HRS DOCUMENTATION RECORD — REVIEW COVER SHEET 

Name of Site: Cristex Drum 

NC0 001 606 250 

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) 707-8376 

 

Documentation Record: 

 Jeanette Stanley (919) 707-8376 

Pathways, Components, or Threats Not Scored: 

 Ground Water Pathway 

The ground water pathway was not scored. Even though ground water beneath 

the site contains tetrachloroethene (PCE) as high as 7,100 μg/L, cis-1,2-

dichloroethene (cis-1,2-DCE) as high as 2,800 μg/L, and trichloroethene (TCE) as 

high as 340 μg/L as well as chlorobenzene, vinyl chloride, and cadmium, the 

ground water pathway score has a minimal impact on the site score because no 

drinking water wells have been impacted by site contaminants. 

 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 sources at the 

site. 

Ground Water-to-Surface Water migration was not scored. Overland migration to 

surface water is sufficient to qualify the site for the National Priorities List (NPL) 

 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 Pathway 

 The air pathway was not scored because the air pathway has a minimal impact on 

 the overall site score. 
HRS DOCUMENTATION RECORD

 Name of Site: Cristex Drum 

 NC0 001 606 250

 EPA Region: 4 

 Date Prepared: May 2013

Street Address of Site*: 500 W. Industry Dr. 

 City, County, State, and ZIP: Oxford, Granville County, NC 27565 

 General Location in the State: Piedmont, 50 miles North of Raleigh 

 Topographic Map: Oxford, NC (Ref. 3) 

 Latitude*: 36.2972o north latitude 

 Longitude*: 78.6067o

 west longitude Location is northeast corner of building near Source 1 

 (contaminated soil) (Ref. 4; Figs. 1, 2) 

 Scores

 Air Pathway — Not Scored 

 Ground Water Pathway — Not Scored 

 Soil Exposure Pathway — Not Scored 

 Surface Water Pathway — 96.00

 HRS SITE SCORE 48.00 

* 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, disposed, or placed, or has 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 42.67 

 Environmental Threat + 53.33 

 96.00 9,216.00 

 

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

 = 9216.00 

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

 then take the square root = 48.00 

2 
 

TABLE 4-1 --SURFACE WATER OVERLAND/FLOOD MIGRATION COMPONENT SCORESHEET

Factor categories and factors Maximum 

Value 

Value Assigned 

 Watershed Evaluated: Foundry Branch 

Drinking Water Threat

Likelihood of Release:

1. Observed Release 550 550.0

2. Potential to Release by Overland Flow: 

2a. Containment 10 0.0 

2b. Runoff 10 0.0

2c. Distance to Surface Water 5 0.0 

2d. Potential to Release by Overland Flow [lines 2a(2b + 2c)] 35 0.0

3.Potential to Release by Flood: 

3a. Containment (Flood) 10 0.0 

3b. Flood Frequency 50 0.0

3c. Potential to Release by Flood (lines 3a x 3b) 500 0.0 

4. Potential to Release (lines 2d + 3c, subject to a maximum of 500) 500 0.0 

5. Likelihood of Release (higher of lines 1 and 4) 550 550.0 

Waste Characteristics:

6. Toxicity/Persistence (a) 0.0 

7. Hazardous Waste Quantity (a) 0.0

8. Waste Characteristics 100 0.0 

Targets:

9. Nearest Intake 50 0.0 

10. Population: 

10a. Level I Concentrations (b) 0.0 

10b. Level II Concentrations (b) 0.0

10c. Potential Contamination (b) 0.0 

10d. Population (lines 10a + 10b + 10c) (b) 0.0

11. Resources 5 0.0 

12. Targets (lines 9 + 10d + 11) (b) 0.0 

Drinking Water Threat Score:

13. Drinking Water Threat Score [(lines 5x8x12)/82,500, subject to a max of 100] 100 0.0

Human Food Chain Threat

Likelihood of Release:

14. Likelihood of Release (same value as line 5) 550 550.0 

Waste Characteristics:

15. Toxicity/Persistence/Bioaccumulation (a) 5.0E8

16. Hazardous Waste Quantity (a) 100.0 

17. Waste Characteristics 1000 320.0 

Targets:

18. Food Chain Individual 50 20.0

19. Population 

19a. Level I Concentration (b) 0.0 

19b. Level II Concentration (b) 0.0

19c. Potential Human Food Chain Contamination (b) 0.003 

19d. Population (lines 19a + 19b + 19c) (b) 0.0

20. Targets (lines 18 + 19d) (b) 20.003

Human Food Chain Threat Score:

21. Human Food Chain Threat Score [(lines 14x17x20)/82500, subject to max of 100] 100 42.67

3 
Environmental Threat

Likelihood of Release:

22. Likelihood of Release (same value as line 5) 550 550.0 

Waste Characteristics:

23. Ecosystem Toxicity/Persistence/Bioaccumulation (a) 5.0E8 

24. Hazardous Waste Quantity (a) 100.0

25. Waste Characteristics 1000 320.0 

Targets:

26. Sensitive Environments 

26a. Level I Concentrations (b) 0.0

26b. Level II Concentrations (b) 25.0 

26c. Potential Contamination (b) 0.0

26d. Sensitive Environments (lines 26a + 26b + 26c) (b) 25.0 

27. Targets (value from line 26d) (b) 25.0 

Environmental Threat Score:

28. Environmental Threat Score [(lines 22x25x27)/82,500 subject to a max of 60] 60 53.33 

Surface Water Overland/Flood Migration Component Score for a Watershed

29. Watershed Scorec

 (lines 13+21+28, subject to a max of 100} 100 96.00 

 

Surface Water Overland/Flood Migration Component Score 

 30. Component Score (Ssw)

c

 (highest score from line 29 for all watersheds evaluated) 100 96

a

 Maximum value applies to waste characteristics category b

 Maximum value not applicable c

 Do not round to nearest integer 

.00 

 

4 
CRISTEX DRUM 

OXFORD, GRANVILLE COUNTY, NC 

LIST OF FIGURES 

Figure 1. Facility Map 

Figure 2. Site Layout with Monitoring Well Locations 

Figure 3. Excavation Areas, Cristex Facility Site, October 2002 

Figure 4. Proposed Geoprobe Locations from 2002 Work Plan, July 2010 

Figure 5. Soil Gas Results, 2002, Tetrachloroethene, Cristex Site 

Figure 6. Sample Location Map (2007), Cristex 

Figure 7. Subsurface Soil Sample Locations, 2010, Cristex Drum Site 

Figure 8. JFD Well Results - 2007 

Figure 9. 15-mile Surface Water Pathway Map 

Figure 10. Surface Water, Sediment, and Ground Water Sample Locations 

Figure 11. Surface Water Pathway, Cristex Drum Site 

Figure 12. Cristex Drum Site, Wetland Delineation June 2012 Large View 

Figure 13. Cristex Drum Site, Wetland Delineation June 2012 

 

5 
78°37'20"W 78°37'10"W 78°37'0"W 78°36'50"W 78°36'40"W 78°36'30"W 78°36'20"W 78°36'10"W 

36°18'30"N36°18'20"N36°18'10"N36°18'0"N36°17'50"N36°17'40"N36°17'30"N

JFD 

Lagoon 

Cristex 

Background Sediment and Surface Water Sample Location 37SD 

Approximate CristexP

roperty Boundary 

Oxford Printing 

BC(

78°37'20"W 78°37'10"W 78°37'0"W 78°36'50"W 78°36'40"W 78°36'30"W 78°36'20"W 78°36'10"W 

Site Name: 

Site Number: Figure: 

Cristex Dru

NCO 001 6

Base map is USGS Topographic Quadrangle, Oxford, NC 1991 

County location: Facility M

1 

0 500 1,000 2,000 

Feet 
MW5 

MW4 

CR04SB 

78°36'30"W78°36'30"W

36°17'50"N

Source 2

MW9 

MW8 

MW

MW3 

MW3I 

MW10 

CR05SB 

Approximate Cristex Property Boundary 

Ditch

Source 1 area

Base map is 2005 aerial imagery available for download at www.nconemap.com. 

County location: 

Monitoring Well 

Subsurface Soil Sample Location 

Site Layout wit

Site Name: Cristex Dru

Site Number: NCO 001 6Figure: 2 
Figure 3.
NOTE: This map of 

proposed subsurface soil sample locations is from the 2002 Work Plan prepared for Cristex under the REC Program. While data was provided to NC Superfund when Cristex withdrew from the REC program, a final figure showing the subsurface soil sample locations was not prepared. This map provides the best guess of sample locations 

Figure 4: Proposed Geoprobe Locations from 2002 Work Plan Site: Cristex Drum Site, Oxford, Granville County Date: 07

NCO001606250 Drawn B

Approximate Scale: See above 
Figure 5 

Soil Gas Results, 2002 

Tetrachloroethene 
 

CR-WS-02

CR-WS-01

CR-SW-07

CR-SW-02

CR-SS-11

CR-SS-10

CR-SS-09

CR-SS-08

CR-SS-07

CR-SS-05

CR-SS-04

CR-SS-03

CR-SS-02

CR-SS-01

CR-SD-11

CR-SD-10

CR-SD-08 CR-SD-09

CR-SD-07

CR-SD-06

CR-SD-05

CR-SD-04

CR-SD-03

CR-SB-11

CR-SB-10

CR-SB-08

CR-SB-05

CR-SB-04

CR-SB-03

CR-SB-01

CR-SS-06

CR-SB-07

CR-SB-06

CR-SB-02

CR-MW-03

CR-MW-04

CR-MW-01

CR-MW-02

United States Environmental Protection Agency

CRISTEX

OXFORD, GRANVILLE COUNTY,

NORTH CAROLINA

TDD No. TNA-05-003-0039

FIGURE 6 

SAMPLE LOCATION

MAP (2007) 

Oxford,

Granville County,

North Carolina

C:\GIS_Workspace\Cristex\mxd's\Figure-4_samples.mxd

0 100 200 400

Feet

Legend

Monitoring Well

Sediment Sample

Surface Soil Sample

Surface Water Sample

Surface Water & Sludge Sample 

Surface Soil & Subsurface Soil Sample

Surface Water & Sediment Sample

Waste Water Sample

Site Structure

Fence

Property Line

Railroad

Cristex

Facility

Gravel Lot

& Drive

Lagoon

Asphalt

Parking

Area

Barren Area

Wetland Approximate Area

Industry

Drive

State Route 1195

Aerial Image Provided by: Granville County GIS
MW10 

36°17'50"N MW9 

MW8 

MW3 

MW3I 

CR11SB 

CR09SB 

CR08SB 

CR07SB 

CR06SB 

CR03SB 

CR02SB 

CR01SB 

Ditch

MW11 

Monitoring Well Location Subsurface Soil Sample Location 

Base map is 2005 aerial imagery available for download at www.nconemap.com. 

County location: Subsurface Soi

Site Name: Cristex Dru

Site Number: NCO 001 6Figure: 7 
PCE > TCE 

TCE > PCE PCE ~ TCE 

MW-7 

MW-6 & 6I 

Lagoon 

Approx Location of Cristex Well 

Figure 8. JFD Well Results – 2007 Figure from 2007 Groundwater Monitoring Results and modified by J. Stanley Oct 2010 

MW-1 
PPE

1 Mile

9 Miles

8 Miles

7 Miles

6 Miles

5 Miles

4 Miles

3 Miles

2 Miles

14 Miles

13 Miles

12 Miles

11 Miles

10 Miles

15 Mile TDL

FIGURE 9 

15-MILE SURFACE WATER PATHWAY MAP

Disclaimer: This map is intended for visual orientation use only.

In no way is this map to be used for precise locational use.

C:\GIS_Workspace\Cristex\mxd's\Figure-4_su rface-water.mxd

CRISTEX

OXFORD, GRANVILLE COUNTY,

NORTH CAROLINA

TDD No. TNA-05-003-0039

United States Environmental Protection Agency

Oxford,

Granville County,

North Carolina

Legend

Surface Water Pathway

Site Warehouse

SOURCE: MODIFIED FROM USGS 7.5 MINUTE QUADRANGLES:

Kitterey & Henderson

0 1 2

Miles

Note:

PPE = Probable point of entry

TDL = Target distance limit
Approx. 

Wetland

stream 

PPE

10 
Former Cristex 

Facility Property 

Approx stream from sites 

Approx. Wetland perimeter 

~850’ 

stream enters and exits culvert under apt. complex 

CR-SD-01(collected 2007)

Textron 

Figure 11: Surface Water Pathway Site: Cristex Drum Site, Oxford, Granville County Base Map fro

NCO001606250 

Scale: as shown 
 

 

 

 

 

 

 

!

