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r n r- -, .- -, Record of Decisionb y u U 'j i ——————Remedial Alternative Selection
Site Name and Location
Carolina Transformer SiteFayetteville, Cumberland County, North Carolina
Statement of Basis and Purpose
This decision document presents the selected remedial action for theCarolina Transformer Site in Fayetteville, North Carolina. Theremedy was chosen in accordance with the Comprehensive EnvironmentalResponse, Compensation, and liability Act of 1980 (CERCLA), asamended by Superfund Amendments and Reauthorization Act of 1986(SARA), and to the extent practicable, the National Oil and HazardousSubstances Pollution Contingency Plan (NCP). This decision documentexplains the factual and legal basis for selecting the remedy for thesite.
The State of North Carolina concurs with the selected remedy. Theinformation supporting this remedial action decision is contained inthe administrative record for this site.
Assessment of the Site
Actual or threatened releases of hazardous substances from this site,if not addressed by implementing the response action selected in thisRecord of Decision (ROD), may present an imminent and substantialendangerment to public health, welfare, or the environment.
Description of the Selected Remedy
The remedy selected by EPA will be the final action for the site.This action will address the remediation of the contaminatedgroundwater, soil, and sediments on and off-site The remedy willalso address the remaining waste materials present at the site.
The major components of the selected remedy include:
Excavation of the contaminated soil/sediment and use of asolvent extraction process to separate organic contaminantssuch as PCB, Dioxin /furans, volatile organics, andpolynuclear aromatic compounds from the soil and sediments.The process will convert inorganic contaminants such as leadand copper to lower solubility hydroxides thereby reducingtheir mobility. TCLP will be run on the treated soil andsediment prior to the return to its original location todetermine if it meets RCRA Toxicity Characteristic Rule.Soil and sediments not meeting the Toxicity Rule will besolidified. The contaminant rich waste stream will betransported off site for treatment.
--j Demolition of the roofs and walls of the three on-site(--j buildings. The debris will be crushed and transported to anO off-site landfill. If the remaining slabs are found to be
contaminated they will be treated with a solvent washingsystem to extract the PCBs.
ON Removal of the debris and solid waste from the site, whichwill be transported to an off-site landfill for disposal
Lr) and/or treatment in accordance with RCRA 40 CFR 264 Subpart0 and 40CFR 761 (a)(4)..
Installation of groundwater extraction wells in conjunctionwith a two component treatment system to remove the metalsand organic contaminants. Additional monitoring wells willbe installed into the lower aquifer to confirm its status.If it is found to be contaminated, the groundwater treatmentsystem mention above will be expanded to address thecontamination of the lower aquifer.
The treated groundwater will be discharged to theFayetteville Publicly Owned Treatment Works (POTW), or theunnamed tributary to the Cape Fear River.
Statutory Determinations
The selected remedy is protective of human health and the environmentand complies with Federal and State requirements that are legallyapplicable or relevant and appropriate to the remedial action. Thisremedy utilized permanent solutions- and alternative treatment (orresource recovery) technologies to the maximum extent practicable andsatisfies the statutory preference for remedies that employ treatmentthat reduces toxicity, mobility, or volume as a principal element.Since this remedy will result in hazardous substances remainingon-site above health based levels, a review will be conducted withinfive years after commencement of remedial action to insure the remedycontinues to provide adequate protection of human health and theenvironment.
C. Tidwell Date/ EPA Regional Administrator
I " "~ "~oduc *" ~ on
The Carolina Transformer Site was proposed for inclusion on theNational Priorities List (N?L) in July 1987. The Site has beer.the subject of a Remedial Investigation (RI) and FeasibilityStudy (FS) performed by the United States EnvironmentalProtection Agency (EPA). The RI , which was completed inSeptember 1990, consisted of a four phase investigation thatfully characterized the presence and extent of contamination onand off site by evaluating the sediments, surface water,groundwater, surface and subsurface soils. The Feasibility study(?S) develops and analyzes potential alternatives for remediationat the site and was issued to the public in draft form in March"" 9 9 0 .
1 . 1 Site Location and Description
The Carolina Transformer site is located in CumberlandCounty, North Carolina, approximately one mile northeast ofFayetteville and north of the intersection of U.S. Highway301 and River Road (Figure 1.0). The approximate mapcoordinates are latitude 35 03' 08" N and longitude 78 50'07" W.
The Site consists of approximately 4.8 acres of relativelyflat terrain and is bounded on the north by awooded/ swamp- like area which is adjacent to an agriculturalfield and numerous homes; on the west by a dirt road whichprovides access to two homes ; to the south by Middle Road,Larry's Sausage Company and Lundy Packing Company; and tothe east by an abandoned home site and an agricultural
on the site are a foundation ands of varying sizes. These are sithe front and northeast portion
hese buildings. Thetively open. Much of thedings has been paved with
1-1
t; Qu y 0 OG4
USGS. VANDEa NC (1987)FIGURE I .0SITE LOCATION MAPCAHOl INAFAYLI TLVILLL. NOHIH CAJOl INA
'f-SX EDGEJV\ PROPERTY
DRAINAGE DITCH
LMRRY'SSAUSAGE
CAROLINATRANSFORMER
SRI03°
FIGURE l.lSITE MAP
UN FEETI1 INCH = 160 FT.
CAROLINAFAYETTEVILLE
TRANSFORMER. NORTH CAROLINA
2.0 Site History and Enforcement Activities
2.1 Site History
\O Carolina Transformer Company (CTC) conducted an electricalf~j transformer rebuilding and repair business from 1957 to 1982CD (Bussey, 1985). The first indication of business operationsCD on the site was the presence of two large buildings depicted
in the 1957 quadrangle map. According to a February 1985,Dun and Bradstreet printout, CTC was founded in 1958. Thefirst parcel of the site was deeded to CTC from Lizzie
^ Talbot McDaniel on February 7, 1959. CTC was incorporatedXay 6, 1959; however, 1965 was the first year the Cumberland
u^ County Tax Office records indicate property of the businesswas identified for tax purposes. In 1967, CTC sold 4.75acres of their property to R. L. Honbarrier.
During an interview on May 23, 1985, Mr. Thomas Stevens,North'carolina Department of Environmental Management(NCDEM), indicated that at one time CTC was one of thelargest firms of its type in the U.S., having clientsthroughout the southeastern U.S. and along the east coast.At no time during that period did CTC apparently operate asa PC3 storage and disposal site for owners of PC3transformers or PCS articles. However, it appears that aspart of their transformer repair and rebuilding operations,?C3 fluids were drained from transformers and not properlystored and managed.
In 1979, EPA conducted soil sampling at the site. Testingrevealed that about one and a half acres of the site werecontaminated with PCBs (Hatcher, 1984). According to theNorth Carolina Secretary of State's Corporate Divisionrecords, in 1979, Mr. Kenneth Strothers started a newtransformer company called Faytranco, which was located inFayetteville, North Carolina. In 1985 FayTranco was shutdc-.7n and dissolved.
According to EPA records, CTC relocated and changed its nameto Faytranco, Inc. in April 1982. On August 13, 1934, EPAstarted cleanup operations at the site, and approximately1,000 tons of contaminated soil were removed. Contaminationover 50 ppm of PCBs, however, still exists at the site(Hatcher, 1984) .
According to a deed dated November 29, 1984, the entire sitewas sold to Cumberland Electrical Repair, Inc. by CTCthrough Mr. Pearson and Mr. Miller. A deed, dated April 15,1985, indicates that Cumberland Electrical Repair, Inc.operated at the site for only about four and one half monthsbefore being ordered by the courts to return the property toCTC.
2-1
2.2 Enforcement Activities
^ After a highly publicized case in North Carolina concerning~ roadside dumping of PCB oil in July 1978, residents living
~~ near Carolina Transformer became concerned about possibleground water contamination from spills at the site. Samplestaken by EPA in 1978 and 1979 revealed contamination of soilon the site by PCBs and chlorobenzene (a PCB carrier
CTN compound) . PCB carrier compounds were also found in ashallow residential drinking water well about 250 feet west
I_Q of the site; this residence was later placed on theFayetteville water system. Sampling also revealed tracecontamination in Carolina Transformer's deep industrialwell. The State attempted to have Carolina Transformercorrect the contaminated soil problem at the site, to noavail.
In March 1982, sampling by the State determined that run-offfrom the site violated surface-water quality standards forPCBs. In 1984, EPA made efforts to have CarolinaTransformer clean up the site. When the efforts failed, EPAissued a CERCIA section 106 Administrative Order requiringthe company to remove and properly dispose of thecontaminated soil. After the company refused, EPA, usingCERCLA emergency funds, began to clean up the site in August1S34. During the removal action, EPA excavated 975 tons ofcontaminated soil and transported it to a hazardous wastelandfill permitted under the Resource Conservation andRecovery Act.
2-2
3.0 Highlight of Community Participation
°P. I Summary of Community Participation
^-5 A Community Relations Plan for the Carolina Transferee:0 Site was finalized in June 1989. A RI/FS Fact Sheet
was also prepared at that time. The RemedialInvestigation (RI) and Feasibility Study (FS) reportsalong with the Proposed Plan were released to thepublic on March 29, 1991. All of these documents as
L^ well as the Administrative Record were made availibleto the public via the Cumberland County Library.
The U.S. Environmental Protection Agency held a publiccomment period from March 29, 1991 through April 30,1991 for parties interested in commenting on theProposed Plan and RI/FS Reports. The public meetingproviding the results of the RI/FS and presentation ofthe proposed plan was held on April 17, 1991.
3-1
4.0 Scope and Role Of Operable Unit Within Site Strategy
4.1 The remedy selected by EPA for the Carolina TransformerCA Site will be the first and final action proposed for1"-"} this site. The selected remedy is protective of human^ health and the environment and complies with Federal<—> and State requirements that are legally applicable or
relevant and appropriate to the remedial action. Thisaction utilizes a permanent solution and will address
^ all contamination present at the site.
LQ The action selected will address the remediation of thecontaminated groundwater, soil, and sediments on andoff site The Remedy will address the remaining debrislocated in the on site buildings. The major componentsof the selected remedy include:
Excavation of the contaminated soil/sediment, whichwill be treated using a solvent extraction process toseparate organic contaminants such as PCB,Dioxin/furans, volatile organics, and polynucleararomatic compounds from the soil and sediments. Theprocess will convert inorganic contaminants such aslead and copper to lower solubility hydroxides therebyreducing their mobility. TCLP will be run on thetreated soil and sediment prior to its return to itsoriginal location to determine if it meets the RCRAToxicity Characteristic Rule. Soil and sediments notmeeting the Toxicity Rule will be solidified. Thecontaminant rich waste stream will be transportedoff-site for treatment.
Demolition of the roofs and walls of the three on-sitebuildings. The debris will be crushed and transportedto an off-site landfill. If the remaining slabs arefound to be contaminated they will be treated with asolvent washing system to extract the PCBs.
Removal of the debris and solid waste from the site,which will be transported to an off-site landfill fordisposal and/or treatment in accordance with RCRA 40CFR 264 Subpart 0 and 40CFR 761 (a)(4).
Installation of groundwater extraction wells inconjunction with a two component treatment system toremove the metals and organic contaminants. Additionalmonitoring wells will be installed into the loweraquifer to confirm its status. If it is found to becontaminated, the groundwater treatment system mentionabove will be expanded to address the contamination ofthe lower aquifer.
The treated groundwater to the Fayetteville PubliclyOwned Treatment Works (POTW), or the unnamed tributaryto the Cape Fear River.
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5.0 Summary of Site Characteristicsc^ .1 Topography and Surface Drainage
° The site consists of approximately 4.8 acres of relatively*—~* flat terrain. The area surrounding the site is generally
low-lying and swamp-like in character. The site itself issituated at the headwaters of an unnamed tributary whichflows from the west corner of the site less than two milesto the Cape Fear River. Other drainage ditches flow along
t_o Middle Road, west to the Cape Fear River and east to LocksCreek. (Fig. 5.1)
5 .2 Site Geology
The Site is located in the Coastal Plain physiographicprovince of North Carolina. The main stratigraphic unit inthe vicinity of the site is the Tuscoloosa Formation whichis of Alluvial origin and Upper Cretaceous in age. Thematerials comprising the Tuscoloosa Formation were derivedfrom crystalline rocks such as granities, gneisses, andschiscts which compose the adjacent Piedmont physiographicprovince. The soils formed from these crystalline materialsconsist of brown to tan, fine to coarse-grained sands; tan,silty sands; clayey sands; sandy clays; and grey to bluesandy clays.
The surficial soils at the site consist of the WickhamSeries and the Roanoke Series. Wickham Series soils covermost of the former facility area. These are well-drainedsoils that formed in loamy luvial sediments on terraces ofthe Cape Fear River and its major tributaries. The loamyhorizon is typically 40 to 60 inches thick and is underlainby sandy alluvial sediments. These are poorly drained soilsthat formed in stratified clayey sediments on terraces ofthe Cape Fear River and its major tributaries. The loamyand clayey horizons are generally 40 to 60 inches thick andoverlie the stratified sediments deposited by the river.
5.3 Site Hydrology
The Carolina Transformer Site may be underlain by as many asthree aquifers. The alluvial deposits where sand and gravelare present could provide large yields to wells. Availableinformation indicates that the alluvial aquifers are notpresently used for water supply in the area. The sands andclays of the Cape Fear and Middendorf Formation serve asaquifers in the Fayetteville area. Wells completed withinthese formations can be screened over a large interval whichcould cover sands and intervening clays. The sands providemuch higher yield and are the most productive aquifers inthe region. The bedrock possesses fracture permeability andis utilized for industrial supplies. A similar such wellwas used by Larry's Sausage Company, located adjacent to the
5-1
APPROXIMATE SCALE
7000 0 3500 7000
(IN FEET)1 Inch - 7000 ft.
SITE DRAINAGE PATTERN
CAROLINA TRANSFORMERFAYETTEVILLE, NORTH CAROLINA
FIGURE S.I
0 I 2
ContaminantAluminumBariumCadmiumChromiumCobaltCopperLeadManganeseMercuryNickelStrontiumTitaniumVanadiumYttriumZincTricMoroetheneTetrachloroetheneBiS(2-ethy!hexyl)
phthaiateMethyl ethyl ketoneTolueneCarbon disulfideBenzeneChlorobenzene1 ,2-Dichlorobenzene1 ,3-Dichlorobenzene1 ,4-Dichlorobenzene1 .2,4-TnchioroDenzenePCBsDioxins/furans
1Contaminants
Groundwater—T—TXX—TXTXXTXT———
T CXXXcX—XcXcc
'able 5.2and Media of
Media
Soil—XXXXXXX——————XXX———X—XX———Xcc
Concern
SedimentXXXXXXXX—XX—XXX—————X—XXXXXXcc
SurfaceWater
—————X—X———X——X———X——X——————c
— —
NOTE: T • Non-Carcinogenic Hazard Index >1.C » Carcinogenic Risk>iE-06.X - Detected at elevated level compared to background but does not pose a risk
to human health or the environment.-- - Not detected in elevated levels compared to background.
, - site. This well is 303 feet deep and is completed into theO bedrock from 12 feet to the total depth. Mr. J. D. Parker,CD President of the Carolina Sand and Gravel Company, Inc.,
indicated, during a conversation on June 22, 1989, thatexploration borings near the site, to the south andnorthwest, showed a thick clay lens starting at
^ approximately 20 feet below land surface (BLS) and extendingdown to at least 50 feet BLS. Copies of the exploration
l-O boring logs were later provided to EPA.
The shallow aquifer, located at a depth of five to eightfeet below ground surface, is flowing through a fine tocoarse sandy layer which varies in thickness from six to 13feet. The shallow ground water appears to flow in anortheasterly direction. The grey to blue-grey clay locatedunder the upper sand layer is very tough and dry (observedfrom samples), indicating that the clay is a very goodconfining layer separating the shallow aquifer from thedeeper aquifers.
5.4 Summary of Nature and Extent of Contamination
This section provides a summary of contamination found atthe Carolina Transformer Site by media. This sections alsooutlines the approximate locations of the contaminationfound. The Remedial Investigation Report (August 1990)gives a more detail account of contamination found at thesite. (Table 5.4 lists the contaminants and media ofconcern)
5.4.1 Groundwater
The results of the EPA field investigations at the CarolinaTransformer site indicates that contamination has occurredwithin the shallow aquifer beneath the site and that thecontamination is contained within the site boundaries. Theinvestigation included installation and sampling of 11temporary ("sand point") and five permanent monitoring wellsin the surficial aquifer in and around the site. Fivepotable water wells located to the north and east of thesite were also sampled.
PCS 1260 was detected in groundwater samples that wereobtained from temporary wells located in the center andsouth western sections of the site. PCB concentrationsdetected were 52 ug/1 and 25 ug/1. PCBs were not detectedaround the perimeter of the site or in the potable waterwells.
Purgeable organic compounds were detected at lowconcentrations (10 ug/1) in samples obtained from temporarywells located in the center, southwestern, and northeasternsections of the site. Detected were benzene, chlorobenzene,carbon disulfide, methyl ethyl ketone and toluene. Again,
5-2
"^ purgeable organic compounds were not detected beyond the^ perimeter of the site. The groundwater sample from^T" monitoring well MW-04 contained 10.OJ ug/1
1,1,1,-trichloroethane and other chlorinated solvents atconcentrations of 2,4J to 42 ug/1. (The numerical valuesaccompanied by a "J" indicates the quantitative value of
C\ the compound is an estimate.) Bis(2-ethylehexyl)phthalatewas detected at relatively high concentrations (920J ug/1)
LO in a sample from a well located in the center of the site.This extractable organic compound was also detected at lowlevels in a well located in the northeastern section of thesite. The down gradient monitoring well indicated higherextractable organic content than the upgradient well but thetotal value of extractables was less than 26J ug/1. Thesources of these extractables were probably industrialchemicals used during the active phase of the site. Withthe cessation of operations and the removal of accumulatedpetroleum products from the site, extractable organicsources are extremely limited. Phenol was detected in lowconcentrations (3.7J ug/1) in a temporary well on the northwestern perimeter of the site. This was the only compounddetected at elevated concentrations in the groundwaterbeyond the perimeter of the site.
High concentrations of barium, chromium, copper and nickelwere detected in the groundwater from wells in the center ofthe site. Pesticides were not detected in groundwater fromany of the wells sampled.
The data for lead levels in the shallow aquifer wereinsufficient to determine the source of lead or whether thelevel is elevated over background. The results from the 11temporary wells indicated lead levels were below detectionlimits. The results from the five permanent monitoringwells indicated lead level ranging from 18 ug/1 to 190ug/1. This latter set of data indicated approximately equallead levels in upgradient and down-gradient wells. Based onthis body of data, it is uncertain whether lead levels ingroundwater are associated with current or previousconditions at the site.
5.4.2 Surface Water
The investigation conducted by EPA has also revealed PCBcontamination in the surface water contained in the drainageditch which runs through the site and into a wooded areasouthwest of the site. PCB was also found to be present inthe surface water contained in the low-lying marsh locatedto the north and west of the site. PCB 1260 contaminationrange from 2.8 ug/1 to 12 ug/1. Concentrations of copperwere elevated in these samples and a single extractableorganic compound, bis (2-ethylhexyl) phthalate, was alsofound.
5-3
*— Samples collected from Locks Creek, up- and down-gradientcp contained no detectable concentrations of PCBs, pesticides,° extractable organic compounds, or volatile organic
compounds. Samples taken contained similar metals atequivalent concentrations.
^ For extended periods of time there is no standing surface^ water on site or in the intermittent stream. This minimizes
the effects on human health and the environment from thismedia. Considering that surface water contamination is theresult of contact with contaminated soils, structures, anddebris the remediation of these other media will eliminatethe necessity for a separate remediation of surface waters.
5.4.3 Soil/Sediment
The site investigations conducted by the EPA have documentedthat the soils and sediments throughout the western andsouthern portions of the site contain moderate to highlevels of PCB compounds. In Figure 5.4 the extent ofcontamination is illustrated graphically. Since allelectrical transformers, condensers, and storage tanks haveeither been removed from the site or drained, the currentand primary source of this contamination is the on-sitesoil. Composite soil/debris samples taken from the mainbuilding, maintenance building, and burn building have beendetermined to contain PCB compounds at levels as high as2200 milligrams per kilogram (mg/kg). Therefore, residualsolids in these buildings must also be considered as sourcesof PCBs. Wipe samples taken from the interior walls of themain building and burn building detected PCB atconcentrations ranging from <1 ug/100 cm to 5.6 ug/100cm . However all samples taken are within Toxic SubstanceControl Act (TSCA) PCB spill Policy limits.
Limited sampling for dioxins/furans confirmed thesecontaminants to be present in the on-site soil, off-sitesoil, sediments, and building soil/debris. The highest soillevels [470 to 550 nanograms per kilogram (ng/kg) toxicequivalent (TEQ)] were found in the on-site soil west of themain building and east of the raised foundation.Concentrations as high as 220J ng/kg TEQ were found in thesediments along the drainage ditch which receives runofffrom this area. However, the highest levels measured, up to19,OOOJ ng/kg TEQ, were found in soil/debris samples takenfrom the buildings on site. Pesticides were found in onlyoccasional samples at measurable levels. These may beresiduals from pest control efforts when the facility wasactive.
Extractable organic compounds were detected in a number ofon-site and off-site soil and sediment samples, however, fewspecific compounds were consistently detected around thesite.
5-4
NOTE: NUMfiERS INDICATE PCS CONCENTRATIONIN SHAI LOW SOII/StOIMENT SAMPLES0" to 2" DELOW GRADE.
( IN FtEDi" s.
SOU /SFDIMLNT PCB LEVEL
Again the sources of these extractables were probablyindustrial chemicals used during the active phase of the
L^ site. With the cessation of operations and the removal of' accumulated petroleum products from the site, extractable,-_ organic sources are extremely limited.
