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 score d. 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 chloroben zene, 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 scor ed 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 wa s 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: Pi edmont, 50 miles North of Raleigh

Topographic Map: Oxford, NC (Ref. 3)

Latitude*: 36.2972 o north latitude

Longitude*: 78.6067 o west longitude Location is northeast co rner 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 contam inant locations presented in this HRS documentation record identify the general area th e 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 natio nal priorities among the known "releases or threatened releases" of hazardous substances; th us, 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 repres ent the initial determinat ion that a certain area may need to be addressed under CERCLA. Accordi ngly, EPA contemplates that the preliminary description of facility boundaries at the time of sc oring will be refined as more information is developed as to where the contamination has come to be located.

1WORKSHEET FOR SITE SCORE

S S 2

1. Ground Water Migration Pathway Sc ore 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 S gw 2 + S

sw 2 + S

s 2 + S

a 2 = 9216.00

6. HRS Site Score: Value on line 5 divided by four, then take the square root = 48.0 0

2T ABLE 4-1 --S URFACE W ATER O VERLAND /F LOOD M IGRATION C OMPONENT S CORESHEET
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

3Environmental Threat

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

Waste Characteristics:
23. Ecosystem Toxicity/Per sistence/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 Score c (lines 13+21+28, subj ect to a max of 100} 100 96.00

Surface Water Overland/Flood Migration Component Score
30. Component Score (S

sw ) 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

4CRISTEX DRUM OXFORD, GRANVILLE COUNTY, NC

LIST OF FIGURES

Figure 1. Facility Map Figure 2. Site Layout w ith Monitoring Well Locations Figure 3. Excavation Areas, Cr istex Facility Site, October 2002 Figure 4. Proposed Geoprobe Locati ons 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, Wetla nd Delineation June 2012 Large View Figure 13. Cristex Drum Site , Wetland Delineation June 2012

578°37'20"W78°37'10"W78°37'0"W78°36'50"W78°36'40"W78°36'30"W78°36'20"W78°36'10"W78°36'0"W78°35'50"W

36°18'30"N 36°18'30"N

36°18'20"N 36°18'20"N

36°18'10"N 36°18'10"N

36°18'0"N 36°18'0"N

36°17'50"N 36°17'50"N

36°17'40"N 36°17'40"N

36°17'30"N 36°17'30"NJFDLagoonCristexBackground Sediment and Surface Water Sample Location37SD Approximate Cristex P roperty BoundaryOxford PrintingOak RidgeApartmentsBackgroundCR-SD-01(collected 2007)78°37'20"W78°37'10"W78°37'0"W78°36'50"W78°36'40"W78°36'30"W78°36'20"W78°36'10"W78°36'0"W78°35'50"WSite Name:Site Number:Scale:Date:Figure:Prepared by:Cristex Drum SiteNCO 001 606 2501:12,500July 19, 2010NCDWMBase map is USGS Topographic Quadrangle, Oxford, NC 1991County location:Facility Map101,000 2,000500FeetMW5MW4CR04SB78°36'30"W78°36'30"W

36°17'50"NSource2MW6DMW9MW8MW7MW6MW3MW6IMW3IMW11MW10CR05SB78°36'20"W78°36'20"W 36°17'50"N

Approximate Cristex Property BoundaryDitchSource1areaBase map is 2005 aerial imagery available for download at www.nconemap.com.County location:Monitoring WellSubsurface Soil Sample LocationSite Layout with Monitoring Well LocationsSite Name:Cristex Drum SiteScale:1:1,600Site Number:NCO 001 606 250Date:July 19, 2010Figure:2Prepared by:NCDWMFigure 3.NOTE: This map ofproposedsubsurface soilsample locations is fromthe 2002 Work Planprepared for Cristexunder the REC Program.While data was providedto NC Superfund whenCristex withdrew from theREC program, a finalfigure showing thesubsurface soil samplelocations was notprepared.This map provides thebest guess of samplelocationsFigure 4: Proposed Geoprobe Locations from 2002 Work PlanSite: Cristex Drum Site, Oxford, Granville CountyDate: 07/20/10NCO001606250Drawn By: JSSApproximate Scale: See aboveFigure 5 Soil Gas Results, 2002

TetrachloroetheneCR-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-09 CR-SD-08 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 CarolinaC:\GIS_Workspace\Cristex\mxd's\Figure-4_samples.mxd 0 200 400 100