 

 

 

 

 

!( 

!( 

!( 

!( 

#0 

# #0 

#0 

#0 

#0 

!( 

!( 

PPE 

Lagoon Breach 

in Lagoon 

MW9 

MW7 

MW6 

MW-2 

MW6D 

36SD 

35SD 

34SD 

32SD 33SD 

31SD 

MW6I 

CRISTEX DRUM SITE

Wetland Delineation

June 2012 Large View 

Fig: 12 

Site: NC0 000 160 250

City Oxford, NC

County: Granville

Date: 

Drawn By: HJZ 

2 

North American Datum 1983

North Carolina State Plane (3200)

Contour Interval 4 Feet 

1 inch = 80 feet 

Feet 

100 50 0 

(

10/08/2012 

Ground Water 

# Sediment 

#0 Surface Water and Sediment 

Wetland Delineations and Permiters 

Lower Area 165.36 ft. 

Middle Area 485.21 ft. 

Upper Area 479.27 ft.11 

Source: Aerial Imagery 2010 high resolution (State of NC); Wetland Delineation, US Army Corpse of Engineers 

100 
 

 

 

 

 

!

 

 

 

 

 

 

#0 

# #0 

#0 

#0 

PPE 

Lagoon Breach 

in Lagoon 

35SD 

34SD 

32SD 33SD 

31SD 

Upper Limit of

Contamination 

CRISTEX DRUM SITE

Wetland Delineation

June 2012 

NC0 000 160 250

Oxford, NC

Granville 

HJZ 

Fig:

Site: 

City

County:

Date: 

Drawn By: 

40 20 0 40 

Feet 

North American Datum 1983

North Carolina State Plane (3200) 

2 

13
 

# Sediment 

(

10/08/2012 

Ground Water 

#0 Surface Water and Sediment 

Wetland Delineations and Permiters 

Lower Area 165.36 ft. 

Middle Area 485.21 ft. 

Upper Area 479.27 ft. 

Source: Aerial Imagery 2010 high resolution (State of NC); Wetland Delineation, US Army Corpse of Engineers 
CRISTEX DRUM 

OXFORD, GRANVILLE COUNTY, NC 

LIST OF REFERENCES 

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

51532, 1990 and Comprehensive Environmental Response, Compensation, and Liability 

Act (42 U. S. C. 9601). Online address: 

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

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

Office of Solid Waste and Emergency Response. Directive 9345.1-13. Revised 2006 

with 2012 updates. Excerpt - 25 pages. Online address: 

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

3. US Geological Survey, 7.5-minute topographic quadrangle maps of North Carolina; 

Oxford, NC, 1981, photo inspected 1984; Wilton, NC, 1977; Stem. NC, 1974, Berea. 

NC, 1981, photorevised 1990. 1 page. 

4. US Environmental Protection Agency, "Standard Operating Procedure to Determine Site 

Latitude and Longitude Coordinates," 1991. Calculation worksheet for Cristex Drum 

Site. 2 pages. 

5. Granville County Register of Deeds; Book 1168, pp. 869 – 872; Book 1286, pp. 458-462, 

and Book 1340, pp. 404-405; NC Secretary of State corporation filing for Cristex, June 

30, 1991, NC Secretary of State corporation filing for IMI, June 20, 1974; New York 

Secretary of State corporation filings for IMI and Steinfeld Mills: December 14, 1944, 

May 7, 1971, December 5, 1952, April 11, 1969. 41 pages. 

6. Mean Annual Lake Evaporation (Inches), US Department of Commerce, 1979, Climatic 

Atlas of the United States, National Climatic Center, Asheville, NC; North Carolina 

Average Annual Precipitation, 1971 – 2000, Prism Group and Oregon Climate Service, 

Oregon State University, 2006; National Oceanic and Atmospheric Administration, Point 

Precipitation Frequency Estimates, NOAA Atlas 14, Volume 2, Version 3, 2004. 5 

pages. 

7. Stutts Truck Tires Web page, June 2010; NC Secretary of State corporation filings for 

Stutts Truck Tires and Jomar Ventures LLC, April 7, 2008, December 5, 2011, June 15, 

2006, March 11, 2011. 10 pages. 

8. Lown, David, Environmental Engineer, NC Superfund Section, Memo to Grover 

Nicholson, NC Superfund Section, October 8, 1996, Mallary, Ken, RPM, US EPA, 

electronic mail message to Terry Stilman, OSC, USEPA, April 30, 1996, and Pierce, R. 

Steve, START Leader, PRC, Geophysical Report, August 23, 1996. SUBJECT: 

Removal Planning. 24 pages. 

19 
9. Stanley, Jeanette, Environmental Chemist, NC Superfund Section, Memo to file, 

November 1, 1996 and Pierce, R. Steve, START, “Summary of October 30 - November 

2, 1996 Removal Investigation at Cristex Drum Site”, February 25, 1997. 20 pages. 

10. SUMMARY OF REMOVAL ACTION. 37 pages. 

• Stanley, Jeanette, Environmental Chemist, NC Superfund Section, Memo to file, 

January 15, 1998. SUBJECT: Site visit during removal. 

• De’Lyntoneus Moore, OSC, US EPA, Field notes, January 16 - 22, 1997. 

• De’Lyntoneus Moore, OSC, US EPA, POLREP, Cristex Drum Site, March 31, 

1997; 

• Removal Action Fact Sheet, December 1996; Benefield, Randy, OHM Corp., 

Report on Mobilization to Cristex Drum Site, March 21, 1997; 

• Non-Hazardous Waste Special Waste Manifests (4), March 28, 1997; 

• MKC Enterprises, Inc. Certificate of Disposal, April 8, 1997; 

• Uniform Hazardous Waste Manifest #93717, March 27, 1997; and 

• BFI WCD No. AZ 2465, Waste Characterization Data. 

11. Lair, Myron D., US EPA Region IV, Emergency Response and Removal Branch and 

De’Lyntoneus Moore, OSC, US EPA, Action Memorandum on Cristex Drum Site, 

February 26, 1997. 7 pages. 

12. Rahn, Phillip L. P.G., President, Aquaterra, Inc., Phase I Environmental Audit, Cristex 

Corporation, March 1, 1991. 18 pages. 

13. Stanley, Jeanette, Environmental Chemist, NC Superfund Section, Cristex Drum Site 

 iESI, May 14, 2012. 413 pages. 

14. Donna Wilson, Environmental Engineer, NC Superfund Section, Memo to file, March 18. 

1998. SUBJECT: Site reconnaissance on March 9, 1998. 6 pages. 

15. Leonhardt, H. Derr II, PE, Leonhardt Environmental, Letter to Donna Wilson, NC 

Superfund Section, January 22, 1999; Cristex Lagoon Sample Results, February 24, 

1998; and Stanley, Jeanette, Environmental Chemist, NC Superfund Section, Memo to 

file, March 11, 1999. SUBJECT: January 30, 1998 Lagoon Samples. 19 pages. 

16. Stanley, Jeanette, Environmental Chemist, NC Superfund Section, Memo to file, 

September 18, 2012, SUBJECT: Background samples. 4 pages. 

17. Regulatory History: Lagoon and Sewer. 73 pages. 

Proposed Increase is Wastewater discharge, June 26, 1981, pp. 1–2, 

Complaint, Heated Water discharge, February 11, 1982, p. 3, 

Notice of Pretreatment Regulations, August 12, 1983. pp. 4-5, 

Accidental Discharge Prevention Plan, September 30, 1983, pp. 6 - 36, 

Industrial Sewer Connection Application, June 6, 1984, pp. 37-48, 

City of Oxford letter to Cristex, August 21, 1985, p. 49, 

Letter to Cristex, pre-treatment monitoring program, Nov. 7, 1985, p. 50, 

20 
Oxford City Manager letter, Feb. 25, 1986, pp. 51-52, 

City of Oxford letter to Burlington Research, Oct. 7, 1986, pp. 53-54, 

City of Oxford letter to Cristex, attempts to close lagoon, pp. 55 - 71, and 

NC DEHNR letter to Revlon (Oil Spill), April 15, 1993, pp. 72 - 73. 

18. Stanley, Jeanette, Environmental Chemist, NC Superfund Section, Memo to file, April 

21, 1999. SUBJECT: NC Air Quality Division file material. Memoranda, Air Quality 

Permits and Permit Applications, Special Orders on Consent and Notices of Violation. 

February 15, 1973 - June 26, 1981. 148 pages. 

19. Donna Wilson, Environmental Engineer, NC Superfund Section, Memo to file, October 

15, 1998. SUBJECT: Field notes taken during the Site Inspection. 59 pages. 

20. Rudo, Ken, Occupational and Environmental Epidemiology Section, Drinking Water 

Health Risk Evaluation, December 1998, DeRosa, Pat, Head, NC Superfund Section, 

Letters to Tommy Brooks and Hoffman Suitt, December 18, 1998. 5 pages. 

21. Granville County, NC, Map of Jomar Ventures LLC Parcel 1600, created July 11, 2012; 

Stanley, Jeanette, Environmental Chemist, NC Superfund Section, Memos to file, 

November 6, 1996, November 19, 1996, March 24, 1999, and April 7, 1999; Donna 

Wilson, Environmental Engineer, NC Superfund Section, Memos to file, February 16, 

1998, March 5, 1998, June 16, 1998. SUBJECT: Site and Adjacent Property Ownership. 

8 pages. 

22. Stanley, Jeanette, Environmental Chemist, NC Superfund Section, Memo to file, January 

30, 2013. 1 page. 

23. Alsmeyer, Eric, U.S. Army Corps of Engineers Regulatory Specialist, Notification of 

Jurisdictional Determination, Action SAW-2013-00141, January 24, 2013. 6 pages. 

24. Geologic Map of North Carolina and Explanatory Text, Bulletin Number 71, North 

Carolina Department of Conservation and Development, 1958; and Heath, R.D., "Basic 

Elements of Ground Water Hydrology with Reference to the Conditions in North 

Carolina", USGS Water Resources Investigation Report 80-44, 1980. pp. 26-29. 5 pages. 

25. Granville County, NC, Wilton Slopes Park, downloaded from website January 29, 2013. 

8 pages. 

26. Geraghty & Miller, Inc., Additional Groundwater Sampling Results, June 23, 1997. 7 

pages. 

27. Mallary, McKenzie, RPM, US EPA, Letter to William H. Doucette, Jr., Arcadis Geraghty 

& Miller, March 11, 1998. 2 pages. 

28. Stanley, Jeanette, Environmental Chemist, NC Superfund Section, Memo to file, April 7, 

1999 with attachments. SUBJECT: Nearest drinking water well. 13 pages. 

21 
29. US EPA Region 4 Inorganic and Organic Traffic Reports, Case 40167, May 19, 2010. 15 

pages. 

30. Stanley, Jeanette, Environmental Chemist, NC Superfund Section, Memos to file, March 

24 and 25, 1999. SUBJECT: Surface water pathway and flow characteristics. 7 pages. 

31. Stanley, Jeanette, Environmental Chemist, NC Superfund Section, Memos to file, March 

25, 1999. SUBJECT: Conversation with City Engineer. 1 page. 

32. Kirk-Othmer Encyclopedia of Chemical Technology, Third Edition, Volume 8, John 

Wiley & Sons, New York, 1979. Excerpt – 10 pages. 

33. Reference number reserved 

34. Reference number reserved 

35. Stanley, Jeanette, Environmental Chemist, NC Superfund Section, Memo to file, April 8, 

1998. SUBJECT: Fishery Location. 1 page. 

36. Reference number reserved 

37. Stanley, Jeanette, Environmental Chemist, NC Superfund Section, Memo to file, April 

21, 1999. SUBJECT: Conversations with Cristex environmental consultant and CVS 

Warehouse manager. 1 page. 

38. Reference number reserved 

39. Reference number reserved 

40. 40 CFR part 261. Online address: http://www.ecfr.gov/cgi-bin/textidx?c=ecfr&tpl=/ecfrbrowse/Title40/40cfr261_main_02.tpl. Page 1 included. 

41. NCAC Title 15A, Subchapter 2L, Section .0200. (15A NCAC 02L .0202). Online 

address: http://portal.ncdenr.org/web/wq/ps/csu/gwstandards. Page 1 included. 

42. Reference number reserved 

43. Stanley, Jeanette, Environmental Chemist, NC Superfund Section, Memo to file, 

February 6, 2003. SUBJECT: ESI sampling trip. 22 pages. 

44. Reference number reserved 

45. US Environmental Protection Agency, “Using Qualified Data to Document an Observed 

Release and Observed Contamination”, EPA 540-F-904-28, OSWER 9285.7-14FS, 

PB94-963311, November 1996. 18 pages. 

22 
46. Mid-Atlantic Associates, Environmental Assessment Report, Cristex Facility, October 

11, 2002. 999 pages. 

47. Stanley, Jeanette, memo to file, October 17, 2012. Wetland delineation 2012. 7 pages. 

48. Stanley, Jeanette, Environmental Chemist, NC Superfund Section, Memo to file, July 24, 

2000 and correspondence with Barry Singer, Esq. SUBJECT: Wetland Delineation and 

permission to enter property. 10 pages. 

49. Administrative Order on Consent for Registered Environmental Consultant-Directed 

Assessment and Remedial Action, Cristex Drum, April 10, 2002. 5 pages. 

50. Granville Economic Development Commission, Oxford Printing Brownfields Letter of 

Intent, August 21, 2000. 9 pages. 