The most frequently detected purgeable organic compound atthe site was toluene. Toluene was detected in on-site and
rjx off-site soil samples generally at levels of 5 to 10 ug/kg.Toluene was also detected in sediment samples at levels of
i_O 1200J and 2400 ug/kg and in a soil/debris sample at a levelof 230 ug/kg. Toluene was probably used at the activefacility as a solvent with the contamination resulting fromspills or waste disposal practices.
Chlorobenzene and dichlorobenzene were detected in on-siteand off-site soil and sediment samples. Concentrations weregenerally less than 50 ug/kg but one sediment samplecontained over 750J ug/kg of dichlorobenzene and 48J ug/kgchlorobenzene. The higher soil sample concentrations werefound off-site along the drainage ditch which carriessurface runoff from the southern portion of the site. Thesources of chlorobenzene and dichlorobenzene were probablespills of transformer oil which occurred during the activephase of the facility since chlorobenzene compounds arefrequently used as PCB carriers in transformer oil.
The solvent trichloroethylene and tetrachloroethylene werefound in a few on-site soil samples at U to 4J ug/kg and ina few off-site soil samples at 5.2 ug/kg to 18J ug/kg.These contaminants probably resulted from operation of thesite since they are not present in the surroundingupgradient wells.
Concentrations of inorganics, with the exception of copper,were generally consistent with background values. Thebackground level of copper in the soil typically ranged fromless than 1 mg/kg to slightly above 3 mg/kg. The levels ofcopper found in on-site soil were as high as 2800 mg/kg nearthe burn building. The copper level in the soil/debrissample from this building was 130,OOOJ mg/kg. The burningof wire and electrical equipment may have spread copper.High levels of copper containing particulates cover much ofthe site. High levels of copper were found in soil/debrissamples taken in all of the on-site buildings. Otherinorganics such as mercury and arsenic were detected atelevated levels in a few soil and sediment samples.
5-5
6.0 Summary of Site Risks
5 9 00 i 86.1 Contaminants of Concern
A baseline risk assessment was performed to evaluate thepotential risks to human health and the environment fromexposure to the site contaminants of concern. The contaminatedmedia of concern are: onsite and offsite soils, sediments,groundwater and surface water. Onsite building debris andsolid waste is also a media of concern. Table 6-1 provides thesite contaminants of concern along with the exposure pointconcentrations. This concentration represents the upper 95percent confidence limit of the arithmetic mean.
6.2 Exposure Assessment
The following potential exposure scenarios were evaluated inthe risk assessment:
Current exposure of onsite trespassers to contaminants insoil through incidental ingestion and dermal contact, andin surface water and sediment through dermal contact.
Current exposure of offsite residents to contaminants insoil through incidental ingestion and dermal contact, andin surface water and sediment through dermal contact.Exposure through ingestion of garden produce grown incontaminated soil was also evaluated.
Future exposure of onsite residents to contaminants ingroundwater through ingestion, direct contact, andinhalation; and to contaminants in soil through incidentalingestion and dermal contact.
Future exposure of onsite residents to contaminants ingarden produce through ingestion of produce—grown incontaminated soil.
In addition to the above scenarios, three additionalassessments were conducted to assess highly contaminated areas.
Current exposure of offsite residents to an offsite areawith high levels of contaminated- soil on either side of thedrainage way immediately south of the site.
Current exposure of onsite trespassers to highlycontaminated debris in one of the site buildings.
Future exposure by onsite residents to groundwater fromonsite well number 44.
6-1
Table 6. 1Contaminant Exposure Point Concentration
ContaminantInorganic Elements
AluminumArsenicBariumCadmiumChromiumCobaltCopperLeadManganeseMercuryNickelStrontiumTitaniumVanadiumYitlrlumZinc
Pesllcide/PCBPCB-1248PCB- 1254PCB- 1260
Extractable Organlcs1 ,2,4-TrlchlorobenzeneBls(2-ethylhexyl)phthalate
Soil'Onsltemg/kg
——29
2.28.80.5
2.100160180
——--———91
ug/kg16.00043.000
650.000
ug/kg2.5
Ollsllemg/kg
—2.274--
8.43.14636
3000.03
—14
300—7456
ug/kg—--
1.800
ug/kg—
__
SedimentOnsltemg/kg1 1 .000
--56
2.415
4 22.500
95180--
4.311--32
6.673
ug/kg9.892
140
ug/kg----
Oflsltemg/kg27.000
--1404.629
5.158015095--
9.216—51
8.6260
ug/kg220
164.400
ug/kg----
GroundwaterOnsite
ug/13,100.000
—18,000
—2,800
6702.900
17024.000
0.341,2001 .4006,5004.9001,5003.500
ug/l----51
ug/l5.051
Olfslleug/l
850,000--
'2,300--
840250350150
13.000.40
520740
5.1002,000
4901,000
ug/l----1.6
ug/l5.05.0
Surlace WaterOnsite
ug/l------------
130--
440------
5.0----78
ug/l----
5.2
ug/l--
2 5
Otlslteug/l
----------
130--
480------12----
160
ug/l----12
ug/l—
100
* Hoi Spot *Well 44
ug/;3.100.000
--19.000
--2,900
6703,000
--8,900
--1,2001.400
--4,9001,5003.500
ug/l----52
ug/l—--
Soilmg/kg
----48----
0.50.51166.05----------
0.5
ug/kg----
280
ug/kg----
Debrismg/kg16,000
775509.013021
130.000760
1,3002.550
31--
1.000
ug/kg- --
2.200
ug/kg----
O
* The hot spot denoted In the table is representative of off-site PCB s o i l c o n t a m i n a t i o nNOTK
1. The values denoted for off-site samples are inaxito represent background concentrations.
exposure concentration and were not intended
Table 6. 1 (continued)Contaminant Exposure Point Concentration
ContaminantPurgeable Organics
1 ,2-Dichlorobenzene1 ,3-Dichlorobenzene1 ,4-DichlorobenzeneBenzeneCarbon DlsulfideChlorobenzeneMethyl Ethyl KetoneTetrachlorobenzeneTolueneTrichlorobenzene
Dloxins/FuransTEQ
Soil 'Onsiteug/kg
--—--
2.5..
2.5--
0.56.22.0
no/kg750
Offsiteug/kg
5.0--
5.0----—----1518
ng/kg29
SedimentOnsiteug/kg
47140500
24--64----
9.4--
ng/kg220
Oflsiteug/kg
5.05.05.02.5--
25----
1.2--
ng/kg160
GroundwaterOnsite
ug/l--
5.05.02.81119
76--
3.9--
ug/l--
Oflsiteug/l
--8.02756
2.52.57.7--
^~ 2.5--
ug/l--
Surface WaterOnsite
ug/l_ _--
--14----------
ug/l--
Offsiteug/l
--------38----------
ug/l—
Hot SpotWell 44
ug/l------
2.86.720--------
ug/l--
Soilug/k(|
22--44--------- -
0 5- _
ng/kg--
Debrisug/kg
------------
?30-
ng/kg19,000
o
-- Indicates no exposure point concentration for this contaminant
v-The potentially exposed populations for current scenarios werereconsidered to be current off site residents, both children ar.dCD adults and current teenage trespassers. The potential futureCD populations that were evaluated were children and adult onsite
residents.
The exposure frequency for the residential scenarios was daily^exoosure or 365 days per year. The trespasser exposure
frecuencv was assumed to be one day per week or 52 days peruriyear. The exposure duration for the adult and child resident
was 30 and 5 years respectively. The exposure duration for thetrespasser was for 30 years.
The soil ingestion rate was assumed to be 200 mg/day forchildren six years and under and 100 mg/day for individualsover six years. T̂ he skin surface area for dermal contact was8620 cm2, 7000 cm2 and 3160 cm2 for adults, teenagers andchildren, respectively. The groundwater consumption rate was 2L/day for adults and 1.4 L/day for children. The inhalationrate was assumed to be 0.6 irr/hr for all groups. Thevegetable consumption rate was assumed to be 0.201 kg/day.
6.3 Toxicity Assessment
Cancer potency factors (CPFs) have been developed by EPA'sCarcinogenic Assessment Group for estimating excess lifetimecancer risks associated with exposure to potentiallycarcinogenic^chemicals. CPFs, which are expressed in units of(mg/kg-day) "•", are multiplied by the estimated intake of apotential carcinogen, in mg/kg-day, to provide an upper-boundestimate of the excess lifetime cancer risk associated withexposure at that intake level. The term "upper bound" reflectsthe conservative estimate of the risk calculated frorr. the CPF.Use of this approach makes underestimation of the actual cancerrisk highly unlikely. Cancer potency factors are derived fromthe results of human epidemiological studies or chronic animalbioassays to which animal-to-human extrapolation anduncertainty factors have been applied. The CPFs for the sitecontairiinan-s of concern are contained in Table 6-2.
Reference doses (RfDs) have been developed by EPA forindicating the potential for adverse health effects fromexposure to chemicals exhibiting noncarcinogenic effects.Rfbs, which are expressed in units of mg/kg-day, are estimatesof lifetime daily exposure levels for humans, includingsensitive individuals. Estimated intakes of chemicals fromenvironmental media (e.g., the amount of a chemical ingestedfrom contaminated drinking water) can be compared to the RfD.RfDs are derived from human epidemiological studies or animalstudies to which uncertainty factors have been applied (e.g.,to account for the use of animal data to predict effects onhumans). These uncertainty factors help ensure that the RfDswill not underestimate the potential for adversenoncarcinogenic effects to occur. The RfDs for the sitecontaminants of concern are contained in Table 6-2.
6-2
uo L /.
TABLE 6.2TOXICITY VALUES
CrIE.'.liCALSORAL
SLOPEFACTOR
Carbor CisJfide
RfD
1.0E-01
REFERENCE
IRIS
INHALATIONSLOPE
FACTORPI)
2-S-'.an;r,8 : , SCC.-C2 !R S . 9 C E - C 2
REFERENCE
HEASTTnchioroelheneBenzeneTetrachlcroetheneTolueneChlorobenzene1 .3-OichJoro£enzene1 ,4-DicMorobenz»n«1 ,2-Oichlorobenzen»1 ,2,4-Trichlorobenzen«bis<2-Ethyihexy1)PhUialat«AluminumArsenicBariumCadmiumChromiumCobaltCopperLeadManganeseMercuryNickelStrontiumTitaniumVanadiumYttriumZincDie:drinA/ochlor-1016Arochloc-1221A/ochlor-1232A/ochlor-1242A/ochfor-124«A/ochlor-1254Arochlor-12602.3.7.8-Tetra-CDD1.2.3.7,8-Penta-CDD1,2,3,4,7.8-Hexa-CDD1 .2,3.4,8.7.8-H»pta-CDDOcta-CDD2,3.7.8-T«lri-COO1,2 3,7.8-P«nl»-COD1.2,3.4,7.»-H«x«-COO1 .2,3.4.6,7.»-H«pU-COFOcta-CDF
1.1E-022.9E-025 1E-02
24E-02
1 4E-02
2.0E+OO
1.8E+017.7E+007.7E+007 7E+007.7E+OO7.7E+OO77E+OO7 7E+OO1 5E+05
82E+03
8.2E+O3
7 4E-C3
1 OE-022.0E-012. OE-02
9 OE-022.0E-O22.0E-02
1.0E-037.0E-025.0E-045.0E-03
1.0E-0130E-042. OE-02
7.0E-03
2.0E-015.0E-05
HEALTH ADV.IRISHEAST/IRISIRISIRIS
HEASTIRISHEASTIRIS
HEASTIRISHEASTIRIS
IRISHEASTHEAST
HEAST
HEASTIRISIRISIRISIRISIRISIRISIRISIRISHEAST
IRIS
IRIS
1.3E-022.9E-023.3E-03
5.0E+01
8.1E+004.1E+01
1.8E+01
1.5E+05
8.2E-H03
6.2E*C3
5.0E-03
4. OE-023.0E-03
1.0E-04
3.0E-04
IRISIRISHEAST
HEAST
HEASTHEAST
HEASTHEASTHEASTIRIS
HEAST
IRIS
HEAST
IRIS
IRIS
NOTES:IRIS - INTEGRATED RESEARCH INFORMATION SYSTEM, (8/90)HEAST - HEALTH EFFECTS ASSESSMENT SUMMARY TABLES (3RD QUARTER. FY 1990)RfD-REFERENCE DOSE
.v-jln addition, the dermal exposures at the site require CPFs and-\jRfDs which have been converted to reflect adsorbed doses ratherOthan administered doses. The toxicity values which have been~j extrapolated to represent adsorbed doses are contained in Table
6-3.
6 . 4 Risk Characterization
Excess lifetime cancer risks are determined by multiplying theintake level with the cancer potency factor. These risks areprobabilites that are generally expressed in scientificnotation (e.g^, 1 x 10 or IE-6). An excess lifetime cancerrisk of 1x10 indicates that, as a plausible upper bound, anindividual has a one in a million chance of developing canceras a result of site-related exposure to a carcinogen over a70-year lifetime under the specific exposure conditions at asite. The Agency considers individual excess cancer risk inthe range of "lO~4 to 10~6 as protective; however the 10~brisk level is generally used as the point of departure forsetting cleanup levels of Superfund sites.
Potential concern for noncarcinogenic effects of a singlecontaminant in a single medium is expressed as the hazardquotient (HQ) (or the ratio of the estimated intake derivedfrom the contaminant concentration in a given medium to thecontaminant's reference dose). By adding the KQs for allcontaminants within a medium or across ail media to which agiven population may reasonably be exposed, the hazard index(HI) can be generated. The HI provides a useful referencepoint for gauging the potential significance of multiplecontaminant exposures within a single medium or across media.
The carcinogenic risk level for ail populations exceeds theupper level ( 10 ) of the EPA acceptable risk range. Forcurrent onsite trespassers, the lifetime excess cancer risk is8.5 x 10""1 primarily from contact with PCBs in site soils,surface water and sediments . A hot spot scenario fortrespasser contact with site debris produced an unacceptablerisk level of 1.8 x 10" , primarily from ingestion and dermalcontact with PCBs and dioxin/furans . For current adult off siteresidents, the lifetime excess cancer risk is 1.6 x 10,whi^e current off site child residents have a risk of 5.7 x10" , primarily from dermal contact with PCBs in sediment.
For hypothetical future scenarios the cumulative lifetimeexcess cancer risk is 2.6 x 10~2 for adult onsite residentsand 1.4 x 10 for child onsite residents. The risks areprimarily related to exposure to PCBs in groundwater, surfacesoil, sediments and produce grown in contaminated soil. Therisks associated with exposure to groundwater from well number44 are 2.3 x 10~2 for adults and 1.3 x 10~2 for children.These risk levels reflect exposure via ingestion and dermalcontact with PCBs and inhalation of benzene.
6-3
5Lt 6.3
DZTVATDN C~ DERMAL CRITICAL TOXICITY VALVES
ORAL DERMAL
RID...
1E-37E-25E-45E-3...——
IE-13E-42E-2...
7E-3——
2E-1—
5E-21E-12E-29E-2
1E-22E-12E-27E-32E-2—
5E-5...
SF.-.
2E+0——————————————
2.9E-2-..————
2.4E-25.1E-2——
1.1E-21.4E-27.7E*01.6E+11.5E+5
AbsorptionFactor(a}
0.21.00.20.20.20.20.20.20.20.20.20.20.20.20.20.20.80.80.80.80.80.80.80.80.80.80.80.50.50.50.5
RfDfc)...
1E-31E-2IE-41E-3———
2E-26E-54E-3———
1E-3—
4E-2—
4E-28E-22E-27E-2———
8E-32E-12E-26E-3IE-2—
2E-5——
SF(c)——
— (d)——————————————
3.6E-2—————
3.0E-26.4E-2——
1.4E-22.8E-21.5E+13.2E+13.0E+5
CnemicalAJurr.i'v.r'
ArsenicBariumCadrr.i'jmChromium VICobaltCopperLeadManganeseMercuryNickelStrontiumTitaniumVanadiumYttriumZincBenzene2-Butancne(MEK)Carbon DisulfideChlorobenzene1.2-Dichlorobenzene1.3-Dichlorobenzene1.4-DichlorobenzeneTetrachloroetheneToluene1,2,4-TrichlorobenzeneTrichloroetheneBis(2-ethylhexyl)phthalatePCBsDieldrlnDioxins/Furans (TEQ)
(a) Based on USEPA HEAs and ATSDR documents(b) Dermal Rfd - Oral R(D X Absorption Factor(c) Dermal SF - Oral SF/Absorptlon Factor(d) Dermal extrapolation of Arsenic inappropriate due to localized effects
r\j The His for ail current scenarios are below the level ofCD concern (1.0). The His for all future scenarios are all aboveCD 1.0. Future'adult and child onsite residents have His of 60
and 200 respectively. The main HI contributors are metals(barium, chromium, nickel, vanadium, manganese) and bis{2-ethylhexyl) phthalate. Exposure to groundwater from well
^ number 44 results in a noncarcinogenic HI of 200 for adults and700 for children, again due to metals and a significant
L-' contribution to risk from chlorobenzene being inhaled in theshowering scenario.
Lead was evaluated using the lead Uptake/Biokinetic (UBK) Xodeideveloped by SPA. The model predicts that 68 percent of thechildren (age 0-7 years) exposed to lead at the site exposureooint concentrations would have blood lead levels above the EPAbenchmark level of 10 ug Pb/dl. The major contributor to thisoredicted percentage is the groundwater lead exposure pointconcentration of 170 ug/1. This concentration also exceeds theEPA action level of 15 ug/1. There is some discrepancyconcerning the groundwater lead concentrations since lead wasnot detected in any of the onsite Phase 1 temporary wells butwas detected in the onsite Phase 3 permanent monitor wells.
Uncertainties associated with the risk characterization includederivation of exposure point concentrations, intakeuncertainties and the toxicity values which were used toevaluate the risk. Another important uncertainty stems fromthe fact that the risk calculations for dermal exposure assumea direct and consistent relationship between the oral toxicityvalues and the extrapolated dermal value. A final uncertaintyinvolves the discrepancy of the onsite groundwater data forlead between Phases 1 and 3 of the RI.
6.5 Environmental Risks
The site habitat consists of four types: wooded area, wetlands,agricultural and grassy area. No special management, preserveareas or parks are located at the site and threatened orendangered species have not been documented at the site. Manyareas onsite and in the drainage ditch along the north boundaryof the site either lack vegetation or had less growth thanadjacent areas.
Surface water concentrations of several chemicals (copper,zinc, toluene, PC3) were above ambient water quality criteria.However, these chemicals were detected in surface water samplesfrom locations which did not retain water throughout the year.For this reason, these areas may not be able to sustain aquaticecosystems.
6-4
^Several chemicals of concern (lead, benzene, chlorobenzer.e,^?C3s) in soil, sediment and surface water at the site have the"'potential for toxic effects and bioaccumulation which may causeadverse effects to some species via the food chain. This is amajor concern for PCBs which may have adverse effects on
-v^ aquatic species, terrestrial animals, birds, plants, amphibians^ and reptiles which frequent the site.L-O
6-5
7 .0 Description of Alternatives'"SioCD
L-0
This section outlines the alternatives that were considered toremediate the following media: groundwater, soil/sediment,structures, and debris/solid waste. The alternatives are presentedand organized by media and are described separately, however thefinal remedy will be a combination of the alternatives listed. Thealternatives decribed in this section are listed below.
Groundwater AlternativesG-l No ActionG-2 Deed RestrictionG-3 Metals Removal/Air Stripping/
Adsorption/DischargeG-4 Metals Removal
Adsorption/DischargeG-5 Adorption/DischargeG-6 Metals Removal/UV
Oxidation/Discharge
Soil/Sediment AlternativesS/S-1 No ActionS/S-2 Fence/Deed
RestrictionS/S-3 Excavation for
Offsite LandfillS/S-4 Excavation for Onsite
IncinerationS/S-5 Excavation for Onsite
Chemical DechlorinationS/S-6 Excavation for Onsite
Solvent Extraction
Structures Alternatives
S-l No ActionS-2 FencingS-3 Partial DemolitionS-4 Complete Demolition
Debris/Solid Wastes Alternatives
D-l No ActionD-2 FencingD-3 Offsite Disposal
7.1 Groundwater
Alternative G-l; No Action. The "no action" alternativewould not involve any remedial action, and the site wouldbe left in its present condition. Funds would not beexpended for monitoring, control, or cleanup of thecontaminated structures. This alternative, which isrequired by the NCP and SARA, is a baseline to which theeffectiveness of other alternatives is compared.
Alternative G-2; Deed Restrictions. This alternativewould consist of placing restrictions on the deeds of thesite and adjacent properties which would prohibit the useof water from the shallow aquifer and the construction ofany new wells into the shallow aquifer. Monitoring of theexisting groundwater wells should be continued on aquarterly basis. The sole effect of this alternative isto eliminate all direct contact with groundwater from theshallow aquifer. The prohibition against all use ofgroundwater from this aquifer, including noncontactcooling and noneatable crop irrigation, would beimplemented to eliminate exposure to fish, water fowl, andother environmental populations. Acceptance of deed
7-1
uor .-> r- restrictions by of f site property owners would beU £. u voluntary. State and local governmental agencies would be
responsible for enforcement of any deed restrictions.
Alternative G-3; Metals Removal/Air Stripping/Adsorption.This alternative involves groundwater extraction usingwells followed by treatment to remove both metalcontaminants and organic contaminants. This alternativewould consist of a groundwater extraction system and threetreatment components. The groundwater extraction systemincluded for this alternative is common for allalternatives that withdraw groundwater for treatment.
The groundwater extraction technique chosen for detailedevaluation is the multiple well point system. This systemwould consist of approximately 23 to 25 well points locatedin a line along the western and northern site boundaries.The RI indicated the hydraulic gradient of the surficialaquifer slopes to the northwest. A line of extraction wellpoints on these boundaries would intercept groundwatermigrating from the site.
