HRS DOCUMENTATION RECORD — REVIEW COVER SHEET 

Name of Site: Wright Chemical Corp.

NCD 024 766 719 

Contact Persons:

U.S. Environmental Protection Agency, Region 4: 

 (Name) (Telephone) 

 Jennifer Wendel 

 NPL Coordinator (404) 562-8799 

 

North Carolina Department of Environment and Natural Resources: 

Site Investigation: (Name) (Telephone) 

Jeanette Stanley (919) 508-8453 

 

Documentation Record: 

 Jeanette Stanley (919) 508-8453 

Pathways, Components, or Threats Not Scored: 

 Ground Water Migration Pathway 

The ground water pathway was not scored because scoring the ground water 

pathway would have a minimal impact on the site score. 

 Surface Water Drinking Water threat/targets 

The drinking water threat was not scored because there is no drinking water 

intake within the 15-mile surface water pathway downstream of the site. 

Surface Water Environmental Threat 

Environmental targets/threats were not scored because scoring the observed 

release to the fishery almost maximized the pathway score. The addition of the 

surface water environmental threat score would have minimal impact on site 

score. 

 Soil Exposure Pathway 

The soil exposure pathway was not scored because the soil exposure pathway has 

a minimal impact on the overall site score. 

 Air Migration Pathway 

The air pathway was not scored because scoring the air pathway would have a 

minimal impact on the site score.
HRS DOCUMENTATION RECORD

 Name of Site: Wright Chemical Corp.

 EPA Region: 4 

 Date Prepared: March 2010

Street Address of Site*: State Rd. 1878 

 City, County, State, and ZIP: Riegelwood, Columbus County, NC 28456 

 General Location in the State: Coastal Plain 

 Topographic Map: Acme 

 Latitude*: 34.3284o north latitude 

 Longitude*: 78.2051o west longitude Location is approximate center of 

 denuded area (Source 1) 

(Ref. 4, pp. 1, 105, 106; Figs. 1, 4) 

Scores

Air Pathway — Not Scored 

Ground Water Pathway — Not Scored 

Soil Exposure Pathway — Not Scored 

Surface Water Pathway — 96.06

HRS SITE SCORE 

48.03

* The street address, coordinates, and contaminant locations presented in this HRS documentation record identify 

the general area the site is located. They represent one or more locations EPA considers to be part of the site based 

on the screening information EPA used to evaluate the site for NPL listing. EPA lists national priorities among the 

known “releases or threatened releases” of hazardous substances; thus, the focus is on the release, not precisely 

delineated boundaries. A site is defined as where a hazardous substance has been “deposited, stored, placed, or 

otherwise come to be located.” Generally, HRS scoring and the subsequent listing of a release merely represent the 

initial determination that a certain area may need to be addressed under CERCLA. Accordingly, EPA contemplates 

that the preliminary description of facility boundaries at the time of scoring will be refined as more information is 

developed as to where the contamination has come to be located. 

1
WORKSHEET FOR SITE SCORE

 S S2

1. Ground Water Migration Pathway Score Not Scored Not Scored 

2a. Surface Water Overland/Flood Migration -- 

 Drinking Water Threat Not Scored Not Scored 

 Food Chain Threat 96.06 9227.52

 Environmental Threat Not Scored Not Scored 

 

 Surface Water Overland/Flood Migration Component 

 (subject to maximum value of 100, Ref. 1, Section 4.1.5) 96.06 9227.52 

 

3. Soil Exposure Pathway Score Not Scored Not Scored 

4. Air Migration Pathway Score Not Scored Not Scored 

5. Total of Sgw

2

 + Ssw2 + Ss

2

 + Sa

2

 = 9,227.52 

6. HRS Site Score: Value on line 5. divided by four, 

then take the square root 48.03

2
 WRIGHT CHEMICAL CORP. 

RIEGELWOOD, COLUMBUS COUNTY, NC 

LIST OF FIGURES 

1. US Geological Survey, Acme Topographic Quadrangle Map, 1984 

2. Sanborn Fire Insurance Map, 1889 

3. Sanborn Fire Insurance Map, 1910 

4. Source Detail Area with Wetland Boundaries 

5. Oak Bark Holdings 

6. Livingston Creek and Cape Fear River 

7. 2007 ESI Sample Location Map 

8. Wetlands 

9. Acme, NC Wetland Inventory Map 

LIST OF TABLES 

1. Source Soil and Background Soil Samples 

2. Source Soil and Background Soil Results 

3. Background Sediment Samples 

4. Background Sediment Sample Results 

5. Sediment Samples 

6. Sediment Sample Results 

7. Source 1 Contaminants Documented in Observed Release to Sediment in the Fishery 

8. Source 1 Contaminants Documented in Source with Containment Factor of 10, not 

documented in Observed Release to Fishery Sediment 

3
WRIGHT CHEMICAL CORP. 

RIEGELWOOD, COLUMBUS COUNTY, NC 

LIST OF REFERENCES 

1. US Environmental Protection Agency, Hazard Ranking System, Final Rule, 55 FR 

51532, 1990. 

 http://www.epa.gov/superfund/sites/npl/hrsres/index.htm#HRS%20Rule. Table of 

Contents and Sections 1 – 6. Excerpt. 75 pages. A complete copy of the Hazard 

Ranking System document is available in the Region 4 Docket. 

2. US Environmental Protection Agency, Superfund Chemical Data Matrix (SCDM). 

Office of Solid Waste and Emergency Response. Directive 9345.1-13. 2004. Appendix 

BI. Excerpt. 15 pages. A complete copy of SCDM is available at 

http://www.epa.gov/superfund/sites/npl/hrsres/tools/scdm.htm, 

3. US Geological Survey, 7.5-minute (1:24,000) topographic quadrangle maps of North 

Carolina; Acme, NC, 1984; point Caswell, NC, 1997; and Freeman, NC, 1986. 3 maps 

merged and modified into one showing radii and target information. 

4. Expanded Site Inspection, Wright Chemical Corp. Site, NCD 024 766 719, Riegelwood, 

Columbus Co., NC, Jeanette Stanley, NC Superfund Section, May 30, 2008. 579 pages. 

5. US EPA, Office of Solid Waste and Emergency Response, Multi-Media, MultiConcentration, Inorganic Analytical Service for Superfund (ILM05.3), February 2004. 4 

pages. 

6 US EPA, Office of Solid Waste and Emergency Response, Multi-Media, Multi-

 Concentration, Organic Analytical Service for Superfund (SOM01.1), January 2006. 

6 pages. 

7. Stanley, Jeanette S., Chemist, NC Superfund Section, Memo to File, December 9, 2009. 

SUBJECT: Source of base maps and elements for Figures 4 – 9. 1 page. 

8. Stanley, Jeanette S., Chemist, NC Superfund Section, Memos (2) to File, December 17, 

2009 and December 18, 2009. Bateson, James, Environmental Engineering Supervisor, 

NC Superfund Section, Memo to File, January 29, 2010 8 pages. 

9. Parker, Stuart F. Geologist, NC Superfund Section, Kaiser Acme Farmarket Site ReAssessment Report, August 13, 2004. 12 pages. 

10. Pettergarrett, Stephanie, Environmental Scientist, NC DENR Water Quality Section, 

email correspondence with Jeanette Stanley, December 17, 2009. 2 pages. 

4

Site: Wright Chemical Corp.

NCD 024 766 719 Date: 02/12/08

Columbus Co., NC Drawn By: JSS

Scale: As Shown

Figure 2: Sanborn Fire Insurance Map, 1889

0 50 100

SOURCE: Sanborn Fire Insurance Maps, Wilmington, NC, sheet 16, 1889

0 200

FEET
Site: Wright Chemical Corp.