51. ENSR Consulting and Engineering (NC), Inc., JFD Electronics/Channel Master Site 

Semiannual Groundwater Remediation Report, May 2002 - October 2002, January 2003. 

Cover page and four figures. 5 pages. 

52. Stanley, Jeanette, Environmental Chemist, NC Superfund Section, Memo to file, June 10, 

2003. SUBJECT: Wetland Frontage. 1 page. 

53. Stanley, Jeanette, Chemist, NC Superfund Section, Preliminary Assessment / Site 

Inspection Report, June 30, 1998. 408 pages. 

54 Stanley, Jeanette, Chemist, NC Superfund Section, Expanded Site Inspection, June 30, 

2003. 180 pages. 

55. Mid-Atlantic Associates, P.A., Phase I Remedial Investigation Work Plan, Cristex 

 Facility, October 2002. 153 pages. 

56. Stanley, Jeanette, Environmental Chemist, NC Superfund Section, Memo to file, June 

 17, 2003. SUBJECT: Groundwater Information. 3 pages 

57. Stanley, Jeanette, Environmental Chemist, NC Superfund Section, Site Reassessment 

Report, April 26, 2007. 11 pages. 

58. T N & Associates, Inc., draft Integrated Removal and Expanded Site Inspection Report, 

Revision 0, February 29, 2008. 527 pages. 

59. Cristex Drum Site, REC File materials, February 2002 – September 2002. 260 pages. 

60. Reference number reserved 

23 
61. US EPA, National Drinking Water Regulations, List of Contaminants and Maximum 

Contaminant Level (MCLs), http://water.epa.gov/drink/contaminants/index.cfm. 14 

pages. 

62. Stanley, Jeanette S., Chemist, NC Superfund Section, email correspondence with US 

EPA Denise Goddard and Nardina Turner, July 29, 2010. 4 pages. 

63. NC DENR Superfund Five-year Review Report, JFD Electronics/Channel Master Site, 

http://www.epa.gov/superfund/sites/fiveyear/f05-04013.pdf, September 2005. 97 pages. 

64. ENSR, Semi-Annual Groundwater Remediation Report, September 2007. Cover page 

and Figure 2-2 only. 2 pages. 

65. E2 Inc., Second Five-year Review Report for JFD Electronics/Channel Master, September 

2010, http://www.epa.gov/superfund/sites/fiveyear/f2010040003551.pdf. 254 pages. 

66. Stanley, Jeanette S., Chemist, NC Superfund, Field notes, December 3, 2012, Chains of 

Custody, December 4, 2012, and US EPA Region 4 Analytical Results, SUBJECT: Well 

Sampling near Cristex Drum. 119 pages. 

67. Stanley, Jeanette S., Chemist, NC Superfund, memo, October 17, 2012, SUBJECT: 

Planned drinking water wells samples near Cristex Drum. 1 page. 

68. Stanley, Jeanette S., Chemist, NC Superfund, memo, May 15, 2012, SUBJECT: Review 

of Updated Receptor Survey and AECOM, Updated Receptor Survey – JFD 

Electronics/Channel Master NPL Site, March 27, 2012. 13 pages. 

 

24 
2.0 SITE DESCRIPTION 

The Cristex Drum site (NC0 001 606 250), 500 W. Industry Drive, Oxford, Granville 

County, NC is located in a predominantly industrial area. The Cristex Drum property contains a 

150,000 sq. ft. structure and a 1⁄2-acre lagoon (partially breached; sediment remaining) on 22 

acres. The area has a mean annual precipitation of 44 - 46 inches and a mean annual lake 

evaporation of 41 inches. The 2-year, 24-hour rainfall is 3.36 inches (Ref. 6). The property is 

owned by Jomar Ventures LLC. Stutts Truck Tires currently operates a pre-cure tire retreading 

plant in the rear of the building, and Habitat for Humanity leases the front of the building for a 

Re-Store (Ref. 7). From 1966 to 1986, the Cristex Drum facility was a warp knit fabric mill 

engaged in knitting, dyeing, and finishing of nylon acetate Tricot (Refs. 5; 17, pp. 9, 39-42; 18, 

pp. 1, 16-18, 20). North of and adjacent to the Cristex Drum property is the JFD 

Electronics/Channel Master (NCD 122 263 825) NPL site (Refs. 63, pp. 4-5; 64; 65, pp. 14-15; 

Figs. 1, 8). 

There are no septic tanks or leaching fields on the property and the facility is provided by 

municipal water (Ref. 12, p. 8). A former AST area, a former oil/water separator area, and a 

ditch draining to the lagoon are surrounded by a fence (Figs. 3. 4). The partially drained 1⁄2-acre 

lagoon and a former drum burial area are outside the fenced area but there is no sign of 

recreation in this area (Refs. 15, p. 20; 17, p. 20; 37; 46, p. 16). 

Fourteen on-property monitoring wells were installed by Cristex’s consultant (Figs. 2, 3; 

Refs. 46, 59), and there are several monitoring wells on the facility property installed for the 

adjacent NPL site (Ref. 53). The nearest private residences served by drinking water wells are 

within 1⁄2 mile of the adjacent NPL site (Ref. 68). No nearby drinking water wells contain siterelated contaminants above NC ground water or US EPA drinking water standards (Refs. 20, 26, 

28, 41, 56, 61, 66, 67). While the facility is located in a predominantly industrial area, the closest 

residential property is the Oakridge Apartment complex approximately 1,350 feet to the east. 

Oakridge houses around 200 residents and is served by municipal water (Fig. 1; Refs. 3, 19, 37). 

In 1997, US EPA Emergency Response and Removal Branch (ERRB) removed 26 buried 

drums and 137 drum carcasses from the surface in an area outside the fence on Cristex property 

(Refs. 8, 9, 10, 11; Figs. 3, 4). During and after plant operations, there were several spills from 

two #6 fuel oil ASTs into the lagoon (Ref. 17, pp. 94. 95; 46, p. 3; 46; 55). Contaminants 

associated only with fuel oil are not used to produce this site score. In 1998, Cristex’s consultant 

removed the ASTs, soil underneath the ASTs, and the 500 - 750 gallon oil/water separator (Ref. 

13, pp. 86, 90, 94, 95; Ref. 46, pp. 6, 9-16). 

In 2001, two ditch areas were excavated by Cristex’s consultant. The ditch below the 

oil/water separator and transformer was excavated to a depth of 1 foot, and 290.88 tons of soil 

were removed (Fig. 3; Ref. 46, p. 11, 44, Drawing 6.1; Photos), characterized as non-hazardous 

waste, and placed in a RCRA Subtitle D Landfill (Ref. 40). Confirmation samples collected 

within this area of excavation did not indicate contaminants above benchmarks. The ditch along 

the eastern edge of the former southeast drum storage pad was excavated to 2' depth and 16 cubic 

yards of soil were removed (Ref. 46, p. 11, Drawing 6.1). The removed soil was characterized as 

25 
hazardous waste and shipped to a RCRA Subtitle C landfill. The area was backfilled. A vapor 

analyzer indicated that impacted soils remained in the area adjacent to the southeast drum storage 

pad (Ref. 46, p. 12). NC Superfund investigated this area during the 2010 ESI sample event 

(Ref. 13, p. 18). 

Remaining known and suspected areas of contaminated soil are around the former drum 

storage pad on the east side of the building, underneath the building, at the northeast corner of 

the building, and possibly in the former drum excavation area (Ref. 13, pp. 12, 13). Documented 

contaminated soil along the eastern side of the building is scored as Source 1. Lagoon sediment 

is also a known source (Ref. 13, p. 13); the lagoon is scored as Source 2. 

An extensive list of chemical products used by the facility has been provided, but their 

chemical composition is not known (Ref. 17, pp. 40-42; Ref. 18, p. 77). Common textile 

contaminants include copper, chromium, and zinc (Ref. 17, p. 5). Common color fastness tests 

conducted in dye facility laboratories used the common dry-cleaning solvent perchloroethylene 

(tetrachloroethene [PCE]) (Ref. 32, p. 337). Solvents were used to clean equipment and for 

dyeing purposes (Refs. 12, p. 11; 18, pp. 83, 88). Phenol, manganese and zinc were detected in 

lagoon water in 1984 (Ref. 17, p. 44). Dye carrier compounds such as phenols, chlorobenzene 

and other chlorinated aromatics, aromatic hydrocarbons, aromatic esters, and phthalates are 

anticipated contaminants (Ref. 32, pp. 151 - 153). 

Surface soil, subsurface soil, and lagoon sediment contaminants include chlorobenzene, 

1,4-dichlorobenzene, tetrachloroethene (PCE), trichloroethene (TCE), cis-1,2-dichloroethene, 

cadmium, cobalt, copper, chromium, lead, manganese, mercury, nickel, and zinc. Ground water 

contaminants include chlorobenzene, 1,2-dichlorobenzene, 1,4-dichlorobenzene, chloroform, 

tetrachloroethene (PCE), trichloroethene (TCE), cis-1,2 dichloroethene, trans-1,2-

dichloroethene, vinyl chloride, chromium, cadmium, manganese, and nickel (Ref. 13, p. 3). 

Except for one side gradient and two background monitoring wells, all wells on the 

Cristex Drum property contain chlorinated solvents. A monitor well near the former drum 

storage pad (MW-3) showed tetrachloroethene (PCE) at 7,100 μg/L; cis-1,2-dichloroethene at 

2,800 μg/L and trichloroethene (TCE) at 340 μg/L (Ref. 13, pp. 148-149, 244-249, 351, 353, 

366; Fig. 2). This contaminated ground water flows toward the contaminated ground water 

emanating from the JFD Channel Master NPL site. The nature and extent of ground water 

contamination at the Cristex Drum site has not been fully determined. Solvent-contaminated 

ground water from the Cristex Drum site may be contributing a significant fraction of the solvent 

being pumped and treated at the JFD Electronics/Channel Master site (Refs. 13; Fig. 8). 

There are seven pumping wells in operation as part of the ground water remedy at the 

JFD Electronics/Channel Master site (Fig. 8; Refs. 64; 65, p. 21). Four of the pumping wells are 

located north of the railroad tracks, three of which are near the former building. One of these 

and the three pumping wells southeast of the railroad tracks are within 100 feet of the stream 

draining the site (Refs. 26; 27; 64; 65, p. 23). Of these four pumping wells near the stream, one 

of these (PW-4) is on the same side of the stream as the Cristex Drum property (Ref. 64, p. 3). 

Based on the relatively gentle slopes across the stream and its modest base flow, it is reasonable 

to expect that these pumping wells could draw ground water from the subsurface of the Cristex 

26 
property and into the treatment system at the JFD Electronics/Channel Master site, even under 

conditions of relatively moderate pumping rates. That this is likely to be happening is indicated 

by ground water sampling results from both sites illustrated in Figure 8. 

 

There is a wetland with greater than 0.1 mile of wetland frontage on the Cristex Drum 

property, just below the lagoon (Refs. 23, 47, 48). In 1982, a release to the surface water 

pathway occurred (Refs. 17, p. 3; 53, p. 9). In 1998, the lagoon dam was partially breached, 

thereby releasing about 400,000 gallons of lagoon water to the surface water pathway (Ref. 46, 

p. 16). Chemical analysis confirms an observed release of chromium, lead, manganese, nickel, 

and zinc to the surface water pathway below >0.1 mile of wetland frontage (Ref. 15). There is a 

fishery within the 15-mile surface water pathway (Refs. 22, 25), but no drinking water intake 

(Ref. 31). 

The Preliminary Assessment/Site Inspection (PA/SI) report was completed in June 1999 

(Refs. 19, 20, 53). Based on findings from the PA/SI, wetland delineation was conducted in July 

2000 (Ref. 48). The August 2000 Expanded Site Inspection (ESI) sample event focused on the 

surface water pathway. The June 2003 ESI report recommended “No Further Remedial Action 

Planned” (NFRAP) under CERCLA (Refs. 43, 54). 

Cristex Corporation signed an Administrative Order on Consent (AOC) with the NC 

Inactive Hazardous Sites Branch (IHSB) in April 2002 and proceeded with remediation under 

the Registered Environmental Consultant (REC) program (Ref. 49). Cristex Corporation 

withdrew from the AOC in 2004 and remediation activity ceased (Ref. 59). In 2007, NC 

Superfund conducted a Site Reassessment based on EPA’s revised (in 2004) contaminant waste 

characteristics values as reported in the Superfund Chemical Data Matrix (SCDM). Based on 

changes to contaminant values as reported in SCDM, NC Superfund recommended the site be reevaluated under CERCLA (Ref. 57). A summary of Significant Events / Investigation is 

provided in the below table. 

 

 

27 
Table 1. Summary of Significant Events / Investigations 

Agency Event Event 

Date Activity Summary Refs. 

City of 

Oxford and 

NC 

Discharge and 

Response to 

complaint 

1982 Discharge from facility to surface water 

pathway 

17, p.3 

EPA Emergency 

Response 

1996 26 Buried Drums and 137 drum carcasses 

removed, soil excavated. 

