresses whether or not the remedy will meetall of the applicable or relevant and appropriate requirements ofother environmental statues and/or provide grounds for invoking awavier.

3. Long-Term effectiveness and permanence refers to the ability of aremedy to maintain reliable protection of human health and theenvironment over time once cleanup goals have been met.

4. Reduction of toxicity, mobility, or volume is the anticipatedperformance of the treatment technologies a remedy may employ.

5. Short-term effectiveness involves the period of time needed toachieve protection and any adverse impacts on human health and theenvironment that may be posed during the construction andimplementation periods until cleanup goals are achieved.

6. Implementabilitv is the technical and administrative feasibility of aremedy including the availability of goods and services needed toimplement the chosen solution.

7. Cost includes capital and operation and maintenance costs.

-59-

8. Support Agency Acceptance indicates whether, based on its review ofthe RI/FS and Proposed Plan, the support agency (IDEM) concurs,opposes, or has no comment on the preferred alternative.

9. Community Acceptance indicates the public support of a given remedy.This criteria is discussed in the Responsiveness Summary.

5.1.1 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT

All of the alternatives, with the exception of the no action alternative,would provide adequate protection of human health and the environment byeliminating, reducing, or controlling risk from the environment throughtreatment, engineering controls or institutional controls. As the no actionalternative does not satisfy the remedial action goal to provide adequateprotection of human health and the environment, it is not eligible forselection. The aspects considered in this evaluation are summarized inTable 14.

5.1.2 COMPLIANCE WITH ARARS

All of the alternatives, except for the no action alternative, would meet allapplicable or relevant and appropriate requirements of Federal and Stateenvironmental laws. Section 6.6 (Table 21) lists the environmentalregulations, policies and guidelines that are applicable to the Cape Fearsite. Table 15 presents a summary of this evaluation.

Since all contamination on site is characterized as contaminted soil anddebris and there is no RCRA characterized waste on-site, land banrequirements, as defined in 40 CFR 268, are not applicable at the Cape Fearsite.

5.1.3 LONG-TERM EFFECTIVENESS AND PERMANENCE

The aspects of this evaluation are summarized in Table 16 under the columnentitled "Long Term Remediation Impact.

5.1.4 REDUCTION OF TOXICITY. MOBILITY. OR VOLUME

The aspects of this evaluation are also summarized in Table 14 under thecolumn entitled "Long Term Remediation Impact".

5.1.5 SHORT-TERM EFFECTIVENESS

The aspects of this evaluation are summarized in Table 16 under the columnentitled "Short Term Remediation Impact".

-60-

TABLE lM

SUMMARY OF REMEDIAL ALTERNATIVES EVALUATIONCAPE FEAR HOOD PRESERVING SITEFATETTEVILLE, HQRTH CAROLINA

Icn

Public Health and EnvironmentalConsiderations

Remedial Alternative

IS:

2S:

No action

Partial excava-tion/dredgingof soils andsedimentswith surfacecapping

TechnicalConsiderations

Does not remove orcontain contaminants.

Contaminants arestored, not destroyedor removed. This isan effective processto prevent directcontact with contami-nated materials andminimize verticalinfiltration. Con-taminated soils belowthe ground water tableare not addressed.

Short TarmRemediation Impact

Not applicable.

Dust releases duringexcavation and dis-placement of aquaticbiota due to dredgedsediments . Endangeredplant species (ifpresent) could also bedisturbed.

Long TermRemediation Impact

Not applicable.

Decrease in contami-nant mobility andreduction of directcontact risk.

InstitutionalConsiderations

Future land useand deed

« restrictions.

Future land useand deedrestrictions.

Estimated Cost (Millions $)Time For Total Range Based

Implementation Present on Sensitivity(years) Worth Analysis

0 0 0

0.75 2.80 2.29-3.30

Excavation/dredging withsoil and sedimentwashing

Soil/sediment washingis considered to bean innovative tech-nology for hazardousapplications. Th»ability to meet cleanupgoals for organic andinorganic contaminantsmust be demonstrated bytreatability testing.Promising results havebeen obtained for PAHs.CCA will be more diffi-cult to remove.

Dust releases duringexcavation and dis-placement of aquaticbiota due to dredgedsediments. Endangeredplant species (ifpresent) could alsobe disturbed.

Decreases in con-taminant mobilityand volume, reduceddirect contact risk,and re<iuced leachingto ground water/surface water.

Future develop-ment allowed.

1.5 11.00 4.30-20.01

TABLE IM( Continued )


Technical Short Term Long Term InstitutionalRemedial Alternative Considerations Remediation Impact Remediation Impact Considerations

4S: Excavation/ This combination of Potential air emissions Decreases contami- Future devalop-dredging of technologies i» expect- during thermal process- nant H/T/V. Direct ment allowed.

Estimated Cost (Millions $1Time For Total Range Based


1.5 14.03 5.67-26.14

CT>roi

soils/sedimentswith thermalprocessing and/orsolidification

ed to exceed cleanupgoals since separatetreatment is providedfor organic andinorganic contaminants.A laboratory "burn"would be required toestablish operatingparameters. Laachatetesting would berequired Cor solidi-fied materials. Vol-ume increase fromsolidification may beobjectionable.

ing could contain toxicgases (metal oxides).Displacement ofaquatic biota andendangered plantspecies (if present)during excavation/dredging.

contact risk andcontaminant leachingto surface and groundwater should begreatly reduced.

GROUND WATER AND SURFACE WATER ALTERNATIVES

1W: No actionI/ong-Ten»Monitoring

Does not remove orcontain contaminants.ARARs are exceeded.Monitors offsitecontaminant migration.

Not applicable. Not applicable. Deed restrictionfor consumptiveground water use.

30(monitoring)

0.59 N/A

TABLE 1H(Continued)

IcnOJi


TechnicalRemedial Alternative Considerations

2W: Flocculation, It is expected thatSedimentation, cleanup goals for PAHsFiltration will be met. Contaau-Carbon Adsorption nant concentrationsDischarge to for benzene, copper.Surface Water chromium and arsenic

will be reduced butmeeting ARARs is lesscertain. Testing wouldbe required to assessthe achievable contami-nant reductions . Re-covery of the fullground water plume willrequire offsite access/easements.

Short TermRemediation Impact

Sludge generationand elimination ofexisting aquaticbiota (if present)during surface waterremediation.

Long Term InstitutionalRemediation Impact Considerations

Reduced public NPDES permit forhealth risk associ- surface waterated with ingestion. discharge.Reduced toxicity toaquatic biota and thered— cockaded wood-pecker, an endangeredspecies.

Estimated Cost (Millions S)Time For Total Range Based

Implementation • Present on Sensitivity(years) Worth Analysis

3.6 3.40 3.25-3.83

3W: Flocculation,Sedimentation,FiltrationAir StrippingCarbon AdsorptionDischarge toSurface Water

Cleanup goals for PAHsand benzene shouldbe mat. As withAlternative 2W, finalCCA removal efficien-cies Must be demon-strated throughtesting. Recovery ofthe full ground waterpluM will requireoffsite access/easements.

Sludge generation,elimination ofexisting aquatic biota(if present), and airMissions containingvolatile organiccontaminants.

Reduced publichealth risk associ-ated with ingestion.Reduced toxicity toaquatic biota and thered-cockaded wood-pecker, an endangeredspecies. Greaterdegree of riskreduction (than 2W)achieved by VOCtreatment.

NPDES permit forsurface waterdischarge.

3.6 3.42 3.22-3.86

-p=»I

TABLE 1H

(Continued)



4W: Surface WaterPrecipitationFlocculation,Sedimentation ,Filtration

Ground WaterFiltrationAir StrippingCarbon AdsorptionDischarge toSurface Water

5W: Flocculation ,Sedimentation,FiltrationDischarge toPOTW

TechnicalConsiderations

All cleanup goals andARARs should be mat.Recovery of the fullground water plumewill require offsiteaccess/easements.

All cleanup goalsshould be met. Themost cost-effectivepretreatment processshould be determinedby treatabilitytesting. Recovery ofthe full ground waterplume will requireoffsite access/easements . Pipingto POTW will alsorequire easements.

Short TenRemediation Impact

Sludge generation andelimination of•xisting aquatic biota(if present), duringsurface waterremediation.

Sludge generation andelimination ofexisting aquatic biota(if present), duringsurface waterremediation.

Long Term InstitutionalRemediation Impact Considerations

Greater degree of IfPDES permit forrisk reduction than surface water2W or JW because discharge.treatment dis-tinguishes betweendifferent contami-nants in groundwaterand surface waterrespectively (organicvs. inorganic).

Greatest degree of Local POTW mustrisk reduction. accept siteContaminated ground wastewaters.water and surfacewater are extracted.Effluent is directto POTW rather thansite surface water.

Estimated Cost (Millions $1Time For Total Range Based


3.» 3.65 3.57-4.14

3.6 3.14 2.84-3.51

TABLE 14'(Continued)


Tedbmlcal Short Term Long Term InstitutionalRemedial Alternative Considerations Remediation Impact Remediation Impact Considerations

EstimatedTime For

Implementation(years)

Cost ($)

Present on SensitivityWorth Analysis

cni

1C: Offsite landfill(hazardous) ofappa rent CCAcrystals

1A: Offsite landfill(nonhazardousI ofassumed asbestosinsulation

IBS: Onsite disposalof solidifiedsludge

2SS: Offsite disposalof solidifiedsludge

Eliminates the risk ofonsite exposure.

Worker exposure duringremoval.


Marker exposure duringremoval.

Direct contact riskreduced in associationwith a cap. Solidifi-cation should limitmobility but thematrix may looseintegrity over time.




Reduced ingestion/direct contact riskto wildlife andpotential humanexposure. Effectivecontainment dependson integrity of theRCHA facility.

Reduced ingestion/direct contact riskto wildlife andpotential humanexposure. Effectivecontainment dependson integrity of theRCBA facility.

Reduced directcontact risk towildlife and humanexposure.

Reduced directcontact risk towildlife and humanexposure. Effectivecontainment dependson integrity of theRCHA facility.

Hazardous waste 0.1manifest andtransport by *licensed haulerto permitted RCRAfacility.

Manifest and transport 0.1by licensed haulerto permitted RCRAfacility.

Future land use 0.1restrictionspossible.

Hazardous waste 0.1manifest. Transportby licensed haulerto permitted RCRAfacility.

9,600 (I/A

13,500 N/A

27,700 N/A

28,900 N/A

cnen

TABLE 1M(Continued)


1L:

2L:

Onsite treatmentof CCA solutionand/or wastewaterwith discharge tosurface water

Offsite transportand treatment ofCCA solutionand/or wastewater

technicalConsiderations

Expected to BeetARARs. High contami-nant concentrationswill pose specialconsiderations tomeet NFDCS or PCrtWrequirements.



Short TermRemediation Impact

Sludge generationduring treatment.

Accident risk due tooff site shipment (12tanker trucks withhazardous liquids 1 .

Long TentRemediation lapact

Reduced spillpotential andcontaminantmigration.

Reduced spillpotential andcontaminantmigration.Effective contain-ment depends onintegrity of theRCRA facility.

Estimated Cost ($1Time For Total

Institutional Implementation- PresentConsiderations (years) Worth

HPDES permit 0.1 104,000or acceptance byPOTW.