NCD 024 766 719 Date: 02/12/08

Columbus Co., NC Drawn By: JSS

Scale: As Shown

Figure 3: Sanborn Fire Insurance Map, 1910

Lead Acid Chambers

Sulphur Bins

Burner House

Iron Burners

Acid Chambers

SOURCE: Sanborn Fire Insurance Maps, Wilmington, NC, sheet 34, 1910

0 200

FEET
Site: Wright Chemical Corp. NCD 024 766 719

See Ref. 7 of HRS Doc Record for figure source information Date: 01/

Columbus Co., NC Drawn By

Kaiser Agricultural

(archived)

Aerial Pho

Figure 4: Source Area Detail with Wetland Boundaries

Area of formerLead Chambers

Livingston Creek

WC‐012‐SS

WC‐011‐SS

WC‐013‐SS

WC‐003/103‐SD

WC‐004‐SD

PPE

WC‐010‐SD

PUBH

PUBHh

PUBH

PUBH

PUBH

PUBHh

PUBH

R2UBH

PFO1A

PFO1/2F

PFO1/2F

PFO1/2F
Figure 5: Oak Bark Holdings 

Site: Wright Chemical Corp.NCD 024 766 719 Date: 02Columbus Co., NC Drawn B

Total 739.9OAK BARK CORPORATION 17.65OAK BARK CORPORATION 137.8OAK BARK CORPORATION 24.15OAK BARK CORPORATION 58.58OAK BARK CORPORATION 60.47OAK BARK CORPORATION 15OAK BARK CORPORATION 34OAK BARK CORPORATION 0.95OAK BARK CORPORATION 21.99OAK BARK CORPORATION 145OAK BARK CORPORATION 78.54OAK BARK CORPORATION 81OAK BARK CORPORATION 37.62OAK BARK CORPORATION 3.53OAK BARK CORPORATION 23.61

OWNER ACRES

Oak Bark properties shown in yellow (color) or medium grey (black & white)

Aerial Ph

Lead chamber area

International Paper, aka Federal Paper Board

~ 1⁄2 mile

EllinKais

See Ref. 7 of Hfor figure sourc
Figure 6: Livingston Creek and Cape Fear River

Site: Wright Chemical Corp.NCD 024 766 719 Date: 05Columbus Co., NC Drawn B

Aerial P

International Paper

Wright 

Cape Fear River

LCV2

LCV (pre-2005)

~ 1⁄2 mile

Holtrachem

Mill Creek

See Ref. 7 of HRS Doc Record for figure source information
Figure 7: 2007 ESI Sample Location Map

Site: Wright Chemical Corp.NCD 024 766 719 Date: 03Columbus Co., NC Drawn B

Sediment SamplesSoilSamples

1

2

7

6510

14

9

8

12

3

Livingston Creek

Railroad

Neils

Eddy Rd

Gas Pipeline and Road

Old Hwy 87

Livingston Creek

~500’

4

11 13

Aerial Ph

Mill Creek

See Ref. 7 of HRS Doc Record for figure source information
Figure 8: Wetlands 

Site: Wright Chemical Corp.NCD 024 766 719 Date: 02Columbus Co., NC Drawn B

Aerial P

See Ref. 7 of HRS Doc Record for figure source information

2.0 Site Description 

 Wright Chemical Corp is located in Columbus County, NC in an industrial / rural area. 

The facility and Riegelwood are served potable water by a surface water intake on the Cape Fear 

River upstream of the site (Ref. 4, pp. 128; Fig. 1). This area of Columbus County is the home 

of several large industrial facilities surrounded by residential properties, agricultural fields and 

wetlands. The portion of the facility being evaluated drains to Livingston Creek and 

subsequently to the Cape Fear River (Ref. 7, p. 1, Figs. 1, 4, 6, 8, 9). 

 The original business on the Wright Chemical Corp. property was Acme Chemical. 

Acme Chemical was a fertilizer and sulfuric acid manufacturing facility founded in 1883 (Ref. 4, 

pp. 244, 401; Figs. 2, 3) and was a family-owned company for four generations (Ref. 4, p. 401). 

The original Acme sulfuric acid plant was a lead-lined “chamber-process” plant which thermally 

extracted sulfur from pyrite. Pyrite ore commonly contains traces of arsenic, selenium, nickel, 

cobalt, and thallium. (Ref. 4, pp. 109, 186). “Lead Acid Chambers” are marked on the 1898 and 

1910 Sanborn Fire Insurance maps (Ref. 4, pp. 173-179; Fig 3). A comparison of early Sanborn 

Fire Insurance Maps with 1961, 1965, 1994, 2004 and 2007 aerial photographs confirms the 

location of the lead chambers (Ref. 4 pp. 115-117; Figs. 2, 3, 4, 5). 

 The second acid plant on the Wright Chemical Corp facility property was a “contactprocess” plant, which metal-catalyzed a refined sulfur feedstock. However, due to the 

corrosivity of sulfuric acid, lead-lined components were typically used in both processes (Ref. 4, 

pp. 109, 115-117, 161-162). Wright Chemical constructed several surface impoundments on the 

northern property during the 1970s (Ref. 4, pp. 109, 117, 120, 128). Acid manufacturing 

occurred on this property until 1991, and the buildings have since been demolished (Ref. 4, p. 

109; Ref. 8, pp. 3-5). The Wright Chemical Corp facility property was sold to Oak Bark 

Corporation in 2004 (Ref.4, pp. 397, 453, 454). 

 The Wright Chemical Corp. site contains denuded, magenta-colored soil primarily on two 

parcels totaling about 80 acres (Ref. 4, pp. 29-32, 88, 92, 115, 116, 453, 454; Ref. 8, pp. 3-8; 

Figs. 4, 5). Aerial photos indicate stressed or absent vegetation extending to the creek channel 

(Ref. 4, pp. 109, 115-117, 180-182; Fig. 4). The magenta soil coloration is characteristic of 

former lead chamber sulfuric acid manufacturing facilities (Ref. 4, pp. 215). Primary 

contaminants are lead and arsenic, but numerous other inorganics and some pesticides were 

detected in this area of denuded magenta colored soil (Ref. 4, pp. 72-81, 215; Ref. 9, pp. 1-12). 

 The HRS score is based on one source -- denuded, contaminated soil, and a release of site 

contaminants to sediment in the fishery. While there are extensive wetlands along the surface 

water pathway (Ref. 7. p. 1; Fig. 9), the environmental threat was not scored because it does not 

make a significant additional contribution to the site score. Samples used for this documentation 

were collected on April 10, 2007 and were collected according to the Sampling and Analysis 

Plan and Quality Assurance Project Plan (SAP/QAPP) (Ref. 4, pp. 99–104). 

14
 SD -Characterization and Containment 

 Source No.: 1 

SOURCE DESCRIPTION

2.2 Source Characterization

Number of the Source: 1 

Name and description of the source: 

 In the 1880s, Acme Manufacturing began operating a lead chamber sulfuric acid and 

fertilizer manufacturing facility on the property, which operated until the 1960s or 1970s (Ref. 4, 

pp. 3, 9, 10, 108, 109, 173 – 179, 244). The Wright Chemical Corp. facility includes an area of 

stressed vegetation and magenta-colored soil (Ref. 4, pp. 3, 88, 92, 116, 117; Fig. 4) 

characteristic of former lead chamber sulfuric acid manufacturing facilities (Ref. 4, pp. 213 - 

215). This magenta-colored soil is primarily on two parcels totaling about 80 acres owned by 

Oak Bark Corporation (Ref. 4, pp. 453, 454; Figs. 4, 5). A comparison of an early Sanborn Fire 

Insurance Map with recent aerial photography confirms the former lead chambers location (Ref. 

4, pp. 4 – 7, 173 – 179; Figs. 2, 3, 4, 5). Numerous other chemical operations have been and 

continue to be conducted on adjacent property (Ref. 4, pp. 9, 10); however, the focus of this 

documentation record is the past lead chamber sulfuric acid manufacturing facility. 

HRS Source Type: Contaminated Soil 

 The source is contaminated soil as defined by samples WC-011-SS, WC-012-SS and 

WC-013-SS documented in the Table 1. These samples were collected near the former lead 

chambers and in the area where both 1) waste materials were placed and 2) overland flow from 

the former lead/acid chambers on the facility was received (Ref. 8, p. 7; Fig. 4). This area of 

denuded soil has a purplish/magenta coloration and appears fairly consistent between the three 

samples (Ref. 8, pp. 1, 3-5). This area remains unfenced and is outside any runoff control 

features. (Ref. 8, pp. 1, 3-5) It is accessible but there are no signs of recreation. (Ref. 8, pp. 1, 3-

5) 

 The source area was observed to consist of three contiguous subareas. These areas are, 

from south to north: Area a) an upland area of denuded soils where the former lead chambers had 

been located, Area b) a wooded slope covered at least in part with bulldozed material similar to 

that observed in the former lead chamber area a), and Area c) a lowland area of contaminated 

soils. Source soil sample WC-012-SS was collected from Area a) while source soil samples 

WC-011-SS and WC-013-SS were collected from Area c), which extends to the probable point 

of entry (PPE) into Livingston Creek, and coincides, generally, with an area classified as nonHRS qualifying wetland type PUBH (Ref. 8, p. 7; Fig. 4). 