8; 9; 10; 

11 

NC 

Superfund 

PA/SI 1998 Surface and subsurface soil; ground water (from 

temporary wells); lagoon water and sediment; 

and surface water pathway samples collected. 

Further action under CERCLA recommended. 

19; 20; 

53 

Cristex Lagoon Breach 1998 Lagoon dam breached and 1⁄2 of its water 

discharged to surface water pathway. 

37; 46, 

p. 16 

US Army 

Corps of 

Engineers 

(COE) 

Wetland 

delineation 

2000 Wetland delineation conducted, >0.1 mile of 

wetland frontage documented. 

48 

NC 

Superfund 

Expanded Site 

Inspection 

2000 Focused on surface water pathway, lagoon, 

surface water, and sediment samples collected. 

No Further Action under CERCLA 

recommended. 

43; 54 

Cristex Entered REC 

Program 

2002 Cristex entered the NC Registered 

Environmental Consultant (REC) Program. 

49 

Cristex Environmental 

Assessment 

2000-

2002 

12 monitoring wells installed and sampled 

(MW-1, 2, 3, 3i, 4, 5, 6, 6i, 7, 8, 9, 10). Soil 

removed from ditch and alongside drum storage 

pad. Some soil was disposed as hazardous 

waste. Remaining lagoon water discharged to 

POTW. Phase I Remedial Investigation Work 

Plan submitted. 

46, 55 

Cristex Partial 

Remedial 

Investigation 

2004 Cristex withdrew from REC program. 

Submitted data included subslab soil and vapor 

sample results and figures. Two additional 

monitoring wells had been installed but not 

sampled (MW-11 and 6D). Soil samples had 

been collected but no figure was generated. 

59 

NC 

Superfund 

Site 

Reassessment 

2007 Based on updated SCDM, further action 

recommended under CERCLA. 

57 

EPA draft iESI 2007 Drought prevented collection of most ground 

water samples. Soil and sediment samples 

collected. 

58, pp. 

7, 20, 21 

NC 

Superfund 

iESI 2010 Subsurface soil, lagoon, ground water, surface 

water, and sediment samples collected. 

13, 29 

US Army 

COE 

Wetland 

delineation 

2012 Wetland delineation conducted, >0.1 mile of 

wetland frontage documented. 

23, 47 

28 
SD-Characterization and Containment 

 Source No.: 1 (Contaminated soil) 

 

SOURCE DESCRIPTION

2.1 Source Characterization – Source 1

Number of the Source: 1 

Name and description of the source: Contaminated soil 

HRS Source Type: Contaminated Soil 

 Source 1 is contaminated soil along the eastern side of the building. Source 1 is defined 

by surface soil samples CR-SS-03 and CR-SS-06 collected in 2007 and sub surface soil samples 

CR-01-SB and CR-03-SB collected in 2010 (Figs. 2, 6, 7). Overland flow from this area, 

including the drum storage pad, the former oil/water separator, and the northeast rear of the 

building, enters the ditch that runs along the eastern perimeter of the building and empties into 

the lagoon (Ref. 17, p. 47; Ref. 55, p. 17; Fig. 2). In 2001, contaminated ditch soil was removed 

by a Cristex consultant (Ref. 46, pp. 11 - 14; Fig. 3). Unrestricted overland flow from this area 

of contaminated soil enters the lagoon and flows to the surface water pathway. This 

contaminated soil overlies the single aquifer below the site (Ref. 1, para. 2.2.1; Ref. 13, p. 20; 

Ref. 24). 

 

 In 2001, Cristex’s consultant removed 16 cubic yards of soil from the eastern side of the 

drum storage pad (Fig. 3, Excavation 3). This soil was characterized as hazardous waste and 

shipped to a RCRA Subtitle C landfill (Ref. 46, pp. 11-13, 31, 619-620; Fig. 3). Cristex’s 

consultant used a vapor analyzer in the area of remaining soil, and the analyzer indicated that 

contaminated soil remained below the excavation (Ref. 46, p. 12). 

 Surface soil samples collected in Source 1 for EPA during the 2007 investigation (Ref. 

58) and subsurface soil samples collected by NC Superfund Section during the 2010 

investigation (Refs. 13, 29) will be used to document contaminants in Source 1. These surface 

and subsurface soil samples do not delineate the size of the source, they only confirm that the 

source size is >0. The final report for a 2003 sample event was not generated by Cristex’s 

consultant; however, data from subslab soil and vapor samples indicates that the area of 

contaminated soil is greater than that encompassed by the three surface soil (including one 

background) and five subsurface soil (including two backgrounds) samples used to document 

Source 1 (Ref. 13, pp. 15, 61; Fig. 5; Ref. 59, pp. 68-120). 

 Records show that soil was sampled in 1996, 1998, 2000, 2002, 2003, 2007, and 2010, as 

summarized in the 2012 iESI report (Ref. 13, pp. 12-20, 57-67); however, only 2007 and 2010 

data will be used to document Source 1. The most current data are from 2007 and 2010 and 

comprise the only Contract Laboratory Program (CLP) soil data for the site. 

 

29 
30 

SD-Hazardous Substances 

 Source No.: 1 (Contaminated soil) 

Location of the source, with reference to a map of the site: Along eastern edge of the former 

drum storage pad and near the northeastern corner of the building (Fig. 2; Fig. 6, sample 

locations CR-SS-03 and CR-SS-06; Fig. 7, sample locations CR01SB and CR03SB). 

Background locations are shown on Figure 6 (CR-SS-01) and Figure 2 (CR05SB and CR04SB). 

Containment

Release via overland migration and/or flood — 

Contaminated soil is not covered by a maintained engineered cover and is outside any 

functioning and maintained run-on control system and runoff management system (Ref. 

1, Table 4-2; Ref. 22). 

 Containment Factor for Surface Water Migration Pathway: 10

2.2.2 Hazardous Substances Associated with Source 1 

The following data tables will provide documentation that Source 1 contains the following 

contaminants: 

Chromium 

Cobalt 

Copper 

Lead 

Manganese 

Mercury 

Nickel 

Zinc 

Cis-1,2-Dichloroethene 

Tetrachloroethene 

Trichloroethene 

Table 2. Background Soil Samples 

Samples Date; 

Time References Description 

Surface Soil 

CR-SS-01 

(bkg) 

09/24/07; 

10:49 

Ref. 58, pp. 18, 38, 41, 

43, 57, 104, 220, 267, 

404, 512, 514, 515; 

Fig. 6 

Light brown sand, fine sandy clay, dry. Medium 

light brown sandy clay. Sample collected 0 – 4’ 

and designated for MS/MSD location. Depth of 

VOA grab not indicated in notes. 

Subsurface Soil 

CR-04-SB 

(bkg) 

5/19/10; 

11:45 

Ref. 13, p. 97, 103, 

109, 351-352, 359-360; 

Fig. 2 

Bkg soil near MW-4 

MS/MSD location. Collected at 30 – 36” (2.5 - 

3'), light brown tight clay 

CR-05-SB 

(bkg) 

5/19/10; 

11:15 

Ref. 13, p. 97, 103, 

109, 351-352, 371; Fig. 

2 

Bkg soil in middle of mowed field. 1’ – 3’, 

orange clay with little sand, material similar to 

CR-03-SB. Collected 2.5’ – 3.5’

 MS/MSD = Matrix Spike / Matrix Spike Duplicate; bkg = background 
SD-Hazardous Substances 

 Source No.: 1 (Contaminated soil) 

Table 3. Background Surface Soil Results 

CR-SS-01 (Bkg) CR-SS-01 MRL 

Organics μg/kg 

Ref. 58, pp. 101-106, 115, 116 

PCE 4.8 U 4.8 

Inorganics mg/kg 

Ref. 58, pp. 400-406, 416 

Chromium 20 1.2 

Cobalt 0.79 J 6.0 

Copper 9.0 3.0 

Lead 5.8 1.2 

Manganese 35 1.8 

Mercury 0.076 UJ (b) 0.12 

Nickel 1.7 J 4.8 

Zinc 6.5 UJ [9.75] (a) 7.2 

(a) = Because matrix spike recovery for zinc was 67%, all zinc results were J-flagged (Ref. 58, p. 402). There was 

baseline instability in either the calibration or preparation blanks and the result is greater than detection limit but less 

than reporting limit (Ref. 58, p. 406). While not required by the HRS or fact sheet (Refs. 1, 45), this qualified 

background quantitation limit is adjusted to demonstrate the relative increase in contamination over background 

levels (Ref. 45, p. 18). 

(b) For mercury, the result is greater than Method Detection Limit (MDL) but less than Method Reporting Limit 

(MRL). Concentration was lower than the lowest standard on the calibration curve (Ref. 58, p. 406). 

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

lowest demonstrated level of acceptable quantitation (Ref. 58, pp. 106, 406). 

bkg = background 

 

31 
SD-Hazardous Substances 

 Source No.: 1 (Contaminated soil) 

Table 4. Background Sub-Surface Soil Results

CR-04-SB (Bkg) 04-SB MRL CR-05-SB (Bkg) 05-SB MRL 

Organics μg/kg 

Ref. 13, pp. 17, 18, 67, 97, 109, 111 

- 116, 129, 130, 244-249, 256, 351-

352, 359-360 

Ref. 13, pp. 17, 18, 67, 97, 109, 111-

116, 131, 132, 244-249, 257, 351-352, 

371

PCE U 6.3 U 6.5

cis-1,2-DCE U 6.3 U 6.5

TCE U 6.3 U 6.5

Inorganics mg/kg 

Chromium 62 1.3 55 1.3

Manganese 22 2.0 38 2.0

Zinc 23 8.0 14 7.9

U = the analyte was not detected at or above the reporting limit 

bkg = background 

Table 5. Source 1 Soil Samples

Samples Date; Time Description 

Surface Soil 

CR-SS-03 

09/27/07; 08:40; Ref. 58, pp. 18, 38, 

41, 43, 57, 104, 220, 267, 404, 505, 

511; Fig. 6 

Collected from 0-2 ft core. dark grey 

sandy silt / yellowish brown silty clay. 

CR-SS-06 09/25/07; 13:12; Ref. 58, pp. 57, 

104, 220, 267, 404, 517, 518; Fig. 6 0-6”; gravel, some dark brown clay 

Subsurface Soil 

CR-01-SB 05/19/10; 10:30; Ref. 13, p. 97, 103, 

109, 351-352, 359; Fig. 7 

Near drum storage pad where consultant 

recommended further study. Collected 

at 34”, very tight light brown clay. 

CR-03-SB 5/19/10; 10:45; Ref. 13, p. 97, 103, 

109, 351-352, 371; Fig. 7 

Off edge of drum storage pad where 

consultant recommended further study. 

Collected at 3’, mottled orange clay. 

CR-103-SB 

duplicate 

5/19/10; 10:50; Ref. 13, p. 98, 104, 

110, 351-352, 371; Fig. 7 Duplicate of CR-03-SB 

 

32 
SD-Hazardous Substances 

 Source No.: 1 (Contaminated soil) 

Table 6. Source 1 Surface Soil Results

CR-SS-03 CR-SS-03 MRL CR-SS-06 CR-SS-06 MRL

Organics μg/kg 

Ref. 58, pp. 101-106, 172 Ref. 58, pp. 101-106, 154

PCE 20 4.6 U 5.6

Inorganics mg/kg 

(Ref. 58, pp. 400-406, 472) (Ref. 58, pp. 400-406, 454) 

Chromium 51 1.1 350 1.3

Cobalt 20 5.7 8.9 6.7

Copper 18 2.9 48 J (b) 3.3

Lead 65 1.1 20 J (b) [13.8] 1.3

Manganese 260 1.7 410 J (#) [330] 2.0

Mercury 0.074 UJ (a) 0.11 0.14 0.14

Nickel 6.5 4.6 11 J (c) [8] 5.3

Zinc 81 6.9 160 J (b) 8.0

(a) For mercury, the result is greater than MDL but less than Method Reporting Limit. Concentration was lower 

than the lowest standard on the calibration curve (Ref. 58, p. 406). 

(b) For copper and zinc, the matrix spike recovery was less than method control limits, indicating a low bias. 

(Refs. 45, p. 8; 58, p. 406). 

(c) For lead, the matrix spike recovery was less than method control limits and the matrix precision was outside the 

method control limits (Ref. 58, pp. 406, 454). For nickel, the PE sample recovery was outside warning limits. This 

uncertain bias. 

(#) For manganese, the matrix spike recovery was greater than method control limits. (Ref. 58, pp. 402, 454 

 [ ] provides the adjusted value for the estimated (J’d) value as adjusted for bias (Ref. 45, pp. 8-11, 18). While not 

required by the HRS or fact sheet (Refs. 1, 45), this qualified concentration is adjusted to demonstrate the relative 

increase in contaminant levels over background levels (Ref. 45, p. 18). 

The method reporting limit (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. 58, pp. 106, 406). 

BOLD = Greater than or equal to 3 times background when reported above MRL in background, or greater than 

background MRL if background is non-detect. 