Hazardous waste 0.1 126,100manifest. Transportby licensed haulerto permitted RCRAfacility.

Range Basedon SensitivityAnalysis

If/A

N/A

3L: Offsite transportof CCA solution.

1T/P: Removal andcleaning oftanks and piping

Recycle as scrap(sail)

2T/P: Removal andcleaning oftanks and piping

Dispose ofoffsite in anonhazardouslandfill

Recycles CCA solution.CCA contaminatedwastewater would betreated on or offsite(Alternatives 1L or2L>.

Eliminates wastedisposal concerns.

Removes old tanks andpiping from the site.

Accident risk dueto offsite shipment(10 tanker truckswith hazardousliquids).

Contaminated watergenerated in washprocess. Potentialair release ofvolatile contaminantsduring excavation.

Contaminated watergenerated in washprocess. Potentialair release ofvolatile contaminantsduring excavation.

Reduced spillpotential andcontaminantmigration onsite.



Liability waiver under 0.1 25,500 N/ACERC1A must be granted.Effective spillprevention, control,and counte measureswould be required atthe relocationfacility.

EPA certification 0.1 (112,400) N/Athat tanks arenonhazardous.

Manifest and transport 0.1 87,900 N/Aby a licensed haulerto permitted RCRAfacility preferred.

TABLE |5

SUMMARY OF INSTITUTIONAL AND LAUD USE HESTRICTIOHSCAPE FEAR HOOD PRESERVING SITEFAYETTEVILLE, NORTH CAROLINA

ICTi

REMEDIAL ALTERNATIVE FENCING11'

ACTIVITIESDEED

RESTRICTIONS LAND USELAND

DEVELOPMENTGROUNDWATER USE

SOIL AND SEDIMENT ALTERNATIVES

IS:

2S:

3S :

4S:

No Action Yes

Surface Cap Yes

Washing Yes

Thermal Piocessing and/or Solidification Yes

Yes Yes

Yes Yes

No N6

No No

Yes

No

No

No

N/A

N/A

N/A

N/A

GROUND WATER AND SURFACE WATER ALTERNATIVES

1W:

2W:

3W:

4W:

5W:

No Action Yes

Pretreat and GAC Yes

2W and Airst ripping Yes

Segregated SW and GW Treatment Yes

Pretreatment and Discharge to POTW Yes

Yes N/A

No N/A

No N/A

Ho N/A

No N/A

N/A

N/A

N/A

N/A

N/A

Yes

No

No

No

No

Fencing restrictions apply to the period of remediation only (except for no action).

Yes = Restrictions ApplyNo = No restrictions after remediation assuming that ARABS or cleanup goals are met.N/A = Not Applicable

TABLE Ig

SUMMARY OF THE PUBLIC HEALTH AND ENVIRONMENTAL EFFECTS EVALUATIONCAFE FEAR WOOD PRESERVING SITEFAYETTEVILLE, NORTH CAROLINA

REMEDIAL ALTERNATIVE SHORT-TERM REMEDIATION IMPACT LONG-TERM RISK REDUCTION

CDro

SOIL AMD SEDIMENT ALTERNATIVES

IS: No Action

2S: Surface Cap

3S: Washing

4S: Thermal Processing andSolidification

GROUND HATER AND SURFACE WATER ALTERNATIVES

1W: No Action

2W: Pretreat and GAC

3W: 2W and Airstripping

4W: Segregated SW andGW treatment

Not applicable

Dust releases during excavation and displace-ment of aquatic biota due to dredged sediments.Endangered plant species (if present)would be disturbed.

Dust releases during excavation and displace-Bent of aquatic biota due to dredged sediments.Endangered plant species (if present) wouldbe disturbed.

Potential air emissions during thermalprocessing could contain toxic gases(metal oxides). Displacement of aquaticbiota and endangered plant species (ifpresent) during excavation/dredging.

Not applicable

Sludge generation and elimination of existingaquatic biota (if present) during surfacewater remediation.

Sludge generation, elimination of existingaquatic biota (if present), and air emissionscontaining volatile organic contaminants.

Sludge generation and elimination of existingaquatic biota (if present) during surfacewater remediation.

Not applicable

Decrease in contaminant mobility and reductionof direct contact risk.

Decreases in contaminant mobility and volume,reduced direct contact risk, and reducedleaching to ground water/surface water.

Decreases contaminant N/T/V. Direct contactrisk and contaminant leaching to surface andground water should be greatly reduced.

Not applicable

Reduced public health risk associated withingestion. Reduced toxicity to aquatic biotaand the red-cockaded woodpecker, an endangeredspecies.

Reduced i .tilic health risk associated withingestion. Reduced toxicity to aquatic biotaand the red-cockaded woodpecker, an endangeredspecies. Greater degree of risk reduction (than2W) achieved by VOC treatment.

Greater degree of risk reduction than 2W or 3Wbecause treatment distinguishes betweendifferent contaminants in groundwater andsurface water respectively (organic vs.inorganic)

TABLE 16

(continued)

REMEDIAL ALTERNATIVE SHORT-TERM REMEDIATION IMPACT LONG-TERM RISK REDUCTION

5W: Pretreat and POTW Sludge generation and elimination of existingaquatic biota (if present) during surfaceuat«r remediation.

Greatest degree of risk reduction. Contaminatedground water and surface vater are extracted.Effluent is direct to POTW rather than sitesurface water.

CTlU3I ,

HAZARDOUS MATERIALS, TANKS AND PIPING

1C and 1A: Offsite disposal of CCACrystals and Asbestos Insulation

1SS: Onsite disposal of solidified sludge

2SS: Offsite disposal of solidified sludge

1L: Onsite Treatment of CCA Solutionand wastewater

2L: Offsite Disposal of CCA Solutionand wastewater

3L: Offsite Transport of CCA Solution

1T/P: Sell cleaned tanks/piping for scraps

2T/P: Dispose of cleaned tanks andpiping offsite

Worker exposure during removal.



Sludge generation during treatment.

Accident risk due to offsite shipment(12 tanker trucks with hazardous liquids).

Accident risk due to offsite shipment(10 tanker trucks with hazardous liquids).

Contaminated water generated in wash process.Potential air release of volatilecontaminants during excavation.

Contaminated water generated in wash process.Potential air release of volatilecontaminants during excavation.

Reduced ingestion/direct contact risk towildlife and potential human exposure.Effective containment depends on integrity ofthe RCRA facility.

Reduced direct contact risk to wildlife andhuman exposure.

Reduced direct contact risk to wildlife andhuman exposure. Effective containment dependson integrity of the RCRA facility.

Reduced spill potential and contaminantmigration.

Reduced spill potential and contaminantmigration. Effective containment dependson integrity of the RCRA facility.

Reduced spill potential and contaminantmigration onsite.



TABLE (7

IMPLEMENTABILTR EVALUATIONCAPE FEAR MOOD PRESERVING SITE

FAYETTEWIIXE. WORTH CAROLINA

REMEDIAL ALTERNATIVE CONSTRAINTS TO IMPLEMENTATIOHESTIMATED

TIME REQUIRED

O

SOIL AMD SEDIMENT ALTERNATIVES

IS: No Action

25: Surface Cap

35: Washing

4S: Thermal Processing andSolidification

GROUND WATER AMD SURFACE HATER ALTERNATIVES

1W: No Action

2W: Pretreat and GAC,3W: 2W and Airstripping, and4W: Segregated SW and GW

5W: Pretreat and POTW

HAZARDOUS MATERIALS, TANKS AMD PIPIMG

1C and LA: Offsite disposal of CCACrystals and Asbestos Insulation

1SS: Onsite disposal of solidified sludge

2SS: Offsite disposal of solidified sludge

1L: Onsite Treatment of CCA Solutionand/or wastewater

2L: Offsite Disposal of CCA Solutionand/or wastewater

3L: Offsite transport of CCA Solution

1T/P: 5*11 cleaned tanks/piping for scrap

2T/P: Dispose of cleaned tanks andpiping offsite

Sot applicable

More extensive clearing and grubbing Bay be required outside the process area

Implementation will depend on favorable results of treatability testing anduse of non-toxic, non—hazardous surfactants.

Effectiveness oust be demonstrated by treatability testing. The increasedvolume created by solidification may be objectionable.

Rot applicable

Recovery of the full extent of the estimated ground water pluma will requireoffsite property easements/approval. Treatability testing would be requiredto demonstrate ultimate effectiveness.

The recovery constraint for alternatives 2W-4W also applies. The POTW mustaccept the wastewater.

Hone

Selection of Alternative 2s or 4S for soils and sediments.

Hone

Selection of Alternative 4W or 5W for surface water treatment.

Hone

A liability waiver under CEBCIA is rquired.

Tanks must be EPA certified as non-hacardous.

Hone

Not applicable

9.3 wraths

l.S years

1.5 years

Not applicable

3.6 - 3.8 years

3.6 years

1 month

1 month

1 month

1 month

1 month

1 month

1 month

1 month

TABLE IB

SUMMARY OF PRESENT WORTH COSTSFOR HAZARDOUS MATERIALS, TANKS AND PIPING


TOTAL PRESENT WORTH COST*1'

1C:

1A:

Off site landfill (hazardous) ofapparent CCA crystals

Off site landfill (non-hazardous) of

$

$

9,600

13,500assumed asbestos insulation

1SS: Onsite disposal of solidified sludge $ 27,700

2SS: Offsite disposal of solidified sludge $ 28,900

1L: Onsite treatment of CCA solution and/or $ 104,000wastewater discharge to surface water

2L: Offsite transport and treatment of $ 126,100of CCA solution and/or wastewater

3L: Offsite transport of CCA solution $ 25,500

1T/P: Removal and cleaning of tanks and piping ($ 112,400)Recycle as scrap (sell)

2T/P: Removal and cleaning of tanks and piping $ 87,900Dispose of offsite in non-hazardous landfill

(1) The total present worth is based on capital costs since remediation isone-time and does not involve O&M.

($) Indicates negative cost - cash flow payment.

-71-

TABLE tl

SUMMARY OF SENSITIVITY ANALYSIS FOR SOIL AND SEDIMENT ALTERNATIVESCAPE FEAR WOOD PRESERVING SITEFAYETTEVILLE, NORTH CAROLINA

REMEDIAL ALTERNATIVE

IS:

2S:

3S:

4S:

No action

Partial excavation/dredging of soils and sedimentswith surface capping

Excavation/dredging with soil and s«di»ent washing

Excavation/dredging of soils/sedi»«nts withthermal processing and/or solidification

Average Cost Hinioua Cost MaxiBua Cost(SI. 000) ($1,000) ($1,000)

0 0 0

2,803 2,289 3,300

10,995 4,300 20,009

14,029 5,671 26,143

11) The same as total present worth costs from Table 5—1.