 Area a) was void of vegetation and generally flat, with a discontinuous low berm on its 

northern edge. Parts of the flat areas and all of the berm area contained bricks, bits of wood, 

concrete and mortar, and pieces of clinker or slag. Soils in this area were of a magenta color 

characteristic of lead contaminated soils observed by NC Superfund and EPA project staff at 

15
SD -Characterization and Containment 

 Source No.: 1 

similar phosphate fertilizer sites under CERCLA assessment or remediation in the southeastern 

United States (Ref. 8, p. 7; Fig. 4). 

 Area b) borders area a) and is sloped to the north, toward the floodplain of Livingston 

Creek. Debris and soil similar to that observed in the berm above was visible on parts of the 

slope. The slope is traversed by a roadbed leading west-northwest down to the floodplain. The 

slope is not wooded on the east-northeast side of this road. The shadow line of the woods makes 

the road location visible on Figure 4, located midway between sample locations WC-011-SS and 

WC-012-SS (Ref. 8, p. 7; Fig. 4). However, there were no samples collected from this area to 

confirm the presence of site hazardous substances. 

 Area c) contains a roughly circular area completely devoid of vegetation, approximately 

200 feet across, visible on Figure 4 as a lighter colored area extending northwest from samples 

WC-011-SS and WC-013-SS. The lighter colored ground appeared to consist of a number of 

overlapping or coalescing low waste piles. The material consists of a mix of these larger 

fragments with magenta colored sand and clay-sized material. It appears this material was 

trucked down the road and dumped in place (Ref. 8, p. 7). 

Location of the source, with reference to a map of the site: 

North of railroad tracks and west of chemical manufacturing facility (Figs. 1, 4, 7) 

Containment

Release via overland migration and/or flood — 

Contaminated soil is outside any controlled runoff feature and is available for continuous 

and ongoing overland flow (Ref. 1, Table 4-2; Ref. 8, pp 1. 3-5). 

An observed release of site contaminants to Livingston Creek (Ref. 1; Ref. 4, pp. 34, 36, 

41, 47, 65, 66; Table 4-9) 

Containment factor: 10

16
 SD-Hazardous Substances 

 Source No.: 1 (Contaminated soil) 

2.4.1 Hazardous Substances 

On April 10, 2007 NC Superfund Section collected three source surface soil samples and 

one background surface soil sample, as summarized in Tables 1 and 2 below (Fig. 4). Samples 

were collected according to the Sampling and Analysis Quality Assurance Project Plan 

(SAP/QAPP) (Ref. 4, pp. 99-104), which was developed in accordance with the NC Superfund 

Section Quality Assurance Program Plan (QAPP) and Quality Assurance Standard Operating 

Procedures (QASOP). The QASOP adopts by reference the Field Branches Quality System and 

Technical Procedures, U. S. Environmental Protection Agency, Region 4. The Program Plan is 

derived directly from the EPA-Approved NC Department of Environmental and Natural 

Resources QA Plan for Data, 2004 (Ref. 4, pp. 99-104). Samples were shipped to a Contract 

Laboratory Program (CLP) laboratory (A4 Scientific) and analyzed for total metals by ICP-AES 

and cyanide analysis by Statement of Work (SOW) ILM05.3 and they were analyzed for 

pesticides per method SOM01.1 (Ref. 4, pp. 34; Refs. 5, pp. 2-4; Ref. 6, pp. 1-6). A US EPA 

Region 4 Science and Ecosystem Support Division Quality Assurance Chemist reviewed and 

validated this data for performance according to the Statement of Work (Ref. 4, pp. 33, 34, 67-

69). 

 

 The depths of the background and source soil samples were all similar (Table 1). The 

source area was observed to be denuded and the level of contamination in the source area likely 

prevented growth of any vegetation for years (Refs. 8, pp. 1, 3-5). The purple/magenta 

coloration in the source samples is indicative of the lead / arsenic contamination (Ref. 4, pp. 

215). Tables 1 and 3 contain summary of field observations and references to these 

observations. 

17
SD-Hazardous Substances 

 Source No.: 1 (Contaminated soil) 

Table 1. Source Soil and Background Soil Samples 

Source 

Samples Date; Time Description 

Surface soil sample (0-9”) in denuded 

area in a wetland with purple soils. 

Purple sand was encountered until 2” 

– 6” when wet sand was found 

WC-011-SS 

4/10/07; 1410 

(Ref. 4, pp. 35, 70, 88, 92, 

95, 97) 

(Ref. 4, pp. 88, 92; Fig. 7) 

WC-012-SS 

4/10/07; 1345 

(Ref. 4, pp. 35, 70, 88, 92, 

96, 98) 

Surface soil sample (0-9”) collected on 

top level by plant area. Purple soils 

encountered. (Ref. 4, pp. 88, 92; Fig. 

7) 

WC-013-SS 

4/10/07; 1420 

(Ref. 4, pp, 35, 70, 88, 93, 

96, 98) 

Surface soil sample (0-6”) in area of 

purple soil in wetland area. All purple 

sand. (Ref. 4, pp. 88, 93; Fig. 7) 

Background surface soil (0-9”), Root 

& organics (0 – 3”, silty sand 3 – 6”, 

fine sandy loam 6 – 9”. Refusal at 9” WC-014-SS 

4/10/07; 1200 

(Ref. 4, pp. 35, 70, 87, 91, 

96, 98) (Ref. 4, pp. 87, 91; Fig. 7) 

18
 SD-Hazardous Substances 

 Source No.: 1 (Contaminated soil) 

Table 2. Source Soil and Background Soil Results 

Units 

mg/kg CRQL WC-011-SS WC-012-SS WC-013-SS 

WC-014-SS*

(Background)

(Ref. 5) 

Ref. 4, pp. 34, 

36, 57, 

Ref. 4, pp. 34, 

36, 59 

Ref. 4, pp. 34, 36, 

61, 62 

Ref. 4, pp. 34, 36, 

63 

Antimony** 6 69 J [34.8] 63 J [31.8] 86 J [43.4] 

 8.3 UJ

 (8.3 U)

Arsenic** 1 430 J [247] 700 J [402] 900 J [517] 1.4 J*

Cadmium 0.5 42 31 40 0.69 U

Copper** 2.5 210 J [172] 720 J [590] 890 J [730] 1.9 J* (3.5 U)

Lead** 1 

3500 J 

[2430]

7800 J 

[5417]

10000 J 

[6944] 16 J [23]

Manganese 1.5 32 27 27 8.9

Mercury 0.1 2.4 2.4 35 

0.056 J* (0.50 

U)

Nickel 4 20 17 19 1.9 J* (5.5 U)

Silver 1 18 29 43 1.4 U

Thallium 2.5 16 22 28 3.5 U

Zinc 6 7500 4700 6700 14 J

J = estimated value 

“U” indicates non-detect. The number adjacent to the “U” or inside () is the MRL. 

[ ] provides the adjusted value for the estimated (J’d) value as adjusted for bias (Ref. 4, pp. 266 - 283). 

*( ) = Minimum Reporting Limit (MRL) is shown in parentheses when a trace value is reported below the MRL. 

The MRL is the analyte concentration which corresponds to the lowest quantitative point on the calibration curve or 

the lowest demonstrated level of acceptable quantitation (Ref. 4, p. 36). 

Trace levels below reporting limits are treated as non-detect (Ref. 1, Table 2-3; Ref. 4, p. 269). 

**Flagging of data in the data reports (Ref. 4, pp 37 – 86) is inconsistent with statements in the data report (Ref. 4, 

pp. 34, 68). Generally, the narrative indicates some data should be J-qualified while data sheets did not show a J. 