The well points would be constructed of 2-inch PVC casingswhich would be screened only in their lower one to twofeet. The well points would be installed to the top of theclay layer which underlies the site at an assumed averagedepth of 9.5 feet below grade.
The individual wells would be connected by insulated PVCheaders installed above ground on blocks. A regulationvalve must be installed on each well's connection to theheader to control flow from the well. This prevents somewells from experiencing excessive drawdown of thegroundwater level compared to other wells on the header. Aminimum of two headers would be used; one serving the wellpoints along the northern site boundary, the other servingwell points along the western boundary. More than oneheader might be used along each boundary if required by thehydraulics of the system.
The headers would be connected to a single, above-gradepump which would pump the groundwater to the treatmentcomponents.
The first treatment component would consist of a skidmounted, packaged, electrochemical metal removal system.This system would consist of a reaction tank, clarifier,sludge thickening and dewatering equipment, multi-mediafilter, chemical storage and feed equipment, and controls.The filter would ensure that precipitant fines do not leavethis process. The sludge, which contains the metal ionsremoved from the groundwater, would be dewatered by a 15cu.ft. capacity filter press. The filler backwash andrecovered water would be returned to the head of the
7-2
precipitation system. The dewatered sludge, estimated to be30 percent solids, would be disposed of in an offsite RCRAlandfill.
Following the metals removal system, the groundwater wouldenter a packed-bed air stripping unit. Volatile organics(e.g., benzene, chlorobenzene, toluene, and carbondisulfide) would be stripped from the aqueous stream andcaptured in activated carbon filters on the vent. When theactivated carbon is spent, it is replaced with fresh sorbantand the spent material is sent to an offsite recoveryfacility. The organics are ultimately incinerated duringsorbant recovery.
The final component is an activated carbon absorption systemto remove non-volatile and semi-volatile organics includingdichlorobenzene, 1,2,4-trichlorobenzene, andbis(2-ethylhexyl)phthalate. When the activated carbon isspent, it is replaced and the spent material is sent offsitefor recovery or disposal. If the activated carbon isrecovered, the organics are ultimately incinerated. If thecarbon is not recovered, the organics are ultimatelydisposed of in a landfill along with the carbon.
Two discharge options have been developed for thisalternative, varying on the discharge point for the treatedgroundwater. Alternative G-3A is based on discharge to theunnamed tributary to the Cape Fear River. Alternative G-3Bis based on discharge to the POTW.
Alternative G-4; Metals Removal/Adsorption. Thisalternative is the same as G-3 except air stripping is notused to remove volatiles. The activated carbon usage ratewill be higher for this alternative. Alternative G-4A isbased on discharge to surface waters; Alternative G-4B ondischarge to the POTW.
Alternative G-5: Adsorption. This alternative (Figure 4-5)involves groundwater extraction using the well point systemfollowed by treatment to remove organic contaminants. Somemetal concentrations would be reduced by activated carbonadsorption. Treated water would be discharged to the CapeFear River Tributary. Only spent carbon is generated fordisposal offsite.
Discharge to the POTW was not considered in conjunction withthis alternative for two principal reasons. First, theFayetteville POTW is a biological treatment facility andwould not provide significant removal of inorganics from thewastestream. Secondly, the City of Fayetteville is engagedin an extensive landfann program for disposal of the POTWsludges. For this reason, the City has stated it could notaccept the discharge from the Carolina Transformergroundwater remediation system unless metal removal wasprovided.
7-3
5 9 0 G v; 0 Alternative G-6; Metals Removal/UV Oxidation. Thisalternative is similar to G-4 except UV oxidation insteadof activated carbon adsorption is used to remove organiccontaminants. Metal sludge requires disposal offsite.Alternatives G-6A and G-6B are based on the same dischargeoptions as developed for Alternatives G-3 and G-4
Alternative G-7; UV Oxidation. This alternative issimilar to G-5 except UV oxidation is used to removeorganics. No residual waste requires disposal offsite.
As in Alternative G-5, the only discharge considered is tothe tributary of the Cape Fear River. The reasons for thisdecision were presented in Section 4.2.1.5.
1.2 Soil/Sediment
Alternative S/S-1; No Action. The "no action" alternativewould not involve any remedial action, and the site wouldbe left in its present condition. Funds would not beexpended for monitoring, control, or cleanup of thecontaminated soil/sediment. This alternative, which isrequired by the NCP and SARA, is a baseline to which theeffectiveness of other alternatives is compared.
Alternative S/S-2; Fence/Deed Restrictions. Thisalternative would involve the construction of a chain-linkfence, approximately 6 feet high to surround thecontaminated areas on site that are not currently fenced.The site is currently partially fenced. Approximately1,100 feet of additional fencing would be required tocompletely surround the site. Warning signs would bedisplayed on the fences to alert the public of potentialhazards. The fence would be effective in restrictingaccess and preventing exposure to the contaminatedsoil/sediment on site. The fence and deed restrictionswould not be effective at restricting access or preventingexposure to offsite soil/sediment such as that present inthe offsite portion of the watershed. It would not reducethe volume of contaminated soil/sediment on site.
Future uses of the property would also be restricted by theapplication of deed restrictions. State and local agencieswould be responsible for the implementation and enforcementof such restrictions.
This alternative, though lacking in effectiveness, servesas a minimal action alternative for comparison againstother alternatives.
7-4
Alternative S/S-3; Excavation for Offsite Landfill. Thisalternative involves the excavation of contaminated soilfor disposal in an offsite landfill. Soil with a PCBconcentration of less than 50 ppm (mg/kg) could be disposedof in a RCRA landfill such as the one located at Pinewood,South Carolina. Soil with a PCB concentration greater than50 ppm must be disposed of in a TSCA landfill such as theone located at Emelle, Alabama. Where necessary, nativesoil will be used to return the surface contours toapproximately the existing elevations to ensure adequatesite drainage. No backfill would be placed in drainageways if adequate drainage could be maintained without it.All fill soil and disturbed areas would be revegetated withnative grasses to control soil erosion. Because the soilwould be remediated to the extent that onsite activitieswould pose no health risk, additional fencing would not berequired.
Two options have been developed for this alternative,varying on the PCB concentration used to determine theextent of excavation.
Alternative S/S-3A involves the excavation of all onsiteand offsite soil/sediment with a PCB concentration ofgreater than 1 ppm. It is estimated that AlternativeS/S-3A would require excavation of 15,345 cubic yards (CY)of contaminated soil/sediment with a PCB content of greaterthan 1 ppm. Of this total approximately one-half (7630 CY)have a PCB content of less than 50 ppm and could bedisposed of in a RCRA landfill. The remainder (7715 CY)have a PCB content of 50 ppm or greater and must betransported to a TSCA certified landfill. Returning thenon-drainage way areas to the existing elevations wouldrequire 5780 CY of fill material.
Alternative S/S-3B is similar to the first alternative withthe exception that onsite excavation would be limited tosoil/sediment with a PCB concentration greater than 10ppm. All onsite soil/sediment with a PCB concentration ofgreater than 1 ppm (including the unexc*vated areas) wouldbe covered with a minimum of 10 inches of clean soil. Morecover material may be required for some areas to maintainadequate site drainage. Offsite contaminated soil/sedimentoccurs primarily in the storm water drainage ways where itwould be difficult to ensure the maintenance of 10 inchesof cover over soil/sediment exceeding 1 ppm. Therefore,offsite soil/sediment would be remediated to a level of 1ppm as in Alternative S/S-3A. This alternative wouldrequire approximately 1575 CY less excavation thanAlternative S/S-3A. Approximately 6055 CY would betransported to a RCRA landfill and 7715 CY would betransported to a TSCA landfill.
7-5
5 9 OQ32Alternative S/S-4; Excavation for Onsite Incineration.This alternative involves the excavation of contaminatedsoil/sediment followed by onsite incineration andredeposition in the original locations. The onsiteincinerator would be a mobile type capable of achieving99.9999 percent PCS destruction. At this level ofdestruction it may be possible to return the treatedsoil/sediment to its original location. However, whileincineration will result in a high degree of organicdestruction, disposal of incineration residuals in a securelandfill may be necessary because of the elevatedconcentration of copper and lead in the onsite and offsitesoil/sediments. A pilot test of the incinerator andadditional soil testing to determine the extent of onsitecopper and lead contamination would be required todetermine whether the treated soil/sediment could bereturned to its original location or would require disposalin a landfill meeting RCRA standards or nonhazardous designstandards. For purposes of this FS, it is assumed that thetreated soil/sediment would be non-hazardous and could bedisposed of by returning the soil to its original location.
The same two options developed for Alternative S/S-3 willbe considered for the onsite incineration alternative.Alternative S/S-4A would excavate and incinerate all onsiteand offsite soil/sediment which has a PCB content ofgreater than 1 ppm. The treated soil/sediment would thenbe returned to its original location. The treated areaswould be graded, compacted, and seeded to control erosion.No additional access controls would be required either onsite or off site.
Alternative S/S-4B would excavate and treat the same volumeof offsite soil/sediment but would excavate only theportion of onsite soil/sediment which exceeds 10 ppm. Thetreated soil/sediment would be returned to its originallocation. Onsite soil/sediment with a PCB content between1 ppm and 10 ppm would be covered with 10 inches of cleansoil. This soil could be either treated soil/sediment fromthe incineration unit or soil from an offsite source.Alternative S/S-4A would require 15,345 CY of excavationand no additional backfill material. Alternative S/S-4Bwould require 13,770 CY of excavation. It is assumed thatthe 5780 CY of cover material required would be suppliedby the treated soil/sediment.
Alternative S/S-5; Onsite Chemical Dechlorination. Thisalternative is very similar to Alternative S/S-4 exceptthat the excavated soil would be chemically treated todechlorinate chlorinated hydrocarbons such as PCBs toproduce a nonhazardous material. In the chemicaldechlorination process, contaminated soil/sediment and analkaline chemical reagent solution would be mixed in abatch reactor to form a slurry.
7-6
The slurry is then heated and the reagent reacts withchlorinated hydrocarbons in the soil/sediment to remove thechlorine atoms and convert them to inorganic chlorides.The soil/sediment and reagent solution are separated in acentrifuge or filter. Additional reagent is added to therecovered solution and the solution is recycled. Thetreated soil/sediment is dewatered and washed to remove theresidual reagent solution. The wash water is alsorecycled.
The dechlorination system does not remove inorganiccontaminants such as copper and lead; however, some amountof removal of soluble compounds would be achieved in thesoil washing process.
Pilot testing of the dechlorination process would berequired to determine the reagent chemical consumptionrates, optimum process parameters, and effect on inorganiccontaminants. It is assumed based on previous tests onsimilar media and organic contaminants that the treatedsoil/sediment would be nonhazardous and could either bereturned to its original location or disposed of in anon-hazardous material landfill. Disposal in a RCRAlandfill would be required only if the treatedsoil/sediment remained hazardous due to leachate frominorganic contaminants. This would be established byconducting TCLP analyses on the treated soil/sediment. Forcomparison with the other soil/sediment remediationalternatives, it is assumed that the treated soil/sedimentwill be returned to its original location.
As in the two previous soil/sediment remediationalternatives, two options will be considered forAlternative S/S-5. Alternative S/S-5A would excavate andchemically dechlorinate all soil/sediment which has a PCBcontent of greater than 1 ppm; Alternative S/S-5B allsoil/sediment with a PCB content greater than 10 ppm. Thequantities of soil/sediment to be excavated anddechlorinated would be the same as in the parallel optionsin the onsite incineration alternative.
Alternative S/S-6; Onsite Solvent Extraction. AlternativeS/S-6 uses a solvent extraction process to separate organiccontaminants such as PCB, dioxin/furans, volatile organics,and polynuclear aromatic compounds from soil and sediment.The process produces a treated soil/sediment and acontaminant-rich waste stream which would be incineratedoff site. This alternative is similar to AlternativeS/S-5 in that the contaminated soil/sediment is excavatedand chemically treated on site. In this alternative,however, the organic contamination in the media isconcentrated in a separate waste stream rather thandetoxified by dechlorination.
7-7
5 y 0 U 0 4 ^n a typical solvent extraction system applicable tocontaminated soil/sediment, the soil/sediment is firstscreened, then placed in a batch washer-dryer. In thewasher-dryer, the solvent is added and the media andsolvent are mixed. The organic contaminants are removedfrom the soil/sediment into the solvent fluid. The solventis decanted from the mixer and sent to the solvent recoverysystem. For highly contaminated media and high removalrates, multiple solvent extraction steps may be necessary.After decantation of the solvent, the soil/sediment mediais then dried by the introduction of steam into thewasher-dryer. Any remaining solvent is volatilized andcollected for reuse. The treated soil/sediment can then behandled using normal earth moving equipment.
Leaving the washer-dryer, the solvent solution containsboth the water and organic contaminants that were in thetreated media. A centrifuge or vacuum filter may berequired to achieve additional liquid/solid separation.The solids would be returned to the washer-dryer. Thesolvent solution is then heated to above 60 C which resultsin a very good separation of the solvent containing theorganic contaminants and the water which was originally inthe soil. Both the water and solvent streams are then sentto steam strippers which recover the TEA for reuse in theextraction step. The recovered contaminant stream isplaced in storage tanks for shipment to offsiteincineration facilities. The water stream may be suitablefor direct discharge or may be used for dust control on thetreated media. The relatively low moisture content of thesoil/sediment is expected to generate very little water fordisposal, therefore, costs will be based on use of thisflow for moisture control in the treated media.
The entire extraction process takes place at alkalineconditions which promote the formation of metalhydroxides. Therefore, conversion of inorganiccontaminants such as lead and copper to lower solubilityhydroxides may also be achieved in this process. Thesehydroxides would be retained in the treated soil/sediment.
The solvent extraction process is capable of achieving PCBand dioxin/furan removal efficiencies of over 99 percent.Since the process efficiencies varies with the type of soiland contaminant, a pilot test is required to establish thenumber of extraction steps, solvent requirements, andeffectiveness of the process. Such tests are also requiredto determine whether the treated soil/sediment can bereturned to its original location or must be disposed of ina landfill. For comparison with the other soil/sedimentremediation alternatives, it is assumed that the treatedsoil/sediment would be returned to its original location.
7-8
As in the previous soil/sediment remediation alternatives,two options will be considered for Alternative S/S-6.Alternative S/S-6A would excavate and treat allsoil/sediment which has a PCB content of greater than 1ppm; Alternative S/S-6B all soil/sediment with a PCBcontent greater than 10 ppm. The quantities ofsoil/sediment to be excavated and treated would be thesame as in the parallel options in the other soil/sedimentremediation alternatives. The same quantity of backfilland landfill cover required by the previous alternativeswould be required by these options also.
7.3 Structures
Wipe samples from the three onsite buildings determinedthat the walls of these structures exhibit surface PCBcontamination at levels below the TSCA requirements forhigh-contact, non-restricted access surfaces.Contamination levels of the floors of these structures andof the raised concrete platform are unknown but, based ondebris samples, they could exceed TSCA imposed levels.The structural integrity of the three onsite buildings isnot known.
Alternative S-l; No Action. The "no action" alternativewould not involve any remedial action and the sitestructures would be left in place in their presentcondition. Funds would not be expended for the monitoringor maintenance of the structures. This alternative is abaseline to which the other alternatives are compared.
Alternative S-2; Fencing. This alternative would involvethe construction of a 6-foot high, chain link fence tosurround the portions of the site that are not currentlyfenced. This alternative is identical to AlternativeS/S-2 described earlier.
Alternative S-3; Partial Demolition. In thisalternative, the roofs and walls of the three onsitebuildings would be demolished using heavy equipment andhand tools. The demolition debris would be crushed orshredded if appropriate to reduce the size of debris priorto transportation to offsite landfills. The total quantityof demolition debris generated by the roofs and walls ofthese structures would be approximately 970 CY. The floorslabs and the raised concrete platform would be left inplace. Because the extent of possible PCB contaminationof the floor slab surfaces is unknown, two options havebeen developed for this alternative.
Alternative S-3A is based on the assumption thatadditional wipe sampling of the floor slabs determines
7-9
that the PCB contamination is below the TSCA cleanuprequirement for high-contact, outdoor surfaces in anindustrial area, 10 ug/100 cm2. In this case, noadditional treatment of the structure slabs would berequired.
Alternative S-3B assumes that the wipe sampling indicatesthat specific areas of the floors are contaminated withPCBs at levels above 10 ug/100 cnr. As a basis forestimation of cost, it is assumed that the contaminatedarea consists of all of the floor area in the burn andmaintenance buildings, the one-half of floor of the mainbuilding (excludes the office area), and one-half of theraised concrete platform. This would result in a totalarea to be treated of 21,350 square feet (SF). Theseareas would be treated using a solvent washing system toextract the PCBs from the concrete. The used solvent andrinse water would be vacuumed from the floor and drummed.The drummed waste would be transported to an offsitelicensed incinerator.
Alternative S-4: Complete Demolition. This alternativeinvolves complete demolition of all three onsite buildingsand the raised concrete platform. The demolition wouldinclude, as applicable, roofs, walls, floor slabs, andfoundations. The demolition would be accomplished usingheavy equipment and hand tools. As in Alternative S-3,the debris would be crushed or shredded, as appropriate,to reduce the size of the material prior to beingtransported off site for disposal. The nonhazardousdemolition debris would be disposed of in the CumberlandCounty Landfill. This alternative would generate a totalof 2,195 CY of demolition material. Because the degree offloor slab contamination has not been determined, twooptions have been developed for this alternative.
Alternative S-4A is based on the PCB contamination of thefloor slabs being less than 10 ug/100 cm allowingdisposal of all slab material as nonhazardous wastes in anon-RCRA landfill. If isolated areas of surfacecontamination are detected through additional wipetesting, these areas would be removed from the slab bypneumatic or mechanical abrasive equipment. The removedmaterial would be collected and drummed for disposal ashazardous waste. For purposes of developing costs,Alternative S-4A will assume a total of 2,000 SF of floorarea exceeds the TSCA requirements of 50 ppm and must beremoved prior to general demolition. Assuming that 1 inchof material would be removed, 6 CY of hazardous materialwould be drummed.
Alternative S-4B assumes that PCB contamination of floorslabs is wide spread and, therefore, removal ofcontaminated material separate from the bulk of the floor
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nfy.;r7 slab is impractical. In this alternative, the slabs wouldu U J/ be treated by the solvent wash technique to remove the PCBs
from the concrete. The used solvent and rinse water wouldbe vacuumed and drummed for offsite incineration.Following the solvent wash, the slabs would be broken upand transported as non-hazardous material to the CumberlandCounty Landfill. As in Alternative S-3B, it is assumedthat 21,350 SF of floor slab would be treated by thesolvent wash equipment.
7.4 Debris/Solid Wastes
Alternative D-l: No Action. The "no action" alternativewould not involve any remedial action to collect, control,or remove debris or solid wastes from the site. Thisalternative is a baseline to which the other alternativesare compared.
Alternative D-2: Fencing. This alternative is identicalto Alternative S/S-2 described earlier.
Alternative D-3; Offsite Disposal. This alternative wouldtransport all debris and solid waste from the site fordisposal in offsite landfills. Solids processing such ascrushing and compaction or the cutting of large items suchas tanks into more manageable sizes would be performedwhere necessary prior to transportation. If the materialis nonhazardous, it would be transported to the CumberlandCounty Landfill, a non-RCRA facility. If the debriscontains more than 50 ppm of PCBs, it would be transportedto a TSCA landfill. If the debris contains less than 50ppm PCBs, but would be otherwise considered hazardous (e.g.failed EPA's TCLP leachate test), it would be transportedto a RCRA landfill.
As discussed in Section 3.3.4, PCBs were not detected inany of the large electrical transformers on site and weredetected in only one of the partially buried tanks onsite. These items would be cut up and disposed of asnon-hazardous materials. The one partially buried tankwhich did contain measurable quantities of PCBs (72 ppmtotal PCBs) would be drained and the drummed liquid wouldbe sent to an offsite incinerator as required by TSCA.This tank would then be handled in the same manner as theother tanks. The tanks and drained transformers havepotential value as scrap material, but this option will notbe considered in developing costs. The empty 55-gallondrums, ceramic insulators, and wooden pallets would also benon-hazardous materials and would be disposed of in thesanitary landfill. It is estimated that a total of 160 CY(80 tons) of solid waste and debris would be transported tothe Cumberland County Landfill.
7-11
,-. , o Tests on the dirt scraped from the floors of the threeU J u onsite buildings indicated that this material has a
substantial degree of PCB contamination. This materialwould be removed from the building floors, drummed, andtransported to a TSCA landfill. The existing Rl-derivedwastes which have been temporarily stored on site wouldalso be drummed and transported to the RCRA landfill. Thetotal volume of hazardous material transported to the RCRAlandfill would be approximately 20 CY (10 tons). An equalamount is assumed to be transported to the TSCA landfill.
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8.0 Summary of Comparative Analysis
This section presents a detailed evaluation of the alternativesdescribed in Section 7. Each alternative is evaluated, using thefollowing nine criteria. The results of the evaluation of eachalternative is then compared and the alternative that best meet therequirements of the nine criteria is identified.
Protection of Human Health and the Environment - Determineswhether each alternative meets the requirement that it beprotective of human health and the environment. This criterion isof key importance. While the remedy selected may on occasion seeka waiver of a given ARAR, the remedy selected must be protectiveof human health and the environment.
Compliance With ARARs - This evaluation is used to determine howeach alternative complies with federal and state (ARARs) asdefined in CERCLA Section 121. A presentation of chemical andlocation specific ARARs is contained in Section 10.Action-specific ARARs are summarized in Appendix A.