TABLE ID

SUMMARY OF SENSITIVITY ANALYSIS FOR GROUND WATER AND SURFACE WATER ALTERNATIVESCAPE FEAR WOOD PRESERVING SITE

FAYETTEVILLE, NORTH CAROLINA

REMEDIAL ALTERNATIVEAverage Cost

(Si.ooo)(1) Minimum Cost

($1,000)Maxi«u« Cost(SI.000)

OJI

iW: No actionLong-Terro Monitoring

2W: Flocculation, Sedinentation, FiltrationCarbon AdsorptionDischarge to Surface Water

3W: Flocculation, Sedimentation, FiltrationAir StrippingCarbon AdsorptionDischarge to Surface Water

4W: Surface WaterPrecipitationFlocculation, Sedimentation, Filtration

Ground WaterFiltrationAir StrippingCarbon Adsorption

Discharge to Surface Water

5W: Flocculation, Sedimentation, FiltrationDischarge to POTW

592

3,398

3,426

3.656

S92

3,248

3,225

3,571

592

3.826

3,861

4,140

3,140 2,842 3,522

(1) The same as total present worth costs from Table 5-2.

Minimum = filtrationAverage - flocculation, sedimentation, filtrationMaximum - ptecipitation, flocculation, sedimentation, filtration

5.1.6 IHPLEMENTABILITY

Table 17 presents a. summary of the evaluation performed on the constraints toimplementation.

5.1.7 COST

Summaries of present worth costs including the minimum and maximum costsgenerated by a sensitivity analysis for these alternatives is given in Tables18 through 20. The uncertainity considered in the sensitivity analysis wasthe volume. Volume for each contaminated environmental medium. Nosensitivity analysis was conducted for the hazardous materials, tanks andpiping alternatives.

5.1.8 STATE ACCEPTANCE

The State of North Carolina supports the alternative stated in theDeclaration and Section 6.0. The state of Carolina recognizes the 10% costshare and operation and maintenance responsibilities associated with thisalternative.

5.1.9 COMMUNITY ACCEPTANCE

The Agency conducted a Public Meeting on February 21, 1989 at theSeventy-First Senior High School Auditorium in Fayetteville, North Carolina.The Agency discussed the findings of the RI, reviewed the evaluation ofremedial technologies and remedial action alternatives as presented in theDraft Final Feasibility Study dated December 16, 1988 and presented theAgency's preferred remedial action alternative. The meeting initiated athree week comment period. Besides the questions addressed at the publicmeeting, no additional comments/guestions/concerns were received by theAgency.

Community acceptance is assessed in the attached Responsiveness Summary. TheResponsiveness Summary provides a thorough review of the public commentsreceived on the RI, FS, Proposed Plan, and U.S. EPA's responses to thecomments received.

6.0 RECOMMENDED ALTERNATIVE

6.1 DESCRIPTION OF RECOMMENDED REMEDY

Description of Selected Remedy

Prior to initiating any remedial action on-site, a site survey will beconducted to determine the presence of any endangered plant species existon-site.

-74-


Off-site disposal of sodium dicromate - copper sulfate - arsenicpentoxide (CCA) salt crystals, the solidified creosote andasbestos-containing pipe insulation. The CCA crystals and solidifiedcreosote will be disposed of at a RCRA permitted landfill. Theasbestos-containing pipe insulation will be disposed of at the CumberlandCounty Solid Waste Facility pursuant to the facilities specifications.

The tanks and associated piping, above and below ground, will be emptied,flushed and cleaned, including triple rinsing, to render the metalnon-hazardous. The metal will then be cut and either sold to a localscrap metal dealer or disposed of at the Cumberland County Solid WasteFacility. For those tanks and/or piping that cannot be cleanedsufficiently to render them non-hazardous will be transported to a RCRApermitted landfill for disposal.

The contents of the tanks and associated piping contains approximately50,000 gallons of 3 percent CCA solution and 15,000 gallons of CCAcontaminated wastewater. A buyer of the 50,000 gallons of 3 percent CCAsolution will first be pursued. If no buyer can be found, then the50,000 gallons of 3 percent CCA solution along with the 15,000 gallons ofCCA contaminated wastewater as well as wastewater generated on-site willbe treated on-site through the water treatment system set up for treatingthe pumped surface waters and extracted groundwater.


The preferred alternative for the remediation of contaminatedsoils/sediment is a soil washing/flushing technique. The alternatesource control alternative is a low temperature process to remove theorganics contaminants followed by either a soil washing/flushingtechnique or soil fixation/aolidification/stabilization process toaddress the inorganics. The decision as to which source controlalternative will be implemented will be based on data generated by thesoil washing/flushing treatability study to be conducted during theremedial design.

Contaminated soils/sediment will be excavated, treated and placed back inthe excavation. All wastewater generated will either be reused ortreated on-site. Following completion of on-site remedial activities,those areas disturbed will be revegetated

MIGRATION CONTROL (Remediation of Contaminated Groundwater)

Groundwater extraction will be accomplished through the use of wellpoints in the upper (surficial) aquifer. Recovery will be conducted in10,000 square foot subareas at a time, and the well points will be movedto adjacent areas for subsequential dewatering.

-75-


A water treatment system will be established on-site. The system'sinfluent will include contents of the tanks and piping, all wastewatergenerated due to remedial actions implemented, pumped surface water, andextracted groundwater. The level and degree of treatrtK t will depend on1) the level of contaminants in the influent and 2) th ultimatedischarge point of the treated water. There are two water dischargealternatives for the treated water. The optimal choice is the localsewer system. The other alternative is to discharge the effluent to asurface stream. The range of treatment for the contaminated waterincludes biological degradation, air stripping, filtration throughactivated carbon filter, and metal removal through flocculation,sedimentation and precipitation. The point of discharge and the degreeof treatment will be determined in the Remedial Design stage. Theeffluents, including both discharged water and/or air, will meet allARAR's.

This recommended alternatives meet the requirements of the NCP, 40 CFRSection 300.68(j) and SARA. This recommended remedy permanently andsignificantly reduces the volume of hazardous substances in the groundwater,reduces the toxicity and/or mobility of contaminants in the soils.

6.2 OPERATIONS AND MAINTENANCE

Long term operation and maintenance (O&M) will concentrate on the groundwaterextraction, water treatment and groundwater monitoring systems.

6.3 COST OF RECOMMENDED ALTERNATIVE

The estimated present worth cost for containerizing and transporting the CCAcrystals and solidified creosote to Pinewood, SC, is $42,400. The estimatedcost for disposing of the asbestos-containing piping insulation at the localcounty landfill is $100. The present worth cost for cleaning and disposingof the tanks and piping is $87,900 if a metal dealer is found to purchase thescrap metal or $112,400 if the Agency needs to dispose of the scrap metal atPinewood, SC. There are no O&M costs associated with the above activities.

The treatment of the liquids held in the tanks, 50,000 gallons of 3 percentCCA solution and 15,000 gallons of CCA contaminated wastewater, has a presentworth cost of approximately $104,000. The O&M costs have been factored intothe O&M costs of operating and maintaining the water treatment system.

The estimated present worth cost for the soil washing/flushing alternativefor contaminated soils and sediments is $11.00 million. This includescapital and O&M costs for the 1.5 year treatment period. The estimated

-76-

present worth cost for the low temperature destruction process combined witheither soil washing/flushing or a soil fixation/solidification/stabilizationprocess for contaminated soils and sediments is $14.03 million. Thisincludes capital and O&M costs for the treatment period.

The estimated present worth cost for pumping surface water and extractinggroundwater and treating the commingled waters ranges from $3.4 to $3.65million, depending on the extent of treatment and ultimate discharge pointfor the treated water. The capital costs and present worth O&M costs over30 years range from $2.11 to $2.34 million and $1.02 to $1.31 million,respectively

The present worth cost of the preferred remedy, including all activities,ranges from $14.37 million to $14.91 million.

6.4 SCHEDULE

The planned schedule for remedial activities at the Cape Fear Site is asfollows:

June 1989 — Approve Record of DecisionJuly 1989 — Initiate Remedial Deaign/Treatability Study

October 1989 — Superfund/State Contract SignedNovember 1989 — Complete Treatability studiesDecember 1989 — Initiate Remedial Action for Addressing

Contaminated Groundwater and Other SpecificCleanup Activities

April 1990 — Complete Remedial Design for Source Control andMobilize

6.5 FUTURE ACTIONS

The only anticipated future action expected to follow completion of theremedial action is periodic monitoring of groundwater to insure remediatedlevels obtained during the remediation is maintained.

6.6 CONSISTENT WITH OTHER ENVIRONMENTAL LAWS

A remedial action performed under CERCLA must comply with all applicableFederal, State and local regulations. All alternatives considered for theCape Fear Site were evaluated on the basis of the degree to which theycomplied with these regulation. The recommended alternatives were found tomeet or exceed all applicable environmental laws, as discussed below:

-77-

TABLE 21

APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS

Law, Regulation,Policy and Standard Application

Resource Conservation and Recovery Act (RCRA)

40 CFR 261:Definition and identification

40 CFR 262:Standards for generators ofhazardous waste

40 CFR 263:Standards for treatment ofhazardous waste

40 CFR 264:Standards for treatment ofhazardous waste

Definition and identification of wastematrial as hazardous

Generator requirements includeidentification of waste generationactivity, obtaining EPA ID number,record keeping, and use of uniformnational manifest

The transportation of hazardous wasteis subject to requirements includingDOT regulations, manifesting, recordkeeping, and discharge cleanup

Incineration requirements

40 CFR 264:Standards for Disposal ofhazardous waste

40 CFR 268:Land disposal restriction

40 CFR 257:Standards for Disposal ofhazardous waste

Closure requirementsClass C closure - landfill closuremeeting minimum technologyrequirements for hazardous materials

Class D closure - landfill closuremeeting minimum technologyrequirements for non-hazardousmaterials

Excavated waste disposed onsite may besubject to land disposal restriction ifplacement occurs

Closure requirements

40 CFR 264, Subpat I:Containers

Storage requirements for containers

-78-

TABLE 21(continued)



Clean Water Act (CWA)

40 CFR 122, 125:National Pollutant DischargeElimination Systems (NPDES)

40 CFR 403:Effluent Guidelines andStandards: PretreatmentStandards

40 CFR 230:Dredge and Fill Requirements

Ambient Water Quality Criteria

CAA Section 109 and 40 CFR 50:National Ambient Air QualityStandards

Occupational Safety and Health Act

29 CFR 1910:General standards for workprotection

29 CFR 1090:Regulations for workersinvolved in hazardous wasteoperations

Discharges of extracted/treatedgroundwater will be subject tosubstantive requirements of the NPDESprocess if discharged to a localstream. NPDES is administrative by thestate

Discharges of extracted/treatedgroundwater will be subject topretreatment requirements if dischargedtot he POTW

Actions in a wetland or floodplain

AWQC may be used for dischargerequirements where there are no statewater quality standards

Preconstruction review of incineration

NAAQS for PMIO applied to fugitive dust

Worker safety for construction andoperation of remedial action

Worker safety for construction andoperation of remedial action

Hazardous Materials Transportation Act

49 CFR 100 through 199:Transportation of hazardousmaterial

The transport of hazardous waste issubject to DOT requirements

-79-

TABLE 21(continued)



Intergovernmental Review of Federal Programs

Executive Order 12372

40 CFR 29

Fish and Wildlife Coordination Act

Endangered Species Act

Section 7(c)

State and local coordination and reviewof proposed EPA assisted projects

Protection of fish and wildlife whenfederal actions result in the controlor modification of a. natural stream orbody of water

consultation with the fish and wildlifeservice if action may impact endangeredspecies or critical habitat

Executive Orders for Flood Plains (EO 11988)

40 CFR Part 6, Subpart A

Executive Orders for Wetlands(EO 11990)

Safe Drinking Water Act

North Carolina Requirements

State Drinking Water Standards

Protection of flood plains affected byremedial action

Protection of wetlands affected byremedial action

Maximum Contaminant Levels (MCLs)established under the Sate DrinkingWater Act were found to be relevant andappropriate to remedial action at the .Cape Fear Site. The cleanup goals forgroundwater were established in Section4.

