The Forshaw Chemical site is approximately 5.25 acres in size and includes two former pentachlorophenol (PCP) formulating buildings, an office building, and a warehouse. The site is located in a mixed industrial/residential area. A municipal park and elementary school are located on the opposite bank of Stewart Creek, just downstream of the site.
Forshaw Chemical began formulating PCP in 1971 up until December 2003, when Forshaw Chemical ceased all PCP production operations. Currently, the property serves as a distribution center only. The original PCP manufacturing building is currently used for storage of Buckshot, a herbicide. This building is rundown and accessible to the public.
During the March 2005 SI for Clorox Chemical, two surface soil samples were collected along the west side of the original PCP formulating building, adjacent to the loading dock area. Analytical results for indicated the presence of PCP at a concentration of 250,000 micrograms per kilogram (µg/kg).
In addition to the soil samples, a duplicate set of surface water and sediment samples were collected at the probable point of entry (PPE). PCP was detected in the surface water at an average concentration of 160 micrograms per liter (µg/L) and in the sediment at a concentration as high as 900 µg/kg.
On October 4, 2005, the North Carolina Superfund Section personnel conducted an on-site/off-site reconnaissance for the Clorox Chemical site. According to an employee of Forshaw Chemical, the City of Charlotte’s stormwater system captures runoff upgradient of the Forshaw Chemical property. Forshaw Chemical’s stormwater system ties into the City of Charlotte’s system on the site, immediately downgradient of the former PCP manufacturing buildings. All stormwater that runs through the Forshaw Chemical property is piped directly into Stewart Creek, Stewart Creek, as well as the entire 15-mile surface water pathway for the site, is considered a fishery.
Based on the potential surface water pathway receptors, the North Carolina Superfund Section proceeded with an ESI for the Clorox Chemical site. On December 5–6, 2005 and January 25, 2006, the North Carolina Superfund Section personnel conducted an ESI sampling event at Clorox Chemical. A total of five soil samples from the overland flow pathway from Forshaw Chemical and immediately upgradient of their stormwater system were collected during the December 2005 ESI sampling event. In addition, a total of six surface water and six sediment samples from the January 2006 ESI sampling event pertain to Forshaw Chemical and its impact upon Stewart Creek.
Since there has been an observed release of PCP to the on-site soils and Stewart Creek, and the potential for soil exposure to the neighboring community, the North Carolina Superfund Section recommended that Forshaw Chemical be added to the Comprehensive Environmental Response, Compensation, and Liability Information System (CERCLIS). The site was added to CERCLIS on April 3, 2006. A Preliminary Assessment (PA) was completed for the site and approved by EPA on April 3, 2006.
On June 6 2007, US EPA arrived on site to collect analytical samples from around the Forshaw Facility. Sample locations focused on the potential pathways of contaminant release offsite. A site reconnaissance was performed to locate the storm water pipe system to help determine sample locations. Samples were collected from sediment/soil located within the storm water pipes, sediment from the lagoon, and sediment/water from the adjacent creek. Samples were brought to the laboratory and analyzed for Dioxins, PCP, Pesticides and Arsenic. Analytical results from the sampling event were reviewed and validated by a TN&A senior chemist. Results showed contaminants above the Region 9 industrial and residential standards for Pentachlorophenol, arsenic, and several dioxin compounds. These results indicated contamination potentially leaving the site. US EPA held a conference call on August 6th to discuss the results with NCDENR, and the EPA. EPA’s toxicologist Scott Sudweeks participated in the conference call to discuss future actions. It was decided that further action was necessary to determine the risk to public health outside of the chemical facilities boundaries. Subsequently, EPA entered into discussions with the PRP as to the path forward.
On August 17, 2009 Forshaw Chemicals and EPA came to agreement on a clean-up strategy and Forshaw Chemicals entered into an Administrative Order on Consent (AOC) with EPA. Forshaw hired Hart and Hickman as their environmental contractor and produced a work plan for the clean-up scope. The plan includes installing a seamless pipe at the impacted portion of the stormwater conveyance system to prevent contamination from migrating into the pipe and ultimately into Stewart Creek. In addition, on site source areas of PCP and Dioxins will be excavated and placed into a biological treatment cell on site. Forshaw will then bioremediate those soils within the treatment cell. If bioremediation efforts fail Forshaw has agreed to dispose of contaminated soils off site at an appropriate disposal facility.
After multiple phone discussions with Hart and Hickman as well as NCDENR it has been decided that no further action or treatment is needed on soils within the treatment cell. The soils have reached the clean-up goal of 300 mg/kg for PCP and only slightly exceed the clean-up goal of 5 ug/kg for dioxins in two of four samples. Those sample results are TC-COMP-2 and TC-COMP-3 with results of 5.15 ug/kg and 5.17 ug/kg respectively. Most importantly, the soils have been removed from the area around the storm sewer and are no longer leaching contaminants into the storm sewer, which ultimately discharges to Stewart Creek. In discussions with the NCDENR it is clear that the site will remain on the inactive hazardous sites list in the future. NCDENR plans to impose industrial land use controls on the site to ensure no unacceptable exposures occur. Since the Dioxin concentrations are only slightly above the Dioxin clean-up goal, but removed from the migration pathway to Stewart Creek as well as access restricted by a fence around the site, the two samples slightly above the Dioxin clean-up goals are considered acceptable. With PCP clean-up goals attained and Dioxin clean-up goals met, the Statement of Work (SOW) goal of source area contaminant removal has been achieved. No further treatment of soils is necessary. All removal action construction is complete.
Hart and Hickman has conducted three sampling events to evaluate the potential that additional sources may be discharging residual PCP into the storm sewer and ultimately Stewart Creek. The first sampling event was conducted in January 2010, the second event was conducted in May 2010 and the final event in September 2010. During the January event residual contamination was observed discharging into Stewart Creek. However, during the May sampling event, all sample locations (except the upgradient location) were below the detection limit (BDL) of 0.020 mg/L. During the September event PCP was detected in the concrete box near the excavation site at a concentration of 0.078 mg/L, which is lower than the January detection of 0.120mg/L. PCP was again not detected in the storm water conveyance system outfall to Stewart Creek. Final data from the September sampling event (also including previous events data) was received on October 20, 2010 in the monthly progress report. Based on two consecutive Non-detect (ND) sample events at the outfall to Stewart Creek the goal set forth in the SOW of zero discharge to Stewart Creek has been met.
At this time all goals set forth in the SOW attached to the Administrative Order on Consent (AOC) have been met or otherwise addressed.
No further removal actions are anticipated.
No Further Removal actions planned.
Response complete.
Send PRP completion letter.
NC DENR cleanup requirements are more stringent than EPA requirements for the site.
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