Feet Legend

Monitoring Well

Sediment Sample

Surface Soil Sample

Surface Water Sample

Surface Water & Sludge Sa mple

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 GISMW10

36°17'50"NMW9MW8MW3MW3ICR11SBCR09SBCR08SBCR07SBCR06SBCR03SBCR02SBCR01SBDitchMW6MW6IMW11 36°17'50"NMonitoring Well LocationSubsurface Soil Sample LocationBase map is 2005 aerial imagery available for download at www.nconemap.com.County location:Subsurface Soil Sample Locations, 2010Site Name:Cristex Drum SiteScale:1:600Site Number:NCO 001 606 250Date:July 19, 2010Figure: 7Prepared by:NCDWMPCE > TCETCE > PCEPCE ~TCEMW-7MW-6 & 6ILagoonApprox Location ofCristex WellFigure 8. JFD Well Results – 2007Figure from 2007 Groundwater Monitoring Results and modified by J. Stanley Oct 2010MW-1PPE 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 2 1

Miles Note:

PPE = Probable point of entry

TDL = Target distance limitApprox.WetlandstreamStream entersand exitsltdPPEculvertunderappt. complex10Former CristexFacility PropertyApprox stream from sitesApprox. Wetland perimeter~850’stream enters and exitsculvert under apt. complexCR-SD-01(collected2007)TextronFigure 11: Surface Water PathwaySite: Cristex Drum Site, Oxford, Granville CountyBase Map from 04-13-12 Granville Co. GISNCO001606250Scale: as shown

### !

!( 

### !( 

### !(



### !( 

# # 0 # # 0 # 0 # 0

# 0

!( 

### !( PPE

Lagoon Breach

in Lagoon

MW9 MW7

MW6 MW-2

MW6D 36SD 35SD

34SD

33SD 32SD

31SD

MW6I 

### CRISTEX DRUM SITE

Wetland Delineation
June 2012 Large View

Fig: 1 2

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

33SD 32SD

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 0 40 20 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 EngineersCRISTEX 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/site s/npl/hrsres/index.htm#HRS Rule

2. US Environmental Protection Agency, S uperfund Chemical Data Matrix (SCDM). Office of Solid Waste and Emergency Re sponse. Directive 9345.1-13. Revised 2006 with 2012 updates. Excerpt - 25 pages. Online address: http://www.epa.gov/superfund/site s/npl/hrsres/tools/scdm.htm

3. US Geological Survey, 7.5-minute topographi c 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, "Standa rd 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 Stat e 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, Pr ism 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, Oct ober 8, 1996, Mallary, Ken, RPM, US EPA, electronic mail message to Terry Stilman, OS C, USEPA, April 30, 1996, and Pierce, R. Steve, START Leader, PRC, Geophysic al Report, August 23, 1996. SUBJECT: Removal Planning. 24 pages.

199. Stanley, Jeanette, Environmental Chemis t, 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 Chemis t, NC Superfund Section, Memo to file, January 15, 1998. SUBJECT: S ite visit during removal.

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

• De’Lyntoneus Moore, OSC, US EPA, POLREP, Cristex Drum Site, March 31, 1997;

• Removal Action Fact Sheet, Decemb er 1996; Benefield, Randy, OHM Corp., Report on Mobilization to Cristex Drum Site, March 21, 1997;

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

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

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

• BFI WCD No. AZ 2465, Wast e Characterization Data.

11. Lair, Myron D., US EPA Region IV, Emer gency Response and Removal Branch and De’Lyntoneus Moore, OSC, US EPA, Ac tion 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 reconnai ssance on March 9, 1998. 6 pages.

15. Leonhardt, H. Derr II, PE, Leonhardt E nvironmental, Letter to Donna Wilson, NC Superfund Section, January 22, 1999; Criste x 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 Chemis t, NC Superfund Section, Memo to file, September 18, 2012, SUBJECT: Background samples. 4 pages.

17. Regulatory History: Lag oon 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 Preventi on Plan, September 30, 1983, pp. 6 - 36,

Industrial Sewer Connection A pplication, 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,

20Oxford City Manager letter, Feb. 25, 1986, pp. 51-52, City of Oxford letter to Bur lington 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 (O il Spill), April 15, 1993, pp. 72 - 73.