 

33 
SD-Hazardous Substances 

 Source No.: 1 (Contaminated soil) 

Table 7. Source 1 Subsurface Soil Results 

CR-01-SB CR-01-

SB MRL

CR-03-

SB 

CR-03-

SB MRL 

CR-103-

SB 

CR-103-SB 

MRL 

Organics μg/kg 

Ref. 13, pp. 17, 18, 

67, 97, 109, 111-116, 

121, 122, 244-249, 

252, 351-352, 359 

Ref. 13, pp. 17, 18, 

67, 97, 109, 111-116, 

125, 126, 244-249, 

254, 351-352, 371 

Ref. 13, pp. 17, 18, 67, 

98, 110, 111-116, 127, 

128, 244-249, 255, 

351-352, 371 

PCE 180,000 21,000 100,000 21,000 69,000 19,000

cis-1,2-DCE 5.3 J (a) 5.5 60 6.6 66 6.1

TCE 4.3 J (a) 5.5 82 6.6 78 6.1

Inorganics mg/kg 

Chromium 260 1.3 17 1.3 18 1.3

Manganese 260 1.9 69 1.9 71 1.9

Zinc 130 7.7 29 7.6 24 7.7

J = estimated value 

(a) = concentration reported is less than the lowest standard on calibration curve, and is lower than the method 

reporting limit (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. 13, pp. 116, 249). 

BOLD = Greater than or equal to 3 times background when detected in background, or greater than background 

quantitation limit (aka MRL) if background is non-detect. 

 

34 
 SD-Hazardous Substances 

 Source No.: 1 (Contaminated soil) 

Surface Soil Background and Source Hazardous Substance and Concentration Summary

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

treated as non-detect and the MRL is shown alongside U (Ref. 1, Table 2-3; Ref. 45, p. 5). 

 Highest Source Background 

 Result Result or U (MRL) 

 

Tetrachloroethene 20 μg/kg U (4.8) μg/kg 

Chromium 350 mg/kg 20 mg/kg 

Cobalt 20 mg/kg U (6.0) mg/kg 

Copper 48 J mg/kg 9.0 mg/kg 

Lead 65 mg/kg 5.8 mg/kg 

Manganese 410 J [330] mg/kg 35 mg/kg 

Mercury 0.14 mg /kg U (0.12) mg/kg 

Nickel 11 J [8] mg/kg U (4.8) mg/kg 

Zinc 160 J mg/kg U (7.2) mg/kg 

Subsurface Soil Background and Source Hazardous Substance and Concentration Summary

 Highest Source Higher Background 

 Result Result or MRL

 

Tetrachloroethene 180,000 μg/kg U (6.5) μg/kg 

 Cis-1,2-Dichloroethene 66 μg/kg U (6.5) μg/kg 

 Trichloroethene 82 μg/kg U (6.5) μg/kg 

 Chromium 260 mg/kg 62 mg/kg 

 Manganese 260 mg/kg 38 mg/kg 

 Zinc 130 mg/kg 23mg/kg

35 
 SD-Hazardous Waste Quantity 

 Source No.: 1 (Contaminated Soil) 

2.1.3 Hazardous Waste Quantity 

2.1.3.1 Hazardous Constituent Quantity — Tier A (Ref. 1, section 2.4.2.1.1) 

Not Scored - NS 

Sufficient evidence does not exist to evaluate Hazardous Constituent Quantity. 

While there is a list of products used on the site (Ref. 17. pp. 40-43), the quantity 

used and the chemical composition of products is unknown and the quantity of 

any waste released to or disposed of on the source is unknown. Also, 163 buried / 

empty drums were removed from the site (Refs. 10; 53, p. 9) and the 500-750 

gallon oil water separator was removed in 1998 (Refs. 13, pp. 86, 90, 94, 95; 46, 

p. 6); however, this is insufficient information on which to base an estimate of the 

total mass of CERCLA hazardous substances in the source with reasonable 

confidence. 

2.1.3.2 Hazardous Wastestream Quantity — Tier B (Ref. 1, section 2.4.2.1.2) 

Not Scored - NS 

Sufficient evidence does not exist to evaluate Hazardous Wastestream Quantity. 

While it is known that drums were received by the facility and stored / used on the 

eastern side of the facility, there is no estimate of the number of drums received or 

a breakdown of their contents and the quantity of any wastestream released to or 

disposed of on the source is unknown. There is insufficient information on which 

to base and estimate of the mass of waste streams disposed / spilled on the facility 

property with reasonable confidence (Ref. 17, pp. 23, 44). 

2.1.3.3 Volume — Tier C (Ref. 1, section 2.4.2.1.3) 

 Score = 0 

 Sufficient evidence does not exist to evaluate volume of the source. 

2.1.3.4 Area - Tier D (Ref. 1, section 2.4.2.1.4) 

Source area is unknown but greater than 0. Source 1 is contaminated soil along 

the eastern side of the building. Source 1 is defined by surface soil samples CRSS-03 and CR-SS-06 collected in 2007 and sub surface soil samples CR-01-SB 

and CR-03-SB collected in 2010 (Figs. 2, 6, 7) 

 Area assigned value not determined, >0 (Ref. 1, Table 2-5) 

2.1.3.5 Source Hazardous Waste Quantity Value = >0 

36 
SD -Characterization and Containment 

 Source No.: 2 (Lagoon) 

2.2 Source Characterization – Source 2

Number of the Source: 2 

Name and description of the source: Lagoon 

HRS Source Type: Surface impoundment 

 Source 2 is the partially breached, unlined, 1⁄2-acre lagoon which lies to the northeast of 

the building (Figs. 1, 2, 3, 6, 10, 12, 13; Refs. 15, p. 19; 17, p. 20; 37). The lagoon had an 

original capacity of 800,000 gallons (Ref. 17, pp. 20, 46). From 1966 to plant closure, storm 

water, boiler blow down, and wastewaters from the various dyeing and finishing processes 

flowed to the unlined pretreatment lagoon (Refs. 12, p. 12; 13, p. 10; 14; 17, pp. 9, 10, 20, 46, 

47). The lagoon discharged to the City of Oxford POTW. Sanitary waste entered the city sewer 

line, bypassing the lagoon (Refs. 12, pp. 11, 12; 13, p. 375; 14; 17, p. 47). During operation and 

after plant closure, there were several oil spills from the ASTs into the lagoon (Ref. 13, pp. 91-

93; Ref. 17, pp. 72, 73; Ref. 46, p. 7). 

In 1982, facility wastewater was observed discharging directly to the surface water 

pathway, bypassing this lagoon (Ref. 17, p. 3; Ref. 53, p. 9). In 1998, the lagoon dam was 

breached by Cristex’s consultant and approximately 1⁄2 of the lagoon volume (400,000 gallons) 

was allowed to enter the surface water pathway. Reportedly, an NC DWQ official granted 

permission to breach the dam; however, no documentation of this conversation has been located 

(Refs. 15, p. 19; 37; 46, pp. 16, 19). In 2001, NC DENR allowed discharge of lagoon water to 

the City of Oxford’s POTW. NC DENR would not allow discharge to the surface water pathway 

in 2001 (Ref. 46, p. 19). Following this water disposal, the lagoon berms were graded to reduce 

overland flow to the lagoon (Ref. 46, p. 19). Since the lagoon dam breach in 1998, outflow from 

the lagoon has entered the surface water pathway and wetland area (Ref. 46, p. 16; Ref. 47. p. 2; 

Figs. 12, 13). There has never been any remediation of lagoon sludge / sediment. There is no 

regular maintenance of the breached lagoon (Ref. 22). 

 The highest levels of lagoon sediment contaminants reported during any sample event 

were from 1999 samples collected by Cristex’s consultant. These highest results were: 

chlorobenzene (160 mg/kg), xylenes (443 mg/kg), 1,2-dichlorobenzene (33 mg/kg), antimony 

(1,670 mg/kg), chromium (133 mg/kg), copper (362 mg/kg), lead (221 mg/kg), nickel (67.5 

mg/kg), mercury (1.28 mg/kg), and zinc (1,490 mg/kg) (Ref. 13, p. 68; Ref. 46, pp. 51, 52, 250-

253, 262-273). 

 Records show that lagoon water was sampled in 1992, 1998, 1999, 2000, 2007, and 2010 

and lagoon sediment was sampled in 1991, 1998, 1999, 2000, 2007, and 2010 as summarized in 

the 2012 iESI report (Ref. 13, pp. 12-20, 68-69). Only two sample events were used to 

document Source 2 (Lagoon) contaminants for this HRS Documentation record: samples 

collected for EPA in 2007 and samples collected by NC Superfund in 2010. Samples collected 

for these two events were analyzed under the Contract Laboratory Program (CLP) and the data 

best characterize Source 2. 

37 
SD-Hazardous Substances 

 Source No.: 2 (Lagoon) 

2.2.1 Hazardous Substances Associated with Source 2 

Table 8. Lagoon Source and Background Sediment Samples - 2007 

Source 

Samples Date; Time Description 

CR-SD-01 9/27/07; 0935 (Ref. 58, pp. 

41, 511, 520; Figs. 1, 11) 

GPS location was recorded (36.291472; -

78.602361) but consultant did not generate a 

map for sample location CR-SD-01. 

Coordinates were plotted on a map for this 

documentation record (Ref. 16; Fig. 11). 

Using the National Wetland Inventory Map 

and HRS Guidance, it was determined that 

the sample CR-SD-01 location was in a very 

similar environmental setting to that of CRWS-02a and CR-SD-10 (Ref. 16). 

CR-WS-02a* 9/26/07 09:30 (Ref. 58, pp. 

42, 513, 520; Fig. 6) 

Lagoon sediment in the center was described 

as hard-packed silt and lagoon was only 6” – 

8” deep in 2007 during the drought. Original 

samples collected using kayak in center of 

lagoon; however, some sample containers 

collected from the center of the lagoon were 

lost in shipment (Ref. 58, pp. 501, 502, 513). 

Replacement sample WS-02a was collected at 

0930 on 9/26/07 along the shoreline and 

analyzed for VOAs, CN & Total Metals only 

(Ref. 58, p. 520). 

CR-SD-10 

9/24/07; 15:40 (Ref. 58, 

pp. 42, 499, 512, 516; Fig. 

6) 

Described as lagoon inlet, GPS location was 

recorded and a map was generated for 

location (Ref. 58, pp. 42, 499, 516). 

*Note that one of the coolers from the 9/24/07 shipment did not arrive at the lab; therefore, sample CR-WS-02 had 

to be recollected (Ref. 58, pp. 501, 502). Sample CR-WS-02a is the replacement sample for the VOA, metal and 

CN portions of sample CR-WS-02. 

 

38 
SD-Hazardous Substances 

 Source No.: 2 (Lagoon) 

Table 9. Lagoon Sediment Background Sample Results - 2007 

CR-SD-01 

(Bkg in offsite pond) 

CR-SD-01 

MRL 

CR-SS-01 

(Bkg)** 

CR-SS01 MRL 

Ref. 58, 101-106, 163, 164, 

400-406, 464

Ref. 58, pp. 101-106, 115, 

116, 400-406, 416

units ug/kg 

Chlorobenzene U 5.1 U 4.8

1,4-

Dichlorobenzene U 5.1 U 4.8

units mg/kg 

Cadmium U 0.62 U 0.60

Chromium 14 1.2 20 1.2

Copper U 3.1 9.0 3.0

Lead 3.7 J (b) [5.3] 1.2 5.8 1.2

Manganese 50 1.9 35 1.8

Mercury U 0.12 0.076 UJ (a) 0.12

Nickel U 5.0 1.7 J (a) 4.8

Zinc 40 7.5 6.5 UJ [9.75] (c) 7.2

**Note that while this background soil sample is not a sediment sample, it does show the level of background soil 

chemical constituents that could potentially enter the lagoon via overland flow. 

“U” indicates non-detect. J = estimated value 

(a) = result is greater than method detection limit (MDL) but less than method reporting limit (MRL). For mercury, 

the concentration was lower than the lowest standard on the calibration curve (Ref. 58, p. 406). For nickel, the PE 

sample recovery was outside warning limits (Ref. 58, p. 406) 

(b) = the matrix spike recovery was less than method control limits, result is low bias (Ref. 58, p. 406). 

(c) Because matrix spike recovery for zinc was 67%, all zinc results were J-flagged (Ref. 58, p. 402). There was 

baseline instability in either the calibration or preparation blanks and the result is greater than detection limit but less 

than reporting limit (Ref. 58, p. 406). While not required by the HRS or fact sheet (Refs. 1; 45), this qualified 

concentration is adjusted to demonstrate the relative increase in contaminant levels over background levels (Ref. 45, 

p. 18). 

