FINAL CLOSEOUT REPORT 

MARTIN MARIETTA/SODYECO 

SUPERFUND SITE 

MECKLENBURG COUNTY, NORTH 

CAROLINA 

August 25,2011 

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10838875 

11 
FINAL CLOSEOUT REPORT 

MARTIN MARIETTAVSODYECO SUPERFUND SITE 

MECKLENBURG COUNTY, NORTH CAROLINA 

I INTRODUCTION 

This Final Close-out report documents that the U.S. Environmental Protection Agency has determined in 

accordance with Close oul Procedures for National Priorities List Sites (OSWER Directive 9320.2-22) 

that all appropriate response actions at the Martin Marietta/Sodyeco Superfund Site have been 

successfully implemented. 

II SUMMARY OF SITE CONDITIONS 

Background 

The Martin Marietta/Sodyeco Superfund Site (EPA ID: NCDOO1810365) is located in Charlotte, 

Mecklenberg County, North Carolina. The Site is located within a 492 acre property referred to as the 

Sandoz Chemical Corporation, Mount Holly Plant, and is located on Highway 27 West in Mecklenburg 

County, North Carolina (see Figure 1). The Site is comprised of five noncontiguous areas located within 

the facility's boundaries. Manufacturing, administrative and storage facilities cover about 362 acres. The 

remaining balance ofthe land is covered by woodlands and grassed areas. 

The entire 492-acre facility is regulated under RCRA authority. DyeStuff Company began operations at 

the facility in 1936. Initially, the plant produced liquid sulfur dyes from purchased raw materials. 

American Marietta (which became Martin Marietta in 1961) purchased the facility in 1958. Martin 

Marietta's products included vat dyes, disperse dyes and specialty chemical products for the 

agrochemical, electronic, lithographic, pigment, plastic, rubber and general chemical industries. Sodyeco 

Inc., purchased the plant from Martin Marietta in 1983. Sodyeco Inc.'s early operations produced wastes 

that consisted of low-volume, aqueous, acidic or alkaline streams containing inorganic salts, which were 

discharged untreated to the Catawba River. Later, Sodyeco Inc.'s operations were expanded and included 

organic solvent wastes. Among the materials placed in landfills at the Site were residual distillation tars 

from solvent recovery operations, empty drums and cartons, discarded chemicals, off-specification 

products, general plant wastes and construction debris. The first indication ofpotential groundwater 

contamination at the Site was the discovery of organic solvents in the Sodyeco's potable water well in 

September 1980. Contaminated groundwater was also detected in water supply wells adjacent to the 

Sodeyco Plant. In June 1982, a hazardous waste site investigation was conducted by EPA. Results of 

surface water, groundwater and sediment samples revealed the presence of organic contaminants in 

groundwater and small amounts in the surface water. The Site was proposed to NPL on December 30, 

1982 (47 FR 58476) and finalized on the NPL September 8, 1983 (48 FR 40674) due to the presence of 

potable water wells within a three mile radius and the presence of two municipal surface water intakes on 

the Catawba River 

The Site contains five contaminated areas designated as A, B, C, D, and E (see Figure 2). Area A is an 

on-site landfill that operated between the 1930s and 1973. Area B is an on-site landfill that operated 

between 1973 and 1978. Area C consists of three covered pits that contained the remains of laboratory and 

production samples, distillation tars, and waste solvents. The two northern pits in Area C were excavated 

in March 1981 and the contents were trucked offsite to a landfill in Pinewood, South Carolina. Removal 

ofthe remaining pit was conducted in 1983. After excavation activities, area C was regraded and planted 

with grass. Area D formerly contained two wastewater settling ponds. The ponds were taken from service 
in 1966; one was cleaned out in 1973 and the other between 1976 and 1977. Area E is located 

down-gradient ofthe old plant and manufacturing area. No waste is known to have been disposed of in this 

area. 

The current land use is heavy industrial. There are two business tenants located within the facility that 

occupy only a few buildings. The majority ofthe former manufacturing facility, including Areas A-E, is 

not in use. Most ofthe land surrounding the Site is primarily undeveloped woodland. The Site is currently 

fenced and requires security clearance for access. The ground water aquifer underlying the Site is 

currently not used as a drinking water source; however, there are no controls preventing that use. Although 

the groundwater is not being used for drinking purposes, the aquifer is classified as a Class IIA aquifer, a 

current source of drinking water. There are no residential properties that exist above or near the ground 

water contaminant plume at the Site. 

Remedial Investigatioe/FeasibiMty Study 

In February 1986, Sandoz Chemical Corporation, the facility owner, entered into an Administrative Order 

on Consent with EPA to conduct the RI/FS to evaluate the extent of contamination and identify feasible 

alternative remedies. 