Maximum contaminant levels establishedby the State of North Carolinaregulations; are adopted from those ofthe Federal Safe Drinking Water Act,and will be met.

-80-

7.0 COMMUNITY RELATIONS

Fact sheets were transmitted to interested parties, residents, media andlocal, state and federal officials during the RI/FS process. The Agency alsoconducted the FS public meeting.

The Information Repository/Administrative Record was established atCumberland County Public Library & Information Center located at 300 MaidenLane, Fayetteville, North Carolina 28301.

A public meeting was held on February 21, 1989, at the Seventy-First SeniorHigh School in Fayetteville, North Carolina. At this meeting, the remedialalternatives developed in the FS were reviewed and discussed and EPA'spreferred remedial alternative was disseminated. The groundwater migrationalternative was presented as described in Section 6.1 Description ofRecommended Alternative. Two source remediation alternatives werepresented. EPA's preferred source remediation alternative for is a soilwashing process. The Agency's back-up alternative in the event that aeffective soil washing process cannot be devised is an on-site lowtemperature process to mitigate the organics followed by either soil washingor a soil fixation/solidification/Btabilization process to address themetals. Both alternatives are permanent remediations but the soil washingalternative is estimated to be 3 million dollars less than the lowtemperature process.

The public comment period concluded on March 14, 1989. The only commentsreceived during the public comment period were those aired and responded toat the public meeting. The Responsiveness Summary summarizes the commentsstated in the public meeting.

8.0 STATE INVOLVEMENT

The State involvement has been maintained throughout the RI/FS process withreviewing pertinent documents such as the draft Remedial InvestigationReport, the draft Feasibility Study, the draft Record of Decision and havebeen carbon copied all relevant correspondences.

The State of North Carolina supports the alternative stated in theDeclaration and Section 6.0. The State of North Carolina recognizes the 10%cost share under CERCLA, Section 104(c) and operation and maintenanceresponsibilities associated with this alternative.

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APPENCIES

APPENDIX A

RESPONSIVENESS SUMMARY

APPENDIX A

RESPONSIVENESS SUMMARY

This community responsiveness summary is divided into the following sections:

SECTION I. Overview. This section discusses EPA's preferredremedial action alternative and public reaction tothis alternative.

SECTION II.

SECTION III.

SECTION IV.

SECTION V.

Background on Community Involvement and Concerns.This section provides a brief history of communityinterest and concerns raised during remedial planningactivities at the Cape Fear Wood Preserving Site.

Summary of Major Comments Received During the PublicMeeting and the Public Comment Period and EPA'aResponses to These Comments. Both the comments andEPA'e responses are provided.

Remaining Concerns. This section describes theremaining community concerns that EPA should be awareof in conducting the remedial design and remedialaction at the Cape Fear Wood Preserving Site.

Transcript of the Public Meeting. This sectionprovides a transcript of the Feasibility Study PublicMeeting held on February 21, 1989 at theSeventy-First Senior High School located near thesite.

SECTION I. OVERVIEW

The public meeting at which EPA presented its preferred alternative to thepublic initiated the public comment period which ended on March 14, 1989.The alternative addresses both the soil and groundwater contaminationproblems at the Site. The preferred alternative specified in the Record ofDecision (ROD) includes: permanent treatment of contaminated soil,groundwater, and surface water and sediment.

In the public meeting, held February 21, 1989, two remedial alternatives wereproposed to the public for source control. Source control remedial actionsaddresses both contaminated soils and sediments in the drainage ditches andswamps. EPA's preferred alternative is soil washing which is expected toremove both the organic and inorganic contaminants. This is the preferredalternative because it eliminates, permanently, the source of contamination.In case that the treatability study indicates that soil washing will notachieve the cleanup goals stated in the Record of Decision (ROD), Table __,the Agency proposed a low temperature desorption process to remove theorganica and a soil fixation/Btabilization/solidification process to addressthe inorganics. The soil washing treatability study is to be performedduring the Remedial Design stage.

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The community, in general, favors remedial action at the Site.

SECTION II. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS

The Cape Fear Site is located in Cumberland County, North Carolina, onthe western aide of Fayetteville near Highway 401. It includes aboutnine acres of a 41-acre tract of land. The site is adjacent to otherindustrial/commercial establishments as well as private residences. Fourhomes are located near the Bite. In addition, a subdivision named"Southgate" is located approximately a quarter of a mile south of the Biteand houses approximately 1,000 people.

Interviews conducted in 1987 revealed that most residents on Reilly Road andon School Street have lived in the area for many years. Due to the transientnature of military life, the majority of Southgate residents are renters whoare not in the area long enough to establish strong community ties.

Although there has been no organized community involvement with the Cape Fearsite to date, community interest in, and concern with, contamination problemsat the site have fluctuated in intensity since the discovery of contaminantsin a residential well across from the site in 1977. Community concerns haverarely been expressed to government officials; rather, information has beenshared and fears discussed primarily among area residents themselves.

Some specific fears expressed by local residents includes how they believethey have been and will be affected by the contamination problem. Otherspecific issues of concern mentioned by area residents and local officialsare:

1. Extent and Nature of the Contamination

Area residents possess various amounts and types of information about theextent of contamination form the Cape Fear site, some of it stemming frommisinformation and some from speculation. Residents do not have a thoroughunderstanding of suspected contamination sources and whether or not theAgency is dealing with the full extent of the contamination problem.

2. Drinking Water Quality

Several residents expressed concern with the quality of their drinking waterand the potential adverse health effects from its consumption.

3. Health and Safety

Several of the residents questioned the health and safety implications posedby the site's accessibility to children and young adults and suggested thatthe area be secured. The numerous acts of vandalism that have occurred atthe site suggests that the area may be a gathering spot for youths carryingout activities that, at the time, go undetected.

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4. Property Value and Quality of Life

Almost every resident interviewed mentioned reductions in their propertyvalue as an area of concern. Some local officials view the area surroundingthe site as holding a good deal of potential for residential development.They are concerned that the property will not be restored to accommodate suchgrowth.

5. Other Area-Wide Environmental Issues

According to local officials, an effort to site a hazardous waste incineratorin the area attracted 4,000 people to the public meeting of the proposedincinerator permit. Organized opposition to North Carolina's proposedmembership in a low-level radioactive waste compact that would oblige theState to eventually host a disposal site.

III. SUMMARY OF PUBLIC COMMENTS RECEIVED PORING THE PUBLIC MEETING AND THEPUBLIC COMMENT PERIOD AND AGENCY RESPONSES

Comments raised during the Cape Fear Wood Preserving public meeting andpublic comment period are summarized briefly below. The comment period wasopen from February 21 to March 14, 1989 to receive comments from the publicon the draft Feasibility Study and proposed remedial alternative.

There was a moderate response from the community in the public meeting but nocomments were received during the pursueing three week public commentperiod. Summaries of the questions received during the public meeting arepresented below.

Public Meeting

The public meeting was held on February 21, 1989 at the Seventy-First SeniorHigh School auditorium. Questions and comments fell into five majorcategories including: concern about public health, thoroughness of researchefforts to determine the extent and impact of contamination, time involved incleaning up the Site and restoring the land, cost of the remedial action, andwhere the discharge of the treated/untreated water from the site will go.

The Agency's presentation and the questions and comments received from thepublic during the February 21, 1989 public meeting is provided in Section V.

Public Comment Period

No comments were received by the Agency during the three week comment periodthat ended on March 14, 1989.

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IV, REMAINING PUBLIC CONCERNS

In addition to those concerns voiced at the public meeting, some additionalpublic concerns are described below.

* Additional sampling/analysis of residential wells forvolatile organics.

* Length of time prior to removing off-site monitorwells.

V. CAPE FEAR FEASIBILITY STUDY PUBLIC MEETING

CAPE FEAR PUBLIC MEETINGFayetteville, North Carolina

21 February 19897:00 PM

JB: This is EPA's meeting on the Cape Fear Wood Preserving Site. Asdirected by the Superfund Law, the Agency is required to have at leastone public meeting for a Superfund site at the conclusion or completionof the Feasibility Study for that site, and the Agency is now at thatstage.

What I would like to do is briefly introduce those from the Agency whocame up; and then, as briefly and quickly as possible, describe what wecall the Remedial Investigation/Feasibility Study process, and thendescribe what we found on-site (the contamination), which is the RIfindings; then briefly go through the evaluation process that we wentthrough in the Feasibility Study to come up with the Remedy we selectedor we're proposing to use to clean-up the site; then explain in betterdetail the remedy we're proposing; and then field any questions that youmay have.

I'm Jon Bornholm; I've been with the Agency for almost five years. I'min the Superfund Program on the Remedial side. This gentleman standingup is Michael Henderson with our Public Relations part, and Chris Kahleis also in the Superfund Program.

Out front, there are four packages of information: three fact sheetsand one package of overheads I will go through tonight. The firstpackage was sent out in November and basically tells or explains whatthe findings of the Remedial Investigation were. The second one, whichwas sent out in December, goes through the Feasibility Study. The lastone is called the Proposed Plan, and it describes the alternativesevaluated to clean-up the site and then identifies the preferredremedial alternative.

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This figure [ ] gives you an idea of where the site is. This [ ]is basically a more close-up picture; and this figure [ ] identifiesmore detail of the site itself.

The Remedial Investigation was conducted the summer of '87, andbasically, the Remedial Investigation consisted of taking environmentalsamples, and analyzing those samples for contaminants we expected to seeon-site as well as taking 10% of those samples and analyzing for a fullrange of possible contaminants. The environmental media sample includedsoils, subsurface soils, surface water and groundwater. Thecontaminants that were of concern were a result of the activities fromthe wood treating process, and basically that's creosote material, coaltar material and then metals coming from what's called a CCA process, awolmanizing process. The letters stand for Copper, Chromium andArsenic; those are the three metals we were looking at as well as thecreosote.

The next couple of overheads I have show sampling areas and the range ofconcentrations we found on-site.

We used a grid system to take our surface soil samples, and this is forchromium. The colored-in areas are the areas that had levels higherthan clean-up standards, so these would be the areas identified forremediation due to chromium contamination.

This overhead is for arsenic; again, we're talking about surface soils,and the hatchad-in, x'ed-in area is the area that had arsenic levelsabove the clean-up standards, and this would be the area identified forremediat ion.

This overhead is for creosote. He use another term for it- PAHs(polyeyelie aromatic hydrocarbons). Again, the area x'ed-in is the areaidentified for remediation due to contamination by creosote.

One of the compounds that we were not expecting to see on-site as acontaminant is benzene. This contaminant is basically due to the resultof having a gasoline tank on-site, buried under the ground, that theoperator used.

And we put all the areas together requiring remediation. This isbasically what it looks like, and this is just for surface soils.