Where a conflict appeared, the data was treated as J’d and subsequently adjusted as appropriate. Data were adjusted 

per “Using Qualified Data to Document an Observed Release and Observed Contamination”, to illustrate the relative 

increase of hazardous substance concentrations of background levels (Ref. 4, pp. 266-283). This is a conservative 

approach. 

**Arsenic and copper results are J’d due to high bias (Ref. 4, p. 34). Background is not adjusted; source/release 

results are adjusted downward by correction factor of 1.74 for arsenic and 1.22 for copper (Ref. 4, pp. 270, 283). 

Antimony and lead results are J’d due to uncertain bias. Because matrix spike sample recovery for antimony and 

lead were low, and because performance evaluation sample recovery were “action high” (Ref. 4, p. 34), data was 

adjusted based on uncertain bias (Ref. 4, pp. 34, 270, 273, 283). Background is adjusted upward and source/release 

results are adjusted downward by correction factor of 1.98 for antimony and 1.44 for lead (Ref. 4, pp. 270, 283). 

BOLD = Observed contamination, which is greater than or equal to 3 times background when detected in 

background, or greater than background quantitation limit (aka MRL) and CRQL if background is non-detect (Ref. 

1, Table 2-3; Ref. 4, p. 266). Note that source samples were compared to background soil sample in Table 2. 

19
 SD-Hazardous Substances 

 Source No.: 1 (Contaminated soil) 

Soil background hazardous substance and concentration summary

 Level shown without “U” is level detected above MRL. J’d levels below MRL are treated as 

non-detect (Ref. 1, Table 2-3; Ref. 4, p. 269). The number shown in parentheses is the higher of MRL or 

CRQL. 

 Antimony non-detect (8.3 UJ, [8.3 U] mg/kg) 

 Arsenic 1.4 J mg/kg 

 Cadmium non-detect (0.69 U mg/kg) 

 Copper non-detect (3.5 U mg/kg) 

 Lead 23 mg/kg 

 Manganese 8.9 mg/kg 

 Mercury non-detect (0.5 U mg/kg) 

 Nickel non-detect (5.5 U mg/kg) 

 Silver non-detect (1.4 U mg/kg) 

 Thallium non-detect (3.5 U mg/kg) 

 Zinc 14 J mg/kg 

Source hazardous substances and concentration summary (estimated concentrations adjusted for bias, 

where appropriate)

 

Antimony ranging from 31.8 – 43.4 mg/kg 

 Arsenic ranging from 247 – 517 mg/kg 

 Cadmium ranging from 31 – 42 mg/kg 

 Copper ranging from 210 – 730 mg/kg 

 Lead ranging from 2,430 – 6,944 mg/kg 

 Manganese ranging from 27 – 32 mg/kg 

Mercury ranging from 2.4 – 35 mg/kg 

 Nickel ranging from 17 – 20 mg/kg 

 Silver ranging from 18 – 43 mg/kg 

 Thallium ranging from 16 – 28 mg/kg 

 Zinc ranging from 4,700 – 7,500 mg/kg 

20
 

 SD-Hazardous Waste Quantity 

 Source No.: 1 (Contaminated Soil) 

2.4.2 Hazardous Waste Quantity 

2.4.2.1.1 Hazardous Constituent Quantity — 

Sufficient evidence does not exist to evaluate Hazardous Constituent Quantity 

2.4.2.1.2 Hazardous Waste stream Quantity — 

Sufficient evidence does not exist to evaluate Hazardous Waste stream Quantity 

2.4.2.1.3 Volume — 

 Sufficient evidence does not exist to evaluate Volume 

2.4.2.1.4 Area

Three points were collected in the former lead chamber / surface impoundment 

area; the area of contaminated soil is determined to be >0 (Ref. 4, pp. 108, 109, 

115-117, 120, 128, 161 173-179, 180-182, 186; Figure 3) 

 

 Area assigned value (Ref. 1, Table 2-5) 

 = A/34,000 = > 0 

2.4.2.1.5 Source Hazardous Waste Quantity Value = >0 

 

 

 

 

 

21
 

 SD-Summary 

SITE SUMMARY OF SOURCE DESCRIPTIONS

 Containment

Source Hazardous Waste Quantity Ground Surface Air 

No. Value Water Water Gas Particulate

1 >0 NS 10 NS NS 

Sum of Source Hazardous Waste Quantity Values = >0 

(Rounded to nearest integer, per Ref. 1, Section 2.4.2.2) 

 

22
SWOF — Surface Water Overland Flow/Flood Migration Pathway 

4.0 SURFACE WATER MIGRATION PATHWAY 

4.1 OVERLAND/FLOOD MIGRATION COMPONENT 

4.1.1.1 DEFINITION OF HAZARDOUS SUBSTANCE MIGRATION PATH FOR 

OVERLAND/FLOOD COMPONENT 

 Source 1 drains northward to Livingston Creek. Historically, there could have been 

several Probable Points of Entry (PPEs) to the perennial surface water pathway into Livingston 

Creek (Ref. 4, pp. 18, 228-231); however, the precise location of former PPEs cannot now be 

determined because buildings and old impoundments have been removed (Ref. 4, pp. 109, 117) 

Two of the three source samples (WC-011-SS and WC-013-SS) (Ref. 4, pp. 88, 93; Ref. 7, p. 1; 

Figs. 7, 9) were collected within an area described as a wetland area adjacent to Livingston 

Creek (Ref. 8, p. 6); however, this area does not meet the 40 CFR 230.3 definition of a wetland 

due to the lack of hydrophytes, therefore, the source lies along the overland flow pathway and 

the PPE is the point where the overland flow enters Livingston Creek (Fig. 4). A portion of this 

source area appeared to consist of low overlapping piles (Ref. 8, p.7) in the wetland area. From 

Source 1, the overland drainage route flows downgradient approximately 100 feet northward to 

Livingston Creek, a perennial water body, marking the start of the in-water segment of the 

surface water migration pathway and the 15-mile target distance limit (TDL) (Figs. 1, 4). 

Livingston Creek is about 29 feet wide and about 3 feet deep in most locations (Ref. 4, pp. 18, 

350). Livingston Creek’s flow below the Wright Chemical Corp. facility property is slightly 

greater than 100 cfs, making it a moderate-to-large stream (Ref. 1, Table 4-13; Ref. 4, pp. 18, 

250, 259, 260, 262). Below the PPE, Livingston Creek meanders in a generally northerly 

direction for three miles through extensive wetlands, and then flows into the Cape Fear River 

(Ref. 4, pp. 2, 124; Figs. 1, 6, 8, 9). Livingston Creek flows past landfills associated with the 

International Paper facility (Figs. 6, 8). There is tidal flow reversal in Livingston Creek (Ref. 

10, pp. 1, 2). 

Mill Creek is upgradient and to the northeast of Source 1 and enters Livingston Creek 

downstream of the PPE from the source. Mill Creek flows past the adjacent Hexion property 

before entering Livingston Creek and does not receive runoff from Source 1 (Fig. 4, 7). 

Mill Creek flows from the east, past a road and an iron pipe near the sewer line (as observed 

during the sample collection event (Ref. 4, pp 88, 92; Figs. 4, 6, 7), and where it is indicated as a 

pipeline on the USGS topographic map (Fig. 1) then along the northern edge of the Hexion 

property. The lower part of the source area, the PPE, and the confluence of Livingston Creek 

with Mill Creek has alternately been mapped as a pond and a wetland (Ref. 7, p. 1; Figs. 1, 8, 9). 

 Below the confluence with Livingston Creek, the Cape Fear flows in an easterly direction 

for about 6 miles, where the river splits to Lyon Thoroughfare. Lyon Thoroughfare flows 

easterly and joins with the Black River. The Cape Fear continues to flow in a general 

southeasterly direction, and 15-mile surface water pathway ends near the confluence of the Black 

23
River and the Cape Fear. The entire surface water pathway is within the Cape Fear River basin 

(which includes the Black River), and is a large stream-to-river system from the point where 

Livingston Creek enters the Cape Fear River to the end of the surface water pathway (>1000 - 

10,000 cfs) (Ref. 1, Table 4-13; Ref. 4, pp. 250 - 265). At the point where Livingston Creek 

flows into the Cape Fear River, the river is about 300 feet wide and 26 feet deep (Ref. 4, pp. 18, 

349). 