[ ] provides the adjusted value for the estimated (J’d) value as adjusted for bias (Ref. 45). 

bkg = background 

39 
 SD-Hazardous Substances 

 Source No.: 2 (Lagoon) 

Table 10. Lagoon Sediment Source Sample Results - 2007

WS-02a WS-02a 

MRL CR-SD-10 CR-SD-10 MRL 

Ref. 58, 101-106, 135, 136, 

400-406, 436 

Ref. 58, 101-106, 111, 112, 

400-406, 412 

units ug/kg 

Chlorobenzene 1,700 320 U 70

1,4-

Dichlorobenzene 410 320 U 70

units mg/kg 

Cadmium 2.5 0.8 U 4.1

Chromium 83 1.6 12 8.3

Copper 130 J (b) 4.0 35 J (b) 21

Lead 51 J (c) [35.4] 1.6 240 J (c) 

[166] 8.3

Manganese 180 J (#) 

[145] 2.4 250 J (#) [201] 12

Mercury 0.25 0.16 U 0.79

Nickel 22 J (#) [16] 6.4 U 33

Zinc 1000 (b) 9.6 390 J (b) 50

J = estimated value; U = Not detected 

 (a) = result is greater than detection limit but less than reporting limit. Results are treated as non-quantifiable for 

HRS purposes (Ref. 45, p. 4) 

(b) = the matrix spike recovery was less than method control limits, result is low bias (Ref. 58, p. 406). 

(c) = uncertain bias, bkg requires upward adjustment and release/source sample requires downward adjustment by 

factor (Ref. 45, pp. 8, 11-18). Number shown in brackets is adjusted value. 

(#) = High bias; PE sample recovery outside of warning limits (Ref. 58, p. 406).. 

 [ ] provides the adjusted value for the estimated (J’d) value as adjusted for bias (Ref. 45, pp. 8, 11-18). While not 

required by the HRS or fact sheet (Refs. 1; 45), this qualified concentration is adjusted to demonstrate the relative 

increase in contaminant levels over background levels (Ref. 45, p. 18). 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. 58, pp. 106, 406). 

BOLD = Greater than or equal to 3 times background when detected in background, or greater than background 

quantitation limit (aka MRL) if background is non-detect (Refs. 1, Table 2-3; 45). 

 

40 
SD-Hazardous Substances 

 Source No.: 2 (Lagoon) 

Table 11. Lagoon Sediment Source and Background Samples - 2010 

Source 

Samples Date; Time Description 

CR-31-SD 

5/19/10; 1545 

(Ref. 13, pp. 18, 19, 74, 99, 

275, 354, 363; Figs. 12, 13)

Lagoon Sediment. Reducing (stinky) black 

silt with wetland vegetation along shoreline. 

CR-37-SD 

05/19/10; 1205 

(Ref. 13, pp. 29, 74, 76, 

101, 288, 354, 372; Ref. 

16, pp. 1, 4; Fig. 1) 

Background in nearby pond. MS/MSD 

location. 

Removed heavy layer of organic material 

from top 4” (leaves, etc.) and collected 4” – 

12” depth, sandy clay (mostly clay, some tan, 

some gray).

Table 12. Lagoon Sediment Source and Background Sample Results - 2010

Antimony Chromium Lead Mercury Zinc 

units mg/kg 

CR-31-SD Ref. 13, pp. 244-249, 275, 354, 363

CR-31-SD 40 71 28 0.63 190 

CR-31-SD 

MRL 16 2.6 2.6 0.26 16 

CR-37-SD Ref. 13, pp. 244-249, 288, 354, 372 

CR-37-SD U 11 5.4 U 8.8 

CR-37-SD 

MRL 8.8 1.5 1.5 0.15 8.8 

U = not detected above the Method Reporting Limit (MRL). J’d levels below MRL are treated as non-detect (Ref. 

1, Table 2-3; Ref. 45, p. 5). 

BOLD = Greater than or equal to 3 times background when detected in background, or greater than background 

quantitation limit (aka MRL) if background is non-detect (Ref. 1, Table 2-3; Ref. 45). 

 Source Result Higher of Background 

 Result or MRL

 Chlorobenzene 1,700 ug/kg U (4.8) ug/kg 

 1,4-Dichlorobenzene 410 ug/kg U (4.8) ug/kg 

 Antimony 40 mg/kg U (8.8) mg/kg 

 Cadmium 2.5 mg/kg U (0.6) mg/kg 

 Chromium 83 mg/kg 20 mg/kg 

 Copper 130 J mg/kg 9.0 mg/kg 

 Lead 240 J [166] mg/kg 5.1 mg/kg 

 Manganese 250 J [201] mg/kg 35 mg/kg 

 Mercury 0.63 mg/kg U (0.12) mg/kg 

 Nickel 22 J [16] mg/kg U (4.8) 

 Zinc 1,000 mg/kg U (7.2 

41 
 SD-Hazardous Waste Quantity 

 Source No.: 2 (Lagoon) 

2.2.2 Hazardous Waste Quantity 

2.2.2.1 Hazardous Constituent Quantity — 

 

Not Scored - NS 

Sufficient evidence does not exist to evaluate Hazardous Constituent Quantity. 

While there is a list of products used on the site (Ref. 17. pp. 40-43), the quantity 

used and wastestream disposed in Source 2 and the chemical composition of 

products is unknown. There is insufficient information on which to base an 

estimate of the total mass of CERCLA hazardous substances in the source with 

reasonable confidence. 

2.2.2.2 Hazardous Wastestream Quantity — 

Not Scored - NS 

Sufficient evidence does not exist to evaluate Hazardous Wastestream Quantity. 

There is insufficient information on which to base an estimate of the mass of 

wastestreams disposed / spilled on the facility property with reasonable 

confidence (Ref. 17, pp. 23, 44). 

2.2.2.3 Volume — 

 Score = 0 

 Sufficient evidence does not exist to evaluate volume of the source. 

The lagoon was breached and level of wastewater is unknown (Ref. 46, p. 16) 

 

2.2.2.4 Area

 Surface impoundment, 1⁄2- acre (Refs.17, p. 20; 46, p. 16) = 

 1/2 acre = 43,560 sq ft/acre / 2 = 21,780 sq. ft. 

 A/13 = 1,675 (Ref. 1, Table 2-5) 

 

2.2.2.5 Source Hazardous Waste Quantity Value = 1,675 

 

42 
 SD-Summary 

SITE SUMMARY OF SOURCE DESCRIPTIONS

 Containment Containment 

Source Hazardous Waste Quantity Ground Surface Air 

No. Value Water Water Gas Particulate

1 >0 NS 10 NS NS 

2 1,675 NS 10 NS NS 

Sum of Source Hazardous Waste Quantity Values = 1,675 

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

 

43 
SWOF — Surface Water Overland Flow/Flood Migration Pathway

4.0 SURFACE WATER MIGRATION PATHWAY 

4.1 OVERLAND/FLOOD MIGRATION COMPONENT 

4.1.1 DEFINITION OF HAZARDOUS SUBSTANCE MIGRATION PATH FOR 

OVERLAND/FLOOD COMPONENT 

 From 1966 to plant closure, storm water, boiler blow down, and wastewaters from the 

various dyeing and finishing processes flowed to the unlined pretreatment lagoon (Source 2) 

(Refs. 13, p. 4; 14, p. 1; 17, pp. 9-10, 18, 20-21, 47). Overland flow from the oil/water 

separator, the drum storage pad area, and soil along the eastern side of the building emptied into 

the ditch on the eastern side of the building which flowed north and emptied into the lagoon 

(Source 2) (Fig. 2; Refs. 14, p. 1; 17, p. 47). Overland flow from Source 1 enters the abovedescribed ditch (Refs. 13, p. 10; 14, p. 1; 17, pp. 9-10, 18, 20-21, 47); therefore, the probable 

point of entry (PPE) to the surface water pathway is the same for both sources. The lagoon 

discharged to the City of Oxford POTW and was never permitted to discharge to the surface 

water pathway (Refs. 12, pp. 7, 9; 14, p. 1; 17, pp. 18-21; 46, p. 19). Any overtopping of this 

lagoon would have entered the surface water pathway (Ref. 22). 

 In 1982, an illegal release to the surface water pathway was reported and five days after 

the report, it was observed to still be discharging via a ditch alongside the lagoon (Refs. 17, p. 3; 

53, pp. 9. 11). In 1998, a well-defined ditch lined with mature pine trees on both sides was 

observed along the eastern side of the lagoon. This eastern ditch terminated near the northern end 

of the lagoon (Ref. 14, p. 1). In 1998, Cristex’s consultant partially breached the lagoon dam and 

allowed lagoon water to flow to the surface water pathway (Refs. 37; 46, p. 16). Around 2001, 

Cristex’s consultant graded the area upgradient of the lagoon to reduce storm water inflow to the 

lagoon (Ref. 46, p. 19). The eastern ditch is no longer present and was likely destroyed when the 

consultant graded near the lagoon (Ref. 22). 

The wetland area below the lagoon is not shown on the Wetland Inventory Maps; 

therefore, a US Army Corps of Engineers (COE) Regulatory Specialist visited the area and 

delineated the wetland area on July 17, 2000, prior to the ESI sampling event (Ref. 48, p. 2). 

During the wetland delineation, the dam was noted to contain mature trees growing in it, and the 

US Army COE regulatory specialist stated this was a strong indication that the dam had been 

seeping for quite some time. In 2000, the lagoon was determined to be hydrologically connected 

to the wetland (Refs. 48, pp. 1-2; 54, p. 41). 

In 2012, a US Army Corps of Engineers (COE) Regulatory Specialist visited the site and 

flagged the wetland perimeter to document frontage of this Palustrine forested wetland (Refs. 22; 

23; 47). NC Superfund collected GPS readings and measured perimeter. This COE Regulatory 

Specialist said the lagoon was no longer hydrologically connected to the wetland (likely due to 

the breach and subsequent reduced water level); however, the wetland began about 40’ below the 

lagoon breach and any discharge from the lagoon would enter this wetland (Refs. 22; 23; 47, p. 

1; Figs. 12, 13). 

44 
SWOF — Surface Water Overland Flow/Flood Migration Pathway

The probable point of entry (PPE) to the surface water pathway is into the wetland; the 

closest edge of which is about 40’ from the lagoon breach. This wetland does not have a defined 

channel and extends both upgradient and downgradient from the lagoon (Refs. 23; 48, p. 1; 47; 

Figs. 12, 13). The wetland perimeter upgradient from the PPE was measured in June 2012 at 

479’ (Ref. 47; Figs. 12, 13). The surface water pathway below the lagoon breach flows for a 

linear distance of about 200’ through the wetland with a perimeter measured in June 2012 at 485’ 

(Refs. 23, 47; Figs. 12, 13). Below this wetland, the wetland drains into and is hydrologically 

connected with a stream fronted by wetlands on both sides, for a length of about 75’ with a total 

frontage of 165’ (as measured in June 2012). The 2012 wetland delineation stopped at this point; 

however, observations made by US Army COE specialists in 2012 and in 2000 concur that 

wetlands border the stream below this point (Refs. 23, 47, 48). 

The stream then flows another 25’ linear feet with wetlands on both sides and joins with 

the stream that flows from the north through a culvert under the railroad track (Figs. 8, 10, 11; 

Refs. 47, 48), about 300 linear feet below the PPE. This stream from under the railroad tracks 

includes runoff from the JFD Electronics/Channel Master and Oxford Printing sites (Figs. 1, 8; 

Refs. 50, 51). While the USGS topographic map does not indicate a perennial stream at this 

location (Fig. 1), water was observed running in this stream even during the 2007 sampling event 

when the drought had caused most wells on the Cristex site to be dry (Ref. 58, pp. 7, 19, 20, 21; 

Figs. 8, 10, 11, 12, 13). 

 Below this stream confluence, a 5’-wide palustrine forested wetland borders the stream 

on both sides, until wetlands end at the area where the stream crosses the dirt/gravel access road 

near sample location 36SD (Refs. 23, pp. 2, 5; 47; 48; Fig. 12). The stream segment length from 

the culvert confluence to the dirt/gravel access road is 400' (Ref. 47; Figs. 12, 13); therefore, the 

total wetland frontage below the PPE down to the point of the dirt/gravel access road (which is 

700 linear feet below the PPE) is 485’ + 165’ + 50’ + 800' = 1,500’, or about 0.28 miles. The 

entire delineated wetland perimeter is 479’ + 485’ + 165’ + 50’ + 800' = 1,979’, or about 0.37 

miles wetland frontage above sample location CR-36-SD. A discussion of contaminated 

wetland frontage will be provided in the Environmental Threat Section below. The next nearest 

wetland below the dirt/gravel road is 1.5 miles below the PPE (Ref. 52). There is a fishery 

within the 15-mile surface water pathway (Fig. 9; Refs. 22, 25). 

 Below the dirt/gravel access road, the perennial stream flows easterly for about 750', and 

joins another unnamed minimal stream that flows from the north (Figs. 8, 10, 11). In another 

3,000' downstream, the surface water pathway joins with Foundry Branch, a tributary to Fishing 

Creek. Foundry Branch flows southward for 2 miles and flows into Fishing Creek (Figs. 9, 11). 

About 2 miles downstream from this point, Coon Creek flows into Fishing Creek from the 

northeast, and the surface water pathway becomes a small-to-moderate stream (Refs. 54, p. 9; 

30). Therefore, the surface water pathway is a minimal stream for the first 4.8 miles (Refs. 1, 

Table 4-14; 30). Fishing Creek flows southward for another 5 1⁄2 miles and enters the Tar River. 