For surface water, we'll go back to this one map here, we're talkingabout from surface down to 3-5 feet in depth would be the depth thatwe. As far as surface water is concerned, we found that this drainageditch here that leads back to this diked pond will also requireremediation. That entails pumping out that water, treating the water,excavating the contaminated so ls and treating those soils. So thatwill address surface water and sediments in this area. We did find somecontamination in the swamp area back here which, again, we will addressthrough excavation and treating that soil as well as surface water.

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As far as groundwater contamination is concerned.... Although thisidentifies for creosote contamination in the upper aquifer, it'sbasically the same area for all the contaminants we look at.

We found that the upper aquifer at the site flows radially in alldirections from the site. This is basically due to: 1) it being a highpoint in the area and 2) the high percentage of sand present at the siteallows a high percolation rate in the ground.

And for the deeper aquifer, we only found a small area of contamination,which is right here [ ]. That's basically due to what we believe isan on-site production well used during the operation of the facility,contaminants leaking down the well-casing and getting into the deeperaquifer. That's why it's so localized.

One of the findings of one of the tasks of the Remedial Investigation isto quantify the amount of material (soils/groundwater) contaminated, andthis table [ ] presents what we feel are the maximum and minimumamounts of contaminated material out there as well as an average.

That basically presents the findings of the Remedial Investigation. TheRemedial Investigation had three basic questions we tried to answer: 1)What are the contaminants of concern at the site? 2) What concentrationof the contaminants? 3) How far from the site has the contaminationmigrated? This information is fed into the Feasibility Study. TheFeasibility Study evaluates, based on information from the RemedialInvestigation, the types of clean-up alternatives that are feasible atthe site.

Going from a list of approximately forty types of remediation, wenarrowed it down to: four for addressing contaminated soils andsediments and five for addressing surface water and groundwater. One ofthe alternatives that we have to consider and carry all the way throughthe evaluation is what we call a No Action alternative. That'sbasically just to let the site sit there and monitor the contaminationand the rate at which the contamination migrates. We use this as a baseline measuring point to measure what good or benefit we get from ourremedial alternatives.

For the contaminated soils these were the four alternatives that wereevaluated in detail:

IS Again, No Action evaluation to present the base line measuringstick.

The other three are actual clean-up alternatives:

2S Is basically capping the contaminated area with a soil cap;

3S An excavation and soil-washing process

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4S Again, we'd be digging up the contaminated Boils and putting itthrough a low-temperature desorption/absorption process.

Where IS and 2S are not permanent clean-ups. Obviously, under HoAction, the contaminants would remain in place and, under 2S, thecontaminants would remain in place although there would be a protectivecap placed over them which would prevent rain basically frominfiltrating the soils and helping spread contaminants into thegroundwater.

3S and 4s are both permanent remedies; they will remediate the site andremove the contamination on a permanent basis.

Over here [ ] are the cost averages for each remediation; this is forsoils and sediments. These numbers are based on that previous overhead[ ] that presented the max/min volume, so the cost is based on volumesof materials treated.

For groundwater and surface water [ ], again we looked at fivealternatives in detail. The first one is No Action; that presents uswith a base line to measure the other alternatives, the benefits to gainfrom the other alternatives.

2W through 5W are basically the same thing, the only difference is...;they are the same in the process that we are withdrawing or extractingwater.

Q: I don't understand those figures.

A: The cost dollars? I'll get to those.

Q: I mean, $3395 for what?

A: OK, those are hundreds of thousands of dollars. So the first numberwould be $592,000. We're talking again in millions of dollars here, sowe're talking about a range between: the high would be 2.8 million to,or the low 2.8 million to a high of 26 million.

2W through 5W, for withdrawing or excavating both surface water andgroundwater, and the only differences between these alternatives is thedegree we treat that water.

We really haven't, as far as selecting a specific treatment, we haven'tdone that, and we will do that after we talk with local sewerauthorities and see if they will accept the water either with some typeof treatment or with no treatment. We have not talked with the localsewer treatment plant. We don't know with regards to that.

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There are some other odds and ends that need addressing on the site, andthese are not in millions of dollars [ ]; these are the actual pricetags, that we estimated, to deal with, to deal with the situationon-site. We found what we believe is asbestos-containing pipeinsulation, what looked like CCA- Chromium, Copper chromium Arseniccrystals, and what was left behind from on of our Emergency Responses,which is basically a pile of ten cubic yards of solidified creosotewhich remains on-site, and then the piping and tanks on-site as well.

Okay, this is basically what's presented in the Feasibility Study [ ];this was done by the Agency's contractor. The last part, which is theactual selecting of the remedy which is left up to the Agency, and whatthe Agency has identified as a preferred alternative: I will start withwhat's up here. For the CCA crystals and creosote contaminatedmaterial; those two materials we are proposing to dispose off-site at aRCRA-approved hazardous landfill. There's two of them we're lookingat: one is out over in Pinewood, South Carolina, 6FX HazardousLandfill, and the other one we looked at would be Emile, Alabama, whichwould be another hazardous waste landfill.

For the asbestos-containing piping insulation, we have been informedthat Cumberland County Landfill can accept that, and therefore we areproposing to remove that and dispose of it at the local landfill.

And, for the liquids contained in the tanks, we would prefer to find awood-treater who would be willing to accept that material, but in thelikelihood that we would not find somebody, we would be proposing totreat that water on-site through the treatment system established forthe groundwater and surface water, so that would be 1L.

Q: How can these price estimates be made without actual costs having beenaccrued and without knowing if the sewage treatment plant would acceptthe waste?

A: These prices are based on worst-case scenarios.

And then, once we empty the tanks, we clean them, try to render themnon-hazardous and ideally we'd be able to sell them for scrap metal.And if we're able to do that, we'd make $112,000 (that's why thenegative sign is up there); it wouldn't cost us anything to do that.The government would make money for once. If we can't render itnon-hazardous or we can't find a scrap metal dealer to accept that metalafter it's been cleaned, we could dispose of that at the countylandfill, and the cost of that would be approximately $87,000.

For soils and sediments, the preferred or proposed clean-up method is3S, so we're talking about, as a minimum cost, 4.3 million and, on thehigh end, 20.9 million to clean up the soil. There's one piece ofinformation lacking that we're working with right now, or not workingwith unfortunately, and that is, we haven't performed a treatability

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study to make sure that the soil-washing process will work. So, as afall-back position, we have identified 4S as a fall-back position incase we cannot find a soil-washing process that will work.

What the thermal process basically means is to process the soils andsediments through a low-temperature furnace at temperatures high enoughto volatilize the creosote, to catch the exhaust gas coming off of thatand then treating it with a scrubber and removing contaminants thatway. Unfortunately, the thermal process itself does not address metals.Following that thermal process, we'd either use a filtration processwhere we'd be mixing with some type of concrete or similar material andmaking a concrete slab or monolith. Or use a soil-washing process toremove the soil. The price tag for that, for 4S, ranges from ourestimates from 5.6 million to 26.1 million.

For the surface water and groundwater, again, right now we are proposingto pump the surface water as well as the contaminated groundwater. Ourpreferred discharge location or discharge point would be to the localsewer system. That would be the less costly, cheapest way to do it.Following negotiations with them, we'd have to negotiate haw much wecould discharge to them and what levels of contaminants, if any, wouldremain in that water we discharge. They might require to clean it up toclean water specs. All that again is yet to be determined.

Q: Which number is that in the preferred alternatives?

A: It would be, it is the preferred alternative: To discharge to a POTW(publicly-owned treatment works).

If the sewer-system would not accept it, our other alternative, ourother discharge alternative is to discharge it to a nearby surfacestream, under what's called an NPDES permit (National PollutionDischarge and Elimination System). It has it's own criteria to protectsurface water from contaminants, and we'd have to meet whatever levelthey set for that discharged water.

So, we're ranging from a minimum cost of approximately 2.8 million up to3.5 million to treat surface water and groundwater, and these costs arebased on the assumption that we will have to build some type oftreatment plant on-site to treat this water.

Qs If you did air stripping, would you have to meet emission requirements?

A: We'd have to meet their specs. Superfund, although we have State andFederal permits, one thing Superfund doesn't actually have to do is getthose permits; we have to meet the technical requirements of thepermits. We would meet all requirements necessary.

This is just a quick overview of the soil-washing process [ ].Basically it entails using a high pressure washing system to break uplarge aggregates of material, soil materials, and wash away the sludge,

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the contaminants, from the soil material. Clean soil, if it's heavyenough, would fall out due to gravity and be put back in place. Thecontaminants, creosote as well as metals, would come into solution or beremoved as suspended solids in the waste water. That waste water wouldthen be biologically treated to remove the creosote and we'd use sometype of population/sedimentation/fixation process to remove the metals.Then that water can be recycled through the system.

Q: How is this process going to work at this large scale site?

A: It's being used as a pilot study right now at a Superfund site up inMinnesota. It's been shut down for the winter. The results seempositive. Again, we haven't done a treatability study and one of themain factors that would influence its acceptability here would be ???,basically the ratio between sand and clay that is in the ground. If wehave a high clay content, then we'd have to use the other alternative,which was 4S which would be the thermal process which would be what wewould be proposing.

Unfortunately, I did not itemize the total cost. For soils, we're using10.9 million as the average cost; 3.4 million for addressing surfacewater and groundwater; if we can find a scrap metal dealer who will takethe metal, these remedies here wouldn't cost anything, they'd kind ofbalance each other, but otherwise, we're talking about close to 200,000for remediation of these items on this overhead [ ].

Are there any questions?

Q: When can we see some movement or activity out at the site?

A: Tonight starts, basically a, starts a three week comment period wherethe Agency encourages the public to express their feelings one way orthe other about what we propose as a remedial alternative. Followingthe closure of that public comment period, we (the Agency) prepares aResponsiveness Summary where we respond to each comment we receive.That usually takes another two weeks. Then we prepare what's called aRecord of Decision, we call is a ROD (another government acronym). TheRecord of Decision is a decision document; it's signed by the RegionalAdministrator, and it sets forth the actual clean-up that the Agencywill implement at the site. And that could take up to a month. Sincethis is a Fund-lead site... In the Agency, we have two kinds ofSuperfund sites: one is Enforcement, where we have know PRPs, orpotentially responsible parties- we have folks who created thecontamination and they are paying for it; we have sites, such as CapeFear Wood Preserving, which is called Fund-lead, and we haven'tidentified any responsible party for the contaminants on-site or theentity who created it is no longer around or doesn't have the money topay for it, so Superfund fund pays for it. In sites like this, we needa matching 10% share from the State. We have to go through thatnegotiation with the State and that negotiation results in what's calleda Superfund State Contract, and we're expecting to take two to threemonths to iron out the language.

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Q: Following the Record of Decision?

A: Yes, a Record of Decision. We firat have to get the state's concurrenceon the remedy selected. If they do not concur, they do not match thefunds and we don't clean up the site. Congress has mandated that we getthe 10% matching funds before we do anything beyond this point.

Q: Does your report here take in consideration state officials saying thatcontaminant ... or solely on the knowledge...

A: He have all the documents that we generated to the State for review.They're using the same information we're using. These numbers aregenerated by our contractor who did the actual study. There's no reasonwhy we would doubt this information. Where their actual decision rolecome in is what type of remedy they would like to see at the site. Butthey would be using the same information.