 When some of the fisheries being evaluated are in fresh water and some are in salt water 

or any are in brackish water, the HRS instructs to use the bioconcentration factor (BCF) data that 

yield the higher factor value to assign the bioaccumulation potential factor value to the hazardous 

substance (Ref. 1, Section 4.1.3.2.1.3). For this reason, the surface water pathway was 

researched to determine if any part of the 15-mile surface water pathway is brackish or salt 

water. 

 Lock 1 is about 9 1/2 river miles upstream from where Livingston Creek flows into the 

Cape Fear River and 37 miles upstream of Wilmington (Ref. 4, pp. 18, 19, 286). The point 

where Livingston Creek flows into the Cape Fear River is 27 1/2 miles upstream from 

Wilmington. The point where the Cape Fear joins the Black River is the upstream intrusion limit 

(200 mg/L chloride), having a 50% chance of being equaled or exceeded in any one year (Ref. 4, 

pp. 296, 309). Saltwater intrusion may affect water quality as far as 20 miles upstream from 

Wilmington (Ref. 4, p. 300). Therefore, the first 10 1/2 miles of the surface water pathway is 

fresh, and the last 4 1/2 miles of the surface water pathway is brackish/salt. 

24
 SWOF — Surface Water Overland Flow/Flood Migration Pathway 

Likelihood of Release 

4.1.2.1 LIKELIHOOD OF RELEASE 

4.1.2.1.1 OBSERVED RELEASE 

Chemical Analysis — Sediment

On April 10, 2007 NC Superfund Section collected five background sediment samples 

from either Mill Creek or Livingston Creek and six (including one duplicate) downstream 

sediment samples from Livingston Creek, as summarized in Tables 3 - 6 below (Fig. 7). 

Samples were collected according to the Sampling and Analysis Quality Assurance Project Plan 

(SAP/QAPP) (Ref. 4, pp. 99-104), which was developed in accordance with the NC Superfund 

Section Quality Assurance Program Plan (QAPP) and Quality Assurance Standard Operating 

Procedures (QASOP). The QASOP adopts by reference the Field Branches Quality System and 

Technical Procedures, U. S. Environmental Protection Agency, Region 4. The Program Plan is 

derived directly from the EPA-Approved NC Department of Environmental and Natural 

Resources QA Plan for Data, 2004 (Ref. 4, pp. 99-104). Samples were shipped to a Contract 

Laboratory Program (CLP) laboratory (A4 Scientific) and analyzed for total metals by ICP-AES 

and cyanide analysis by Statement of Work (SOW) ILM05.3 and they were analyzed for 

pesticides per method SOM01.1 (Ref. 4, pp. 34, 68). A Quality Assurance Chemist with the US 

EPA Region 4 Science and Ecosystem Support Division reviewed and validated this data for 

performance according to the Statement of Work (Ref. 4, pp. 33, 34, 67-69). 

25
SWOF — Surface Water Overland Flow/Flood Migration Pathway 

Likelihood of Release 

Background concentration — Sediment

 Only those compounds found in a source and a release sample at levels greater than three 

times background (or greater than background reporting limits when not detected in background) 

are listed below in the background data. For the listed compounds not detected in the 

background, only the Minimum Reporting Limit (MRL) (Ref. 4, p. 36) and the ContractRequired Quantitation Limit (CRQL) (Ref. 5) values are given. When samples are analyzed by 

the EPA Contract Laboratory Program, the Hazard Ranking System Final Rule (Ref. 1, Table 2-

3) instructs that when the background concentration is not detected or is less than the 

quantitation limit, an observed release is established when the sample measurement equals or 

exceeds either the Sample Quantitation Limit (SQL), or if this can not be determined, the 

Contract-Required Quantitation Limit (CRQL) (Ref. 1, Table 2-3; Ref. 4, p. 266; Ref. 5). For 

inorganic compounds, Reference 5 provides the Contract Required Quantitation Limit (CRQL) 

(Ref. 1, Section 1.1, see definition for CRQL). 

 

Table 3. Background Sediment Samples 

Sample 

number Date; time Description 

WC-001-SD 4/10/07;1250 

(Ref. 4, pp. 35, 70, 88, 

91, 95, 97; Fig. 7) 

Grab sediment sample upstream of Old 

Highway 87 on Livingston Creek; 

background sample (MS/MSD); 

Tan sand, no layer or organics 

(Ref. 4, pp. 88, 91) 

WC-002-SD 4/10/07; 1310 

(Ref. 4, pp, 35, 70, 88, 

92, 95, 97; Fig. 7) 

Grab sediment sample downstream of 

railroad on Livingston Creek; background 

sample (Ref. 4, pp. 88, 92) 

WC-008-SD 4/10/07; 1145 

(Ref. 4, pp, 35, 70, 87, 

95, 97; Fig. 7) 

Grab sediment sample downstream of Neils 

Eddy Road on Mill Creek; background 

sample (Ref. 4, pp. 87, 90) 

WC-009-SD 4/10/07; 1120 

(Ref. 4, pp, 35, 70, 87, 

90, 95; Fig. 7) 

Grab sediment sample upstream of iron pipe 

near sewerline and roads on Mill Creek; 

background sample (Ref. 4, pp. 87, 90) 

WC-010-SD 4/10/07;1515 

(Ref. 4, pp, 35, 70, 88, 

93, 95, 97; Fig. 7) 

Grab sediment sample upstream of 

confluence of Mill Creek and Livingston 

Creek on Mill Creek; background/attribution 

(Ref. 4, pp. 88, 93; Ref. 8, p. 1) 

26
27

 SWOF — Surface Water Overland Flow/Flood Migration Pathway 

Likelihood of Release 

Table 4. Background Sediment Sample Results 

 CRQL WC-001-SD WC-002-SD WC-008-SD WC-009-SD WC-010-SD 

Analyte (mg/kg) 

Ref. 5 

Ref. 4, pp. 36, 

37 

Ref. 4, pp. 

36, 39 

Ref. 4, pp. 

36, 51 

Ref. 4, pp. 

36, 53 

Ref. 4, pp. 

36, 55 

bkg bkg bkg bkg bkg 

Arsenic** 1 1.5 U 3.7 U 1.6 U 2.4 U 2.4 J* (1.7) 

Cadmium 0.5 0.77 U 1.2 J (1.9 U) 0.78 U 1.2 U 0.86 U 

Copper** 2.5 29 J 63 J 10 J 13 J 8.6 J 

Lead** 1 3.7 J [5.3] 26 J [37] 2.4 J [3.5] 5.7 J [8.2] 10 J 

Zinc 6 18J 130 5.4 J 21 J 38 

J = an estimated quantity 

“U” indicates non-detect, and the number adjacent to U is the MRL. 

[ ] provides the adjusted value for the estimated (J’d) value as adjusted for bias (Ref. 4, pp. 266 - 283). 

*( ) = Minimum Reporting Limit (MRL) is shown in parentheses when a trace value is reported below the 

MRL. The MRL is the analyte concentration which corresponds to the lowest quantitative point on the 

calibration curve or the lowest demonstrated level of acceptable quantitation (Ref. 4, p. 36). 

**Note that the flagging of some data in the data tables (Ref. 4, pp 37 – 86) is inconsistent with 

statements at beginning of the data report (Ref. 4, pp. 34, 68). Generally, the narrative indicates some 

data should have been J-qualified while data sheets did not show a J. Where a conflict appeared, the data 

was treated as J’d and subsequently adjusted as indicated. 

**Arsenic and copper results are J’d due to high bias (Ref. 4, p. 34). Background is not adjusted; 

source/release results are adjusted downward by correction factor of 1.74 for arsenic and 1.22 for copper 

(Ref. 4, pp. 270, 283). 

** Antimony and lead results are J’d due to uncertain bias. Because matrix spike sample recovery for 

antimony and lead were low, and because performance evaluation sample recovery were “action high” 

(Ref. 4, p. 34), data was adjusted base on uncertain bias (Ref. 4, pp. 34, 270, 273, 283). Background is 

adjusted upward and source/release results are adjusted downward by correction factor of 1.98 for 

antimony and 1.44 for lead (Ref. 4, pp. 270, 283). 
 SWOF — Surface Water Overland Flow/Flood Migration Pathway 

Likelihood of Release 

Contaminated Samples — Sediment

 The following sediment samples were collected on April 10, 2007. . 