Long-Term Effectiveness and Permanence - Addresses the results ofa remedial action in terms of the risk remaining at the site afterresponse objectives have been met. The primary focus of thisevaluation is the effectiveness of the controls that will beapplied to manage risk posed by treatment residuals or untreatedwastes.
Reduction of Toxicity, Mobility, and Volume - Addresses thestatutory preference for selecting remedial actions that employtreatment technologies that permanently and significantly reducetoxicity, mobility, and volume of a hazardous substance as theirprincipal element. This preference is satisfied when treatment isused to reduce the principal threats at the site throughdestruction of toxic contaminants, irreversible reduction incontaminant mobility, or reduction of total volume of contaminatedmedia.
Short-term Effectiveness - Addresses the impacts of thealternative during the construction and implementation phase untilremedial response objectives have been met. Alternatives areevaluated with respect to their effects on human health and theenvironment during implementation of the remedial action and untilprotection is achieved.
Implementability - Addresses the technical and administrativefeasibility of implementing an alternative and the availability ofvarious services and materials required during its implementation.
Cost - The cost estimates provide an order-of-magnitude evaluationfor comparison of alternatives. Capital cost, annual cost, apresent worth analysis, and a cost sensitivity analysis (whereappropriate) are part of this evaluation.
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State acceptance - EPA requests state comments and concurrenceCD for consideration in final selection.
Community acceptance - EPA considers input from the affectedcommunity and considers and responds to all commments receivedprior to the final selection of a remedial action (long term
^ cleanup).1 "8.1 Groundwater Alternatives
8.1.1 Alternative G-l; No Action
Protection of Human Health and the Environment. Since noremedial action would be taken, this alternative would notprovide any increase in the protection of human health or theenvironment.
The risk assessment conducted for this site determined thatthere are currently no significant carcinogenic ornon-carcinogenic risks posed to existing human population bygroundwater due to two factors: contaminated groundwater hasnot migrated offsite, and there are no local onsite oroffsite withdrawals from the shallow aquifer.
The "no action" alternative would not be protective of futureonsite residents who might use the shallow aquifer fordomestic uses. Such persons would be exposed to groundwaterposing a non-carcinogenic hazard index greater than 1 and acarcinogenic risk of greater than 10.
The "no action" alternative would also not be protective offuture offsite residents should contaminated groundwatermigrate from the site and wells be constructed to use theshallow aquifer.
Compliance with ARARs. This alternative would not result inreturning the quality of the onsite, shallow aquifergroundwater to a level which would meet the Safe DrinkingWater Standards.
Long-Term Effectiveness and Permanence. Because remedialactions would not occur, this alternative would not provideany long-term effectiveness or permanence. The long termrisks due to contaminated groundwater would be unchanged.
Reduction of Toxicity, Mobility, and Volume. Thisalternative would have no effect on the toxicity, mobility,or volume of contaminated groundwater beyond naturalattenuation effects due to dilution and natural biologicaldegradation of some organic compounds. The potential fordilution of contaminants is dependent on the degree ofcross-media contamination that occurs due to contact withcontaminated soil/sediment.
8-2
O Short-Term Effectiveness. Because no site activities^ would occur, there would be no effect on the community.
There would be no construction or operation relatedimpacts to the environment.
" Implementability. This criterion is not applicable to a"no action" alternative.
Cost. This alternative would not incur any costs.
8.1.2 Alternative G-2: Deed Restrictions
Protection of Human Health and the Environment. Thisalternative does not offer any increase in the protectionof the environment; however it does provide substantialprotection to human health. If implemented and strictlycomplied with, deed restrictions which prohibitinstallation of wells in the shallow aquifer wouldeliminate human contact with contaminated groundwater.
Compliance With ARARs. Same as Alternative G-l: NoAction.
Long-Term Effectiveness and Permanence. This alternativewould be effective at preventing human exposure tocontaminated groundwater for as long as local propertyowners abide by the deed restrictions. It is possiblethat at some future date additional groundwater testingwill indicate that contaminants no longer exceed SafeDrinking Water Act Standards. However, unless such areduction in contaminant levels occurs, the deedrestrictions must be considered permanent. Sampling ofthe existing groundwater monitoring wells would continuefor an indefinate period.
Reduction in Toxicitv, Mobility, and Volume. Same asAlternative G-l: No Action.
Short-Term Effectiveness. Because this alternative wouldinvolve only institutional steps, there would be noconstruction phase that might affect the community. Sinceno one in the area is currently using water from theshallow aquifer, there would be no exposure tocontaminated groundwater during the interval until thedeed restrictions are put in place. The implementationperiod would be six months to one year depending on thedegree of community acceptance this alternative receives.
Implementability. The implementability of deedrestrictions is considered the ability to attach therequired restriction to the property deeds for theCarolina Transformer site and adjacent property whichmight be effected, and the ability to enforce suchrestrictions once attached.
8-3
The attachment of deed restrictions to the CarolinaTransformer site deed can be assumed to be agreeable tothe current property owner and, therefore, readilyimplemented. Voluntary acceptance of similar restrictionsby the owners of adjacent property is questionable. Theseowners would be relinquishing a potentially valuableproperty right (access to a shallow aquifer) for little orno gain. Such a restriction on their deed would beexpected to result in some reduction in the commercialvalue of their property.
Even if acceptable to current owners of the site andadjacent properties, enforcement of such restrictionswould be difficult. The procedures for issuing a stategroundwater withdrawal permit do not require documentationthat no deed restrictions against withdrawals fromspecific aquifers exist. Future owners could choose toignore or be unaware of the existence of therestrictions. The restrictions could also be lost duringfuture property transfers.
For the above reasons, the implementability of thisalternative is considered is low compared to otheralternatives.
Costs. The costs for implementation of this alternativeconsist of the cost to purchase agreements to accept deedrestrictions from adjacent property owners and theattorney and court costs to amend the affected propertydeeds. It is very difficult to accurately estimate thecost to purchase deed restriction agreements. Although noone is currently using this aquifer, property owners maybe extremely reluctant to give up such a property rightwithout a financial inducement to do so. Also, since thecontaminated groundwater has not been shown to have leftthe site, it is difficult to determine which propertyowners would be affected.
For these reasons, a cost estimate for this alternative isbased on rough assumptions and may not meet the desireddegree of accuracy, +50 percent to -30 percent. Assumingthat there are five property owners in addition to theCarolina Transformer site owner and that each owner wouldagree to accept $10,000 (including all attorney fees) inreturn for the deed restriction, this alternative wouldhave a cost of $50,000. There would be no annual feesincurred by this alternative.
8.1.3 Alternative G-3; Metals Removal/Air Stripping/Adsorption
Protection of Human Health and the Environment. The risksto future users of groundwater associated with ingestion,inhalation, and dermal contact with contaminants in the
8-4
00 H Jshallow aquifer groundwater would be reduced by thispump-and-treat alternative. The operation of thegroundwater extraction and treatment system would continueuntil the groundwater meets the remedial goals. Thetreatment system would remove both metals and organics toan extent at which discharge of the treated groundwater tothe unnamed tributary to the Cape Fear River
(Alternative G-3A) or the Fayetteville POTW (AlternativeG-3B) would be possible.
Compliance With ARARs. The remedial goals for groundwaterremediation are based, in part, in meeting the MCLGs orMCLs and the North Carolina Groundwater Standards.Operation of the Alternative G-3 equipment would becontinued until the groundwater attains these limits.
If discharged to the tributary of the Cape Fear River, thetreated water from the process would not cause violationof any ambient water quality standard. If discharged tothe POTW, the effluent would meet the City's standards fordischarge to the sewer system. The activated carbonfilters on the air stripper offgas would ensure the airdischarge meets all emission standards from this source.
Long-Term Effectiveness and Permanence. This alternativewould be effective at achieving a high degree ofpennanenance in remediating the existing volume ofcontaminated groundwater. The long-term effectiveness andpermanence of this alternative is dependent upon theremoval of contaminated soil/sediment to eliminatecontinued cross-media contamination. Assuming thecontaminated soil/sediment is also removed, there shouldbe no need for continued operation of the extraction andtreatment system once the remedial goals are met.Sampling of the existing monitoring wells would continuefor an indefinite period after achievement of the remedialgoals to confirm the permanence of the action.
Reduction of the Toxicity. Mobility, and Volume. Thisalternative would be effective at reducing the mobilityand volume of both organic and inorganic groundwatercontaminants.
The organic contaminants would be ultimately concentratedin the activated carbon sorbant without change in theirtoxicity. The fate of these contaminants would be linkedto that of the spent sorbant. If the sorbant is thermallyrecycled, the organics would be destroyed duringregeneration or in a separate afterburner. If the spentsorbant is landfilled rather than recycled, the toxicityof the contaminants would not be reduced but theirmobility in the general environment would be minimized.
Inorganic contaminants removed from the groundwater wouldbe concentrated in the sludge generated by the
8-5
precipitation process. Except for contaminants such aschromium which may be converted to a less toxic valencestate, the toxicity of inorganic contaminants would not bereduced by the treatment system. At the lowconcentrations present in the sludge, recovery of metalswould not be economically feasible. Disposal in anappropriate landfill would minimize the mobility ofinorganics in the general environment.
Short-Term Effectiveness. Short-term risks to humanhealth and the environment during the implementation andoperation phases of Alternative G-3 would be limited.Some increase in ambient air concentrations of volatileorganic contaminants which escape the air stripper'sactivated carbon absorption system would be experiencedbut at levels which meet emission limits and cause nothreat to human health or the environment. Similarly,organic and inorganic contaminants will be present at muchreduced levels in the effluent from the treatment system.Whether discharged to the Cape Fear River's tributary orto the POTW, this effluent would increase the totalquantity of these contaminants in surface waters. The lowconcentrations present in the effluent would provide nosignificant human health or environmental effects.
Implementability. The installation techniques andtreatment technologies used in Alternative G-3 are wellunderstood and have been successfully implemented at othersites on similar media and contaminants. The processequipment consists of standard groundwater treatmentsystems and would require no special designs. Pilot planttesting would be required to obtain optimum processkinetics and equipment sizing. Such testing wouldoptimize chemical utilization, air stripper air-to-fluidratios, and activated carbon type among other designfactors.
The treatment facility could be mounted on severalequipment skids to minimize construction relatedproblems. The treatment facility must be manned for bothoperation and maintenance considerations. With sufficientgroundwater equalization storage, the groundwaterextraction system could operate continuously while thetreatment system could operate on a 40-hour/week basis.
Costs. The detailed capital cost estimates forAlternatives G-3A and G-3B are presented in Tables 8-1 and8-2, respectively. The capital costs of both systemsinclude installation of the groundwater extraction system(wells), storage tanks for groundwater and chemicals, thevarious treatment components, and sludge dewatering andstorage equipment. Alternative G-3A includes the cost ofa discharge line to the Cape Fear River's tributary.Alternative G-3B includes the cost of a pipeline to theexisting sewer left station adjacent to the site.
8-6
00 45Annual operation and maintenance (O&M) costs associatedwith these alternatives include costs for electric power,chemicals, activated carbon replacement, maintenanceparts, sludge disposal, and labor. Because of the lack ofphysical data on the shallow aquifer, there isconsiderable uncertainty over how long the treatmentsystem must operate to achieve the remediation goals.
For purposes of comparative costs, it is assumed that thesystem would operate for 10 years, and that chemical andactivated carbon consumption drop off by 10 percent eachyear over that period (i.e., 10 percent of first year'sconsumption used in the tenth year). Power, maintenance,and labor requirements are assumed to remain constant overthis period. The first year O&M costs for AlternativesG-3A and G-3B are presented in Tables 8-1 and 8-2,respectively.
The 10-year present worth costs of Alternatives G-3A andG-3B are $878,500 and $949,700 respectively.
8.1.4 Alternative G-4; Metals Removal/Adsorption
Protection of Human Health and the Environment. Thisalternative would provide approximately the same degree ofprotection of human health and environment as AlternativeG-3.
Compliance With ARARs. Operation of the groundwaterextraction and treatment system would be continued untilthe groundwater attains the MCLGs or MCLs set by the SafeDrinking Water Act and/or the North Carolina DrinkingWater Standards. In Alternative G-4A, the effluent fromthe treatment system would comply with the City'sstandards for discharge to the sewer system. InAlternative G-4B, the discharge to the Cape Fear tributarywould not cause violations of ambient water qualitystandards.
Long-Term Effectiveness and Permanence. This alternativewould provide the same degree of long-term effectivenessand permanence as Alternative G-3.
Reduction of Toxicity, Mobility, and Volume. Thisalternative would provide the same reduction in thetoxicity, mobility, and volume of groundwater contaminantsas Alternative G-3.
Short-Term Effectiveness. The short-term risks associatedwith this alternative would be similar to Alternative G-3except that without an air stripper, there would be noincrease in ambient air concentrations of volatileorganics. These compounds would be removed in thegroundwater activated carbon adsorption system.
8-7
5 9 0046Implementability. The implementability of thisalternative would be similar to that of Alternative G-3.
Costs. The detailed capital cost estimates forAlternative G-4A and G-4B are presented in Tables 8-3 and8-4, respectively. The capital cost categories areidentical to Alternative G-3 except for the deletion ofthe air stripper and its associated equipment. It isassumed that the activated carbon adsorption equipmentwould be the same size as the equipment in AlternativeG-3. The elimination of the air stripper would increasethe organic load on the adsorption equipment. The costestimate assumes that this increased loading would beaccommodated by more frequent activated carbon replacementrather than by larger units.
Annual O&M costs associated with Alternatives G-4A andG-4B include the same categories as their respectiveAlternative G-3 options and are also presented in Tables5-3 and 5-4. The principal difference between the G-4option and G-3 the option is the lower power costsreflecting the deletion of the air stripper and the higheractivated carbon replacement costs.
The present worth costs of Alternatives G-4A and G-4Bbased on 10 years of operation are $830,500 and $898,800,respectively.
8.1.5 Alternative G-5; Adsorption
Protection of Human Health and the Environment. Thedischarge of groundwater to the Cape Fear River tributarywithout treatment for metals removal would result in somedegree of elevated hazard risk to human health due topotential dermal contact by offsite persons duringwading. The chronic and lifetime hazard index posed bythe untreated metals in the discharge would be 0.04 and0.003, respectively. A hazard risk of 1.0 or greater isconsidered to be significant.
The metals content in the discharge would exceed the NorthCarolina Ambient Water Quality Standards as discussed inthe following section; therefore, some degree of elevatedthreat to the aquatic environment would occur until thedischarge reaches the Cape Fear River.
Compliance With ARARs. As in the previous twoalternatives, this alternative would continue operationuntil the groundwater attains the Safe Drinking Water ActMCLGs and MCLs. Without metals removal, the treatedgroundwater would exceed the North Carolina Ambient WaterQuality Standards for barium, total chromium, copper,lead, manganese, nickel, and zinc at the point ofdischarge. The effluent would be discharged to thenormally dry drainage stream leaving the site and the
8-8
stream would not meet Ambient Water Quality Standardsuntil it confluence with the Cape Fear River inapproximately one-half mile. At a flow rate of only 10gpm, the mixing zone required to achieve the standardswould be very small even during low flow conditions.
Long-Term Effectiveness and Permanence. This alternativewould provide the same degree of long-term effectivenessand permanence as the previous two alternatives.
Reduction in Toxicity, Mobility, and Volume. Organiccontaminants would be concentrated in the activated carbonmedia. As in the previous two alternatives, thesecontaminants would be destroyed if the activated carbonwere recycled. If disposed of without recycling, mobilityand volume would be reduced without change to thecontaminants toxicity.
This alternative uses dilution by the remainder of thePOTW influent to reduce the toxicity of inorganiccontaminants. The secondary treatment provided by thePOTW would not provide significant removal of inorganics.However, the levels of inorganic would also not adverselyaffect the POTW's operations. This alternative wouldincrease the mobility and volume of inorganiccontaminants.
Short-Term Effectiveness. This alternative would have fewshort term impacts during implementation. Thisalternative requires minimal supervision and generatesonly spent activated carbon as a waste material.
Implementability. Activated carbon adsorption utilizesstandard modules and can be quickly implemented.
Costs. The detailed capital and annual O&M costsestimates for Alternative G-5 are presented in Table 8-5.The activated carbon adsorption equipment would be thesame as in the two previous alternatives. The presentworth of this alternative is $435,000.
8.1.6 Alternative G-6; Metals Removal/UV Oxidation
Protection of Human Health and the Environment.Alternative G-6 provides the same level of protection ofhuman health and the environment as Alternatives G-3 andG-4. The hazards due to both metals and organics would bereduced by this alternative.
Compliance with ARARs. This alternative offers the samedegree of compliance with ARARs as Alternatives G-3 andG-4.
Long-Term Effectiveness and Permanence. The long-term8-9
5 9 neffectiveness and permanence of this alternative would bethe same as Alternatives G-3, G-4, and G-5.
Reduction in Toxicity, Mobility, and Volume. The metalsremoval process for this alternative would be identical tothe process used in Alternatives G-3 and G-4 and wouldoffer the same reduction in the mobility and volume ofinorganic contaminants.
The UV oxidation process would convert the organiccontaminants to less hazardous materials. This wouldresult in the reduction of organic contaminant toxicityand volume. The process does not produce any hazardousbyproducts which would require additional handling orstorage.
Short-Term Effectiveness. The metal removal and UVoxidation equipment would be modular, skid mounted systemswhich would minimize effects on human health and theenvironment during implementation and operation. Organicand inorganic contaminants would be present at muchreduced levels in the discharge from the treatmentsystem. Whether discharged to the Cape Fear Rivertributary (Alternative G-6A) or the POTW (AlternativeG-6B), this effluent would ultimately increase the totalquantity of these contaminants in surface waters. The lowconcentrations present in the effluent would present nosignificant human health or environmental effects. As inall alternatives providing metal removal, metal oxidesludges must be transported from the site to a chemicalwaste landfill.
Implementability. UV oxidation is a demonstratedtechnique for destruction of organic compounds in water;however, a pilot plant study would be required to optimizethe process factors and equipment sizing. Such testingwould optimize chemical utilization, power consumption,and oxidation tank detention times among other factors.UV oxidation equipment is available from several qualifiedmanufactures who would be capable of conducting the pilottest and furnishing the required equipment.
Costs. The detailed capital cost estimates forAlternatives G-6A and G-6B are presented in Tables 8-6 and8-7, respectively. The costs for metal removal areidentical to those developed for the previous alternativesusing this process. The costs for the hydrogen peroxidestorage tank and metering equipment and the UV lightreactor tank.
Annual O&M costs associated with these alternativesinclude the costs of chemicals, power, maintenance parts,sludge disposal, and labor. The first year O&M costs arepresented in Tables 8-6 and 8-7. The present worth of thetwo Alternative G-6 options are $993,300 and $1,055,500.
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5 9 00498.1.7 Alternative G-7; UV Oxidation
Protection of Human Health and the Environment. Thisalternative would provide a degree of protection of humanhealth and the environment equivalent to Alternative G-5:Absorption.Compliance with ARARs. This alternative would provide thesame compliance with ARARs as Alternative G-5. Withoutmetals precipitation, metal levels in the treated effluentwould be above Ambient Water Quality Standards until aftera mixing zone in the Cape Fear River.
Long-Term Effectiveness and Permanence. This alternativeprovides the same degree of long-term effectiveness andpermanence as the six earlier alternatives.
Reduction in Toxicity, Mobility, and Volume. Organiccontaminants would be destroyed, eliminating theirtoxicity and volume. Inorganic contaminants would beunaffected but the combination of these contaminants withthe remainder of the POTW influent wastes would providedilution to reduce the groundwater flow's toxicity. ThePOTW would provide no significant removal of inorganiccontaminants.
Short-Term Effectiveness. This alternative would have fewshort term impacts on the public health or the environmentduring implementation and operation. The alternativegenerates no sludges and requires only minimalsupervision.
Implementability. The UV oxidation system is ademonstrated technique, however; this alternative wouldrequire pilot testing to optimize oxidation tank detentiontime, chemical dosages, and other process variables.
Costs. Detailed capital and annual O&M costs ofAlternative G-7 are presented in Table 8-8. These costsare identical to Alternative G-6: Metal Removal/UVOxidation with the deletion of the metal removal andsludge handling equipment.
The present worth of this alternative is $590,600.
8.2 Soil/Sediment Alternatives
8.2.1 Alternative S/S-1; No Action
Protection of Human Health and the Environment. Sinceremedial action would not be initiated, this alternativewould not provide any increased protection to human healthor the environment. Specifically, the non-carcinogenichazard index would be greater than 1 for future onsiteresidents and carcinogenic risk would be greater than 1 x10 for all populations evaluated in the Risk
8-11
5 9 0060Assessment Report. Also concern for PCB exposure byterrestrial animals, birds, and plants would not bereduced.
Compliance with ARARs. The "no action" alternative wouldnot meet ARARs; specifically, TSCA regulations for cleanupand disposal of PCB spills. Violations of state waterquality standards in the periodic surface waters leavingthe site would be expected to occur due to cross-mediacontamination. Cross-medial contamination of groundwaterwould also be expected to continue resulting incontaminant concentrations exceeding Safe Drinking WaterStandards.
Long-Term Effectiveness and Permanence. Because remedialactions would not occur, the existing risks at the sitewould remain. Since site controls would not beimplemented, the criterion addressing the adequacy andreliability of controls is not applicable to thealternative.
Reduction of Toxicity, Mobility, and Volume. Sinceremedial activities would not occur, there would not be areduction in the toxicity, mobility, or volume ofcontaminants at the site. The existing type and quantityof hazardous material would remain onsite. Cross-mediacontamination of groundwater, surface water, and sedimentwould continue to occur.
Short-Term Effectiveness. Because site activities wouldnot occur, protection of workers and the community wouldnot be required. Environmental impacts due toconstruction or implementation would not be encounteredsince there would be no activities performed at the site.