18. Stanley, Jeanette, Environmental Chemist, NC Superfund Section, Me mo to file, April 21, 1999. SUBJECT: NC Air Quality Division file material. Memoranda, Air Quality Permits and Permit Applications, Special Orde rs 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 dur ing the Site Inspection. 59 pages.

20. Rudo, Ken, Occupational and Environmenta l Epidemiology Secti on, Drinking Water Health Risk Evaluation, December 1998, De Rosa, Pat, Head, NC Superfund Section, Letters to Tommy Brooks and Hoffman Suitt, December 18, 1998. 5 pages.

21. Granville County, NC, Map of Jomar Ventur es LLC Parcel 1600, cr eated 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 Superfu nd Section, Memos to file, February 16, 1998, March 5, 1998, June 16, 1998. SUBJECT: Si te 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 Engi neers Regulatory Specialist, Notification of Jurisdictional Determination, Action SAW-2013-00141, January 24, 2013. 6 pages.

24. Geologic Map of North Carolina and Expl anatory 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 Investig ation 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 Gr oundwater 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: Near est drinking water well. 13 pages.

2129. 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 w ith 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, Me mo to file, April 21, 1999. SUBJECT: Conversations with Cris tex 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=/ecfrbrows e/Title40/40cfr261_ main_02.tpl. Page 1 included.

41. NCAC Title 15A, Subchapter 2L, Sec tion .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: ES I sampling trip. 22 pages.

44. Reference number reserved

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

Release and Observed Contaminati on”, EPA 540-F-904-28, OSWER 9285.7-14FS, PB94-963311, November 1996. 18 pages.

2246. Mid-Atlantic Associates, Environmental Asse ssment Report, Criste x Facility, October 11, 2002. 999 pages.

47. Stanley, Jeanette, memo to file, Octobe r 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 Regist ered 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 Repor t, 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 Superf und 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 Re medial 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 Re moval and Expanded Site Inspection Report, Revision 0, February 29, 2008. 527 pages.

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

60. Reference number reserved

2361. US EPA, National Drinking Water Regulati ons, List of Contaminants and Maximum Contaminant Level (MCLs), http://water.epa.gov/dri nk/contaminants/index.cfm . 14

pages.

62. Stanley, Jeanette S., Chemist, NC Supe rfund Section, email correspondence with US EPA Denise Goddard and Nardina Turner, July 29, 2010. 4 pages.

63. NC DENR Superfund Five-year Review Repor t, JFD Electronics/Channel Master Site, http://www.epa.gov/superfund/sites/fiveyear/f05-04013.pdf , September 2005. 97 pages.

64. ENSR, Semi-Annual Groundwater Remedia tion Report, September 2007. Cover page and Figure 2-2 only. 2 pages.

65. E 2 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 Supe rfund, 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 sample s near Cristex Drum. 1 page.

68. Stanley, Jeanette S., Chemist, NC Su perfund, memo, May 15, 2012, SUBJECT: Review of Updated Receptor Survey and AECOM, Updated Receptor Survey – JFD

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

242.0 SITE DESCRIPTION

The Cristex Drum site (NC0 001 606 250), 50 0 W. Industry Drive, Oxford, Granville County, NC is located in a pre dominantly industrial area. The Cr istex Drum property contains a 150,000 sq. ft. structure and a 1⁄2-acre lagoon (parti ally breached; sediment remaining) on 22 acres. The area has a mean annual precipitati on of 44 - 46 inches and a mean annual lake evaporation of 41 inches. The 2- year, 24-hour rainfall is 3.36 inch es (Ref. 6). The property is owned by Jomar Ventures LLC. Stutts Truck Tire s 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 wa rp knit fabric mill engaged in knitting, dyeing, and fi nishing 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 (N CD 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 ar ea, a former oil/water separator area, and a ditch draining to the lagoon are surrounded by a fe nce (Figs. 3. 4). The partially drained 1⁄2-acre lagoon and a former drum burial area are outsid e the fenced area but there is no sign of