The Tar River is a moderate-to-large stream. The 15-mile surface water pathway ends another 

4.7 miles downstream near the Granville Co. - Franklin Co. line (Fig. 9; Refs. 30; 54, p. 9). 

 

45 
SWOF — Surface Water Overland Flow/Flood Migration Pathway 

4.1.2 LIKELIHOOD OF RELEASE 

4.1.2.1 OBSERVED RELEASE 

Observed Release by Direct Observation 

 In 1998, the lagoon dam was breached by Cristex’s consultant and approximately 1⁄2 of 

the lagoon volume (400,000 gallons) was allowed to enter the surface water pathway. 

Reportedly, an NC DWQ official granted permission to breach the dam; however, no 

documentation of this conversation has been located (Refs. 37; 46, p. 16). Lagoon water 

contained lead, bis-(2-ethylhexyl) phthalate, 1,4-chlorobenzene, and chlorobenzene (Ref. 15). 

Phthalates and chlorobenzene are known dye carriers (Ref. 32). In 2001, NC DENR would not 

allow discharge to the surface water pathway but instead allowed discharge of lagoon water to 

the City of Oxford’s POTW (Ref. 46, p. 19). 

 An observed release to surface water has been documented by direct observation and will 

be documented by chemical analysis. 

 

46 
SWOF — Surface Water Overland Flow/Flood Migration Pathway 

Observed Release by Chemical Analysis

 Samples of surface water / sediment were collected in 1998, 2000, 2007, and 2010 

(summarized at Ref. 13, pp. 74-76). Although all events showed an observed release to the 

surface water pathway, only metals data for surface water and sediment samples collected in 

2010 will be used to document the observed release by chemical analysis. Data from 2010 is the 

most recent CLP data and best represents current site conditions. Samples collected in the 

tributary flowing from JFD Electronics/Channel Master serve not only as background for the 

release below 0.34 miles of wetland frontage but also serve to account for any potential impact 

of that site on contamination observed further downstream. 

 Chemical analysis confirms an observed release of chromium, lead, manganese, nickel, 

and zinc to the surface water pathway below >0.1 mile of wetland frontage (Ref. 15). 

Background concentration — Sediment

Table 13. Background Sediment Sample 

Sample 

number Date; time Description 

CR-37-SD 5/19/10; 1205 

Refs. 13, pp. 101, 372; 

16, p. 1; 29, pp. 5, 15; 

Fig. 1 

Background collected off site in nearby pond 

shoreline. MS/MSD location. Removed top 4” 

layer of leaves, etc. and collected 4” – 12” depth, 

sandy clay (mostly clay, some tan, some gray). 

CR-35-SD 05/19/10; 1435 

Refs. 13, pp. 100, 361; 

23; 29, pp. 5, 13; Figs. 

10, 12, 13 

In HRS-qualifying (Palustrine forested) wetlands 

(at this point, wetlands border the creek). 

Sediment in tributary entering from JFD north of 

tracks, about 15’ below the culvert under the RR 

tracks. Sediment yellow clay with a tinge of 

grey clay, roots and some sand on the bottom of 

the creek. Creek at this point about 1’ deep and 

slow moving. 

Table 14. Background Sediment Sample Results 

 Analyte (mg/kg) Chromium Lead Manganese Nickel Zinc 

CR-37-SD 11 5.4 44 <5.9** 8.8

CR-37-SD MRL 1.5 1.5 2.2 5.9 8.8

CR-35-SD 43 16 170 19 110

CR-35-SD MRL 1.5 1.5 2.2 5.8 8.8

**trace detections below the quantitation limit are treated as non-quantifiable for HRS purposes (Ref. 45, pp. 4, 7) 

MRL = Minimum Reporting Limit 

47 
SWOF — Surface Water Overland Flow/Flood Migration Pathway 

Table 15. Sediment Samples 

Description 

CR-32-SD 

5/19/10; 1530 

Refs. 13, pp. 99, 362; 

23; Figs. 10, 12, 13 

The GPS’d location and wetland delineation determined 

that this sample was within the wetland perimeter and 

slightly upstream from the lagoon breach / PPE. Medium 

brown clayey sand. 

CR-33-SD 

05/19/10; 1525 

Ref. 13, pp. 100, 362; 

Figs. 10, 12, 13 

At PPE in wetland, sediment ~40’ downstream of lagoon 

breach, sediment a medium brown clayey sand. 

CR-34-SD 

05/19/10; 1457 

Ref. 13, pp. 100, 361; 

Figs. 10, 12, 13 

Sediment in wetland, upstream of confluence with stream 

from JFD Channel Master and in wetland downstream of 

lagoon. Sediment appears much the same as CR-35-SD 

with somewhat more sand.

CR-36-SD 

05/19/10; 1410 

Ref. 13, pp. 100, 360, 

361; Figs. 10, 12, 13 

Downstream of 0.34 miles of wetland frontage (but not in 

wetlands) and downstream of confluence with JFD 

stream; collected from pool about 2 1/2' deep. Sediment 

mostly clay - some tan, some grey. 

CR-136-

SD 

05/19/10; 1415 

Ref. 13, pp. 76, 100, 

360, 361; Figs. 10, 12 

Duplicate of CR-36-SD. (Note that Ref. 13, p. 74 states 

that CR-136 is a duplicate of CR-35. This was a typo. 

Field notes and data tables reflect that it was a duplicate 

of CR-36.) 

Table 16. Sediment Sample Results

 Analyte (mg/kg) Chromium Lead Manganese Nickel Zinc 

CR-32-SD 34 28 690 20 120

CR-32-SD MRL 1.6 1.6 2.4 6.4 9.5

CR-33-SD 590 21 370 9.5 110

CR-33-SD MRL 1.6 1.6 2.4 6.3 9.4

CR-034-SD 21 6.9 68 9.2 34

CR-34-SD MRL 3.1 1.2 1.9 5.0 7.4

CR-36-SD 30 12 400 12 24

CR-36-SD MRL 1.3 1.3 2.0 5.4 8.1

CR-136-SD 25 8.5 210 14 21

CR-136-SD MRL 1.3 1.3 1.9 5.2 7.7

48 
SWOF — Surface Water Overland Flow/Flood Migration Pathway 

Table 17. Background Surface Water Samples 

Sample 

number Date; time Description 

CR-37-SW 

05/19/10; 1155 

Refs. 13, pp. 101, 372; 

16; 22, pp. 62, 63; 29, 

pp. 5, 14; Fig. 1 

Background, off site; 

Background in pond shoreline, west of 

Cristex 

MS/MSD location

CR-35-SW 

05/19/10; 1430 

Refs. 13, pp. 100, 361; 

29, pp. 5, 13; Figs. 10, 

12, 13 

In stream draining from JFD; 

Surface water in tributary entering from 

north of tracks, about 15’ below the culvert 

under the RR tracks.

Table 18. Background Surface Water Results – 2010* 

 Analyte (mg/kg) Chromium Lead Nickel Zinc 

CR-37-SW U U <1.0** 4.9 

CR-37-SW MRL 2.0 1.0 1.0 2.0 

CR-35-SW 6.6 1.9 11 120 

CR-35-SW MRL 2.0 1.0 1.0 2.0 

*While metals water data was reported with a J-qualifier (temperature >6.0oC), subsequent correspondence with the 

lab confirmed that this data should not have been J-qualified. NC Superfund intentionally shipped acid-preserved 

water samples without ice in their own cooler separate from any other samples to save on shipping costs. The 

metals water sample collection ILM05.4 SOW does not require icing of acid-preserved water samples and icing is a 

secondary, backup preservation method (Ref. 62). 

Table 19. Surface Water Samples

Sample number Date; time Description 

CR-33-SW

05/19/10; 1520 

Ref. 13, pp. 100, 361; 

Figs. 10, 12, 13 

Surface Water about 40’ below 

lagoon breach in braided wetland. 

CR-34-SW 

05/19/10; 1453 

Ref. 13, pp. 100, 361; 

Figs. 10, 12, 13 

Surface water in wetland, above 

confluence with stream from JFD 

Channel Master, in braided stream 

below lagoon. 

CR-36-SW 

05/19/10; 1350 

Ref. 13, pp. 100, 360; 

Figs. 10, 12 

Surface Water below 0.1 mile 

wetland frontage; pooled area below 

gravel road. Pool was ~2.5’ deep. 

CR-136-SW 

05/19/10; 1355 

Ref. 13, pp. 100, 360; 

Figs. 10, 12 

Surface Water below 0.1 mile 

wetland frontage; Duplicate of CR36-SW. 

 

49 
SWOF — Surface Water Overland Flow/Flood Migration Pathway 

Table 20. Surface Water Results* 

 Analyte (mg/kg) Chromium Lead Nickel Zinc 

CR-33-SW 52 5.2 5.8 73 

CR-33-SW MRL 2.0 1.0 1.0 2.0 

 CR-34-SW 68 5.4 5.5 73 

CR-34-SW MRL 2.0 1.0 1.0 2.0 

CR-36-SW 18 3.1 17 83 

CR-36-SW MRL 2.0 1.0 1.0 2.0 

CR-136-SW 18 3.2 18 84 

CR-136-SW MRL 2.0 1.0 1.0 2.0 

*While metals water data was reported with a J-qualifier (temperature >6.0oC), subsequent correspondence with the 

lab confirmed that this data should not have been J-qualified. NC Superfund intentionally shipped acid-preserved 

water samples without ice in their own cooler separate from any other samples to save on shipping costs. The 

metals water sample collection ILM05.4 SOW did not require icing of acid-preserved water samples and icing is a 

secondary, backup preservation method (Ref. 62). 

Attribution 

From 1966 to 1986, the Cristex Drum facility was a warp knit fabric mill engaged in 

knitting, dyeing, and finishing of nylon acetate Tricot (Refs. 5; 17, pp. 9, 39-42; 18, pp. 1, 16-18, 

20). Common textile contaminants include copper, chromium, and zinc (Ref. 17, p. 5). Copper, 

chromium and zinc, as well as lead, manganese and nickel, were detected in both Source 1 and 

Source 2 at levels exceeding background soil levels (see Sections 2.1 and 2.2 of this HRS 

documentation record). Manganese and zinc were also detected in lagoon (Source 2) water in 

1984 (Ref. 17, p. 44). 

The 2010 iESI sample event conducted by NC Superfund personnel included collection 

of surface water and sediment samples at the background location (not in wetland), at the PPE 

(in wetland), downstream from the PPE (in wetland), at the culvert flowing from the north under 

the Railroad tracks (in wetland) and in the stream downstream of the wetlands. Another 

sediment sample was collected in the wetland and slightly upgradient from the PPE (Refs. 16; 

22, pp. 62, 63; Figs. 1, 10, 12, 13). 

 Chromium, lead, manganese, nickel, and zinc were found at the PPE and below 0.34 

miles of wetland frontage. Surface water samples show elevated chromium, lead, nickel, and 

zinc at the PPE, in the wetland below the PPE, and below 0.34 mile of wetland frontage. While 

it appears that JFD Electronics/ Channel Master may have contributed some contaminants to 

sediments in the surface water pathway, this would only impact the portion of the surface water 

pathway target distance limit below its confluence with the stream channel carrying runoff from 

the JFD Electronics/Channel Master and Oxford Printing sites. Levels of these contaminants at 

the Cristex Drum site PPE and wetlands prior to the JFD Electronics/Channel Master and Oxford 

Printing stream channel confluence are significantly greater than background (Refs. 13, pp. 99-

100, 278-289, 360-362; 47; 48). 

50 
51 

SWOF — Surface Water Overland Flow/Flood Migration Pathway 

These contaminants were found in Source 1 (soil) (Tables 2 – 7 above):

Tetrachloroethene 

Chromium 

Cis-1,2-DCE 

Cobalt 

Copper 

Lead 

Manganese 

Mercury 

Nickel 

Zinc 

These contaminants were found in Lagoon Sediment (Source 2) (Tables 8 – 12 above):

Chlorobenzene 

1,4-Dichlorobenzene 

Cadmium 

Chromium 

Copper 

Lead 

Manganese 

Mercury 

Nickel 

Zinc 

Hazardous Substances Released to Surface Water Pathway (Tables 17 – 24 above):

 Chromium 

 Lead 

 Manganese 

 Nickel 

 Zinc 

Hazardous Substances Released to Surface Water Pathway below 0.34 miles 

of wetland frontage, below confluence with tributary from JFD 

Electronics/Channel Master (Tables 13 – 20 above):

 Chromium 

 Lead 

 Manganese 

 

Surface Water Pathway Observed Release Factor Value = 550

4.1.4 Potential to Release 

 Potential to release via overland flow was not evaluated because an 

observed release to surface water was established by chemical analysis as well as by 

direct observation. 
SWOF — Food Chain 

4.2 HUMAN FOOD CHAIN THREAT 

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

likelihood of release, waste characteristics, and targets. 

LIKELIHOOD OF RELEASE 

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

drinking water threat (Ref. 1, para. 4.1.3.1). 

 550

4.2.1 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. 

4.2.1.1 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 site 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, para. 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). Toxicity, Mobility and Bioaccumulation are taken from 

SCDM (Ref. 2). 