Results ofthe RI showed the groundwater in the five indentified CERCLA areas A through E were 

contaminated with toluene, chlorobenzene, ethylbenzene, xylene, o-dichlorobenzene, 

tetrachloroethylene, and trichloroethylene. The Site posed an unacceptable carcinogenic risk to human 

receptors via ingestion of local water fowl and small mammals and the ingestion of ground water. The site 

also posed an unacceptable non-carcinogenic risk to human health via inhalation intake from Area D and 

the ingestion of onsite groundwater. 

Selected Remedy 

EPA issued the ROD for the clean-up ofthe Site in 1987. The remedial action objectives at the site were 

to protect human health and the environment from exposure to contaminated on-site soils through 

inhalation and direct contact, and to restore contaminated groundwater to levels protective of human 

health and the environment. 

The cleanup consisted ofthe following elements: 

•Extraction, treatment and discharge of contaminated ground water for all five areas; 

"Excavation and off-site incineration for Area D; 

•Installation ofa landfill cap for Area B; and, 

•Implementation of one ofthe following activities after treatability studies were undertaken for Area C, 

including: 1) flushing; 2) soil washing; 3) thermal processing; or 4) in-situ steam stripping and 

excavation and off-site incineration. 

No soil remediation was deemed necessary for CERCLA Areas A and E during the RI/FS. 

The initial cleanup approach for Area C was an interim action. The final cleanup plan for Area C was 

outlined in a 1994 Explanadon of Significant Difference (ESD), and included in-situ soil flushing, with 
the flushing water being captured and treated by the existing ground water treatment system. The ESD 

also included confinuation ofa vacuum extracfion pilot study to treat soil stock-piled on site that was 

contaminated with VOCs. The vacuum extraction method eventually proved ineffective and EPA issued a 

second ESD in November 1998, which required off-site treatment and disposal for the stock-piled soil in 

Area C. 

Remedial Construction Activities 

Installation ofthe asphalt cap for Area B was completed in October 1989. The off-site treatment and 

disposal of Area C stockpiled soils was completed in March of 1999. The installafion of an in-situ 

flushing system for the Area C soil was completed during the third week of September of 1999. 

Remediation of Area D soil was completed in April 1999. A total of 397 tons of soils were removed in 

two phases, and sent off-site for treatment and disposal. 

The groundwater system was designed to removed VOCs from the shallow (Areas C and D), 

intermediate (Areas A/B, D and E) and deep aquifers (Area D). The groundwater remediation involved 

extraction through recovery wells and treatment in the onsite RCRA wastewater treatment facility. The 

treated water is discharged to the Catawba River, as regulated by the National Pollutant Discharge 

Elimination System (NPDES) program. The groundwater extraction wells for Areas A through E were 

installed 1990. The contaminated groundwater continues to be treated in the RCRA-regulated on-site 

wastewater treatment facility, along with contaminated groundwater from the RCRA-regulated portions 

ofthe facility. 

The remedial actions were completed by the responsible party, with oversight by the state RCRA 

program. The Preliminary Close-Out Report was issued by EPA on September 29, 1999. 

Since the groundwater remedy was constructed, implementation has been conducted under the facilities 

RCRA permit and authority. The facility's permit incorporated the groundwater remediation goals and 

cleanup levels established in the 1987 ROD and require ICs for limiting the use of groundwater from 

aquifers impacted by site contaminants. At the time the Site was listed on the NPL, the RCRA Hazardous 

Solid Waste Amendments (HSWA) provisions had not been promulgated, and it was necessary to use 

CERCLA response authority to address the contamination at the Site outside ofthe regulated RCRA 

units (Areas A - E). Since the facility's RCRA permit and authority have been used to implement the 

groundwater cleanup and HSWA now provides the legal authority necessary to continue to the treatment 

until cleanup levels are achieved in the CERCLA areas outside ofthe RCRA regulated units, EPA has 

concluded that the groundwater risks originally identified in the 1987 ROD no longer need to be 

addressed by CERCLA authority. 

Institutional controls (ICs) were also necessary because the selected remedy resulted in hazardous 

substances, pollutants, or contaminants remaining at the Site above levels that would allow for unlimited 

use and unrestricted exposure in the soils. More specifically, the remedy capped soil in place in CERCLA 

Areas A and B, as well as left contaminated soils covered by clean soils in place in Area D. These 

Declarations of Perpetual Land Use Restrictions were implemented on August 10, 2011 at The Office of 

the Register of Deeds for Mecklenburg County, North Carolina. 
The 1987 ROD, as amended by the ESDs, was further amended to select no further CERCLA acfion for 

groundwater and required institutional controls preventing disturbance ofthe caps and preclude direct 

contact with any onsite soils impacted by site contaminants. The ROD amendment was signed on July 5, 

2011. 