Table 5. Sediment Samples 

Distance from PPE 

(ft.) Fig. 7 Description 

WC003-SD 250 4/10/07; 1440 

(Ref. 4, pp, 35, 70, 88, 

93, 95, 97; Fig. 7) 

Grab sediment sample upstream of confluence 

of Livingston Creek and Mill Creek; sample 

collected at bend, 0 – 9”, sandy material, all tan 

(Ref. 4, pp. 88, 93) 

WC013-SD* Same as above 4/10/07; 1440 

(Ref. 4, pp, 35, 70, 88, 

93, 96, 98; Fig. 7) 

Duplicate of WC-003-SD. See discussion 

below regarding WC-103-SD / WC-013-SD 

(Ref. 4, pp. 88, 93) 

WC004-SD 

750 

4/10/07; 1540 

(Ref. 4, pp, 35, 70, 88, 

93, 95, 97; Fig. 7) 

Grab sediment sample downstream of 

confluence of Livingston Creek and Mill Creek, 

approximately 75 yards downstream of 

confluence. Grey silty sand, 0 – 6” 

(Ref. 4, pp. 88, 93) 

WC005-SD 2650 4/10/07; 1055 

(Ref. 4, pp, 35, 70, 87, 

90, 95, 97; Fig. 7) 

Grab sediment sample 30’ upstream of second 

pipeline (36” iron). Little organic on top, mix of 

sand, clay and organics. (Ref. 4, pp. 87, 90) 

WC006-SD 2800 4/10/07; 1040 

(Ref. 4, pp, 35, 70, 87, 

89, 95, 97; Fig. 7) 

Grab sediment sample collected 50’ downstream 

of sewer pipeline, sandy clay material under 2” 

organic layer. (Ref. 4, pp. 87, 89) 

WC007-SD 4000 4/10/07; 1010 

(Ref. 4, pp, 35, 70, 87, 

89, 95, 97; Fig. 77) 

Grab sediment sample on Livingston Creek; 

release sample 0.1 mile wetland frontage, 

upstream of wooden pier. 0 – 6”, grey clay with 

tan sand (Ref. 4, pp. 87, 89) 

* Note that field log notes discuss the collection of WC-003-SD (Ref. 4, pp. 88, 93) but do not 

specifically discuss the collection of the duplicate WC-103-SD. However, the sample plan (Ref. 

4, p. 102) lists sample WC-103-SD and the chain of custody shows that WC-103-SD was sample 

collected at same time as WA-003-SD (Ref. 4, pp. 96, 98). Note also that the laboratory report 

did not contain results for WC-103-SD, but did show results for WC-013-SD, a sample not listed 

on the chain of custody. WC-013-SD (as reported by the lab), shows the same date, time and 

CLP sample ID number as that indicated for WC-103-SD on the chain of custody (Ref. 4, pp. 35, 

65, 66, 70, 86). 

28
SWOF — Surface Water Overland Flow/Flood Migration Pathway 

Likelihood of Release 

Table 6. Sediment Sample Results 

WC-003-

SD 

WC-013-

 mg/kg CRQL SD 

WC-004-

SD 

WC-005-

SD 

WC-006-

SD 

WC-007-

SD 

Reference Ref. 5 

(Ref. 4, pp. 

34, 36, 41,)

(Ref. 4, pp.34, 

36, 65, 66)

(Ref. 4, pp. 

34, 36, 43) 

(Ref. 4, pp. 

34, 36, 45) 

(Ref. 4, pp. 

34, 36, 47) 

(Ref. 4, pp. 

34, 36, 49) 

Sample 

purpose release release/dup release release release release 

Arsenic** 1 31 J [17.8] 29 J [16.6] 1.3 U 

2.9 J 

(3.1 U) 

320 J 

[183.9] 

0.95 J (1.3 

U) 

Cadmium 0.5 3.5 3.6 0.30 U, J 1.1 U.J 2.4 U, J 

0.28J 

(0.65 U) 

Copper** 2.5 

190 J 

[155] 150 J [122] 5.4J 73 J [59] 

770 J 

[631] 22 

Lead 1 

520 J**

[360] 

430 J**

[300] 

8.2 J** 

[5.7] 

130 J** 

[90] 

1200 J**

[830] 

25 J** 

[17] 

Zinc 6 660 780 5.9J 160 380 36 

 

J = estimated quantity 

“U” indicates non-detect, and the number adjacent to U is the MRL. 

[ ] = value adjusted for bias (Ref. 4, pp. 266 - 283). 

*( ) = Minimum Reporting Limit (MRL) is shown in parentheses when a trace value is reported below the 

MRL. When an estimated level is reported below Contract Required Reporting Limit (CRQL) / MRL, 

this value is considered non-detect (Ref. 1, Table 2-3) 

**Note that the flagging of some data in the data tables (Ref. 4, pp 37 – 86) is inconsistent with 

statements at beginning of the data report (Ref. 4, pp. 34, 68). Generally, the narrative indicates some 

data should have been J-qualified while data sheets did not show a J. Where a conflict appeared, the data 

was treated as J’d and subsequently adjusted as indicated. 

**Arsenic and copper results are J’d due to high bias (Ref. 4, p. 34). Background is not adjusted; 

source/release results are adjusted downward by correction factor of 1.74 for arsenic and 1.22 for copper 

(Ref. 4, pp. 270, 283). 

** Lead results are J’d due to uncertain bias. Because matrix spike sample recovery for lead was low, 

and because performance evaluation sample recovery were “action high” (Ref. 4, p. 34), data was 

adjusted base on uncertain bias (Ref. 4, pp. 34, 270, 273, 283). Background is adjusted upward and 

source/release results are adjusted downward by correction factor of 1.44 for lead (Ref. 4, pp. 270, 283). 

BOLD indicates an observed release

An observed release must be either greater than background CRQL / MRL (when non-detect) or three 

times the level detected in background (Ref. 1, Table 2-3; Ref. 4, pp. 266 - 283). To determine an 

Observed Release, the highest detect / CRQL of the five background sediment samples was used. 

29
SWOF — Surface Water Overland Flow/Flood Migration Pathway 

Likelihood of Release 

Background sediment concentration summary (highest detected level, or the highest quantitation 

limit of the five background samples)

 Arsenic 3.7 U mg/kg 

 Cadmium 1.9 U mg/kg 

 Copper 63 J mg/kg 

 Lead 37 mg/kg (adjusted upward due to uncertain bias) 

 Zinc 130 mg/kg 

Hazardous substances in observed release to sediment summary. 

Sample WC-003-SD and its duplicate WC-013-SD serve to document the observed release of 

arsenic, cadmium, copper, lead, and zinc into the fishery. While samples just downstream of the 

site (WC-004-SD and WC-005-SD) did not show site contaminants, sample WC-006-SD showed 

higher levels of site contaminants. Given the passage of time since operations ceased, it can be 

anticipated that various storm and erosion events could cause uneven distribution and migration 

of contaminants downstream from the source. 

 Arsenic 320 mg / kg 

 Cadmium 3.6 mg/kg 

 Copper 770 mg/kg 

 Lead 830 mg/kg 

 Zinc 780 mg/kg 

30
SWOF — Surface Water Overland Flow/Flood Migration Pathway 

Likelihood of Release 

Further discussion: 

There appears to be some pesticide contamination at this site; however, this information was not 

used to produce the site score. A nearby upgradient facility manufactured chlorinated pesticides 

(Ref. 9, pp. 1-12). 

4.1.2.1.1.1 ATTRIBUTION 

The Wright Chemical Corp site was a fertilizer and sulfuric acid manufacturing facility 

founded in 1883 (Ref. 4 pp. 397, 401). The original Acme plant was a lead-lined “chamberprocess” plant that thermally extracted sulfur from pyrite (Ref. 4 pp. 109). Sanborn Fire 

Insurance Maps dated from 1898 and 1910 confirm that “Lead Acid Chambers” were previously 

present on the property where Source 1 has been identified (Ref. 4 pp. 173-179; Fig. 3). 