 

52 
 SWOF — Food Chain 

Hazardous 

Substance 

Source 

No. 

Toxicity 

(Ref. 2) 

Persistence 

(Ref. 2) 

T/P value (Ref. 

1, Table 4-12) 

BCF (Food 

Chain) 

(Ref. 2) 

T/P/BPFV

(fresh) (Ref. 

1, Table 4-

16) 

Chromium 1,2 10,000 1 10,000 500 5 x 106

Lead 1,2 10,000 1 10,000 5 5 x 104

Manganese 1,2 10,000 1 10,000 50,000 5 x 108

Nickel 1,2 10,000 1 10,000 0.5 5,000

Zinc 1,2 10 1 10 5 50

PCE 1 100 0.4 40 50 2,000

TCE 1 1,000 0.4 400 50 2 x 104

cis-1,2-DCE 1 1,000 0.4 400 50 2 x 104

Chlorobenzene 2 100 0.0007 0.07 50 35

1,4 

Dichlorobenzene 2 10 0.4 4 5,000 2 x 104

Antimony 2 10,000 1 10,000 5.0 5 x 104

Cadmium 2 10,000 1 10,000 5,000 5 x 106

Cobalt 1 10 1 10 5,000 5 x 104

Copper 1, 2 0 1 0 500 0

Mercury 1, 2 10,000 0.4 4,000 50,000 2 x 108

BCF = Bioaccumulation 

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

Bioaccumulation Potential Factor Value 

Persistence Factor Value, Ref. 1, para. 4.1.3.2.1.2; Ref. 2 

Chromium, lead, manganese, nickel, and zinc were in the release to the surface water 

pathway. Chromium, lead, and manganese were in the release to 0.34 miles of wetland 

frontage. Other contaminants shown in the above table were documented in a source 

having a containment >0. 

Manganese has a T/P/BPFV value of 5 x 108

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

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

53 
 SWOF — Food Chain 

4.2.1.2 Hazardous Waste Quantity 

 Containment 

Source Hazardous Waste Quantity Surface 

No. Value Water 

1 >0 10 

2 1,675 10 

Sum of Source Hazardous Waste Quantity Values = 1,675 

The Hazardous Constituent quantity for Sources 1 and 2 is not adequately determined. 

The Source Hazardous Waste Quantity is undetermined, but greater than zero. The source 

hazardous waste quantity sum of 1,675 yields a hazardous waste quantify factor value of 

100 (Ref. 1, Table 2-6). Also, because of actual contamination at Level II concentrations 

in the surface water migration pathway, the Hazardous Waste Quantity Factor Value 

receives a minimum factor value of 100 (Ref. 1, Section 2.4.2.2; see Section 2.1.3 for 

Sources 1 and 2 and Section 4.3.3.2 of this HRS documentation record). 

 Hazardous Waste Quantity Factor Value = 100 

4.2.1.3 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 

(Ref. 1, Table 2 - 7, paragraphs 4.1.3.2.3 and 2.4.3.1) 320

54 
 

SWOF — Food Chain 

4.2.2 HUMAN FOOD CHAIN THREAT - TARGETS 

Actual Human Food Chain Contamination 

 Observed Release to Surface water sediment was documented in Section 4.1.2.1. 

Actual contamination of the fishery has not been documented. 

 

4.2.2.1 Food Chain Individual (Ref. 1, para. 4.1.3.3.1) 

 If there is an observed release of a hazardous substance having a bioaccumulation 

potential factor value of 500 or greater to surface water in the watershed and there is a 

fishery (or portion of a fishery) present anywhere within the target distance limit, assign a 

value of 20. Fishing for human consumption occurs within the 15-mile target distance 

limit (TDL) according to a biologist with the North Carolina Division of Water Quality 

(Ref. 22). Known fishing areas within the 15-mile TDL include the Tar River 

downstream of the PPE (Ref. 25).

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

 Food Chain Individual Factor Value 20

 

4.2.2.2 Food Chain Population -- 

 Fishing has not been documented in this minimal stream at the property or at the 

most downstream point of documented contamination; therefore, only the potential 

human food chain contamination will be evaluated. 

4.2.2.3 Potential Human Food Chain Contamination 

 Fishing occurs in the 15-mile surface water pathway and >0 pounds per year is 

caught. The actual production of the fishery is not documented (Refs. 22, 25); therefore, 

the lowest human food chain population value is assigned (>0 – 100 lbs/year, or 0.03). 

Since the surface water pathway is a minimal stream down to 4.8 miles below the PPE 

and fishing occurs, the dilution factor is 1 (Refs. 1, Table 4-18, para. 4.1.3.3.2.3; 30, 35). 

Identity of Fishery = Foundry Branch, Fishing Creek and Tar River 

Annual Production (pounds) >0 

Type of surface Water Body = Minimal Stream – to – moderate-to-large stream 

Population Value (Pi) = 0.03 

Dilution Weight = 1 

Pi x Di = 0.03 

Pi x Di / 10 = 0.003

Potential Human Food Chain Contamination = 0.03 x 1 / 10 = 0.003

55 
SWOF — Food Chain

4.2.2.4 Level I Concentrations – None Documented 

4.2.2.5 Level II Concentrations – None Documented 

4.2.2.6 Calculation of Human Food Chain Threat - Targets Factor Category Value

(Ref. 1, para. 4.1.3.3.3) 

 Human Food Chain Threat-Targets Factor Category Value = 

 20 + 0.003 = 20.003

 

4.2.2.7 Calculation of Human Food Chain Threat Score 

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

 550 x 320 x 20.003 / 82,500 = 42.67 

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

 Human Food Chain Threat Score = 42.67

56 
 SWOF — Environment 

4.3 ENVIRONMENTAL THREAT 

4.3.1 LIKELIHOOD OF RELEASE 

 

 The environmental threat likelihood of release factor category is the same as that 

for the drinking water threat (Ref. 1, para. 4.1.4.1). 

550

 

4.3.2 ENVIRONMENTAL THREAT WASTE CHARACTERISTICS 

4.3.2.1 Ecosystem Toxicity/Persistence/Bioaccumulation 

 All hazardous substances eligible for toxicity/persistence evaluation in the 

drinking water threat and human food chain threat are also eligible in the environmental 

threat evaluation (Ref. 1, para. 4.1.4.2.1), which includes substances in the observed 

release and substances associated with a source with a containment factor value greater 

than 0 for the watershed (Ref. 1, para. 4.1.2.2). An observed release of chromium, lead, 

manganese, nickel, and zinc was documented in the release to the surface water pathway 

(Tables 13 – 20 above). Chromium, lead, and manganese were in the release downstream 

of 0.34 miles of wetland frontage. PCE, TCE, cis-1,2-DCE, chlorobenzene, antimony, 

cadmium, cobalt, copper, and mercury were documented in a source with a containment 

factor >0 (Tables 2 - 12 above). 

Hazardous 

Substance 

Source 

No. 

Eco 

Toxicity 

(Ref. 2) 

PF Eco T/P value 

(Ref. 1, Table 

4-20) 

BCPF (Env) 

(Ref. 2) 

T/P/BPFV 

(fresh) (Ref. 1, 

Table 4-21) 

Chromium 1,2 10,000 1 10,000 500 5 x 106

Lead 1,2 1,000 1 1,000 50,000 5 x 107

Manganese 1,2 0 1 0 50,000 0

Nickel 1,2 100 1 100 500 5 x 104

Zinc 1,2 10 1 10 50,000 5 x 106

PCE 1 100 0.4 40 50 2,000

TCE 1 100 0.4 40 50 2,000

cis-1,2-DCE 1 0 0.4 0 50 0

Chlorobenzene 2 10,000 0.0007 7 5,000 3.5 x 104

1,4 

Dichlorobenzene 2 10 0.4 4 5,000 2 x 104

Antimony 2 100 1 100 5 500

Cadmium 2 10,000 1 10,000 50,000 5 x 108

Cobalt 1 0 1 0 5,000 0

Copper 1, 2 1,000 1 1,000 5,000 5 x 106

Mercury 1, 2 10,000 0.4 4,000 50,000 2 x 108

PF = Persistence Factor Value (Ref. 2) 

Ecosystem Toxicity Factor Value (Ref. 2) (fresh water) 

T/P/BPFV = Toxicity/Persistence/Bioaccumulation Potential Factor Value 

57 
SWOF — Environment 

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

Ecosystem Toxicity/Persistence/Environmental Bioaccumulation Factor Value = 5 x 108

 

4.3.2.2 Hazardous Waste Quantity 

 Assign the same hazardous waste quantity factor value as in the drinking 

 water threat and human food chain threat (Ref. 1, paragraphs 4.1.2.2.2 and 

 4.1.4.2.2). 

100

4.3.2.3 Environmental threat – waste characteristics factor category value 

 Ecosystem Toxicity/Persistence Factor Value = 10,000 

 Ecosystem Toxicity/Persistence Factor Value x Hazardous Waste Quantity 

 Factor Value: 10,000 x 100 = 1 x 10

6 

 Ecosystem Bioaccumulation Potential Factor Value = 50,000 

 Ecosystem Toxicity/Persistence x Hazardous Waste Quantity Value x 

 Bioaccumulation Potential Factor Value: 

 1 x 10

6 

x 50,000 = 5 x 10

10

 Environmental Threat – Waste Characteristics Factor Category Value 

 (Ref. 1, Table 2-7) 

320

 

58 
SWOF — Environment

4.3.3 ENVIRONMENTAL THREAT – TARGETS 

4.3.3.1 Level I Concentrations – No Level I concentrations were noted 

4.3.3.2 Most Distant Level II Samples 

 CR-36-SD, CR-136-SD (duplicate), CR-36-SW, and CR-136-SW 

 (duplicate)

 Distance from the Probable Point of Entry: 

 The PPE is into wetlands (Refs. 47; 48, p. 1; Figs. 12, 13). The wetland perimeter 

upgradient from the PPE was measured in June 2012 at 479’ (Ref. 47; Figs. 12, 13). The 

wetland perimeter downstream from the PPE was measured in June 2012 at 485’ (Ref. 

47; Figs. 12, 13). The entire wetland perimeter is 964’ + 485’ = 1449’. Below this 

wetland, the wetland drains into and is hydrologically connected with a stream fronted by 

wetlands on both sides, for a total frontage of 165’ (as measured in June 2012) which 

flows another 25’ and joins with the stream that flows from the north through a culvert 

under the railroad track (Figs. 8, 10, 11; Refs. 47, 48), about 300 linear feet below the 

PPE. 

Below this stream confluence, 5’-wide wetlands border the stream on both sides, 

until wetlands end at the area where the stream crosses the dirt/gravel access road (Refs. 

47, 48). The stream segment length from the culvert confluence to the dirt/gravel access 

road is 400' (Ref. 47; Figs. 12, 13); therefore, the total wetland frontage below the PPE 

down to the point of the dirt/gravel access road (which is 700 linear feet below the PPE) 

479’ + 485’ + 165’ + 50’ + 800' = 1,979’, or about 0.37 miles wetland frontage above 

sample location 36-SD. The surface water pathway from the PPE to this most distant 

sample (CR-36-SD) is a minimal stream (Ref. 30). 

Sample 32SD defines the most upstream sample showing Level II contamination 

in the wetlands; therefore, wetland frontage upstream from 32SD is subtracted from the 

total wetland frontage having Level II contamination. The length of wetland perimeter 

upstream of 32SD was totaled (244'), an arc was drawn between sides through 32SD, the 

length of this arc was measured (45'), and the total impacted wetland frontage was 

adjusted to 1,979' - 244' + 45" = 1,780', or 0.34 miles (Fig. 12). 

Total wetland frontage exposed to Level II contamination: 0.34 miles 

 Wetland Value (Ref. 1, Table 4-24): 25 

Sum of Sensitive Environments Value + Wetland Value: 25 

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

 Level II Concentrations Factor Value = 25 

4.3.3.3 Potential Contamination - Not Documented 

4.3.3.4 Calculation of Environmental Threat Score

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

 550 x 320 x 25 / 82,500 = 53.33

59 
60 

Table 4-1 Surface Water Overland/Flood Migration Component Scoresheet 

Summary

Human Food Chain Threat

Likelihood of Release: 550

Waste Characteristics: 100

Toxicity/Persistence/Bioaccumulation 5 x 108

Hazardous Waste Quantity 100

 Waste Characteristics Factor Category Value 320

Targets: Food Chain Individual Factor Value 20 

 Food Chain Population Value 

 

 Potential (calculated value not used) 0.003 

Human Food Chain Threat Score: 

 [550 x 320 x 20.003] / 82,500 = 42.67

Environmental Threat

Likelihood of Release: 550

Waste Characteristics: 100

Ecosystem Toxicity/Persistence/Ecosystem Bioaccumulation 

 5 x 108

Hazardous Waste Quantity 100

 Waste Characteristics Factor Category Value 320

Targets: Wetland 25 

 

 Potential (not evaluated) 

Environmental Threat Score: 

 [550 x 320 x 25] / 82,500 = 53.33