Implementability. This criterion is not applicablebecause remedial activities would not occur. Services andmaterials and the activities normally needed to coordinatewith other agencies would not be necessary.
Cost. There would be no costs incurred since remedialactivities would not be performed.
8.2.2 Alternative S/S-2; Fence/Deed Restrictions
Protection of Human Health and the Environment. Risksassociated with dermal contact with or ingestion of onsitecontaminated soil/sediment would be controlled by theseaccess and use restrictions. Security fencing withwarning signs would reduce (but not eliminate) thepossibility of site trespassers coming into contact withcontaminated onsite media. The use restrictions wouldprevent the type of long-duration contact associated withresidential development. This alternative would not beeffective at protecting human health or the environment
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Table A-1 (continued)Action Specific-ARARs
Groundwater
L.OCDCD
Standard, Requirement.Criteria, or Limitation
North Carolina (continued)
North Carolina Solid and Hazardou* Watte
Management Act
Nortti Carolina Huardou* Watte Management
Rule*
LocalCity of Fayettevllle. NC. Swer Ordinance
Citation
NCAC-15-2D 0518
NCAC-15-2D0525
NC AC-15- 20 0000
NCAC-15-2D 1100
NCAC-15-2H 0610
GSNC-134-21Aet*eq
NCAC-10-10F 0032 et *eq
FayetlevMIe City Code
Section 31-38
Section 31-44
Section 31-46
Section 31 -52 to 65
Description
limit* on VOC emitoona
Emission (tandarda lor hazardous air pollutant*.
Monitonng requlrementa.
Control requirement* lor toxic air pollutant*
Requirement* lor toxic air pollutants
Standard* lor hazardou* waste management lacilitie*.
Permit* required to dlecharg* to city *ew»r *y*iem.
Prohibit* di (charge of toxic aubitance* In amount* which
would Interfere with POTW operation
Presents specific pollutant limitation on organic and
Inorganic contaminant*
Industrial diecharger application requirement*
inorganic contaminant*
AlternativesG-1
—
—
—
—
—
—
—
—
—
—
G-2
—
—
—
—
—
—
—
—
—
—
G-3
RA
RA
RA
RA
RA
RA
A1
A'
A'
A -
G-4
—
—
—
—
—
RA
A'
A*
A -
A"
G-5
—
—
—
—
—
RA
—
—
—
—
G-C
—
—
—
—
—
RA
A"
A*
A'
A"
G-7"
—
—
—
—
—
RA
—
—
—
—
* Applies to option * A* only — - Not applicable or appropriate and relevant** Applie* to option "B" only A - Applicable requirement
AR - Appropriate and re1' >t requirement
Table A-2Action Specidc-ARARs
Soil/Sediment
ON
i-O
Standard, Requirement.Criteria, or Limitation
FederalReeource Conservation and Recovery Act
Identification ol Hatardou* Wa«ta*
Treatment ol He_rardou» Waste* In • Unit
Requirements tot Generation. Storage.
Treatment, and DiapOMl ol Hazardou* Wacta
Toxic Subwance* Canlrol Act
Subpart G - PCB Spill Cleanup Policy
Subpart D - Storage and Dlapoaal
Clean Air Acl
National Emmioo Standard* tor Haiardou*
Air Pollutant*
Citation
40 USC Sect lOOOetteq
40CFR 261
40CFR264 1
40CFH 2C54OO
40CFR263
40CFR284
15 USC 2601
40CFR 761 125
40CFR 761 60
40CFR 761 65
40CFR 761 70
40CFR761 75
42 USC 18S7 el •«)
40CFHC1 Subpart A
Description
Clatwftcauon and identification ol hazardous watte*.
Rule* and regulations lor the treatment ol ha^ardou*
wade*
Rules and regulations lor storage, transportation, and
operation ol hazaidou*wa*te generator*
Requirement* lor PCB spill cleanup
Diapoul requirement* lor RGB-contaminated material.
Storage requirement* lor atorage lor dlipoaal ol
PCB-conlamlnaled material
Incinerator requirement* for PCB-contaminated material*
ChemicaJ wa«te landfill requirement lor PCB-
contaminated material*
General requirement* lor emiinon* o(ha7ardouf
pollutani*
AlternativesS/S-1
—
—
—
—
—
—
—
—
—
S/S-2
—
—
—
—
—
—
—
—
—
S/S-3
RA
—
—
A
A
S/S-4
RA
—
A
—
S/S-5
RA
—
—
—
s/s-«
RA
—
—
—
to
RA
A
A
—
—
Table A-2 (continued)Action Specific-ARARs
Soil/Sediment
-OCDCD
Standard. Requirement.Criteria, or Limitation
Federal (continued)
Standard* ol Performance toe New
Stationary Source*
North CarolinaNorth Carolina Air Pollution Control Law
Norm Carolina Air Pollution Control
Regulation*
Citation
40CFRC1 SubpartE
40 CRF 00 Subpart Db
40 CHF 60 SubpartE
GSNC-143-2lBel*eq
NC AC-15- 2D 0201
NCAC-15-2D 0400
NC AC-15-200600
NCAC-16-2D 0605
NCAC-15-2D 0518
NC AC-16-200518
NCAC-15-2O0521
NCAC-15-2O 0525
NC AC-15- 2DOb30
Description
Emission standard* lor mercury.
Standard* ol performance lor Industrial *t*am generator*
Standard* of performance lor waete Incinerator*.
Classification ol air pollution cource*
Ambient air quality standards
Emission control standard*.
Limit* on partlculale emlaalon* from an Incinerator
Limit* on sulfur dioxide emission* (of combutDon
•ource*
Limn* on nitrogen oxide* from combustion eource*.
Control o( vidble emlcaioni
LmiHuon standaid* lor hazardou* air pollulant*
Piavenbon ol significant deterioration reguUbon* lor
cumbuvtion eource*
AlternativesS/S-1
—
—
—
—
—
—
—
—
—
—
—
—
S/S-2
—
—
—
—
—
—
—
—
—
—
—
—
S/S-3
—
—
—
—
—
—
—
—
—
—
—
—
S/S-4
A
—
A
RA
RA
RA
RA
RA
RA
RA
RA
RA
S/S-5
—
—
—
RA
RA
RA
—
RA
RA
RA
—
RA
S/S-0
—
TBC
—
RA
RA
RA
— '
RA
RA
RA
—
RA
i
—
TBC
—
I..OCDCO
Table A-2 (continued)Action Specific-ARARs
Soil/Sediment
Standard, Requirement,Criteria, or Limitation
North Carolina (continued)
North Carolina Solid and Hazardous Waste
Management Act
North Carolina Hazardous Waste Management
Rules
North Carolina Sedimentation Pollution
Conlrol Act
Citation
NCAC-1S-2O 0533
NCAC-15-2D 06OO
NCAC-15-2O 1100
NCAC-15-2H0600
NCAC-15-2H06O3
NCAC-15-2H oeiO
GSNC-l34-21Ael seq
NCAC-10-10F 0032 at seq
NC AC-10- 10F0032(c)
NCAC-10-10F 0032(p)
NCAC-10-10F0032(q)
GSNC-I13A 54 1
Description
Slack height regulation* lor combustion sources
Monitoring requirement*
Control requirements for toxic air pollutants
Requirements lor Air Quality Permits
Application requirements lot Air Quality Permits.
Requirements lor toxic air pollutants
Standards lor hazardous waste management facilities.
General standards for HWMFs
Standards lor hazardous waste incinerators
Standards for locabon ol HWMFs
Permit required tor excavation ol onstte and offsila
•oil/sedlmenta
AlternativesS/S-1
—
—
—
—
—
—
—
—
—
—
—
S/S-2
—
—
—
—
—
—
—
_
—
—
—
S/S-3
—
—
—
—
—
—
RA
RA
—
RA
A. RA
S/S-4
RA
RA
RA
RA
RA
RA
RA
RA
RA
RA
A. RA
S/S-5
RA
—
—
RA
RA
—
RA
RA
RA
A. RA
s/s-e
RA
—
—
RA
RA
—
RA
RA
RA
A RA
Table A-2 (continued)Action Specific-ARARs
Soil/Sediment
Standard, Requirement,Criteria, or Limitation
North Carolina (continued)Citation
GSNC-113A57
Description
Mandatory ctandards loc erotton control in areai of
excavation
AlternativesS/S-1
—
S/S-2
—
SIS-3
A. RA
S/S-4
A. RA
S/S-6
A. RA
S/S-D
A. RA
r.O
CD
— - Not applicable or appropriale and relevantA - Applicable requirementAR - Appropriate and relevant requirementTBC - To be conddered
CT\
L.O
Table A-3Action Specific-ARARs
Structures and Debris/Solid Wastes
-OoCD
cr\
LO
Standard, Requirement,Criteria, or Limitation
FederalResource Conservation and Recovery Act
kJeodflcatton ol Hazardous Wsstes
Treatment of Hazardous Wastes in • Unit
Requirement! lor Generation. Storage.
Treatment, and Disposal ol Hazardous Wade
Toxic Subatancet Control Act
Subpart Q - PCB Spill Cleanup Policy
Subpart 0 - Storage and Disposal
North CarolinaNorth Carolina Solid and Hazardous Waste
Management Act
Citation
40 USC Sect 1609etteq
4OCFR 281
40CFR 264 1
40CFH 265 4OO
40CFR263
40CFR 264
15 USC 2601
40CFH 761 125
40CFR 781 60
40CFR761 65
40CFR 761 70
40CFR 761 75
GSNC-134-21Aet wq
Description
Classification and Identification of hazardous wacte*.
Rules and regulationa tor the treatment ol hazaidoua
watte*
Rules and regulation* lor storage, transportation, and
operation ol hazardous waste generators
Requirements lor PCB spill cleanup
Disposal requirements lor PCB contaminated material.
Storage requirements tor storage lor dicpotal of
RGB-contaminated material
Incinerator requirements lor PCB-contaminated materials
Chemical waste landfill requirement lor PCB-
conlammated materials
AlternativesS-1
—
—
—
—
—
—
—
—
S-2
—
—
—
—
—
—
—
—
S^3
A
A
A
A
A-
A'
A'
A*
S-4
A
A
A
A
A'
A'
A"
A -
0-1
—
—
—
—
—
—
—
—
D-2
—
—
—
—
—
—
—
—
D-3
A
A
A
A
A
A
A
A
CD
Table A-3 (continued)Action Specilic-ARARs
Structures and Debris/Solid Wastes
Standard. Requirement,Criteria, or Limitation
North Carolina (continued)No»tn Carolina Huardoul Waele Management
Rule*
Citation
NCAC-10-10F 0032 el »eq
NCAC-lO-10F0032(c)
NCAC-10-10F0032(q)
Description
Standards lot hazardous watte management lacilitjea
General standard* for HWMFr
Slandarda lor location ol HWMFi
AlternativesS-1
—
—
—
S-2
—
—
—
S-3
RA-
RA-
RA'
S-4
RA-
HA*
RA-
D-1
—
—
—
D-2
—
—
—
D-3
RA
RA
RA
• Applies to *B* option only. — - Not applicable oc appropriate and relevantA - Applicable requirementAR - Appropriate and relevant requirement
ON
S 9off the site. As discussed in the Risk Assessment Report,significant carcinogenic risks are presented by exposureto offsite contaminated soil/sediment.
This alternative would not prevent the additionalmigration of hazardous substances into the surface water,offsite sediments, or underlying groundwater aquifer.
Compliance with ARARs. This alternative would have thesame lack of compliance with state and federal ARARs asAlternative S/S-1 No Action.
Lonq-Term Effectiveness and Permanence. The long-termeffectiveness of this alternative depends upon theenforcement and maintenance provided. Primary site accessrestriction would be maintained by the security fencearound the site. This fence would be requiredindefinitely to prevent access. Periodic repair orreplacement of the fence would be necessary. The deedrestrictions would prohibit land uses that could disturband/or cause exposure to hazardous substances contained inthe soil/sediment. The deed restrictions would berequired indefinitely and must follow through any futureproperty transfers. The restriction must be maintainedindefinitely unless future testing determines thecontamination has been naturally attenuated to safe levelsor a future remedial action is undertaken.
This alternative has no long-term effectiveness foroffsite soil/sediment such as that found along the surfacewater drainage ditch to the south of the site.
Reduction of Toxicity, Mobility, and Volume. Sinceremedial activities would not occur, there would be noreduction in the toxicity, mobility, or volume ofsoil/sediment contaminants at the site. The existing typeand quantity of hazardous material would remain onsiteundergoing only natural attenuation or migration offsitethrough cross-media contamination (e.g., the transport ofsoil as sediment to offsite watersheds).
Short-Term Effectiveness. The minimal intrusiveactivities involved with installing a peripheral fencearound the site would result in very slight environmentalimpacts to workers or the community. Since the fencewould be installed beyond the zone of contaminatedsoil/sediment in most cases, simple measures to limitworker contact with soil/sediment during constructionwould be sufficient. The alternative would result in noadditional exposure by the community at large.
Implementability. The installation of a peripheral fenceat the site can be easily implemented. The fence would beof standard industrial fencing material which is readilyavailable and involves no special materials. A fence forthe offsite portion of the waterway which contains
8-13
0059contaminated soil/sediment would be very difficult toimplement due to factors such as multiple land ownership,the strong potential for flood damage during heavy rains,and very difficult construction and maintenancerequirements. Fencing along the offsite waterway is notincluded in the development of costs for this alternative.
Deed restrictions are legally implementable for the sitebut for offsite property would require either voluntarycompliance by the property owners or condemnation of theproperty. In addition, past experience with wastedisposal sites has demonstrated that deed restrictions maybe ignored by future landowners or not included as a deedrequirement during property transfers. There is currentlyno governmental agency responsible for tracking andenforcement of such deed restrictions.
Cost. The estimated capital and annual costs ofimplementing Alternative S/S-2 are presented in Table 8-9.The capital costs include the required fencing materialsand warning signs and the legal costs of instituting deedrestrictions on the site only. The annual costs includefence maintenance, site mowing, and weekly security visitsto confirm the fence integrity. The annual costs to ensurecompliance with the deed restrictions have been estimated.The 30-year present worth of this alternative would be$172,000.
No sensitivity analysis was performed for thisalternative.
8.2.3 Alternative S/S-3; Excavation for Offsite Landfill
Protection of Human Health and the Environment. Thisalternative would protect the local community and theenvironment by eliminating all contact with soils andsediments which have a PCB content of over 1 ppm. Thisalternative would also eliminate cross-media contaminationof surface water and greatly reduce contamination of thesurficial aquifer groundwater.
The disposal of contaminated soil/sediment in a RCRA orTSCA landfill, as appropriate to its PCB content, willprevent future exposure to site contaminants.
Compliance with ARARs. This alternative would comply withTSCA regulations (40 CFR 761.6) relating to the treatmentand disposal of PCB-contaminated media since all mediawith a PCB level of greater than 50 ppm would be disposedof in a TSCA-certified landfill. The PCB Spill Policy (apolicy to be considered) requires that a 10-inch layer ofclean soil be placed over any area where PCB-Contaminated(10 ppm or more) media is excavated. Both of thesealternative options meet this requirement.
8-14
0 0 (if) Offsite transport of contaminated soil/sediment would begoverned by DOT regulations. The proposed landfillfacilities meet the requirements for a RCRA or TSCAdisposal facility, as applicable.
Long-Term Effectiveness and Permanence. The excavationand removal of the contaminated media from the site andoffsite drainage area would permanently reduce theresidual risk to the local community and the environment.It would also reduce the potential for cross-mediacontamination of surface water, sediment, andgroundwater. Alternative S/S-3A would have greatereffectiveness and permanence since it would remove soil inthe 1 ppm to 10 ppm PCB range which the other option wouldnot.
Disposal of contaminated soil/sediment in a RCRA or TSCAlandfill is considered to be a permanent disposal method.Properly designed, sited, and operated, such landfillswould permanently isolate the contaminants from thegeneral environment.
Alternative S/S-3B would have somewhat lower long-termeffectiveness and permanence than Alternative S/S-3Abecause it does not remove the portion of onsitesoil/sediment containing between 1 and 10 ppm PCB.Although both alternatives meet the PCB Spill Policy, thepotential for continued cross-media contamination ofgroundwater is greater for the S/S-3B option.
Alternative S/S-3B also would place more reliance onmaintaining the vegetative ground cover than wouldAlternative S/S-3A. The 10-inch clean soil cover must bemaintained over soil cover exceeding 1 ppm PCB in order toprovide the required degree of protection of human health.
In general, both of the two above points would apply toall of the soil/sediment remedial alternatives' "A" and"B" options.
Reduction of Toxicitv, Mobility, and Volume. Landfilldisposal reduces the mobility of soil/sedimentcontaminants but does not effect their toxicity or volume.
Alternative S/S-3A would provide a higher degree ofreduction in pollutant mobility than would S/S-3B becauseit removes the portion of the onsite soil containingbetween 1 and 10 ppm PCB. This factor would apply to allof the soil/sediment alternatives' "A" and "B" options.
Short-Term Effectiveness. The principal short termimpacts of implementation of this alternative are due tothe excavation of the contaminated media and the placementof backfill soil. These activities would result in
8-15
n n -: 1 increases in ambient noise levels, windblown dust, andJ U O i soil erosion. These impacts would be mitigated by
limiting the hours of operation, soil moisture control,erosion control measures, and restablishing vegetativecover. The excavation work would be staged andcoordinated with the backfill and seeding activities tominimize the potential for dusting and erosion.
There would be some risk of exposure to contaminantsduring the transport of soil/sediment to the offsitelandfills as a result of dust losses or accidents. Thetrailers would be covered and all applicable RCRA and DOTregulations would be followed. The transport would alsoresult in unavoidable increases in local truck traffic inthe site area. This effect would be minor given the closeproximity of major roads (Business Route 95) to the site.
Implementability. The excavation, transport, and landfilldisposal of soil are established processes and numerouscontractors would be available to perform the work. Cleanbackfill soil is readily available in the area.
A significant potential problem with the transport ofcontaminated soil/sediment to offsite RCRA and TSCAlandfills is the current problems with shipments ofhazardous waste from North Carolina to South Carolina orto Alabama. Both of these states have attempted to tax,prohibit, or otherwise regulate shipments of hazardousmaterials to the landfills located in their states.
Cost. The estimated capital and annual cost ofAlternatives S/S-3A and S/S-3B are presented in Tables8-10 and 8-11, respectively. Because the exposure riskdue to contact with onsite soil would be eliminated, thisalternative does not include costs for additionalfencing. Periodic mowing and visits by security personnelwould occur, however. The total present worth ofAlternatives S/S-3A and S/S-3B would be $9,228,800 and$8,463,600, respectively.
8.2.4 Alternative S/S-4; Excavation for Onsite Incineration
Protection of Human Health and the Environment. Thisalternative would provide generally the same degree ofprotection to human health and the environment asAlternative S/S-3. All contact with soils or sedimentscontaining over 1 ppm PCBs would be eliminated. Becauseincineration would not eliminate or reduce the inorganiccontent of the media, some elevated risk due to ingestionand dermal contact with inorganics would remain. This riskwould not exceed a chronic hazard quotient of 1 or acarcinogenic risk index of greater than 10 for anyaffected onsite or offsite population.
8-16
,, ,, ,- ,-, Compliance with ARARs. The requirements of the National5 9 J U 0 / Ambient Air Quality Standards (NAAQS) and the National
Emission Standards for Hazardous Air Pollutants (NESHAP)are relevant and appropriate to this alternative and woube complied with by installing air emission controldevices on the incinerator and controlling the release o:fugitive dust and volatile emissions during excavation aimaterial handling. Incineration of the soil/sedimentwould meet the requirements in 40 CFR 761.60 and 761.70.
Compliance with TSCA PCS regulations (40 CFR 761.60 to761.70) would be achieved by following the treatment,storage, and disposal requirements for PCBs based on theiform and concentration. Regulations pertaining tothermal destruction, soil handling, or gaseous wastetreatment, and NESHAP guidelines would be followed througthe use of air emission control devices at the site.Since this is a CERCLA site, a National PollutantDischarge Elimination System (NPDES) permit is notrequired for onsite activities; however, the requirementswould be followed if the scrubber water from theincinerator is to be treated onsite and discharged to alocal stream. If the scrubber water is discharged to theFayetteville wastewater treatment facilities, thewastewater would be treated as required to meet the citypretreatment requirements. RCRA Subpart 0 regulationsrelating to incinerators would be relevant andappropriate; however, the more stringent TSCA regulationswould be followed. Applicable OSHA requirements would bemet by following appropriate site safety activitiesdescribed in the contractor's Health and Safety Plan. TheNorth Carolina Hazardous Waste Management Act would befollowed whenever their requirements are more stringentthan the corresponding federal requirements.
Long-Term Effectiveness and Permanence. The incinerationof contaminated soil/sediment would permanently eliminatethe hazards associated with organic contaminants such asPCB, and dioxin/furans. Removal efficiencies in excess of99.9 percent of all organic contaminants would beachieved.
As discussed earlier, this alternative does not eliminateinorganic contaminants. In fact, incineration may convertinorganic contaminants to more soluble compounds. Thisstudy assumes that the incinerated media would pass theEPA's toxicity characteristic leachate procedure (TCLP)and could be replaced in its original offsite and onsitelocations. If this assumption proves to be incorrect, thetreated media would be trucked to an offsite RCRA landfilland replaced with clean backfill.
8-17
59 0063Alternative S/S-4A would provide greater effectiveness andpermanence since this option would treat onsitesoil/sediment in the 1 ppm to 10 ppm PCB range whichAlternative S/S-4B would not. Continued compliance withthe EPA PCB Guidance would be possible only if the 10-inchsoil cover over media in this range were maintained.
Annual maintenance activities at the site would includeperiodic site visits, maintenance of vegetation cover, andgroundwater monitoring. A 5-year review would be requiredto ensure the effectiveness of the alternative inprotecting the public health and the environment.