Q: Who is the contractor?

A: The contractor is Camp, Dresser & McKee. They're a national A & E(architecture and engineering) firm. We call them a REM II contractor.They've done work for the Agency east of the Mississippi. Theirheadquarters is outside Washington, but they have a local office inAtlanta, and that's the office we deal with.

Q: How reliable are the results that Camp, Dresser & McKee generated?

A: We have about three or four contractors we rely on to do this kind ofwork.

Q: If the degree of contaminants that you have shown here tonight, in yourall background and experience, what is the possibility...is it at alevel where the contaminants propose a health threat and what is thepossibility of the no action alternative?

A: My feeling from what I've heard from the State is that they prefer somekind of permanent remedy at the site, not the No Action alternative.The No Action alternative, for at least surface soils, is not acceptablefor health-based reasons.

Q: What about the water?

A: Again, the groundwater does exceed clean-up standards, and therefore wewould encourage clean-up, not knowing what the future holds for thatarea. It could go one way or another. If it goes residential, we wouldhave to clean it up; if it stays as it is, there's not much of a push toclean it up. It's not going to affect anyone.

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Q: Is there any immediate danger within the area?

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A: From groundwater? No, groundwater is very localized. The one well thatwas contaminated, I believe the owner/operator dug that person a newwell.

Q: On that figure [2-6] does that big circle represent the upper watersystem or lower or both?

A: This bio circle? It was the surficial, the upper aquifer.

Q: And what do you call upper as far as depth?

A: I think it goes down to between 30 and 50 feet and then we find aconfining zone which separates the upper aquifer from the deeperaquifer.

Q:

A: Okay, this is the contaminants found in the upper aquifer.

Q: How far has the contamination gone?

A: This is the residence where we found contamination in the person'swell. I would guess, looking at this scale, it's about 250 feet west.

Q: How far south has the contamination...

A: This should be the condition of the wells; they would show up clean.

Q:

A: I was under the assumption that we had a pair of wells there.

Q: Is that well a deep or shallow well?

A: I'm not sure if that's deep or shallow.

A: I don't have that information off hand, but hopefully I have it here.

Q:

A: I believe we found. . . Where that 400 is? There should be two here, andI... That 400 represents what we found in the shallow well. So, sincewe're talking about the upper aquifer, that's why there's no dot here;we only have a deep well there. So we found 400 ug/1 of contaminants(PAHs). And this figure [ ] — that oval is computer generated fromgroundwater modeling program.

Q: How long has it been since that well's been sampled?

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A: I'd have to say August '87.

Q:

A: That might be date of the report. We performed the RemedialInvestigation during the summer of '87. So it was sometime during thatsummer. Mr. Jackson's private well, which was a shallow, hand-dug well,which is near this point was found contaminated back in 1980 or 1979.And, in response, he was provided a new well.

Q: Let me ask you this: How far has the contamination moved since 1979?

A: This would be, this figure is based on data collected the summer of '87.

Q: Contamination was found in 1979/1980 across the road?

A: And we found contamination two summers ago and this 400 represents thatcontamination. And based on computer modeling, we have projected thatthe contaminants have migrated this far, as of the summer of '87. Ithink groundwater horizontal velocity is, I want to say, is 15 ft/yr —the rate it's moving.

Q: 50 ft/yr?

A: 15 ft/yr is what we've calculated the water is moving. That's not to saythe contamination is moving at that rate; it's just saying the water ismoving at that rate. Contaminants don't move as quickly as the waterdoes. So, if anything, it might be a tad larger than this area rightnow, but it wouldn't, cost-wise, it wouldn't effect the cost. Again,we're dealing with a maximum/minimum range, and I'm sure it will fallwithin that range of volume with the estimated cost it's based on.

Qt With contaminants on both side of the road and a ditch along side theroad that crosses underneath the road.

A: That would be this right here [ ].

Q: That ditch I thought does on down to a lake, is there contamination fromthe site in the lake and ditch since the majority of flow appears to goin that direction.

A: We did not find, you know our Remedial Investigation, we did not findcontaminants in this area, which was basically on the other side ofReilly Road. To answer the other question, we don't know.

I'm not saying no contamination has gone that far, but we don't haveinformation to judge one way or the other. All we can do is work on theinformation we have, and, according to the samples collected during theRemedial Investigation, we did not find contamination in that ditch onthe other side of the road.

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Q: I think it was about 25 years ago, there was a pond and all the fish werekilled in the pond by contamination.

JBi Back here somewhere?

Q: Did you find any contamination in that direction?

A: He did find contamination through this drainage ditch and in the dikedpond that is an area targeted for remediation. We did not find surfacewater or sediment contamination in this ditch on this side, and thereforeit was not identified as an area for remediation. As far as a pond inthis area, we have no information to make one judgement or the other onthat.

Any other questions?

Q: How about Southgate here?

A: All the supply wells in that area were tested, yes. And we found... Theonly thing we found in the wells were elevated levels of trihalomethanes(THMs).

Q: Did you find a source?

A: No, no, we weren't able to identify that to any source.

Q: It was one of the supply wells?

A: It was one of the supply wells in Southgate subdivision, and we foundTHM. THM is trihalomethane either chlorine or fluorine: trichloro- ortrifluoromethane.

Q: That was in '87?

A: That was back in '87.

Q: And you tested for what?

A: We tested it looking for contaminants from this site. The levels werebelow drinking water standards. We did identify or notify theowner/operator of the well and the local government of our finding and asfar as Superfund program goes, that's as far as we carry it. We identifythe right folks hopefully and that's as far as we go with that.

Q:

A: No to this site, no.

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Q: Do local officials know what has been found at the site?

A: As far as the local state offices, yes. The county offices...! have notbeen in direct contact with them. We have established an informationrepository/administrative record at the public library which containsall the documents including the information I reviewed tonight

JB: Any other questions. I thank you and appreciate you for coming. I hopecleanup gets going as quickly as possible.

END OF TAPE

APPENDIX B

PROPOSED PLAN/LEGAL NOTICE

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IV34S COURTL.AND STREET

ATLANTA, GEORGIA 30365

SUPERFUND PROGRAM PROPOSED REMEDIAL ACTIONFACT SHEET

for

CAPE FEAR WOOD PRESERVING SITEFAYETTEVILLE

CUMBERLAND COUNTY, NORTH CAROLINA

February 1989 For More Info Contact:Jon BornholmSuperfund Branch(404)347-7791

CURRENT STATUS

This is the second Fact Sheet discussing the Feasibility Study (FS) for theCape Fear Wood Preserving Superfund Site. The previous Fact Sheethighlighted and summarized the findings documented in the Draft FeasibilityStudy. This Fact Sheet proposes the Agency's preferred remedial alternativefor the Cape Fear Site as well as inform the public of the upcoming publicmeeting on the Feasibility Study. The main emphasis of the meeting will beon the Agency's proposed remedial action. The date of the meeting isFebruary 21, 1989 at Seventy-First Senior High School Auditorium. Themeeting is to begin at 7:00 pm. The Seventy-First Senior High School islocated at on Raeford Road in Fayetteville, North Carolina.

SITE DESCRIPTION AND HISTORY

The history of the Site has been summarized in previous Fact Sheets and canbe found in either the Remedial Investigation (RI) report or the Final DraftFeasibility Study document, copies of both are located in the InformationRepository/Administrative Record (IR/AR). The IR/AR is located in theCumberland County Public Library and Information Center.

Major site structures and features are shown in Figure 1. This figure willalso allow the reader to locate areas on the Site that require remediation.

FEASIBILITY STUDY

Results of the RI show that the soils, sediments, surface water andgroundwater contain contaminant concentrations above applicable relevant andappropriate requirements (ARARs) or target risk levels used in public healthevaluations (1 person out of 1,000,000 for carcinogenic compounds and ahazard index of 1 for noncarcinogenic compounds). The contaminants targetedfor remediation are listed in Table 1 along with a specific cleanup goal foreach contaminant in each environmental media (soil, surface water/sediment,

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each environmental media (soil, surface water/sediment, and groundwater) andthe rationale for selecting the particular cleanup goal.

The cleanup goals were derived through reviewing existing ARARs, reverse riskassessment techniques (calculated values), background concentrations,environmental protectiveness, and analytical detection limits. Considerationwas also given to direct contact exposure, leaching to groundwater andsurface water as well as present and future residential versus industrialland use scenarios. All of the above information can be found in Appendix C- Risk Assessment of the Remedial Investigation Report dated October 6, 1988.

The FS stage of the Superfund process begins near the end of the RI. Theprimary objective of the FS is to document and support the selection of themost appropriate remedial clean-up response for a Superfund site. Briefly,the FS evaluates a list of remedial responses based on cost, engineeringfeasibility, environmental impact, and then recommends the mostcost-effective solution for the contaminants found at a site that willadequately protect public health and the environment.

-FORMER CREOSOTEUNIT SUMP

OLD CREOSOTE/CCA UNfT

FORMER LAGOONSTORAGE TANKS

100 0 100

SCALE IN FEET

SANDERS\J*ESID£NCE

\\D

JACKSONRESIDENCE LJ

. SEASONAL

/

OSOTE-CONTAMWATEDSOUDFIED SLUDGE

STORAGETANK

STORAGETANKS

— -UNDERGROUND"GASOUNESTORAGE TANKS

— — CLEARED AREA

CONCRETE PLANTDISCHARGE POND

Figure 1. Site Map Identifying and Locating Site Features

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TABLE 1. Summary Of Contaminated Media And Cleanup Goals

Media

Ground Water

Surface Hater

Soil

Sediment

Site Related ContaminantsExceeding ARARa, RiskAssessment Values, orEnvironmental Criteria

BenzenePAHs (carcinogenic)PAHa (noncarcinogenic)

ArsenicChromium (total)Copper

ArsenicBenzeneChromium (total)PAHe (carcinogenic)PAHs (total)

PAH (total)ArsenicChromium (total)

Clean DpGoals

uq/liter510

14,350

uo/litcr121114

ma/ktj940.005882.S

100

ma/kQ3.09468

Rationalefor Cleanup

Goals

abc

dde

c, fb9c.hi

jkk

(a) ARAR - Maximum Contaminant L*v«l (MCL).

(b) The Contract Laboratory Required Quantitation Limit is proposed since sine* the calculated rick assessmentvalue is below analytical detection limit*. Should this limit be reduce with time as analytical proceduresimprove, the new (lower) limit would become the cleanup goal.

(c) Value derived using reverse risk assessment techniques.

(d) ARAR - Ambient Water Quality Criteria.

(e) The goal presents background conditions since th Ambient Water Quality Criteria Concentration (6.5 ng/L) isbelow background.

(f) The future use worker scenario is used since this is the BOX* likely future use and arsenic is not posing •significant risk under current use conditions.

(g) The goal represents site background conditionsassessment value is below background levels.

of the range observed) since the calculated risk

(h) The value listed represents a current use scenario sine this IB more conservative than the levels derived forthe future use worker scenario.

(1) Value is based on typical background concentrations (from the literature] sine* the calculated levelnecessary to prevent future leachate from exceeding a hazard index of 1 in groundvater (60mg/kg) is less thanrepresentative background conditions.

(j) Concentration researched by EPA to be protective of aquatic biota.