Denuded, magenta-colored soil characteristic of former lead chamber sulfuric acid 

manufacturing facilities (Ref. 4 pp. 214-215) has been documented in the vicinity of the former 

process areas on the property (Ref. 8, pp. 1-8). This magenta colored soil typically contains lead 

in the 4,000 – 20,000 mg/kg range and depending on the raw materials used in the processes, it 

can also contain substantial amounts of other metals and contaminants (Ref. 4 p. 215). Source 1 

has been documented to contain elevated concentrations of metals including arsenic, cadmium, 

copper, lead, and zinc (see Table 2 of this HRS documentation record) (Ref. 4, pp. 34, 36, 57-59, 

61-63; Fig. 4). 

 

Source 1 drains north, downgradient into Livingston Creek (Figs. 1, 4). Sediment 

samples taken from Livingston Creek directly downgradient from source 1 show elevated 

concentrations of metals analogous to those found in source 1 (Ref. 4, pp. 35-56, 87-93; Fig. 7). 

 Additionally, sediment samples WC-011-SS and WC-013-SS have been documented as 

being located in a wetland contiguous to Livingston Creek (Ref. 8, p. 6, Fig. 4). Since samples 

WC-011-SS and WC-013-SS are located in a wetland contiguous with Livingston Creek, 

evidence of direct deposition of hazardous chemicals directly into the Creek from source 1 is 

present. 

 There are three current/former facilities/sites that are upgradient from this site – Hexion, 

Kaiser Agricultural, and Kaiser Acme Farmarket (Ref. 4, pp. 108, 109-110, 117; Ref. 9, 1-12). 

There are two nearby facilities/sites that are downgradient from Wright Chemical – International 

Paper (aka Federal Paperboard) and Holtrachem (Ref. 4, p. 3, Figs. 5, 6). The neighboring 

Hexion facility was at one time owned and operated by the Wright Chemical Corp. The history 

of chemical manufacturing on this adjacent 20-acre Hexion parcel included formaldehyde, 

hexamine, chloropicrin, silicon compounds and pharmaceuticals. There is no history of work 

with metals (Ref. 4, pp. 9, 129, 397-404). One sample (WC-010-SD; Tables 3, 4) was collected 

downgradient of Hexion and up gradient from Livingston Creek. This sample documents any 

31
impact to Mill Creek that may have occurred from runoff from the Hexion site prior to it entering 

Livingston Creek. 

The archived Kaiser Agricultural Chemical site (NCD 980 842 470) adjacent to and south 

of the lead chamber properties was once part of Acme Chemical and was owned by Wright 

Chemical. This parcel housed the fertilizer portion of the operation, it was investigated under 

CERCLA, and was archived from CERCLA in 1989 (Ref, 4, p. 110, 111). The former Kaiser 

Acme Farmarket (NCD 980 557 847) pesticide facility is about 1⁄4 mile to the south. This facility 

was associated with chlorinated pesticide manufacturing from 1967 – 1971 and subsequently for 

pesticide retail sales. There is no evidence it had metal contamination (Ref. 9, pp. 1-12). 

 To the north and across Livingston Creek is the 978-acre parcel owned by Federal Paper 

Board Co., Inc. (aka International Paper) (Ref. 4, p. 452.3; Fig. 5). Adjacent to and east of 

Federal Paper Board, bordering the Cape Fear River is the former Holtrachem (aka LCP 

Chemicals; Honeywell; Allied Signal) mercury cell chlor-alkali plant site (NCD 991 278 631), 

currently owned by Honeywell International (Ref. 4, pp. 452.4, 452.5; Fig. 6). Both of these 

sites are downgradient from the Wright Chemical Corp site. There is some flow reversal on 

Livingston Creek (Ref. 10, pp. 1, 2); however, neither the Holtrachem nor the International Paper 

site are associated with any lead, arsenic, cadmium, copper, or zinc contamination (Ref. 8, p. 2). 

Holtrachem has high contamination with mercury and PCBs (Ref. 8, p. 2). 

4.1.2.1.2 POTENTIAL TO RELEASE TO SURFACE WATER— 

 Not scored because observed release to surface water sediment documented by 

chemical analysis 

 

=============================================================== 

 Surface Water Sediment Observed Release Factor Value— 550

 (Ref. 1, Section 4.1.2.1.1)

32
 SWOF Human Food Chain Threat 

4.1.3 HUMAN FOOD CHAIN THREAT 

 The human food chain threat is evaluated based on three factor categories: likelihood of 

release, waste characteristics, and targets. 

4.1.3.1 HUMAN FOOD CHAIN THREAT-LIKELIHOOD OF RELEASE 

 The human food chain threat likelihood of release is the same as that for the drinking 

water threat (Ref. 1, Section 4.1.3.1). Level II contamination in Livingston Creek from the PPE 

downstream 2800 feet to Sample WC-006-SD has been documented as a part of a fishery. (Ref. 

4, pp. 35, 70, 87, 531-533, Fig. 7). 

 550

4.1.3.2 HUMAN FOOD CHAIN THREAT-WASTE CHARACTERISTICS 

 The waste characteristics factor category for each watershed is based on two factors: 

toxicity/persistence/bioaccumulation and hazardous waste quantity (Ref. 1, Section 4.1.3.2). 

4.1.3.2.1 Toxicity/Persistence/Bioaccumulation 

 The HRS instructs to evaluate the waste characteristics factor category based on two 

factors: toxicity/persistence and hazardous waste quantity. And, to evaluate only those hazardous 

substances that are available to migrate from the sources at the property to surface water in the 

watershed via the overland/flood hazardous substance migration path for the watershed. Such 

hazardous substances include hazardous substances that meet the criteria for an observed release 

to surface water in the watershed, and all hazardous substances associated with a source that has 

a surface water containment factor value greater than 0 for the watershed (Ref. 1, Section 4.1.2.2, 

also see sections 2.2.2, 2.2.3, 4.1.2.1.2.1.1, and 4.1.2.1.2.2.1). Tables 7 and 8 of this HRS 

documentation record present those substances documented in the observed release to the 

fishery, and those substances documented in the source with a containment factor value greater 

than 0. 

 As discussed above, Livingston Creek (3 miles) and the first 7 1⁄2 miles in the Cape Fear 

River is fresh, and the last 4 1/2 miles of the surface water pathway is brackish/salt. (See 

discussion in 4.1.1.1 above; Ref. 4, pp. 296, 300, 309). 

 The Hazard Ranking System (HRS) instructs that if bioconcentration factor (BCF) data 

are available for both fresh water and salt water for the hazardous substance, use the BCF data 

that corresponds to the type of water body (that is, fresh water or salt water) in which the 

fisheries are located to assign the bioaccumulation potential factor value to the hazardous 

substance. If, however, some of the fisheries being evaluated are in fresh water and some are in 

salt water, or if any are in brackish water, use the BCF data that yield the higher factor value to 

33
SWOF – Human Food Chain Threat 

assign the bioaccumulation potential factor value to the hazardous substance (Ref. 1, Section 

4.1.3.2.1.3). Because the fishery is located in fresh water, only fresh water bioaccumulation 

values will be used as per the HRS. 

Table 7. Source 1 Contaminants Documented in Observed Release to Sediment in the Fishery 

PF# Hazardous 

Substance 

Tox. Factor 

value 

BPFV*

Fresh 

Food**

BPFV* 

Salt 

Food** 

T/P value 

(Ref. 1, Table

4-12)

(fresh) (Ref. 1, 

Table 4-16)

T/P/BPFV T/P/BPFV 

(salt) (Ref. 1, 

Table 4-16)

Arsenic 10,000 1 5 500 10,000 5 x 10 E4 5 x 10 E6 

Cadmium 10,000 1 5,000 50,000 10,000 5 x 10 E7 5 x 10 E8 

Copper 0 1 500 50,000 0 0 0 

Lead 10,000 1 5 5,000 10,000 5 x 10 E4 5 x 10 E7 

Zinc 10 1 5 50,000 10 50 5 x 10 E5 

Table 8. Source 1 Contaminants Documented in Source with Containment Factor of 10, not 

documented in Observed Release to Fishery Sediment 

Hazardous 

Substance 

Tox. Factor 

value 

PF# BPFV*

Fresh 

Food**

BPFV* 

Salt 

Food** 

T/P value 

(Ref. 1, Table

4-12)

T/P/BPFV 

(fresh) (Ref. 1, 

Table 4-16)

T/P/BPFV 

(salt) (Ref. 1, 

Table 4-16)

Antimony 10,000 1 5 5 10,000 5 x 10 E4 5 x 10 E4 

Manganese 10,000 1 50,000 50,000 10,000 5 x 10 E8 5 x 10 E8 

Mercury 10,000 1 50,000 50,000 10,000 5 x 10 E8 5 x 10 E8 

Nickel 10,000 1 0.5 500 10,000 5 x 10 E3 5 x 10 E6 

Silver 100 1 50 50,000 100 5 x 10 E3 5 x 10 E6 

Thallium 100 1 500 50 100 5 x 10 E4 5 x 10 E3 

T/P/BPFV = Toxicity/Persistence/Bioaccumulation Potential Factor (Ref. 1, Table 4-16) **Ref. 