Reduction of Toxicity, Mobility, and Volume. Incinerationwould greatly reduce the toxicity, mobility, and volume ofPCBs, dioxin/furans, and other organic soil/sedimentcontaminants. Thermal destruction of PCBs is anirreversible process with a destruction and removalefficiency exceeding 99.9999 percent and, therefore, thealternative would satisfy the statutory preference fortreatment as a principal element of a remedial action.The effectiveness of this incineration alternative todestroy organics would have to be tested during the trialburn. Inorganic contaminants (e.g., copper) may form moreoxidized compounds, but would not be destroyed. Thetoxicity and mobility of these oxidized compounds may begreater or less than the original inorganic compounds inthe soil/sediment.
Short-Term Effectiveness. The short-term effectiveness ofthis alternative would be similar to Alternative S/S-3with the additional considerations related to emissionsfrom onsite incineration. The same steps to control siteaccess, fugitive dust emissions, and surface runoff wouldbe taken. In addition, incinerator exhaust emissionswould be monitored during all site activities to ensurethe effectiveness of incineration emission controls. Evenwith the stringent controls placed on incineratoremissions, combustion by-products and products ofincomplete combustion could be introduced into theenvironment.
The short-term risks of this alternative to workers wouldbe potential exposure to contaminated soil/sediment duringexcavation and material handling. There would also be arisk of worker exposure to inorganic contaminants withtoxic characteristics during soil replacement. These riskswould be minimized by compliance with the OSHArequirements and guidelines for hazardous waste siteactivities.
8-18
5 9 OU64Since incineration is a complex industrial operation,there is always the risk of accidents. Risks associatedwith incineration include:
Incomplete destruction of organic contaminants resultingin the release of toxic or hazardous vapors andparticulates.
Malfunction of the incinerator resulting in fire orexplosion.
Air pollution control equipment malfunction resulting inrelease of toxic or hazardous vapors or solids.
Accidental releases due to improper operation.
The threat from these possibilities would be minimized byfollowing proper operation, maintenance, and safetyprocedures.
The time required to implement and complete this remedialprocess would be substantial. Depending on whichincineration technology is used, incinerator fabricationtime may be needed and the alternative implementationcould take an additional 8 to 9 months. Since incineratorfeed rates are a function of moisture content andcombustibility, increased moisture content or lowcombustibility could decrease the throughput to theincinerator, thus increasing the time necessary tocomplete the remediation.
Implementability. The excavation, thermal treatment, andreplacement soil/sediment are established practices andcontractors that specialize in this type of work arereadily available. Transportation and setup of the mobileincinerator are also proven operations, but could be timeconsuming. Coordination between site activities may bedifficult due to the limited size of the site.
The use of a transportable incinerator to destroy organiccontaminants is a proven and reliable technology.Inorganic contaminants would not be destroyed as discussedpreviously. O&M requirements for a mobile incinerator arefairly extensive, but would normally be the responsibilityof the incinerator owner/operator.
Complex operating procedures would require fully trainedoperating personnel. Detailed and careful monitoring ofthe incineration processes would be required. Laboratoryanalyses of the incinerated residue would be required toensure that the organic contaminants were beingeffectively destroyed. Additionally, samples from
8-19
excavated soil/sediment would be taken to confirm that the59 00 6 FJ contaminated surface/sediment is removed to acceptable
levels.
A major consideration in evaluating the implementabilityof an onsite incinerator is the location of a wasteincinerator on a relatively small site and in such closeproximity to a food processing facility, Larry's Sausage.A very high degree of stack emission controls would berequired to ensure that operation of the incinerator metall ARAR's.
Costs. The estimated capital and annual costs forAlternatives S/S-4A and S/S-4B are presented in Tables8-12 and 8-13 respectively. A major assumption in thedevelopment of this alternative's cost is the assumptionthat the treated soil/sediment could be placed back in itsoriginal location. The total present worths ofAlternatives S/S-4A and S/S-4B are $18,019,300 and$16,301,200, respectively.
8.2.5 Alternative S/S-5; Excavation for Onsite ChemicalDechlorination
Protection of Human Health and the Environment. Thisalternative would protect human health and the environmentfrom PCS contamination located at the Carolina Transformersite by chemically treating the contaminated soil/sedimentand dechlorinating the PCB molecules. The chemical reagentwould be recovered and reused, any wastes would beincinerated offsite and the treated soil/sediment would beredeposited onsite. This alternative would have no effecton inorganic soil contaminants such as copper.
The excavation and treatment of the contaminatedsoil/sediment in conformance with the specified cleanuplevel (<1 ppm for Alternative S/S-5A, or <10 ppm forAlternative S/S-5B) would effectively minimize danger topublic health and the environment at the site from PCBsand other chlorinated hydrocarbons to approximately thesame extent as onsite incineration. Carcinogenic riskwould be reduced to the range of 1 x 10 to 1 x10 . Non-carcinogenic risk factors due to contact oringestion of soil/sediment would not be increased. Thisalternative eliminates the primary contaminants of concernto the other biotic receptors, both plant and animal, aswell.
Compliance with ARARs. The requirements of NAAQS andNESHAP are relevant and appropriate to this alternativeand would be complied with by implementing air emissioncontrol devices on the dechlorination equipment andcontrolling the release of fugitive dust and volatileemissions during material handling.
8-20
g n 0 o h This alternative may not be in compliance with parts of' ° TSCA chemical-specific and action-specific regulations,
including 40 CFR 761.60, 761.70, and 761.75.Soil/sediment having PCB concentrations in excess of 50ppm are specifically required by Part 761.60 (a)(4) to bedisposed in an incinerator (761.70), chemical wastelandfill (761.75), or by equivalent treatment (761.60(a)). Chemical dechlorination will require pilottreatment tests to be considered an equivalent treatmentmethod since limited studies are available that documentits effectiveness and effectiveness may vary withsoil/sediment composition and other factors.
The evaluation of the federal location-specific ARARswould be similar to the evaluation of the onsiteincineration alternative with the exception that apollutant dispersion analysis would not be required sincethere is no onsite combustion involved. The same stateARARs would also apply.
Long-Term Effectiveness and Permanence. The extent ofresidual risk posed by the chlorinated hydrocarboncontaminated material would be reduced and possiblyeliminated depending on the degree of dechlorinationachieved with the implementation of this alternative. Thedestruction of such organic contaminants at the site wouldreduce the long-term risks associated with direct humancontact and inhalation and with cross-mediacontamination. The system is ineffective in removinginorganic contaminants from soil/sediment media.
The remaining reagent and rinse water would be recycled orincinerated offsite and the treated soil/sediment would beredeposited onsite.
Reduction of Toxicity, Mobility and Volume. Chemicaldechlorination has been demonstrated to reduce PCBconcentrations in transformer oil to <10 ppm. Full scaledemonstration plants have achieved reductions in soilmedia to a residual of less than 2 ppm. Since the PCB andother chlorinated hydrocarbon contaminants would bepermanently destroyed, chemical dechlorination couldessentially eliminate the toxicity, mobility, and volumeof the contaminants and satisfy the statutory preferencefor treatment as a principle element of a remedialaction.
Short~Term Effectiveness. Temporary hazards to thecommunity and the environment during the implementation ofthis alternative would include the possibility of releaseof and exposure to contaminants transported by surfacerunoff, adsorption of airborne dust, or release by
8-21
volatilization of PCBs during the chemical dechlorination5 9 G 0 u 7 process. The potential for release or exposure via these
routes would be minimized with the use of berms and sumpsto control runoff, nonreactive dust suppressants and windscreens to prevent fugitive dust emissions, and vehicledecontamination to prevent spread of contaminantsoffsite. Even with the use of emission controls duringimplementation of this alternative, some uncontrolledemissions to the environment can be expected.
Implementability. Handling of contaminated soil/sedimentduring chemical dechlorination are established proceduresand contractors that specialize in this type of work aregenerally available.
Research on polychlorinated compounds has shown that acatalyst can be used at room temperature to cause a rapidreduction reaction where chlorine atoms on the organiccompound are replaced with hydrogen atoms. However, theprocess may not completely dechlorinate some organicchemicals and may produce equally toxic or more toxicbyproducts. A treatability study using site specificsoil/sediment would be required to determine thedechlorination efficiency, reagent requirements, andbyproducts produced. Such testing would determine iffurther remedial action is required to treat thebyproducts produce.
Cost. The detailed capital and annual cost estimates forAlternative S/S-5A and Alternative S/S-5B are presented inTable 8-14 and Table 8-15, respectively. The capitalcosts associated with implementation include treatabilitytesting, material handling, chemical dechlorination,soil/sediment sampling, and site restoration. Included inthe cost of chemical dechlorination is the operating costof the dechlorination equipment and disposal of residualreagent and rinse water offsite by the contractor. Annualcosts associated with this alternative include mowing therevegetated areas and weekly visits by securitypersonnel. As in the onsite incineration alternative,this alternative's costs are based on the assumption thatthe treated soil/sediment can be redeposited in itsoriginal location. The total present worth ofAlternatives S/S-5A and S/S-5B are $8,560,900 and$7,820,800, respectively.
8.2.6 Alternative S/S-6; Excavation for Onsite SolventExtraction
Protection of Human Health and the Environment. Thisalternative would protect the local community and theenvironment by chemically treating the contaminatedsoil/sediment containing PCB concentrations above 1 ppm
8-22
r n n H .:: o (for Alternative S/S-6A) or above 10 ppm (for Alternative0 -; u u u u S/S-6B). The treatment would involve the extraction of
the PCB molecules from the soil. The treated soil wouldbe redeposited onsite and the solvent residuals would betransported offsite for recycling or incineration.
Treatment of the soils and removal of the PCB contaminantswould control the risk of direct contact or ingestion ofPCBs in the contaminated soils. Depending upon thesolvent used, this alternative may also be effective forother organic contaminants such as dioxin/furans. Thetreatment system would not reduce risks associated withcross-media contamination by inorganic contaminants.
Compliance with ARARs. This alternative's compliance withARARs would generally be the same as onsitedechlorination. The concentrated wastes which would bedrummed for offsite incineration must meet RCRA and DOTregulations for shipment of hazardous materials. Thisalternative does not generate a wastewater stream,therefore, no discharge to surface waters or the POTWwould be required.
Long-Term Effectiveness and Permanence. The long-termeffectiveness and permanence of this alternative would besimilar to the previous alternative, dechlorination,except that the organic contaminants would be concentratedand then incinerated offsite. Residual organiccontamination in the treated soil/sediment would besimilar. The residual risk due to all forms of contactwith onsite and offsite soil/sediment would be reduced.
Reduction of Toxicity, Mobility, and Volume. The solventextraction process achieves reductions in the toxicity andvolume of organic contaminants and in the mobility ofinorganics. The process concentrates the organiccontaminants in a liquid waste stream which is then sentto an incinerator for destruction. The process hasdemonstrated over 99 percent PCB removal from soils andsediments in demonstration scale projects. Similarremoval efficiencies would be expected for dioxin/furansand other organics. The soil does retain a residual TEAcontent of up to 500 ppm, however, TEA is not toxic andreadily biodegrades. The process does not reduce thetoxicity or volume of inorganic contaminants. It does,however, convert metals such as mercury, lead, zinc,chromium, and copper to their lowest solubility states,thus minimizing their mobility.
8-23
J -^ ~ ° ̂ Short-Term Effectiveness. The short-term impacts of thesolvent extraction process would be very similar todechlorination. The principle effects would be the resultof excavation and replacement activities, not the solventextraction equipment.
Hazardous materials extracted from the soil/sediment wouldbe transported to an offsite licensed incinerator.
Implementability. As in the two previous alternatives,the material handling portion of this alternative usesestablished practices and contractors that are readilyavailable. The solvent extraction process must be pilottested prior to implementation to confirm removalefficiencies, number of extraction cycles, solventconsumption, and other process variables. Such testingwould also confirm whether the treated media is suitablefor replacement or whether it must be landfilled offsite.
Cost. The detailed capital and annual cost estimates forAlternatives S/S-6A and S/S-6B are presented in Tables8-16 and 8-17, respectively. The capital costs includedmaterial handling, pilot plant operation, solventextraction, confirmation testing, and site restoration.Annual costs are limited to periodic site mowing andsecurity inspections. The total present worths ofAlternatives S/S-6A and S/S-6B are $9,346,000 and$8,539,800, respectively.
8.3 Structure Alternatives
8.3.1 Alternative S-l; No Action
Protection of Human Health and the Environment. TheRemedial Investigation and Risk Assessment for theCarolina Transformer site did not identify any chemicalcontamination risks associated with the onsite structuresalthough the possibility exists that untested surfaces maycontain high levels of PCBs. Physical risks do exist totrespassers due to the uncertain structural soundness ofthe buildings. The integrity of the structures can beexpected to continue to deteriorate, increasing thisrisk. The "no action" alternative would not provide anymitigation of this risk.
The onsite building provides no hazard to the environmentunless undetected high levels of PCB contamination existson walls and floors.
Compliance with ARARs. The results of PCB surfacecontamination tests indicate that the structure currentlymeets the PCB Spill Cleanup Policy for high
8-24
contact surfaces. If untested areas exist which exceed5 9 00/0 this level, the "no action" alternative would not bring
these areas into compliance.
Lonq-Term Effectiveness and Permanence. Because remedialactions would not occur, the existing chemical andphysical risks at the site would remain. Since sitecontrols would not be implemented, the criterionaddressing the adequacy and reliability of controls is notapplicable to the alternative.
Reduction of Toxicity. Mobility, and Volume. Sinceremedial activities would not occur, there would not be areduction in the toxicity, mobility, or volume ofcontaminants at the site. If present, the existing typeand quantity of hazardous material would remain on site.
Short-Term Effectiveness. Because site activities wouldnot occur, protection of workers and the community wouldnot be required. Environmental impacts due toconstruction or implementation would not be encounteredsince there would be no activities performed at the site.
Implementability. This criterion is not applicablebecause remedial activities would not occur. Services andmaterials and the activities normally needed to coordinatewith other agencies would not be necessary.
Cost. There would be no costs incurred since remedialactivities would not be performed.
8.3.2 Alternative S-2; Fencing
Protection of Human Health and the Environment. Risksassociated with structurally unsound building and dermalcontact with potentially contaminated surfaces would becontrolled by access restrictions. Security fencing withwarning signs would reduce (but not eliminate) thepossibility of site trespassers gaining access to thebuildings.
Compliance with ARARs. As described in Section 8.3.1.this alternative would not meet ARARs related to PCB spillcleanup if contaminated surfaces exists.
Lonq-Term Effectiveness and Permanence. The long-termeffectiveness of this alternative depend upon theenforcement and maintenance provided. The security fencewould be required indefinitely to prevent access.Periodic repair or replacement of the fence would benecessary.
Reduction of Toxicity, Mobility, and Volume. Sinceremedial activities would not occur, there would not be a
8-25
n GO/ i reduction in the toxicity, mobility, or volume ofstructure contaminants at the site. If present, theexisting type and quantity of hazardous material wouldremain onsite.
Short-Term Effectiveness. The minimal intrusiveactivities involved with installing a peripheral fencearound the site would result in very slight environmentalimpacts to workers or the community. Since the fencewould be installed beyond the zone of contamination fromthe structures, simple measures to limit worker contactwith contaminated structures during construction would besufficient.
Implementability. The installation of a peripheral fenceat the site can be easily implemented. The fence would beof standard industrial fencing material which is readilyavailable and involves no special materials.
Cost. The costs associated with this alternative arepresented in Table 8-18. The total 30-year present worthof this alternative would be $168,900.
8.3.3 Alternative S-3; Partial Demolition
Protection of Human Health and the Environment. Bydemolishing all building roofs and walls, this alternativewould eliminate hazards to trespassers due todeteriorating structural integrity. Solvent treatment ofPCB-contaminated floor surfaces (Alternative S-3B), ifrequired, will reduce the potential risks associated withthe remaining floor slabs.
Compliance with ARARs. The demolition of the structures'roofs and walls will be conducted in accordance withapplicable OSHA worker safety regulations. AlternativeS-3A assumes that the floor slab surfaces currently complywith PCB Spill Cleanup Policy of 10 ug/100 cm . If somefloor areas currently exceed this level, Alternatives S-3Bwould achieve this ARAR by solvent washing the areas.Incineration of the solvent and rinses would be conductedin an appropriately certified TSCA incinerator.Non-hazardous demolition debris would be disposed of in alicensed landfill.
Lona-Term Effectiveness and Permanence. Both alternativesS-3A and S-3B would provide the same degree of long-termeffective reduction in the hazards associated with onsitestructures. Both would be permanent solutions since alldemolition debris (and wastewater if applicable) would beremoved from the site.
8-26
59 GO/ '/' Reduction of Toxicitv. Mobility, and Volume. Thiscategoryis not applicable for Alternative S-3A since it assumesthat the only hazard presented by the onsite structures isa physical hazard due to deteriorating structuralsoundness. If PCS contamination on floor surfacesrequires treatment, Alternative S-3B, solvent washingconcentrates the contaminant in a solvent and rinseliquids which would be incinerated. This alternative wouldprovide destruction of the contaminant.
Short-Term Effectiveness. Short-term risks to theenvironment and the local community during site activitieswould involve airborne dust during demolition activitiesand transport of demolition debris to the landfill. ForAlternative S-3B, there would also be a risk of exposureto contaminants during offsite transport of solvent andrinse wastes as a result of an accidental spill. RCRA andDOT regulations are designed to minimize the danger ofaccidental release during transport and reduce the hazardsassociated with such a release should it occur. Siteaccess would also be restricted during implementation toprevent accidental exposure to the public. Transport ofdemolition debris would result in uncontrollable effectssuch as increased traffic in the area of the site whichwould lead to increased noise and fugitive dust emissions.
Implementability. The demolition of structures is anestablished practice and contractors that perform thiswork are readily available. Chemical treatment of thebuilding slabs is an innovative technology that has beenshown to be effective in extracting PCB molecules as deepas 1-inch in non-earthen surfaces such as concrete slabs.
Implementation of this alternative would require that thechemical treatment process be demonstrated to providetreatment of PCB contaminated material to 10 ug/100cm2. The effectiveness of the chemical treatment wouldhave to be evaluated during demonstration testing.
Cost. The detailed capital and annual cost estimates forAlternatives S-3A and S-3B are presented in Tables 8-19and 8-20, respectively. The capital costs associated withthese alternatives include demolition of the roofs andwalls of the structures, chemical treatment of thebuilding slabs and disposal of the demolition debris andthe waste from the chemical treatment. The annual O&Mcost would include fence maintenance and weekly securityvisits. The total present worth of these alternatives isestimated to be approximately $189,700 and $238,100,respectively.
8.3.4 Alternative S-4: Complete Demolition
8-27
o ,-., --, , 7 Protection of Human Health and the Environment. These7 U U / v-> alternatives provide essentially the same degree of
protection to human health and the environment as partialdemolition alternatives since the floor slabs present nosignificant hazards if the PCB level of the slabs meetsthe 10 ug/lOOcm2 remedial goal.
Compliance with ARARS. Complete demolition of the sitestructures will be conducted in accordance with OSHAworker safety regulations. Spot areas of concrete whichcontain excessive PCB contamination would be removed andlandfilled in a TSCA landfill. The remaining demolitiondebris will be disposed of in a construction materiallandfill meeting state requirements.
Lonq-Term Effectiveness and Permanence. The demolitionand removal of the structures from the site wouldeffectively minimize the danger to the public and theenvironment in the area of the site. In addition,placement of the PCB-contaminated material in a securelandfill would reduce the potential for the migration ofcontaminants into the soil and groundwater.
Reduction of Toxicity, Mobility, and Volume. Thiscategory is not applicable to Alternative S-4A since itassumes that the only hazard presented by the structuresis a physical one due to deteriorating structuralsoundness. If PCB contamination of floor surfaces ispresent, the removal and landfill of this material wouldreduce its mobility but would have no effect on the volumeor toxicity of the contaminated material.
Short-Term Effectiveness. The short term risks to theenvironment and the local community wold be essentiallythe same as those presented by partial demolition. Theseparate removal and disposal of PCB-contaminated concreteflooring would result in the generation of minor amountsof fugitive dust which could be contaminated with PCBs.Dust collection equipment would be used on this equipmentfor protection of the general public and demolitionworkers.
Implementability. The demolition of structures as well asoffsite transportation and disposal of contaminatedmaterials would be easily implemented using conventionalconstruction technologies. These technologies are allestablished and proven methods of hazardous wasteremediation.
Cost. The detailed capital and annual cost estimates forAlternatives S-4A and S-4B are presented in Tables 8-21and 8-22, respectively. The capital cost categories forthese alternatives are the same as for partial demolition
8-28
with the addition of costs for breaking up the slabs and59 U 0/ -t foundations and transporting the additional waste volume
to the landfill. The total present worth of thesealternatives would be $337,900 and $369,700, respectively.
8.5 Debris/Solid Waste Alternatives
8.5.1 Alternative D-l; No Action
Protection of Human Health and the Environment. Sinceremedial action would not be initiated, this alternativewould not provide any protection to human health or theenvironment. Specifically, the non-carcinogenic hazardindex would be greater than 1 for future onsite residentsand carcinogenic risk would be greater than 1 x 10~b forall populations evaluated in the Risk Assessment Report.Also concern for PCS exposure by terrestrial animals,birds, and plants would not be reduced.
Compliance with ARARs. The no action alternative wouldnot meet ARARs; specifically, TSCA regulations for cleanupand disposal of PCB spills. Violations of state waterquality standards in the periodic surface waters leavingthe site would be expected to occur due to cross-mediacontamination. Cross-media contamination of groundwaterwould also be expected to continue.
Lonq-Term Effectiveness and Permanence. Because remedialactions would not occur, the existing risks at the sitewould remain. Since site controls would not beimplemented, the criterion addressing the adequacy andreliability of controls is not applicable to thealternative.