(k) The same value proposed for Boils is applied due to a similar human exposure route, and low expected impact tosurface water on a volumetric basis.

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EXTENT OF CONTAMINATION

Based on clean-up goals, the extent of contamination was estimated for eachenvironmental media. The following figures (Figures 2 through 4) define theareas of contamination requiring remediation for each contaminant or group ofcontaminants in each environmental media.

Soil

An evaluation of the soil sample results indicates that despite previousremoval activities, areas with high inorganic (copper, chromium and arsenic)and polyeyelie aromatic hydrocarbon (PAH) or creosote concentrations stillremain. The areal extent of surface soil for all contaminants exceedingcleanup goals encompasses approximately 150,000 square feet (3.4 acres).In estimating the volume, a minimum 3 foot and maximum 10 foot contaminantdepth are considered in the main process area and where subsurfacecontamination was identified. Outside the main process area, 1 foot and 3foot minimum and maximum depths, respectively, are considered. Three feet isconsidered as a benchmark since this is the average depth to groundwater.Using minimum and maximum depths described, the total volume of soil forpotential remediation ranges from 14,100 cubic yards to 46,800 cubic yardswith an average of 30,500 cubic yards.

Figure 2 defines the area of the Site requiring surficial soil remediation.This area encompasses all areas found to be contaminated.

Surface Water and Sediment

Surface water locations exceeding cleanup goals for arsenic, chromium andcopper include the water supply pond, the northeast seasonal swamp, thedrainage ditch south and west of the railroad tracks, the diked pond, andconcrete plant discharge pond. Depending on the season, an approximateminimum-maximum range of 0.8-1.2 million gallons (MG) is estimated, with anaverage of approximately 1.0 MG.

Sediments exceeding cleanup goals for total PAHs, arsenic and chromium linethe northeast seasonal swamp, the drainage ditch south and west of therailroad tracks, and the diked pond (refer to Figure 1). Since the exactvertical profile of sediment contamination is not known, volumes wereestimated for a minimum 1-foot depth, which represents a practical lowerlimit for removal, and a maximum 3-foot depth, the average depth togroundwater. The resulting minimum - maximum volume range for remediation isapproximately 1,800-5,400 cubic yards with an average of 2,900 cubic yards.

Groundwater

Comparing results for polycyclic aromatic hydrocarbons and benzene, tolueneand xylenes in both the upper and lower aquifers shows close correspondencein representing the horizontal extent of organic contamination. Using theorganic areal extents, an upper aquifer thickness of 25 feet, lower aquiferdepth of 50 feet, and an average effective soil porosity of 0.20, the volumesof contaminated groundwater in the upper and lower aquifers were estimated

SURFACE AREA EXCEEDING CLEANUPGOAL FOR ARSENIC. BENZENE.CHROMIUM AND/OR PAH*

Figure 2. Horizontal Extent Of Contamination ExceedingCleanup Goals In Surficial Soils

to be 23.48 and 0.6 million gallons, respectively. Experience at othercontaminated sites shows that 4 times this contaminated volume may berequired for withdrawal and treatment. Consequently, 93.9 and 2.4 milliongallons have been used in the upper and lower aquifers, respectively, toestimate a maximum expected treatment duration.

Figure 3 provides the estimated boundary for the plume of contamination,including both PAHs and benzene, in the upper aquifer and Figure 4 providesthe approximate plume boundary for both PAHs and benzene contamination in thelower aquifer.

PROPOSED CLEAN-UP GOALS

Are shown in Table 1.

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NO WOf IAILLICDO EVnutfZO MCA

REMEDIAL ACTION ALTERNATIVES EVALUATED

The entire lint of remedial alternatives considered for the Cape Fear Sitecan be found in the previous Fact Sheet or in the Final Draft FS document(dated December 16, 1988) located in the IR/AR. These remedial actionalternatives were formulated considering contaminant types , contaminantconcentrations, and applicable technologies. The alternatives were thenevaluated based on technical feasibility and inplementability, long-term andshort-term effectiveness and impacts, protective ness of human health and theenvironment (i.e., level of risk reduction, compliance with ARARa or cleanupgoals, and reductions in contaminant mobility /toxicity/volume ), and cost. Asummary of the remedial action alternatives evaluated for the contaminated

•oils and sediments isprovided in Table 2.Similarily, Table 3and Table 4 presentthe remedial actionalternatives evaluatedfor groundwater/surface water and thehazardous materials,tanks, and piping,respectively.

SOILS/SEDIMENTALTERNATIVES

ALTERNATIVE 1S» NOACTION

This alternativeprovides the baselinecase for comparingsoil/sedimentalternatives and thelevel of improvementachieved. No remedialaction besidescontinued monitoringwould be performed.Given the lowsolubility of PAHs,natural soil flushingis not expected toreduce soilcontamination belowcleanup goals withinan acceptable timeframe.

Figure 3. Approximate Upper Aquifer Plume ExceedingPAH and Benzene Cleanup Goals

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No reduction in the mobility/toxicity/volume (M/T/V) of the contaminantspresent are realized. Cleanup goals will be exceeded.

ALTERNATIVE 25; PARTIAL EXCAVATION/DREDGING OF SOILS AND SEDIMENTS WITHSURFACE CAPPING

This alternative involves excavating contaminated soils outside the mainprocess area and excavating/dredging contaminated sediments.Excavated/dredged materials would be transported to the central process areaand capped along with the contaminated soils found in the process area.

Thii alternative would reduce the mobility of the contaminants but wouldnot alter the toxicityor volume. Thisalternative could beimplemented and

inEGEND

completedapprox imately 4 months.

ALTERNATIVE 3S; SOILAND SEDIMENT WASHING

Soil/sediment washinginvolves on-sitetreatment ofcontaminated soils andsediments with water anddetergents and/orsurfactants, ifnecessary. Soilsexceeding cleanup goalswould be excavated andprocessed through aseries of washingprocesses. The cleanedsoils would be replacedin the excavation. Thewastewater generatedwould be treated throughthe on-site watertreatment system.

This alternative reducesthe M/T/V of thecontaminants by removingthe contaminants fromthe soils/sediments.This alternative would

Figure 4. Approximate Lower Aquifer Plume ExceedingPAH and Benzene Cleanup Goals

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take approximately 2 years to complete once implemented.

ALTERNATIVE 4St THERMAL PROCESSING OF CONTAMINATED SOILS AND SEDIMENTSCOMBINED WITH FIXATION/SOLIDIFICATION/STABILIZATION ORWASHING

This alternative involves the excavation of all contaminated soils andsediments exceeding cleanup goals. Materials containing organic

TABLE 2. Development Of Remedial Action Alternatives For Soils/Sediments


IS No actionNatural flushing

2S Excavate isolated areas of soil contaminationExcavate/dredge sedimentsDewater dredged sedimentsCap soils and dewatered sedimentsRevegetate

35 Excavate/dredge soils and sedimentsWash excavated materials onsiteWater supply source:

A. Purchase from Fayetteville Public WorksCommission and truck to the site.

B. Purchase from a private water company and pipeto the site.

C. Install an onsite well outside the contaminantplume area.

Redeposit washed soils/sediments in the excavated areaRevegetate

4S Excavate/dredge soils/sedimentsDewater dredged sedimentsThermal process excavated materialsSolidify/stabilize processed soils/sediments andredeposit in the excavated area.Revegetate

S denotes remedial alternative for soil/sediment.

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TABLE 3. Development Of Remedial Action AlternativesFor Groundwater And Surface Water


1W* No actionLong-term groundwater monitoring

2W Groundwater extraction by well points and a deepwell Flocculation , sedimentation, andfiltration (surface and groundwater)Activated Carbon Adsorption (surface andgroundwater)Discharge treated effluent to surface water(western ditch)

3W Groundwater extraction by well points and a deepwell Flocculation, sedimentation, and filtration(groundwater and surface water)Air stripping (groundwater)Activated carbon adsorption (surface andgroundwater)Discharge treated effluent to surface water(western ditch)

4W Groundwater extraction by well points and a deepwell Groundwater treatmentFiltrationAir StrippingActivated carbon adsorptionSurface water treatmentPrecipitationFlocculation, sedimentation, and filtrationDischarge treated effluent to surface water(western ditch)

5W Groundwater extraction by well points and deepwell(s)PretreatmentPrecipitation (surface and groundwater)Flocculation, sedimentation, and filtration(surface and groundwater)Discharge to POTW

W denotes remedial alternative for groundwater or surface water.

Flocculation - The removal of suspended material by adding chemicalsresulting in the suspended materials formingheavier masses that will settle out.

-ID-

concentrations greater than cleanup goals (PAHs and benzene) would undergothermal desorption while soils with inorganic levels exceeding remediationobjectives (arsenic and chromium) would be eitherfixated/solidified/stabilized or ran through a soil washing process.

This alternative reduces the M/T/V of the contaminants by removing thecontaminants for the soils/sediments. This alternative would takeapproximately 2 years to complete once implemented.

GROUNDWATER ALTERNATIVES

ALTERNATIVE 1W; NO ACTION

The purpose of the no action alternative is to evaluate site impacts in theabsence of remediatioi As part of no action, groundwater monitoring wouldbe conducted.

No exposure pathways are eliminated and reduction in the risk level are.achieved. There is no reduction in the H/T/V of the contaminants. A 30-yeartime frame is used for comparative purposes.

ALTERNATIVE 2V?; PUMP SURFACE WATER AND EXTRACT GROUNDWATER AND TREAT THROUGHFLOCCULATION. SEDIMENTATION. FILTRATION AND ACTIVATED CARBONADSORPTION

Surface water and groundwater would be pumped to the treatment systemon-site. Surface water would be removed from the northeast swamp, drainageditch and diked pond before sediments remediation in these features.Groundwater extraction will be accomplished by well points in the upperaquifer. Recovery would be conducted at one approximate 10,000 square feeteubarea at a time, and the well points would be moved to adjacent subareasfor subsequent dewatering. The lower aquifer will be pumped following thecompletion of the remediation of the overlying upper aquifer to avoidpotential drawdown of the contaminants.

Extraction and treatment of contaminated groundwater and surface water willreduce contaminant M/T/V. The overall project duration from design toclosure is estimated to be about 3.6 years.

ALTERNATIVE 3W; PUMP SURFACE WATER AND EXTRACT GROUNDWATER AND TREAT THROUGHFLOCCULATION. SEDIMENTATION. FILTRATION, AIR STRIPPING ANDACTIVATED CARBON ADSORPTION

Surface water and groundwater would be pumped to the treatment systemon-site. Surface water would be removed from the northeast swamp, drainageditch and diked pond before sediments remediation in these features.Groundwater extraction will be accomplished by well points in the upperaquifer. Recovery would be conducted at one approximate 10,000 square feetsubarea at a time, and the well points would be moved to adjacent subareasfor subsequent dewatering. The lower aquifer will be pumped following thecompletion of the remediation of the overlying upper aquifer to avoidpotential drawdown of the contaminants.

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This scheme provides air stripping for groundwater and therefore achieves ahigher level of treatment than provided in Alternative 2W. Extraction andtreatment of contaminated groundwater and surface water will reducecontaminant M/T/V. The overall project duration from design to closure isestimated to be about 3.6 years.