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

Fourteen on-property monitoring wells were in stalled by Cristex’s cons ultant (Figs. 2, 3; Refs. 46, 59), and there are several monitoring we lls on the facil ity property installed for the adjacent NPL site (Ref. 53). The nearest privat e 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 industr ial area, the closest residential property is the Oakr idge Apartment complex approxima tely 1,350 feet to the east. Oakridge houses around 200 resident s 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 pl ant 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 prod uce this site scor e. In 1998, Cristex’s consultant removed the ASTs, soil underneath the ASTs, an d 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 Cr istex’s consultant. The ditch below the oil/water separator and transfor mer was excavated to a depth of 1 foot, and 290.88 tons of soil were removed (Fig. 3; Ref. 46, p. 11, 44, Drawi ng 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 di d not indicate contaminants above benchmarks. The ditch along the eastern edge of the former southeast drum st orage pad was excavated to 2' depth and 16 cubic yards of soil were removed (Ref. 46, p. 11, Drawi ng 6.1). The removed soil was characterized as

25hazardous 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 Supe rfund investigated this area during the 2010 ESI sample event (Ref. 13, p. 18).

Remaining known and suspected areas of cont aminated soil are around the former drum storage pad on the east side of the building, undern eath 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 b een 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 th e common dry-cleaning solv ent perchloroethylene (tetrachloroethene [PCE]) (Ref. 32, p. 337). Solv ents were used to clean equipment and for dyeing purposes (Refs. 12, p. 11; 18, pp. 83, 88). Phenol, manga nese and zinc were detected in lagoon water in 1984 (Ref. 17, p. 44). Dye carrie r compounds such as phenols, chlorobenzene and other chlorinated aromatics, aromatic hyd rocarbons, aromatic esters, and phthalates are anticipated contaminants (Ref. 32, pp. 151 - 153).

Surface soil, subsurface soil, and lagoon sedime nt contaminants include chlorobenzene, 1,4-dichlorobenzene, tetrachloroethene (PCE), trichloroethene (TCE), cis -1,2-dichloroethene, cadmium, cobalt, copper, chromium, lead, mangan ese, mercury, nickel, and zinc. Ground water contaminants include chlorobenzene, 1,2-dichlo robenzene, 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 bac kground monitoring wells, all wells on the Cristex Drum property contain ch lorinated solvents. A monitor well near the former drum storage pad (MW-3) showed te trachloroethene (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 s ite. The nature and extent of ground water

contamination at the Cristex Drum site has no t been fully determined. Solvent-contaminated ground water from the Cristex Drum site may be c ontributing a significant fraction of the solvent being pumped and treated at the JFD Electroni cs/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 s ite (Fig. 8; Refs. 64; 65, p. 21). Four of the pumping wells are located north of the railroad tracks, three of wh ich are near the former building. One of these and the three pumping wells southe ast of the railroad tracks are wi thin 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 stre am as the Cristex Drum property (Ref. 64, p. 3). Based on the relatively gentle slopes across the str eam and its modest base flow, it is reasonable to expect that these pumping wells could draw ground water from the subsurface of the Cristex

26property and into the treatment system at the JFD Electronics/C hannel 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 fr ontage 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 wa ter 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 pathwa y (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 finding s from the PA/SI, wetland deli neation was condu cted in July 2000 (Ref. 48). The August 2000 Expanded Site In spection (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 Administra tive Order on Consent (AOC) with the NC Inactive Hazardous Sites Branch (IHSB) in Ap ril 2002 and proceeded with remediation under the Registered Environmental Consultant (R EC) 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 repor ted in the Superfund Chemical Da ta Matrix (SCDM). Based on changes to contaminant values as reported in SCDM, NC Superfund recommended the site be reevaluated under CERCLA (Ref. 57). A summa ry of Significant Events / Investigation is provided in the below table.

27Table 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 subsur face 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 con ducted, >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 prev ented 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 con ducted, >0.1 mile of wetland frontage documented. 23, 47

28SD-Characterizati on 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/wa ter 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, c ontaminated 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 fl ows to the surface water pathway. This contaminated soil overlies the single aquifer be low 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, Excava tion 3). This soil was charac terized as haza rdous 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 doc ument 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 a nd 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 (includi ng 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 docume nt Source 1. The most current data are from 2007 and 2010 and comprise the only Contract Laboratory Program (CLP) soil data for the site.

2930 SD-Hazardous Substances Source No.: 1 (Contaminated soil)

Location of the source, with re ference to a map of the site : Along eastern edge of the former drum storage pad and near the northeastern corner of the bu ilding (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 (C R-SS-01) and Figure 2 (CR05SB and CR04SB).