Reduction of Toxicity, Mobility, and Volume. Sinceremedial activities would not occur, there would not be areduction in the toxicity, mobility, or volume ofcontaminants at the site. The existing type and quantityof hazardous material would remain onsite. Cross-mediacontamination of groundwater, surface water, and sedimentwould continue to occur.
Short-Term Effectiveness. Because site activities wouldnot occur, protection of workers and the community wouldnot be required. Environmental impacts due toconstruction or implementation would not be encounteredsince there would be no activities performed at the site.
Implementability. This criterion is not applicablebecause remedial activities would not occur. Services andmaterials and the activities normally needed to coordinatewith other agencies would not be necessary.
Cost. There would be no costs incurred since remedialactivities would not be performed.
8-29
8.5.2 Alternative D-2; Fencing
Protection of Human Health and the Environment. Risks9 0 G / b associated with dermal contact with or ingestion of onsite
contaminated debris/solid wastes would be controlled bythese access restrictions. Security fencing with warningsigns would reduce {but not eliminate) the possibility ofsite trespassers coming into contact with contaminatedonsite media. This alternative would not be effective atprotecting human health or the environment offsite. Thisalternative would not prevent the additional migration ofhazardous substances into the surface water, offsitesediments, or the underlying groundwater aquifer.
Compliance with ARARs. As described in Section 5.4.1.2.this alternative would not meet state and federal ARARs.
Lonq-Term Effectiveness and Permanence. The long-termeffectiveness of this alternative depends on theenforcement and maintenance provided. Primary site accessrestrictions would be maintained by the security fencearound the site. The fence would be required indefinitelyto prevent access. Periodic repair or replacement of thefence would be necessary.
Reduction of Toxicity, Mobility, and Volume. Sinceremedial activities would not occur, there would be noreduction in the toxicity, mobility, or volume ofdebris/solid waste contaminants at the site. The existingtype and quantity of hazardous material would remainonsite undergoing only natural attenuation or migrationoffsite through cross-media contamination.
Short-Term Effectiveness. The minimal intrusiveactivities involved with installing a peripheral fencearound the site would result in very slight environmentalimpacts to workers or the community. Since the fencewould be installed beyond the zone of contaminateddebris/solid wastes in most cases, simple measures tolimit worker contact with debris/solid waste duringconstruction would be sufficient. This alternative wouldresult in no additional exposure by the community atlarge.
Iroplementability. The installation of a peripheral fenceat the site can be easily implemented. The fence would beof standard industrial fencing material which is readilyavailable and involves no special materials.
Cost. The costs for this alternative would be identicalto Alternative S-2: Fencing which were presented in Table8-18.
8-30
5 9 - ' >8.5.3 Alternative D-3; Offsite Landfill
Protection of Human Health and the Environment. Thisalternative would provide protection from the hazardsassociated with current site conditions by permanentlyremoving the debris/solid wastes from the site fordisposal in an offsite sanitary landfill, RCRA-permittedlandfill as appropriate. Disposal in a secure hazardouswaste landfill, or TSCA landfill, would eliminate thethreat of direct contact with PCBs and reduce the threatof potential migration of these contaminants into the soiland to the groundwater.
Compliance with ARARs. All debris and solid wastes with aPCB level of greater than 50 ppm would be transported to aTSCA facility disposal in compliance with 40CFR 761(a)(4). If any debris has a HOC exceeding 1000 ppm, itwill be incinerated at the facility in accordance withRCRA 40 CFR 264 Subpart O. Liquids if present, would bedrummed and incinerated in accordance with 40 CFR 268.42(a) (1).
Long-Term Effectiveness and Permanence. The removal ofdebris/solid waste from the site would effectivelyminimize the danger to the public and the environment inthe area of the site. In addition, placement ofcontaminated material in a secure landfill would reducethe potential for the migration of contaminants into thegroundwater.
The long-term risks associated with offsite disposal wouldbe the responsibility of the owner/operator of theselected hazardous waste facility. Exposure dangers wouldbe minimized by confonnance to RCRA and TSCA regulationspertaining to leachate control, groundwater monitoring,and cap maintenance. A long-term residual risk, however,would be associated with this alternative sincecontaminants are contained rather than treated ordestroyed.
Reduction of Toxicity, Mobility, and Volume. Sincedisposal in an offsite landfill does not permanentlydestroy or treat contaminated material, it would notdirectly reduce the toxicity or the volume of thecontaminated material. However, the mobility of thecontaminants would be indirectly reduced through offsitecontainment. Landfill disposal is not an irreversibleprocess and would not comply with the statutory preferencefor treatment as a principle element of a remedial action.
8-31
5 9 O U / 7Short-Term Effectiveness. The short-term risks associatedwith implementation of this alternative would involveexposure of the public and the environment to contaminantsfrom migration in airborne dust, surface runoff, or as aresult of an accidental spill during offsite transport.The potential for contaminant migration could be reducedthrough use of nonreactive dust suppressants along withberms and sumps. RCRA and DOT regulations are designed tominimize the danger of accidental release during transportand reduce the hazards associated with such a release,should it occur. Transport of contaminated materialoffsite would result in increased traffic in the area ofthe site which would increase noise and fugitive dustemissions. Even with the use of emission controls, someuncontrolled emissions can be expected. All vehicleswould be decontaminated before leaving the site to preventthe spread of contamination to the local community. Apotential for worker exposure to contaminants, includingvolatile PCBs, would exist during excavation, materialhandling, transport, and landfill placement. Worker riskwould be minimized by compliance with OSHA guidelines andrequirements for hazardous waste site work.
Implementability. Excavation and site restoration, aswell as offsite transport and disposal of contaminatedsoil, would be easily implemented using conventionalconstruction technologies. These technologies are allestablished and proven methods of hazardous wasteremediation. Contractors that specialize in this type ofwork are readily available.
Cost. The detailed cost estimate for the offsite disposalalternative is presented in Table 8-23. Capital costsinvolved in implementing this alternative would includematerial handling, offsite transportation, and disposal.The total present worth of this alternative would be$67,600.
8.6 State Acceptance
The State of North Carolina, as represented by the NorthCarolina Department of Environmental, Health, and NaturalResoures, concurs in the selection of Alternatives G-4, S/S-6,S-3, and D-3 as the preferred Alternative for the CarolinaTransformer Site.
8.7 Community Acceptance
During the public meeting, held on April 17, 1991, theFayetteville community had no objections with the selection ofAlternatives G-4, S/S-6, S-3, and D-3 as the preferredAlternative for the Carolina Transformer Site.
8-32
GO/' o8.8 Summary
Tables 8-1 through 8-3 present a summary ranking of eachalternative against the evaluation criteria and eachalternatives present worth cost. Each alternative performanceagainst the criteria was ranked on a scale of zero to five,with zero indicating that none of the criteria's requirementswere met and five indicating all of the requirements were met.
8-33
VO
Table 8.1Remedial Alternatives Evaluation Summary
Groundwater
AlternativeG-l: No Action
G-2: Deed Restrictions
G-3A: Mutals Removal/Air Stripping/Adsorption/Discharge to River
G-3B: Metals Removal/Air Stripping/Adsorption/Discharge to POTW
G-4A: Metals Removal/Adsorption/Discharge to River
G-4B: Metals Removal/Adsorption/Discharge to POTW
G-5: Adsorption/Discharge to River
G-6A: Metals Removal/UV Oxidation/Discharge to River
G-6B: Metals Removal/UV Oxidation/Discharge to POTW
G-7: UV Oxidation/Discharge to River
Criteria Rating'Protection ot
Human Healthand the
Environment0
3
5
5
5
5
3
5
5
3
ComplianceWith ARABS
0
0
5
5
5
5
3
5
5
4
Long-TermEtlectiveness
andPerma nonce
0
3
5
5
5
5
5
5
5
5
Reduction inToxicity,Mobility,
and Volume0
0
5
5
5
5
4
5
5
4
Short-TermEffectiveness
NA
5
4
4
5
5
5
5
5
5
ImplementabllilyNA
4
5
5
5
5
5
5
5
5
PresentWorth
Cost ($)0
50.000
878.500
949.700
830,500
898.800
435,000
993.300
1.055,500
590.600
o
• Rating of 0 indicates complete noncompliance with criteria.Rating ot 5 Indicates complete compliance with criteria.
en
Table 8.2Remedial Alternatives Evaluation Summary
Soil/Sedirnent O
AlternativeS/S-1: No Action
S/S-2: Fence/Deed Restrictions
S/S-3A: Excavation lor Offsite Landfill(PCBs > 1 ppm)
S/S-3B: Excavation lor Ollslle Landfill(PCBs> 10 ppm)
S/S-4A: Excavation lor Onsite Incineration(PCBs > 1 ppm)
S/S-4B: Excavation lor Onsite Incineration(PCBs> 10 ppm)
S/S-5A: Excavation lor Onsite ChemicalDechlorlnatlon (PCBs > i ppm)
S/S-5B: Excavation lor Onsite ChemicalDechlorinatlon (PCBs > 10 ppm)
S/S-6A: Excavation lor Onslle SolventExtraction (PCBs > 1 ppm)
S/S-6B: Excavation lor Onsite SolventExtraction (PCBs > 10 ppm)
Protection olHuman Health
and theEnvironment
0
2
5
4
5
4
5
4
5
4
ComplianceWith ARABS
0
0
5
5
4
4
5
5
b
S
Criteria 1Long-Terrn
Eltectivenessand
Permanence0
2
5
4
5
4
5
4
5
4
Bating*Reduction in
Toxicity,Mobility.
and Volume0
0
3
3
5
4
5
4
5
4
Short-TermEffectiveness
NA
5
5
5
4
4
5
5
5
5
ImplementabllityNA
4
5
5
3
3
5
5
5
5
PresentWorth
Cost ($)0
172.000
9.228.800
8.463.600
18.019,300
16.301.200
8.560.900
7.820.800
9.346.000
8.539.800
* Baling of 0 indicates complete noncompllance with criteria.Rating ol 5 indicates complete compliance with cntena.
Table 8.3Remedial Alternatives Evaluation Summary
Structures and Debris/Solid Wastes
AlternativeStucturesS-1: No ActionS-2: FencingS-3A: Partial DemolitionS-3B: Partial DemolitionS-4A: Complete DemolitionS-4B: Complete DemolitionDebris/Solid WastesD-1: No ActionD-2: FencingD-3: Ollsite Disposal
Protection olHuman Health
and theEnvironment
2T
34
4
5
025
ComplianceWith ARABS
NAMA
NANA
1 NANA
005
CriteriaLong-Term
Effectivenessand
Permanence
2T
34
4
5
025
bating*Reduction in
Toxicity,Mobility,
and Volume
00
5
5
004
Short-TermEtlectiveness
NA54433
NA53
Implementabilily
NA55555
NA55
PresentWorth
Cost ($)
0168000189,700238,100337,900369.700
0168.90067.600
OCDC-
' Rating ol 0 Indicates complete noncompllance with criteria.
59 00629.0 Selected Remedy
EPA has selected combination of the alternatives presented in thisdocument to serve as the selected remedy for the Carolina TransformerSite. The selected remedy is protective of human health and theEnvironment. Those alternatives EPA has selected to serve as the remedyfor the Carolina Transformer Site are listed below. (Tables 9-1 and 9-2list the remedial goals that will be met by the selected remedy.) Theremay be some changes made to the remedy as a result of the remedialdesign and construction process. However, such changes in generalreflect modifications resulting from the engineering design process.
1. Alternative S/S-6; Excavation of the contaminated soil with PCB's inexcess of 1 ppm and use of a solvent extraction process to separateorganic contaminants such as PCB', dioxin/furans, volatile organics,and polynuclear aromatic compounds from the soil and sediments. Theprocess will convert inorganic contaminants such as lead and copperto lower solubility hydroxides thereby reducing their mobility.TCLP will be run on the treated soil and sediment prior to itsreturn to its original location to determine if it meets the RCRAToxicity Characteristic Rule. The treated soil and sediment willalso be modeled to assure that its placement will not causeviolation of North Carolina's Groundwater Standards. Soil andsediments not meeting the Toxicity Rule or which is shown bymodeling to cause future violations of North Carolina's GroundwaterStandards will be solidified. The contaminant rich waste streamwill be transported off site for treatment. Table 9-3 lists themajor components involved and their associated cost.
2. Alternative S-3; Demolition of the roofs and walls of the threeon-site buildings. The debris would be crushed and transported to anoff-site landfill. If the remaining slabs are found to becontaminated with PCBs in excess of lOug/100cm they will betreated with a solvent washing system to extract the residual PCBs.Table 9-4 list the major components and their associated cost.
3. Alternative D-3; The debris and solid waste from the site will betransported to an off-site landfill for disposal and/or treatment inaccordance with RCRA 40 CFR 264 Subpart O and 40CFR 761 (a)(4).This alternative is designed to reduce the risk associated withdirect contact with materials remaining on site to within the 10carcinogenic risk level and the non-carcinogenic hazardous index of1. Table 9-5 lists the major components and their associated cost.
4. Alternative G-4; Install groundwater extraction wells and use a twocomponent treatment system (Metals Removal, Adsorption) to removethe metals and organic contaminants. The risk to future users ofgroundwater associated with ingestion, inhalation, and dermalcontact with contaminants in the groundwater would be reduced bythis pump and treat system. The operation of the system wouldcontinue until the groundwater meets the remediation goals listed in
9-1
5 9 0063Table 9-1. Table 9-6 list the major components and their associatedcost.
The goal of this remedial action is to restore ground water to itsbeneficial use, which is a potential potable water source. Based
on information obtained during the remedial investigation and on acareful analysis of all remedial alternatives, EPA believes theselected remedy will achieve this goal. It may become apparent,during implementation or operation of the ground water extractionsystem and its modifications, that contaminant levels have ceased todecline and are remaining constant at levels higher than theremediation goal over some portion of the contaminated plume. In sua case, the system performance standards and/or the remedy may bere-evaluated.
The selected remedy will include ground water extraction for anestimated period of 10 years, during which time the system'sperformance will be carefully monitored on a regular basis andadjusted as warranted by the performance data collected duringoperation. Modifications may include any or all of the following:
a) at individual wells where cleanup goals have been attained,pumping may be discontinued;
b) alternating pumping at wells to eliminate stagnation points;
c) pulse pumping to allow aquifer equilibration and to allowadsorbate contaminants to partition into ground water; and
d) installations of additional extraction wells to facilitate oaccelerate cleanup of the contaminant plume.
To ensure that cleanup goals continue to be maintained, the aquiferwill be monitored at those wells where pumping has ceased on anoccurrence of every 5 years following discontinuation of ground wateextraction.
If it is determined, on the basis of the preceding criteria and thesystem performance data, that certain portions of the aquifer cannotbe restored to their beneficial use, all of the following measuresinvolving long-term management may occur, for an indefinite period otime, as a modification of the existing system:
a) engineering controls such as physical barriers, or long-termgradient control provided by low level pumping, as containmentmeasures;
b) chemical-specific ARARs will be waived for the cleanup ofthose portions of the aquifer based on the technicalimpracticability of achieving further containment reduction;
c) institutional controls will be provided and maintained torestrict access to those portions of the aquifer which remain
9-2
,-, r-, ,1 A above health-based goals, since this aquifer is classified as5 9 UUO +a potential drinking water source;
d) continued monitoring of specified wells; and
e) periodic re-evaluation of remedial technologies forgroundwater restoration.
The decision to invoke any or all of these measures may be made duria periodic review of the remedial action, which will occur atintervals of at least every five years, in accordance with CERCLA121(c). To ensure State and public involvement in this decision atthis Site, any changes from the remediation goals indentified in thiROD will be formalized in either an Explanation of SignificantDifference document or an Amendment to this Record of Decision,thereby providing an opportunity for State and public.
Monitoring wells will be installed into the lower aquifer to confirmits status. If it is found to be contaminated, the groundwatertreatment system mentioned above will be expanded to address thecontamination of the lower aquifer. The protectiveness of theremediation of the lower aquifer will be identical to that of theshallow aquifer and meet the same groundwater quality criteria
The treated groundwater will be discharge to the Fayetteville POTW othe unnamed tributary to the Cape Fear River.
9-3
5 9 0 0 8 5
Contaminant
AluminumBariumChromiumCobaltCopperLeadManganeseMercuryNickelStrontiumTitaniumVaiadiumYttr 'umZincPCS-1260Bis'2-ethylhexl)Fhthalate1 ,2,4-TrichlorobenzeneMethyl Ethyl KetoneTjlueneCarbon DisulfideBenzeneChlorobenzene1 ,3-Dichlorobenzene1 ,4-Dichlorobenzene
Table 5- iGroundwater Remediation
MaximumDetected
Concentrationug/l
1,900,00019,000
2,900670
3, COG190
25,0000.4
1,2001,4006,70049001,5003,500
52920
5
10c, 5
118020
9.337
UpgradientConcentration
Ranqe *ug/!
1,900-740,000250-6,000
32-640ND** -180
25-340ND-110
270-2,700ND-0.22ND-16088-610
320-2,90050-1,200
20-64035-900
NDND
ND-1.5NDNDNDNDNDNDND
Goals
RemedialGoalugyl
—i.oon
50—
1,3001550
1100——
615—
5,000
.149
1901,000
551
10060
1.8
Selection Bas;s
Lack of RiskNCGSMCLG
Lack of RISKMCLG
EPA GuidelineNCGSNCGSMCLG
Lack of n'SkLack of R.SK
PfDLack of Risk
Seccncary MCL
NCGSMCLGMCLG
RfDNCGS
= fD
NCGSMCLGMCLGMCLG
Groundwater samples 16GW, 19GW, 21GW, MW1, and MW2.ND denotes not detected.
9 U 0 o 6 Table 9.2Soil/Sediment Remedial Goals
Contaminant
PCB (total)Dioxins/Furans
MaximumConcentration
Detectedmg/kg
2,1004.2E-04
Range ofBackground
Concentration 'mg/kgND"ND
RemedialGoal
mg/kg1 (10)*-*1.2E-04
Selection Basis
ERA GuidelinesCarcinogenic Risk
Soil samples 19SLA, 19SLB, 20SLA and 20SLBND denotes not detected.() Indicates alternative goal.
5 9
Tac'9 '? . jCos! Estimate
Q u o / Alternative S/S-6A: Onsite Solvent Extraction
ItemMobilization/Demobilization
Material HandlingExcavation - Onsite
- OftsiteConfirmation Sampling
SamplingRGB'STAL&TCLDioxin/Furans
Protective Clothing (Level D)Hauling to Site - Onsite
- Offsite
Quantity Units1 LS
5,7809,565
505050
UnitCost($)
1,000.00
CYCY
EventsAnalysesAnalyses
10 Analyses200 Sets
5,780 CY9,565
Solvent ExtractionMobilization/Demobilization 1Feed Soil Sampling
PCB'sTreated Soil Sampling
PCB's
CY
LS60 Events60 Analyses60 Events60 Analyses
TCLP i 20 AnalysesDicx-n/Fura-s 30 Ana!yses
Air Sampling & AnalysisPilot Plant
30 AnalysesLS
Loading Equ;pment ! 2V5CO Tons
1.371.37
25.00120.00
Capital AnnualCost(S) Ccs;(S/Yr)
1,000^
7,90013,100
1,3006.000
1,050.00 52,500850.00 8,500
30.001.303.10
500,000.0010.00
120.0010.00
6,0007,500
29,700 !!
500,000600
7.200600
120.00 7,200300.00 9.000350.00 25,500
1,900.00 57,000150,000.00 150,000
6.70 ! 144,100Solvent Extraction 2 1 . 5 0 0 ' Tons . 220.00 4,945,000;Waste Material TransportWaste Material incineration
Return Soil - Onsite
•0 Drums 200.00 , 2,0006, COO ib. 0.80
5,780 CY 1.30- Of'site '• 9,565 CY
Grading Compaction 15.345 CYHydroseeding 46,000 : SY
Maintenance Mowing 10 Events/Yr
Security 52 ; Visits/Yr|
SubtotalBid Contingencies (1 5%)Scope Contingencies (1 5%)
Construction TotalPermitting and Legal (3%)Construction Services (5%)
Total ImplementationEngineering Design (8%)
Total CapitalTotal AnnualPresent Worth (30 years of maintenance)
3.102.500.40
300.00
100.00
4,800 t
7,50029,70038,40018,400
6,080,500912,100912,100
7.904,700237,100395,200
8,537,000683,000
9,220,000
3.00C
5. 200
8.20C
8,2009,346,000
All costs rounded to the nearest $100.
9 0 0 8 8v^csi Est,.T.at9
Alternat ive S-3B' Panial Demolition
ItemMobilization/Demobilization
Fencing6-R. FencingCorner PostsCorner BracesWarning Signs
DemolitionMobilization/DemobilizationMain BuildingMaintenance BuildingBurn Building
Solvent WashingWashing EquipmentWash SolventConfirmation Sampling
PCBsProtective Clothing (level D)Vacuum Truck
DisposalTransport to LandfillTransport toTSCA IncineratorDisposal in LandfillIncineration
Fencing Maintenance
•Maintenance Mowing
Site Security
SubtotalBid Contingencies (15%)Scope Contingencies (15%)
Construction TotalPermitting and Legal (3%)Construction Services (5%)
Total ImplementationEngineering Design (8%)
Total CapitalTotal AnnualPresent Worth (30 years ol maintenance)
Quantity1
1,10024
10
18807318
1170
15153C24
9711
9531,500
1
10
52
UnitsLS
Ft.Posts
BracesSigns
LSCYCYCY
EachGallon
SamplesAnalyses
Sets
UnitCost($)
1,000.00
I 15.2585.0030.00
5.00
1,000.005.705.705.70
4,500.0054.0020.00
175.0030.00
Hours 99.00
CYTrucKload
CYGallons
Event/Yr.