ALTERNATIVE 4W: PRECIPITATION. FLOCCULATION. SEDIMENTATION AND FILTRATION OFSURFACE WATER. FILTRATION, SIR STRIPPING AND ACTIVATEDCARBON ADSORPTION OF GROUNDWATER

This alternative provides separate treatment for surface water andgroundwater based on the different contaminants found in these media.

Surface water will be pumped to a treatment system on-site. Surface waterwould be removed from the northeast swamp, drainage ditch and diked pondprior to sediment remediation in these targeted areas. Extractinggroundwater will be accomplished by well points in the upper aquifer andpumped to a separate treatment system. Recovery would be conducted at oneapproximate 10,000 square feet subarea at a time, and the well points wouldbe moved to adjacent subareas for subsequent dewatering. The lower aquiferwill be pumped following the completion of the remediation of the overlyingupper aquifer to avoid potential drawdown of the contaminants.


ALTERNATIVE 5W; PRETREATMENT OF GROUNDWATER AND SURFACE WATER WITH DISCHARGETO PUBLICLY OWNED TREATMENT WORK

As with other water alternatives, surface water will be pumped andgroundwater extracted through well points. The water will be pretreated, asdetermined by the publicly owned treatment work (POTW), and the effluent willthen be discharged to the POTW.


ALTERNATIVES FOR HAZARDOUS MATERIALS. TANKS AND PIPING

ALTERNATIVE 1C AND 1A; OFFSITE LANDFILLING OF CCA CRYSTALS ANDASBESTOS-CONTAINING PIPE INSULATION

Small quantities of apparent CCA crystals, characterized as hazardous, willbe transported to a RCRA permitted landfill. The asbestos-containinginsulation, characterized as non-hazardous, will be disposed of at theCumberland County Solid Waste Facility.

Contaminant mobility is reduced by removal. Since no treatment is evoked,toxicity and volume are unaffected. The above activities should be completedin a month.

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XLTERNATIVE 1SS; ONSITE DISPOSAL OF SOLIDIFIED SLUDGE

On-site disposal of creosote contaminated sludge which was previouslysolidified will be capped along with other soils and sediments (Alternative2S).

Disposing this solidified sludge on-site in association with a cap shouldreduce contaminant mobility but will have minimal affect on contaminanttoxicity and volume.

ALTERNATIVE 2SS; OFFSITE DISPOSAL OF SOLIDIFIED SLUDGE

If either Alternative 2S or 4S is not selected, the creosote contaminatedsludge will be transported to a RCRA permitted landfill for disposal.

Contaminant mobility is reduced by source removal, whereas toxicity andvolume are unaffected.

ALTERNATIVE 1L; ONSITE TREATMENT OF CCA SOLUTION AND/OR WASTEWATER IN TANKS

The liquids would be fed at a low rate into the treatment system establishedfor addressing the groundwater and surface water.

Contaminant mobility, toxicity and volume decrease with treatment.

ALTERNATIVE 2L; OFFSITE TREATMENT OF CCA SOLUTION AND/OR WASTEWATER IN TANKS

If Alternative 4W is not selected for surface water, other alternatives maynot be adequate to treat high contaminant concentrations since they are notspecifically targeted for metals removal. In this event, off-site treatmentat a RCRA permitted facility is necessary.

A reduction in the contaminants toxicity (reduction of hexavalent chromium)and mobility would be reduced. Volume would remain unchanged.

ALTERNATIVE 3L; OFFSITE TRANSPORT OF CCA SOLUTION

As an alternative to headstrong the 3 percent CCA solution, this solutioncould be shipped to another wood preserver for use.

This alternative would achieve.a reduction in the mobility and volume of thecontaminant but since there was no treatment, toxicity remains the same.

ALTERNATIVE 1T/P AND 2T/P; REMEDIATION OF TANKS AND PIPING

Nine tanks, eight above ground and one below, remain on-site and are targetedfor removal. In addition, piping associated with the tanks and piping tiedinto the wood treating process (both creosote and CCA) is scheduled forremoval. Tanks and piping will be render non-hazardous through steamcleaning, flushing and rinsing (triple rinse). Alternative 1T/P provides anopportunity for a scrap metal dealer to purchase the metal and Alternative2T/P allows for disposal of the cut up metal at the Cumberland County SolidWaste Facility.

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TABLE 2. Development Of Remedial Action Alternatives ForHazardous Materials, Tanks, And Piping

Material Alternative Technologies Employed

Apparent CCA Crystals

Asbestos Insulation(Assumed)

Solidified Sludge

CCA Wastewater and/orCCA 3% Solution

Tanks and Piping

1C

1A

1SS2SS

1L

2L

3L

1T/P + 2T/P

1T/P

2T/P

Offaite landfill (hazardous).

Offsite landfill (nonhazardous)

Onsite disposal.Offsite landfill (hazardous)

Treat wastewater and solutiononsite for Cr+6

Treat wastewater and solutiononsite with surface waters.

Treat wastewater and solutionoffsite.

Transport CCA solution offsite.

Locate (Piping)Empty (Tanks)Excavate (OST and Piping)Drain/Purge (Piping)Clean (Tanks and Piping)Cut (Tanks and Piping)

Dispose of as:Scrap metal

at an offsite landfill(nonhazardous)

C denotes Crystals (apparent CCA)A denotes Asbestos (assumed)SS denotes Solidified SludgeL denotes Liquid (CCA Hastewater and/or CCA 3% Solution)T/P denotes Tanks/Piping

Based on visual characterization. These materials were not sampled.

UST - Underground Storage Tank.

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EPA'S PROPOSED REMEDIAL ALTERNATIVE

Prior to initiating any remedial action on-site, a Bite survey will beconducted to determine the presence of any endangered plant species existon-Bite.


Off-site disposal of sodium dicrornate - copper sulfate - arsenicpentoxide (CCA) salt crystals, solidified creosote andasbestos-containing pipe installation. Since CCA crystals and thesolidified creosote are characterized as hazardous, they will be disposedof at a RCRA permitted landfill. The asbestos-containing pipeinstallation is characterized non-hazardous and will be disposed of atthe Cumberland County Solid Waste Facility pursuant to the facilitiesspecifications.

The tanks and associated piping, above and below ground, will be emptied,approximately 50,000 gallons of 3 percent CCA solution and 15,000 gallonsof CCA contaminated wastewater, flushed and cleaned, including triplerinsing, to render them non-hazardous. The metal will then be cut andeither sold to a local scrap metal dealer or disposed of at theCumberland County Solid Waste Facility. Tanks and/or piping that cannotbe cleaned sufficiently to render them non-hazardous will be transportedto a RCRA permitted landfill for disposal.

A buyer for the SO,000 gallons of 3 percent CCA solution will first bepursued. If no buyer can be found, then the 50,000 gallons of 3 percentCCA solution along with the 15,000 gallons of the CCA contaminatedwastewater as well as wastewater generated by on-site activities will betreated on-site through the water treatment system(B) set up for treatingthe pumped surface waters and extracted groundwater.


The preferred alternative for the remediation of contaminatedsoils/sediment is a soil washing technique. The alternate source controlalternative is an on-site low temperature process to remove the organiccontaminants followed by either a soil washing technique or soilfixation/eolidification/Btabilization process to address the inorganics.The decision as to which source control alternative that will beimplemented will be based on data generated by the soil washingtreatability study to be conducted during remedial design.

Contaminated soils/sediment will be excavated, treated and placed back inthe excavation. All wastewater generated will either be reused ortreated on-site. Following completion of on-site activities, those areasdisturbed by remedial activities on-site will be revegetated.

MIGRATION CONTROL (Remediation of Contaminated Groundwater}

Groundwater extraction will be accomplished through the use of wellpoints in the upper (surficial) aquifer. Recovery will be conducted in

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10,000 square foot subareas at a time, and the well points will be movedto adjacent areas for subsequential dewatering.


A water treatment system will be established on-site. The system'sinfluent will include contents of the tanks and piping, all wastewatergenerated due to remedial actions implemented, pumped surface water, andextracted groundwater. The level and degree of treatment will depend on1) the level of contaminants in the influent and 2) the ultimatedischarge point of the treated water. The range of treatment for thecontaminated water includes air stripping, filtration through activatedcarbon filter, bioreroediation, and metal removal through flocculation,sedimentation and precipitation. There are two water dischargealternatives for the treated water. The optimal choice is the localsewer system. The other alternative is to discharge the effluent to alocal surface stream. The point of discharge and the degree of treatmentwill be determined in the Remedial Design stage. The effluent will meetall ARAR's.

EXPRESS YOUR OPINION/PUBLIC COMMENT PERIOD

The Community's Role in the Superfund Process

EPA relies on the public to ensure that the cleanup method selected for eachSuperfund site meets the needs of the local community, in addition to beingan effective solution to the problem. To this end, EPA has set a publiccomment period from February 21 through February 14, 1989 to encourage publicparticipation in the selection process. In addition to the public commentperiod, the Agency held a public meeting at which the findings andconclusions of the FS will be presented to the public. Questions will beentertained at the meeting. The public meeting will be held on February 21,1989 at 7:00 pro in the Seventy-First Senior High School Auditorium at Route21, Box 479, Raeford Road, Fayetteville, North Carolina.

In addition, EPA has placed the RI/FS reports and this Proposed Flan in thepublic Information Repository. The Information Repository is located at theCumberland County Public Library and Information Center. EPA encouragesresidents and other interested parties to make written and oral comments onthe Proposed Plan and the FS document through February 14, 1989. Commentswill be summarized and responses provided in the Responsiveness Summarysection of the Record of Decision (ROD). The ROD is the document that statesEPA's final alternative selection.

At this point, however, the proposed alternative is merely the preliminarychoice for solving the contamination problems at the site. EPA will make thefinal selection only after consideration of all comments on any of theremedial alternatives addressed in this Proposed Plan and FS report.

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EPA encourages the public to become involved in the selection process byattending the public meeting, becoming informed, and commenting on thealternative presented. The Agency will accept oral or written commentsduring the public comment period. Comments, or requests for furtherinformation, should be sent to:

Michael HendersonCommunity Relations CoordinatorU.S. EPA, Region XV345 Courtland Street, NEAtlanta, GA 30365(404)347-3004

The Agency encourages concerned citizens to become involved and have theirnames added to the Cape Fear Wood Preserving site mailing list. If you areinterested, send your name and address to Jon Bornholm, EPA, 345 CourtlandSt., NE, Atlanta, GA 30365.

RECORD OF DECISION

The Record of Decision (ROD) is the decision document in which the Agencyselects as well as supports the remedial alternative to be implemented at aSuperfund site.

ADMINISTRATIVE RECORD/INFORMATION REPOSITORY

Section 113 (k) of the Comprehensive Environmental Response, Compensation,and Liability Act (Superfund), as amended by the Superfund Amendments andReauthorization Act (SARA), requires that the Agency establish anAdministrative Record (AR) at or near the site at issue for public review.The AR ie to contain all information used by the Agency to make its decisionon the selection of a remedial response under the Superfund Law.

EPA has established an Information Repository/Administrative Record at theCumberland County Public Library and Information Center. The InformationRepository/Administrative Record must contain all thedata/correspondences/documents/rationale used by the Agency in developing andchoosing the remedial alternative selected to clean up the site.

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