Containment

Release via overland migration and/or flood — Contaminated soil is not covered by a mainta ined engineered cove r and is outside any functioning and maintained run-on control sy stem 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 sa ndy 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 = backgroundSD-Hazardous Substances Source No.: 1 (Contaminated soil)

Table 3. Background Surface Soil Results CR-SS-01 (Bkg) CR-SS-01 MRL Organics μ g/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 (R ef. 58, p. 402). There was baseline instability in either the calibration or preparation blan ks 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 (Ref s. 1, 45), this qualified background quantitation limit is adjusted to demonstrat e the relative increase in contamination over background levels (Ref. 45, p. 18). (b) For mercury, the result is greater than Method Det ection 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 acceptabl e quantitation (Ref. 58 , pp. 106, 406). bkg = background

31SD-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 μ g/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

32SD-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 μ g/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 le ss than Method Reporting Limit. Concentration was lower

than the lowest standard on the ca libration curve (Ref. 58, p. 406). (b) For copper and zinc, the matrix sp ike 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 concentr ation which corresponds to the lowest quantitative point

on the calibration curve or the lowe st demonstrated level of acceptable quantitation (Ref. 58 , pp. 106, 406).

BOLD = Greater than or equal to 3 times background when reported above MRL in b ackground, or greater than background MRL if background is non-detect.

33SD-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 μ g/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.

34SD-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 μ g/kg U (4.8) μ g/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 Hazard ous Substance and Concentration Summary

Highest Source Higher Background

Result Result or MRL

Tetrachloroethene 180,000 μ g/kg U (6.5) μ g/kg Cis-1,2-Dichloroethene 66 μ g/kg U (6.5) μ g/kg

Trichloroethene 82 μ g/kg U (6.5) μ g/kg Chromium 260 mg/kg 62 mg/kg Manganese 260 mg/kg 38 mg/kg Zinc 130 mg/kg 23mg/kg

35SD-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 substanc es 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 ev aluate 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 es timate of the number of drums received or

a breakdown of their contents and the quantity of any wa stestream released to or disposed of on the source is unknown. Ther e 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 alongthe eastern side of the building. Source 1 is defined by surface soil samples CRSS-03 and CR-SS-06 collected in 2007 a nd 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

36SD -Characterizati on 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 gall ons (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 th e City of Oxford POTW. Sanita ry 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 dire ctly to the surface water pathway, bypassing this lagoon (Ref. 17, p. 3; Re f. 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 pathwa y. 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 discha rge 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 a nd wetland area (Ref. 46, p. 16; Ref. 47. p. 2; Figs. 12, 13). There has never been any remedi ation 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) (R ef. 13, p. 68; Ref. 46, pp. 51, 52, 250- 253, 262-273).

Records show that lagoon water wa s 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 C ontract Laboratory Program (CLP) and the data

best characterize Source 2.

37SD-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 verysimilar 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.

38SD-Hazardous Substances Source No.: 2 (Lagoon)

Table 9. Lagoon Sediment Ba ckground 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 se diment 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 th e 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 zi nc results were J-flagged (R ef. 58, p. 402). There was baseline instability in either the calibration or preparation blan ks 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 (Ref s. 1; 45), this qualified concentration is adjusted to demonstrate the relative increa se in contaminant levels over background levels (Ref. 45, p. 18). [ ] provides the adjusted value for the estimated (J’d) value as adjust ed for bias (Ref. 45). bkg = background

39SD-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 tr eated 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 qua lified concentration is adjusted to demonstrate the relative increase in contaminant levels over background levels (Ref . 45, p. 18). The MRL is th e analyte concentration which corresponds to the lowe st 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).

40SD-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

41SD-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 S ource 2 and the chemical composition of products is unknown. There is insufficien t information on which to base an

estimate of the total mass of CERCLA h azardous substances in the source with

reasonable confidence.

2.2.2.2 Hazardous Wastestream Quantity —

Not Scored - NS

Sufficient evidence does not exist to eval uate 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 wa stewater is unknown (Ref. 46, p. 16)

2.2.2.4 Area Surface impoundment, 1⁄2- acr e (Refs.17, p. 20; 46, p. 16) = 1/2 acre = 43,560 sq f t/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

42SD-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)

43SWOF — 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 SU BSTANCE 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 alo ng 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 path way 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 surf ace water pathway (Ref. 22).