Event/Yr.
Visit s/Yr.
5.353,300.00
2.005.80
1,000.00
300.00
100.00
.-
CapitalCost($)
1.000
16.800200100100
1,0005,000
400100
4,5009,200
3002,600
9002,400
5,2003,3001,9008,700
63,7009,6009,600
82,9002,5004,100
89,5007,200
96,700
AnnualCost(VYr)
1,000
I 3,000
5.200
9,200
9,200238,100
All costs rounded to the nearest $100.
G 0 o 9Taoie ° • 5
Cost EstimateAlternative D-3: Offsile Disposal of Debris/Solid Wastes
ItemMobilization/Demobilization
Material HandlingLaborEquipment
Landfill DisposalTransport to LandfillTransport to RCRA LandfillTransport to TSCA LandfillLandfillRCRA LandfillTSCA Landfill
SubtotalBid Contingencies (15%)Scope Contingencies (15%)
Construction TotalPermitting and Legal (3%)Construction Services (5%)
Tctal ImplementationEngineering Design (8%)
Total CapitalTotal AnnualPresent Worth
Quantity1
1515
8011
801010
UnitsLS
DaysDays
TonsTruckloadTruckload
TonsTonsTons
UnitCost(S)
1,000.00
1,900.00500.00
5.35500.00
1,850.002.00
210.00245.00
,-
CapitalCcst(S)
1,000
28,5007,500
400
5001,900
2002,1002,500
44,6006,7006,700
58,0001,7002,900
62,6005,000
67,600
AnnualCcsKS/Yf)
I
67,500All costs rounded to the nearest $100.
5 9 0 0 9 0Table 9.6
Cost EstimateAlternative G-48. Metal Removal/Adsorption
Item Quant i ty UnitsMobilization : 1 LSGroundwater Extraction System ;
Extraction EquipmentPowerMainienanceLabcr (2 T^'mo)
Meiais Removal SystemPilot TestPackage UnitEnclosure (20 ft x 25 ft)Air Blowe'Uti l i ty ConnectionsChemicals & PowerMaintenanceLabor (8 nr 'wk)Sludge Transport to Landfil l
11,140
1
24
11
5001
LSKWHA'r
LS/YrHr/yr
TestUnit _SF
Blower1 LS
5,2561
416
5
iOOOGal/YrLS/YrHr/Yr
Drums/YrSludge Disposal in Landfill 1 ' Ton/Yr
Activated Ca^bcn SystemAct vatec Ca rbcn UnitCareen ReplacementMaintenanceLabor (2 hr/mo)
Discharge SystemDischarge L r-e lo POT\V LineSewer Charge
MonitoringInfluent Samples (1 per mo)Eff luent Samples (1 per wk)
1 Unit4.000 LBAYr
1 : LS/Yr24 . Hr/Yr
50 • Ft5.25c : lOOOGal/Yr
•2
UnitCost ($)
1.000
140,0000.0710030
5,000140,000
101,5007,3000.35
7,0003075
300
4,0001.20300
30
3.501.70
Capital 'st Year AnnualCost (S) Ccst (S.V0
1,000
140,000, • 100
5,OCO
'00700
140,0005.0001,5007,300
i .SOO7. COO
•2.500400
300
4,0004.3CO
300700
2003 900
Samples/Yr j 2552 Samples/Yr ; 25 :
300'.300
PCBs ' 64 ; Anaiyses/Yr 65 d 200Metals 64 ; Anaiyses/Yr U5Purgeaole Organtcs 64 '• Analyses/Yr
SubtotalBid Contingencies (l5°/b)Scope Conting«ncies (15%)
Construction TotalPermitting and Legal (3%)Construction Services (5%)
Total ImplementationEngineering Design (8%)
Total CapitalTotal 1st Year AnnualPresent Worth (10 years of operation)
I125
; 9,3003,000
303.00045,50045,500
394,0001 1 ,80019,700
425.50034,000
459,500
!|
60.700
ii
.60,700
898,800All costs rounded 10 the nearest $100.
10. Statutory Determinations
„--- The U.S. EPA and N.C. Department of Environment, Health andCA Natural Resources have determined that this remedy is protectiveCD of human health and the environment, attains ARARs, is costCD effective, utilizes permanent solutions, alternative treatment
technologies or resource recovery technologies to the maximumextent practicable which satisfies the statutory reouirements ofSection 121 of CERCLA
CT\10.1 Protection of Human Health and the EnvironmentI.T) ————————————————————————————————————————Based on the risk assessment developed for this site, dermalcontact with and ingestion of the contaminated soil andsediment, ingestion and inhalation of the contaminatedgroundwater, are the identified risks associated with the site.
The selected remedy of solvent extraction in conjunction withthe groundwater extraction and treatment system is protective ofhuman health and the environment. The alternatives selectedprovide a permanent remedy that removes the contaminants fromthe associated media and disposes of the reduced contaminatedwaste stream off site.
10.2 Compliance with Applicable or Relevant and AppropriateRequirements (ARARs)
The remedy selected will comply with all applicable or relevantand appropriate chemical-, action-, and location-specificrequirements (ARARs) of Federal and more stringent Stateenvironmental laws. This Site does not contain California ListWaste and and the residual materials remaining on site will notcontain RCRA characteristic waste. The concentrated wastedesignated for off site treatment will be drummed andtransported off site per RCRA and DOT regulation.
10.2.1 Chemical Specific ARARs
Chemical specific ARARs includes those laws andregulations governing the release of materialspossessing certain chemical or physicalcharacteristics, or containing specified chemicalcompounds. These requirements generally set health orrisk-based concentration limits or dischargelimitations in various environmental media for specifichazardous substances, contaminants and pollutants. Thechemical specific ARARs which set the concentrationlimits for the cleanup criteria at this site are listedbelow by media.
The ground water cleanup standards for this Site areset at the most stringent of the following ARARs sincethe aquifer is a potential drinking water source: SafeDrinking Water Act (SDWA); Clean Water Act (CWA); andNorth Carolina Water Quality Standards.
10-1
S 9 0092The soil and debris cleanup standards are based onGuidance on Remedial Actions for Superfund Sites withPCB Contamination, OSWER Directive No. 9355.4-01.,Toxic Substance Control Act (TSCA). Table 10-1 gives adetailed break-down of the governing Chemical-SpecificARARs.
10.2.2 Location-Specific ARARs
Location-specific ARARs are design requirements oractivity and/or contaminant concentration restrictionsbased on the geographical or physical position of thesite and its surrounding area. ( Table 10-2 outlinesthe location specific ARARs applicable to the Site.)
10.2.3 Action Specific ARARs
Action Specific ARARs are those ARARs that placeactivity-based requirements on a particular technologyor places condition on dealing with specificsubstances. (Table A-l in Appendix A outlines theAction-Specific ARARS applicable to this Site)
10.3 Cost Effectiveness
The present estimated cost of EPA's selected remedy is$10,474,200.00. The selected remedy provides a permanentsolution and affords overall effectiveness proportional to itscosts such that the remedy represents a reasonable value for themoney. When the cost and overall effectiveness of the selectedremedy is compared to the other alternatives, the selectedremedy is the most cost effective.
10.4 Utilization of Permanent Solutions and AlternativeTreatment Technologies or Resource Recovery Technologiesto the Maximum Extent Practicable
The remedy selected meets the statutory requirement ofutiliizing permanent solutions and treatment technologies to themaximum extent practical. The selected remedy provides the bestbalance in terms of long and short term effectiveness,permanence, implementability, cost, reduction in toxicity,mobility and volume.
10-2
Table 10-1Potent ial Chemical-Specific ARARs
Standard, RequirementCriteria or Limitation Citation Description
Applicable/Relevant andAppropriate
c:Gvr.
Comment
FederalSafe Drinking Water Act
National PrimaryDrinking WaterStandards
40 USC Sect. 300
40CFR Part 141
National SecondaryDrinking WaterStandards
Maximum ContaminantLevel Goals
40 CFR Part 143
Pub. L No 99-339, lOOStat.642(1986)
Establishes health-based No/Yesstandards for publicwater systems (maximumcontaminant levels).
Establishes welfare-based No/Nostandards for public watersystems (secondary maximumcontaminant levels).
Establishes drinking water No/Yesquality goals set at levelsof no known or anticipatedadverse health effect.
The MCLs for organic andinorganic contaminants arerelevant and appropriate forgroundwater at the site sinceit is a potential drinking watersource.
The secondary MCLs forinorganic contaminantsin groundwater are "tobe considered" guidelines.
Proposed MCLGs for organicand inorganic contaminantsare relevant and appropriatefor goundwater potentiallyused for drinking water
Table 10-1 (continued)Potential Chemical-Specific ARARs
VC
Standard. RequirementCriteria or Limitation
Federal (continued)Clean Water Act
Citation
33 USC Sect.1251-1376
Description
Applicable/Relevant andAppropriate
0V.",
Comment
Water Quality Criteria 40CFRPart 131
Resource Conservationand Recovery Act (RCRA).as amended
RCRA GroundwaterProtection
RCRA SWMURequirements
42 USC 6905.6912.6924.6925
40 CFR Part 264
40 CFR Part254 3-4
Sets cnterial for waterquality based on toxicityto aquatic organisms and.human health.
No/Yes
Provides for groundwaterprotection standards,general monitoringrequirements and technicalrequirements.
Provides for protectiongroundwater at solid wastemanagement unit.
No/Yes
Yes/No
The AWQC for organic andinorganic contaminants arerelevant and appropriate.
The RCRA MCLs are relevantand appropriate forgroundwater at the site.
May be applicable ifremedial action includesprovisions for an on-sitelandfill.
Table 1 u- l(contmued)Potential Chemical-Specific ARARs
Cn
Standard. RequirementCriteria or Limitation Citation Description
Applicable/Relevant andAppropriate
O
Comment
Federal (continued)
Clean Air Act
National Primary andSecondary AmbientAir Quality Standards
National EmissionsStandards for HazardousAir Pollutants(NESHAPs)
Toxic Substances ControlAct (TSCA)
Occupational Safety andHealth Administration
40 USC 1857
40 CFR Part 50
40CFRPart61
15 USC 2601
29 CFR 1910Part 120
Sets primary and secondary No/Yesair standards at levels toprotect public health andpublic welfare.
Provides emissions standard No/Yesfor hazardous air pollutantsfor which no ambient airquality standard exists.
Regulates disposal of TBCwaste materialscontaining PCBcontamination.
Provides safety rules for Yes/Nohandling specificchemicals for siteworkers during remedialactivities.
May be relevant or appropriateif on-site treatment unitsare part of remedial actions
Maybe relevant or appropriateif on-site treatment unitsare part of remedial actions
The substantive requirementsfor treatment and disposalof PCB contaminatedare to-be-considered.
Health and safety requirementsare applicable to all potentialremedial actions
Standard, RequirementCriteria or Limitation
Federal (continued)
Citation
Table] o-i (continued)Potential Chemical-Specific ARARs
Description
Applicable/Relevant andAppropriate
CDCD
Comment
Departmen t of Trans-ation (DOT) HazardousMaterials TransportationAct
49 USC 1801 Regulates off-sitetransportation ofspecific hazardouschemicals and wastes.
Yes/No Regulations for transport ofcontaminated media off-site areapplicable to potentialactivities at the site.
StateNorth Carolina WaterQuality ControlStandards
North Carolina DrinkingWater Act
15ANCAC2B
130ANCAC311-327
Establishes water quality Yes/Norequirements applicableto all surface waters ofNorth Carolina whichprotect public health andthe environment.
Regulates water systems No/Yeswithin the State whichsupply drinking waterthat may affect the publichealth.
Guidelines for allowablelevels of toxic organicand inorganic compoundsin surface water aftera discharge is mixed witha receiving stream.
Provides the State with theauthority needed to assumeprimary enforcementresponsibility under thefederal act.
Table 10- 2Potential Location-Specific ARARs
Standard, Requirement.Criteria, or Limitation Citation Description
Applicable/Relevant andAppropriate Comment
0CDV.-o
FederalResource Conservationand Recovery Act (asamended)
LocationStandards
Fish and WildlifeCoordination Act
42 DSC 6901
40CFR264.18(b)
16 DSC 661-666
A TSD facility must bedesigned, constructed,operated, and maintainedto avoid washout.
No/Yes Potential remedial alternativeswithin the 100-year floodplain.Requirement is relevant andappropriate.
Floodplain ManagementExecutive Order
Executive Order11988; 40 CFR 6.302
Actions that are to occurin floodplain should avoidadverse effects, minimizepotential harm, restore andpreserve natural andbeneficial value.
Yes/No Remedial actions are to preventincursion of contaminated ground-water onto forested floodplain.
Table io-2(continued)Potential Location-Specific ARARs
en
MD
Standard, Requirement,Criteria, or Limitation Citation Description
Applicable/Relevant andAppropriate
oV;CO
Comment
Federal (continued)Wetlands Protection Executive Order
11990;40CFR6,Appendix A.
Requires that EPA conductactivities to avoid, to theextent possible, the longand short-term adverseimpacts associated with thedestruction or modificationof wetlands.
Yes/No Remedial actions to impact site,directly by stopping incursionof contaminated groundwaterinto wetlands area associatedwith Cape Fear River.
Endangered Species Act 16 DSC 1531
Clean Water Act
Dredge or FillRequirements(Section 404)
Rivers and HarborsAct of 1889Section 10 permit
33 DSC Sect. 1251
40 CFR 230
33 USC Sect. 403
Requires action to conserve No/Noendangered species orthreatened species, includingconsultation with theDepartment of Interior.
Requires permit tor discharge No/Noof dredged or fill materialinto aquatic environment.
Requires permit for structures No/Noor work m or affectingnavigable waters.
No threatened or endangeredspecies or critical habitatswere identified in or nearthe site.
No alternative will be developedwhich will discharge dredgeor fill material into anaquatic environment.
No alternative involves work thatwould affect a navigable waterway
en
Standard, Requirement,Criteria, or Limitation
Federal (continued)Wilderness Act
Citation
16 USC 131150CFR35.1
Table 10-2(continued)Potential Location-Specific ARARs
Description
Area must be administeredin such a way as will leaveit unimpaired as wildernessand will preserve itas a wilderness.
Applicable/Relevant andAppropriate
No/No
Comment
No wilderness areas exist onsiteor adjacent to the site.
OV,\o
National WildlifeRefuge System
Wild and ScenicRivers Act
16 USC 66850 CFR 27
16 USC 127140 CFR
Restricts activities within No/NoNational Wildlife Refuge.
Prohibits actions that will No/Nohave direct adverse effectson a scenic river.
No wildlife refuge areas existonsite or adjacent to the site.
No scenic river in area.
Coastal Zone ManagementAct
16 USC Sect. 1451et.seq.
Conduct activities in mannerconsistent with approvedState Management Program.
No/No Area is not in thecoastal zone.
59 0 : ( j D
APPENDIX A
ACTION-SPECIFIC ARARs
en
vO
Table A-1Action Specific-ARARs
Groundwater
CD
Standard, Requirement,Criteria, or Limitation
FederalResource Conservation and Recovery Act
Identification of Hazardous Waete*
Treatment of Hazardous Wacte* in a Unit
Requirement* for Generation. Storage.
Treatment, and Disposal of Hazardous Watte
Safe Drinking Water Act
Subpart B - Maximum Contaminant Level*
Subpart f - Recommended Maximum
Contaminant Level*
Subpart G - National Revlted Primary
Drinking Water Regulation* Maximum
Contaminant Level*
National Secondary Drinking W«tei
Regulation*
Citation
40 USC Sect 1 000 «l eeq
40CFR291
40CFR264 1
40CFR 265400
40 CFH 293
40CFR204
42 USC Sect 30Of el eeq
40CFR 141.11
4OCFR 141 12
40CFR 141 50
40CFR 141 61
40CFR 141 60
40CFR 1433
Description
Class ficanon and identification of hazardous wastes
Rule* and regulation* lex the treatment of hazardous
wastes
Rule* and regulations lor storage, transportation, and
operation of hazardous waste geneialor s.
Primary MCLs leu organic and inorganic contaminants
Additional MCL* and MCLGs lor organic contaminant*.
Reviced MCLs and MCLG* for organic and inorganic
contaminants
Secondary MCLs for inorganics
AlternativesG-1
--
—
—
—
—
—
—
G-2
—
—
—
—
—
—
—
G-3
RA
RA
RA
RA
G-4
RA
RA
HA
RA
G-5
RA
RA
RA
RA
G-0
RA
RA
RA
RA
G - 7
•"
HA
RA
RA
RA
Cn
vc
Table A-1 (continued)Action Specific-ARARs
roStandard. Requirement,
Criteria, or LimitationFederal
Reeource Conservation and Recovery Act
MenUicatton ol Hazardous Wastes
Treatment ol Hazardous Wa*tet In a Unit
Requirements lor Generation. Storage.
Treatment, and Disposal ol Hazardout Waste
Sale Dnnking Water Act
Subpan B - Maximum Contaminant Level*
Subpart F - Recommended Maximum
Contaminant Level*
Subpan G - National Reused Pnmary
Drinking Water Regulation* Maximum
Contaminant Level*
National Secondary Onnking Water
Regulations
Citation
40 USC Sect 1OO9 et eeq
40CFR261
40CFR 204 1
40CFR2064OO
40CFR203
40CFR204
42 USC Sect 3001 el eeq
40CFR 141 11
40CFR 141 12
40CFR 141 SO
40CFR 141 01
4OCFR 141 00
40CFR 1433
Description
Classification and identification ol hazardous wastes
Rules and regulations lor the treatment ol hazardous
waste*
Rule* and regulations lor storage, transportation, and
operation ol hazardous waste generator*
Primary MCL* lor organic and inorganic contaminant*.
Additional MCL* and MCLGs lex organic contaminants
Revised MCLs and MCLGs lor organic and inorganic
contaminant*
Secondary MCL* kx inorganic*
AlternativesG-1
—
—
—
—
—
—
—
G-2
—
—
—
—
—
—
_
G-3
RA
RA
RA
RA
G-4
———
RA
RA
HA
RA
G-5
RA
RA
RA
RA
G-«
RA
RA
RA
RA
G-7
RA
RA
HA
-- - - -
RA
I
Table A-1 (continued)Action Specilic-ARARs
Groundwater
CD
O-J
Standard, Requirement.Criteria, or Limitation
Federal (continued)National Primary and Secondary Drinking
Water Regulation* Synthetic Organic
Chemical* and Inorganic Chemicals
Clean Water Act
National Pollutant Dlecharge Elimination
Syctem Permit Regulation*
ToKlc Subetance* Control Act
Subpart G - PCB Spill Cleanup Policy
Clean Air Act
National Emianon Standard* tor Hazardou*
Air Pollutant*
Citation
55 PR 30370
(July 25. 1000)
33 USC Sect 1251-1378
«OCFR 122 Subpart C
15 USC 2601
40CFR7C1 125
42 USC ia57eteeq
40CFR61 Subpart A
40CFROI Subpan ff
Description
Revised MCI « and MCLGs lor organic and inorganic
contaminant*
U*e ol best available technology economically
achelvable lor toxic pollutant* discharged to a POTW
Discharge must comply with EPA approved water
quality management plan
Dlecharge mutt comply with federal water quality
criteria
Requirement* lot PCB eplll cleanup
General requuement* lor emiaaion* ol ha^ardou*
pollutant*
EmiMton atandaid* Io4 beniene
AlternativesG-1
—
—
—
—
—
—
_
G-2
—
—
—
—
—
—
G-3
HA
RA-
RA"
RA"
RA
^ A
A
G-«
RA
HA*
RA"
RA"
RA
--
——
G-5
RA
„
RA
RA
RA
—
1 - - " - " -
G-e
RA
HA'
RA"
RA"
RA
—
—
G-7
RA
—
RA
RA
RA
—
Cn
Table A-1 (continued)Action Specific-ARARs
Groundwater cr.
Standard. Requirement.Criteria, or Limitation
North CarolinaNorth Carolina Water Quality Standard*
North Carotin* Drinking W*ler and Ground-
W*l»r Standard*
North Carolina Drinking Wat«r Act
North Carolina Rule* Governing Public
Walw Supplie*
North Carolina Mr Pollution Control Law
North Carolina Air PoduDon Conliol
Regulation*
Citation
NCAC-1SA-2B0204
NC AC -ISA-28 0208
NCAC-16A-2B 0211
NCAC-16A-2B0500
NCAC-15-2C 0108
NCAC-15-2C 0113
NCAC-15-2L 0202
GSNC-1 13A-31 1 •! MX)
NCAC-10-10O 1000
GSNC-143-21B •! *aq
NCAC-1&-2D 0201
NCAC-1S-2D O4OO
NCAC-16-2O ObOO
Description
Location ot sampling ait«t and mixing zone*
Watei qualily Mandardt lor toxic «ub«<anc»» and
lompvratur*
Wal*i quality ctandaid*
Etlluwit limit* in effluant limned segment*
Standards (CM construcljon ol well* not used lor water
supply
Procedure* lor abandonment ol wells
Groundwaler quality standards
North Carolina dnnkmg water ctandardt
ClaidAcation ol wr pollunon sources
Ambient air quality rtandaidt
krrtitflion control standard*
AlternativesG-1
—
—
_-
—
_
—
—
—
—
—
—
G-2
—
—
—
—
—
—
—
—
RA
—
G-3
HA'
RA-
RA'
RA-
RA
RA
HA
RA
RA
RA
HA
G-4
RA*
RA-
RA-
HA-
RA
RA
RA
RA
—
G-S
RA
RA
RA
RA
RA
RA
RA
RA
—
—
L —
Q-«
RA-
RA-
RA-
RA-
RA
RA
RA
RA
—
—
—
Q-7
RA
RA
RA
RA
RA
———— - 1
i R A
RA
RA
—