2, Appendix BI, pp. 1-15 

BPFV = Bioaccumulation Potential Factor Value 

#

PF = Persistence Factor Value, Ref. 1, Section 4.1.3.2.1.2; Ref. 2 

*Ref. 1, Section 4.1.3.2.1.3; Ref. 2. 

 Of those contaminants documented in the observed release to the fishery, cadmium has 

the highest T/P/BPFV freshwater value. Of those contaminants documented in the source but 

not in fishery sediment, manganese and mercury have the highest freshwater values. 

Manganease and mercury were used to assign the toxicity/persistence/bioaccumulation factor 

value as per Section 4.1.3.2.1.4 of the HRS. 

=============================================================== 

 Toxicity/Persistence/Bioaccumulation Factor Value: = 5 x 108

34
 SWOF – Human Food Chain Threat 

4.1.3.2.2 Hazardous Waste Quantity 

 HRS (Ref. 1), Section 4.1.3.2.2 instructs that if any target for that migration pathway is 

subject to Level I or Level II concentrations, assign either the value from Table 2-6 or a value of 

100, whichever is greater, as the hazardous waste quantity factor value for that pathway. (Ref. 1, 

Section 2.4.2.2) 

 

 Hazardous Waste Quantity Factor Value = 100 

4.1.3.2.3 Human Food Chain Threat Waste Characteristics Factor Category Value: 

 

 Toxicity/Persistence Value = 10,000 

 Bioaccumulation Potential Factor Value = 50,000 

 Toxicity/Persistence Value x Hazardous Waste Quantity Factor Value: 

 10,000 x 100 = 1,000,000 (1 x 106

) 

(Toxicity/Persistence x Hazardous Waste Quantity) x Bioaccumulation Potential 

Value: 

 (1 x 106) x 50,000 = 5 x 1010

=============================================================== 

Human Food Chain Hazardous Waste Quantity Assigned Value/ 

Human Food Chain Waste Characteristics Factor Category Value 320

 (Ref. 1, Table 2 - 7; Sections 4.1.3.2.3 and 2.4.3.1): 

35
 SWOF – Human Food Chain Threat

4.1.3.3 HUMAN FOOD CHAIN THREAT - TARGETS 

Actual Human Food Chain Contamination 

 Observed Release to Surface water sediment (Level II) was documented in Section 

4.1.3.1. 

 Livingston Creek, from WC-001-SD upstream of Old Highway 87 until its confluence 

with the Cape Fear River is a fishery. Brim, bass and catfish are caught in the creek, and catches 

are cooked and consumed on the creek banks (Ref. 4, pp. 88, 91, 531 – 533). The Cape Fear 

River is an important fishery (Ref. 4, pp. 291 – 293; 490 – 502; 531 -- 533). Atlantic Sturgeon, 

Striped Bass and American Shad catches are three of the seven anadromous species found in the 

Cape Fear River system, along with several nonnative species (Ref. 4, pp. 490 - 502). The Cape 

Fear River is a commercial fishery (Ref. 4, pp. 289, 291, 293). The estimated 1981 harvest was 

1.3 million pounds for the entire basin downstream of Lock 1 (Ref. 4, p. 292); however, the 

fishery has experienced a decline (Ref. 4, 492). Commercial off-shore shad fishing has been 

phased out, making the inshore Cape Fear River shad fishery even more important (Ref. 4, p. 

492). The Atlantic Sturgeon is a threatened species and the shortnose sturgeon is an endangered 

species; there is a reproducing population of these two species in this drainage basin (Ref. 4, p. 

495). 

 Researchers at the University of North Carolina Wilmington's Center for Marine Science 

performed a pilot study in 2003-2004 to assess metals and organic contaminant concentrations at 

three areas in the Lower Cape Fear River system (Ref. 4, p. 476). One of these areas was 

Livingston Creek, about 40 meters upstream of the confluence with the Cape Fear River (LVC) 

(Ref. 4, pp. 475, 476; Fig. 6). The clam and bottom-feeding fish tissue concentrations of arsenic, 

cadmium, mercury, selenium, and Dieldrin exceeded their respective recommended 

concentration range, indicating potential human health problems (Ref. 4, pp. 476, 480 -- 484). 

 

4.1.3.3.1 Food Chain individual (Ref. 1, Section 4.1.3.3.1) 

Level II contamination in Livingston Creek from the PPE downstream 2800 feet to Sample WC006-SD has been documented as a part of a fishery. (Ref. 4, pp. 35, 70, 87, 531-533, Fig. 7). 

 "If any fishery (or portion of a fishery) is subject to Level II concentrations, assign a 

value of 45. 

=============================================================== 

 Food Chain Individual Factor Value = 45

36
SWOF – Human Food Chain Threat 

4.1.3.3.2 Population 

 

4.1.3.3.2.1 Level I Concentrations -- not scored 

 

4.1.3.3.2.2 Level II Concentrations 

 Arsenic, cadmium, copper, lead, and zinc contamination have been documented in source 

1 and in sediment in the fishery. The level of contaminants is summarized below: 

 mg/kg WC-003-SD WC-013-SD WC-006-SD 

Arsenic 31 J [17.8] 29 J [16.6] 320 J [183.9] 

Cadmium 3.5 3.6 2.4 U, J 

Copper 190 J [155] 150 J [122] 770 J [631] 

Lead 520 J** [360] 430 J** [300] 1200 J** [830] 

Zinc 660 780 380 

Given the active fishing occurring in Livingston Creek (Ref. 4, p. 531) >0 pounds of fish are 

caught in Livingston Creek and consumed. A Food Chain Population value of 0.03 is assigned 

(Ref. 1, Table 4-18). 

Level II Concentrations Factor Value = 0.03

4.1.3.3.2.3 Potential Human Food Chain Contamination – not scored 

4.1.3.3.3 Calculation of Human Food chain threat - targets factor category value (Ref. 1, 

Section 4.1.3.3.3) 

Human food chain threat-targets factor category value = 

Human Food Chain Individual + Level II concentrations = 

 45 + (0.03) = 45.03 

4.1.3.4 Calculation of human food chain threat score 

 Likelihood of release x waste characteristics x targets / 82,500 = 

 550 x 320 x 45.03 / 82,500 = 96.06 

=============================================================== 

Human Food Chain Threat Score = 96.06

37
38

 SWOF/Environment 

4.1.4 ENVIRONMENTAL THREAT 

 Even though there are extensive wetlands along the surface water pathway (Ref. 7, p. 1, 

Fig. 9), the environmental threat was not scored because it would have had a minimal additional 

impact on the surface water pathway score. 
Table 4-1 Surface Water Overland/Flood Migration Component Scoresheet

Human Food Chain Threat 

 Maximum Value Value Assigned

Likelihood of Release: 550 550

Waste Characteristics: 

Toxicity/Persistence/Bioaccumulation (a) 5 x 108

Hazardous Waste Quantity (a) 100

Waste Characteristics 1,000 320

Targets: Food Chain Individual Factor Value 50 45

 Level I Concentrations (b) 

 Level II Concentrations (b) 0.03

 Potential Human Food Chain Contamination (b) 

 

 Population (Level I + Level II + Potential) (b) 45.03 

Human Food Chain Threat Score: 

 [550 x 320 x 45.03] / 82,500 = 100 96.06

(a)Maximum value applies to waste characteristics category 

(b)Maximum value not applicable

39