In 1982, an illegal release to the surface wate r pathway was reported and five days after the report, it was observed to still be discharg ing via a ditch alongside the lagoon (Refs. 17, p. 3; 53, pp. 9. 11). In 1998, a well-defined ditch li ned 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 c onsultant 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 (C OE) 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 specialis t stated this was a strong indi cation 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 peri meter. This COE Regulatory Specialist said the lagoon was no longer hydrological ly 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).

44SWOF — 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 la goon 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 side s, for a length of a bout 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 sp ecialists 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 obser ved running in this stream ev en during the 2007 sampling event when the drought had caused most wells on the Cristex site to be dr y (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' (R ef. 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 Se ction below. The next nearest wetland below the dirt/gravel road is 1.5 miles be low 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 perenni al 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 mile s and flows into Fishing Creek (Figs. 9, 11). About 2 miles downstream from this point, C oon 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 flow s 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 Gr anville Co. - Franklin Co. lin e (Fig. 9; Refs. 30; 54, p. 9).

45SWOF — 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 ca rriers (Ref. 32). In 20 01, 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.

46SWOF — 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 su rface 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 curr ent site conditions. Samples collected in the tributary flowing from JFD Electronics/Channel Master serv e not only as background for the release below 0.34 miles of wetland frontage but al so serve to account for any potential impact

of that site on contaminati on observed further downstream.

Chemical analysis confirms an observed release of chromium, l ead, 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 en tering 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 Sedi ment 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 li mit are treated as non-qua ntifiable for HRS purposes (Ref. 45, pp. 4, 7) MRL = Minimum Reporting Limit

47SWOF — 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 wetla nd 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 a nd 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 a bout 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

48SWOF — 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 >6.0 o C), 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 milewetland frontage; Duplicate of CR36-SW.

49SWOF — 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 >6.0 o C), 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 Tr icot (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 detect ed in both Source 1 and

Source 2 at levels exce eding background soil levels (see Sections 2.1 and 2.2 of this HRS documentation record). Manganese and zinc were also detected in lag oon (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 b ackground location (not in wetland), at the PPE (in wetland), downstream from the PPE (in wetla nd), 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 a nd slightly upgradient fr om the PPE (Refs. 16; 22, pp. 62, 63; Figs. 1, 10, 12, 13).

Chromium, lead, manganese, nickel, and zi nc 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 m ile of wetland frontage. While it appears that JFD Electronics/ Channel Master may have contributed some contaminants to sediments in the surface water pathway, this wo uld only impact the porti on 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 Prin ting sites. Levels of these contaminants at the Cristex Drum site PPE and wetlands prior to the JFD Electronics/Cha nnel Master and Oxford Printing stream channel confluence are signifi cantly greater than background (Refs. 13, pp. 99- 100, 278-289, 360-362; 47; 48).

5051 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 Se diment (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 conflu ence 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 estab lished 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 cate gory 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 wast e 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 containmentfactor value greater than 0 for the watershed (R ef. 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).

52SWOF — 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 10 6

Lead 1,2 10,000 1 10,000 5 5 x 10 4

Manganese 1,2 10,000 1 10,000 50,000 5 x 10 8

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 10 4

cis-1,2-DCE 1 1,000 0.4 400 50 2 x 10 4

Chlorobenzene 2 100 0.0007 0.07 50 35
1,4

Dichlorobenzene 2 10 0.4 4 5,000 2 x 10 4

Antimony 2 10,000 1 10,000 5.0 5 x 10 4

Cadmium 2 10,000 1 10,000 5,000 5 x 10 6

Cobalt 1 10 1 10 5,000 5 x 10 4

Copper 1, 2 0 1 0 500 0 Mercury 1, 2 10,000 0.4 4,000 50,000 2 x 10 8

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

Bioaccumulation Poten tial 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 th e above table were documented in a source having a containment >0.

Manganese has a T/P/BPFV value of 5 x 10 8

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

Toxicity/Persistence/Bioaccumulation Factor Value: = 5 x 10 8

53SWOF — 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 undeterm ined, 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 actua l contamination at Level II concentrations in the surface water migration pathway, th e Hazardous Waste Quantity Factor Value receives a minimum factor value of 100 (R ef. 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 Char acteristics 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 10 6 )

(Toxicity/Persistence x Hazardous Waste Quantity) x Bioaccumulation

Potential Value:

(1 x 10 6 ) x 50,000 = 5 x 10 10

========================= ==================== ================== Human Food Chain Hazardous Waste Quantity Assigned Value/

Human Food Chain Waste Characte ristics Factor Category Value (Ref. 1, Table 2 - 7, paragraphs 4.1.3.2.3 and 2.4.3.1) 320

54SWOF — Food Chain

4.2.2 HUMAN FOOD CHAIN THREAT - TARGETS

Actual Human Food Chain Contamination

Observed Release to Surface water se diment was documented in Section 4.1.2.1.