III MONITORING RESULTS 

Contaminated soils above industrial cleanup levels were excavated and disposed of off-site or were 

capped in place in Areas B, C and D. Post-excavation sampling was conducted and described in the 

remedial action report dated September 29, 1999. 

IV SUMMARY OF OPERATIONS AND MAINTENANCE REQUIRED 

For CERCLA Areas A, B, and C, the Clariant Corporation, under the existing RCRA C permit, is 

conducting the long-term monitoring, and operation and maintenance activities at the Site. The primary 

activities associated with O&M, associated with the site, include: 

"Visual inspection ofthe cap, assuring that it is stable and sound; and 

•Monitoring of institufional controls 

Operation of the water treatment plant and associated groundwater monitoring is being conducted under 

the RCRA Subfitle C permit and is not part ofthe CERCLA response. 

V DEMONSTRATION OF CLEANUP ACTIVITY QUALITY ASSURANCE AND QUALITY 

CONTROL 

Activities at the site were consistent with the ROD, and subsequent ESDs. The RD work plan incorporated 

all EPA and State quality assurance and quality control (QA/QC) procedures and protocol. EPA analytical 

methods were used for all validation and samples taken during the RA. 

The QA/QC program used throughout the RA was rigorous in conformance with EPA and State standards; 

therefore EPA and the State determined that all analytical results are accurate to the degree needed to 

assure satisfactory execution ofthe RA and are consistent with the ROD and the RD plans and 

specifications 

VI FIVE YEAR REVIEW 

Three Five Year Review Reports for the Site have been issued, in 1996, 2002 and 2007. The 2007 five 

year review report concluded that the remedy selected in the ROD is protective in the short term, but 

recommended follow-up actions to analyze the extraction wells for their effecfiveness in addressing 

ground water contamination, conduct maintenance on the Area B cap, and to evaluate the type of ICs that 

should be implemented at the Site. All recommended actions have been addressed. Additional 

groundwater studies are being conducted to address issues identified in the 2007 five-year review report 

under RCRA oversight. These activities included installation of additional groundwater extraction and 

monitoring wells in Areas D and E. These activifies were completed in 2007 and 2010. Repairs to surficial 

cracks on the Area B cap were completed in 2008. EPA incorporated insfitutional controls into a decision 
document in the July 5,2011 ROD. The ICs preventing disturbance ofthe caps and preclude direct contain 

with any onsite soils impacted by site contaminants were implemented in August 2011 and filed at The 

Office ofthe Register of Deeds for Mecklenburg County, North Carolina. 

VH SITE COMPLETION CRITERIA 

This site meets all the site completion requirements specified in OSWER Directive 9320.2-22, Close-Out 

Procedures for Nafional Priorities List Sits. All CERCLA remedial activifies specified in the ROD, ROD 

Amendment and ESDs at the Martin Marietta/Sodyeco Site are complete and the Site poses no 

unacceptable risk to human health or the environment. The only remaining CRECLA activities to be 

performed at the Site are O&M and five-year reviews. The contaminated groundwater at the site is being 

addressed under the RCRA corrective action permit and as a result, CERCLA action is not necessary. 

Therefore, EPA has determined that no further response action is necessary at the Site. 

VIII AUTHORIZING SIGNATURE 

U.S. Enviri 

f¥/5ak\jJit.. Hill, Director 

^ '"Superfund Division 

Date: ^^r/// 
BIBLIOGRAPHY 

EPA Record of decision: Martin Marietta/Sodyeco Site: EPA ID NCD001810365. Charlotte,' 

Mecklenburg County, September 1987 

Explanation of Significant Differences for the Martin Marietta/ Sodyeco Site: prepared by USEPA Issued 

November 1998 

Amended Record of Decision: Martin Marietta/Sodyeco Site: EPA ID NCD001810365. Charlotte, 

Mecklenburg County, July 5, 2011 

Preliminary Closeout Report: Martin Marietta/ Sodyeco Site, prepared by Usepa, Issued September 29, 

1999 

Declaration of Perpetual Land Use Restrictions For A Federal Superfund Site: Clariant Corporafion, 

martin Marietta Superfund Site, Charlotte, Mecklenburg County, North Carolina. Recorded August 10, 

2011 
FIGURE 1 (Site Locafion) 
FIGURE 2 (CERCLA AREAS A-E )