Actual contamination of the fi shery has not been documented.

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

If there is an observed re lease of a hazardous substan ce 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 anywhe re within the target di stance 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 w ithin 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 contam ination; 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 (Ref s. 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 minima l 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 St ream – to – moderate-to-large stream Population Value (P i ) = 0.03 Dilution Weight = 1

P i x D i = 0.03

P i x D i / 10 = 0.003

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

55SWOF — 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 F ood Chain Threat - Target s Factor Category Value (Ref. 1, para. 4.1.3.3.3)

Human Food Chain Threat-Tar gets Factor Category Value =

20 + 0.003 = 20.003

4.2.2.7 Calculation of Human Food Chain Threat Score

Likelihood of release x waste char acteristics x targets / 82,500 =

550 x 320 x 20.003 / 82,500 = 42.67

========================= ==================== ================== Human Food Chain Threat Score = 42.67

56SWOF — Environment

4.3 ENVIRONMENTAL THREAT

4.3.1 LIKELIHOOD OF RELEASE

The environmental threat likelihood of rel ease factor category is the same as that for the drinking water thr eat (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), wh ich includes substances in the observed

release and substances associated with a so urce 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 th e release downstream of 0.34 miles of wetland frontage. PCE, TC E, cis-1,2-DCE, chlor obenzene, antimony, cadmium, cobalt, copper, and mercury were do cumented 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 10 6

Lead 1,2 1,000 1 1,000 50,000 5 x 10 7

Manganese 1,2 0 1 0 50,000 0

Nickel 1,2 100 1 100 500 5 x 10 4

Zinc 1,2 10 1 10 50,000 5 x 10 6

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 10 4

1,4

Dichlorobenzene 2 10 0.4 4 5,000 2 x 10 4

Antimony 2 100 1 100 5 500

Cadmium 2 10,000 1 10,000 50,000 5 x 10 8

Cobalt 1 0 1 0 5,000 0 Copper 1, 2 1,000 1 1,000 5,000 5 x 10 6

Mercury 1, 2 10,000 0.4 4,000 50,000 2 x 10 8

PF = Persistence Factor Value (Ref. 2) Ecosystem Toxicity Factor Value (Ref. 2) (fresh water) T/P/BPFV = Toxicity/Persistence/Bio accumulation Potential Factor Value

57SWOF — Environment

========================= ==================== ================== Ecosystem Toxicity/Persistence/Environm ental Bioaccumulation Factor Value = 5 x 10 8

4.3.2.2 Hazardous Waste Quantity

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

water threat and human food chai n threat (Ref. 1, paragraphs 4.1.2.2.2 and 4.1.4.2.2).

100

4.3.2.3 Environmental threat – waste ch aracteristics fact or category value

Ecosystem Toxicity/Per sistence Factor Value = 10,000

Ecosystem Toxicity/Persistence Fa ctor 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 Char acteristics Factor Category Value (Ref. 1, Table 2-7)

320

58SWOF — 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 (duplicat e), CR-36-SW, and CR-136-SW (duplicate)

Distance from the Probable Point of Entry: The PPE is into wetlands (Refs. 47; 4 8, p. 1; Figs. 12, 13). The wetland perimeter upgradient from the PPE was measured in J une 2012 at 479’ (Ref. 47; Figs. 12, 13). The wetland perimeter downstream from the PPE wa s 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), a bout 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/grave l access road (Refs. 47, 48). The stream segment length from the cu lvert confluence to th e dirt/gravel access road is 400' (Ref. 47; Figs. 12, 13); therefor e, the total wetland frontage below the PPE down to the point of the dirt/g ravel 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 ups tream from 32SD is subtracted from the total wetland frontage having Level II contam ination. The length of wetland perimeter upstream of 32SD was totaled (244'), an ar c 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 Leve l 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 Envi ronmental Threat Score

Likelihood of release x waste char acteristics x targets / 82,500 = 550 x 320 x 25 / 82,500 = 53.33

5960 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 10 8

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 10 8

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