w .
1
PB99-964009
EPA541-R99-027
1999
EPA Superfund
Record of Decision:
Ross Metals Inc OU 1
Rossville, TN
4/2/1999
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ROSS METALS
SUPERFUND SITE
RECORD OF DECISION
April 2,1999
\
PRO'
U.S. Environmental Protection Agency
Region 4
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RECORD OF DECISION
TABLE OF CONTENTS
1.0 DECLARATION Declaration - 1
2.0 DECISION SUMMARY ....: -1-
2.1 SITE NAME, LOCATION, AND DESCRIPTION -1-
2.2 SITE HISTORY AND ENFORCEMENT ACTIVITIES -1-
2.3 HIGHLIGHTS OF COMMUNITY PARTICIPATION -9-
2.4 SCOPE AND ROLE OF OPERABLE UNIT -11-
2.5 SITE CHARACTERISTICS -13-
2.5.1 Land Use -13-
2.5.2 Climatology -.13-
2.5.3 Physiography -13-
2.5.4 Surface Water -14-
2.5.5 Geology and Hydrogeology -17-
2.5.6 Previous Investigations -28-
2.5.7 Nature and Extent of Contamination -30-
2.5.7.1 Soil and Sediment -30-
2.5.7.2 Groundwater -35-
2.5.7.3 Surface Water -36-
2.5.7.4 Contaminant Fate And Transport -38-
2.5.8 Treatability Studies -43-
2.5.8.1 Dewatering Study, December 1997 -43-
2.5.8.2 Stabilization Study, March 1998 -45-
2.5.8.3 Biosolids Study, November 1998 -46-
2.6 SUMMARY OF SITE RISKS -46-
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RECORD OF DECISION
TABLE OF CONTENTS
2.6.1 Human Health Risk Assessment Summary .45-
2.6.1.1 Data Evaluation .45.
2.6.1.2 Exposure Pathways _4g.
2.6.1.3 Toxicity Values .53.
2.6.1.4 Risk Characterization .55.
2.6.2 Ecological Risk Assessment Summary .59.
2.6.2.1 Identification of Chemicals of Concern -69-
2.6.2.2 Ecological Exposure Assessment .72.
2.6.2.3 Ecological Effects Assessment _7g_
2.6.2.4 Conclusions _90_
2.7 REMEDIATION OBJECTIVES _91_
2.7.1 Remedial Goals _9I_
2.7.2 Remedial Action Objectives .93.
2.7.3 Extent of Source Material Contamination Above Remedial Goals . -95-
2.8 DESCRIPTION OF SOURCE MATERIAL ALTERNATIVES ....... -102-
2.8.1 Alternative S-l - No Action _102-
2.8.1.1 Description -102-
2.8.1.2 Overall Protection of Human Health and the Environment
-102-
2.8.1.3 Compliance with ARARs _105_
2.8.1.4 Long-Term Effectiveness and Permanence -105-
2.8.1.5 Reduction of M/T/V Through Treatment -105-
2.8.1.6 Short-Term Effectiveness _105-
2.8.1.7 Implementability _105_
2.8.1.8 Cost -106-
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RECORD OF DECISION
TABLE OF CONTENTS
2.8.2 Alternative S-2 - Capping -106-
2.8.2.1 Description -106-
2.8.2.2 Overall Protection of Human Health and the Environment
r -107-
2.8.2.3 Compliance with ARARs -109-
2.8.2.4 Long-Term Effectiveness and Permanence -111-
2.8.2.5 Reduction of M/T/V Through Treatment -112-
2.8.2.6 Short-Term Effectiveness -113-
2.8.2.7 Implementability -113-
2.8.2.8 Cost -114-
2.8.3 Alternative S-3 - Capping With Pavement in Place -114-
2.8.3.1 Description -114-
2.8.3.2 Overall Protection of Human Health and the Environment
-115-
2.8.3.3 Compliance with ARARs -117-
2.8.3.4 Long-Term Effectiveness and Permanence -119-
2.8.3.5 Reduction of M/T/V Through Treatment -120-
2.8.3.6 Short-Term Effectiveness -121-
2.8.3.7 Implementability -121-
2.8.3.8 Cost -122-
2.8.4 Alternative S-4 — Capping With Construction of Above-Ground Disposal
Cell -122-
2.8.4.1 Description -122-
2.8.4.2 Overall Protection of Human Health and the Environment
-123-
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RECORD OF DECISION
TABLE OF CONTENTS
2.8.4.3 Compliance with ARARs -125-
2.8.4.4 Long-Term Effectiveness and Permanence -127-
2.8.4.5 Reduction of M/T/V Through Treatment -128-
2.8.4.6 Short-Term Effectiveness -129-
2.8.4.7 Implementability -129-
2.8.4.8 Cost -130-
2.8.5A Alternative S-5 ~ Excavation And Onsite Treatment With
Solidification/Stabilization
Option A - Onsite Disposal of Treated Waste -130-
2.8.5A.1 Description -130-
2.8.5A.2 Overall Protection of Human Health and the Environment
-132-
2.8.5A.3 Compliance with ARARs -134-
2.8.5A.4 Long-Term Effectiveness and Permanence -136-
2.8.5A.5 Reduction of M/T/V Through Treatment -137-
2.8.5A.6 Short-Term Effectiveness -138-
2.8.5A.7 Implementability -138-
2.8.5A.8 Cost -139-
2.8.SB Alternative S-5 - Excavation And Onsite Treatment With
Solidification/Stabilization
Option B - Offsite Disposal of Treated Material -140-
2.8.5B.1 Description -140-
2.8.5B.2 Overall Protection of Human Health and the Environment
-141-
2.8.5B.3 CompKance with ARARs -142-
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RECORD OF DECISION
TABLE OF CONTENTS
2.8.5B.4 Long-Term Effectiveness and Permanence -142-
2.8.5B.5 Reduction of M/T/V Through Treatment -142-
2.8.5B.6 Short-Term Effectiveness -143-
2.8.5B.7 Implementability -144-
2.8.5B.8 Cost • -144-
2.8.6A Alternative S-6 ~ Capping w/ Excavation & Onsite Treatment of
Principal Threat Waste
Option A-Onsite Disposal of Treated Principal Threat Waste . -145-
2.8.6A.1 Description -145-
2.8.6A.2 Overall Protection of Human Health and the Environment
-147-
2.8.6A.3 Compliance with ARARs -149-
2.8.6A.4 Long-Term Effectiveness and Permanence -151-
2.8.6A.5 Reduction of M/T/V Through Treatment -152-
2.8.6A.6 Short-Term Effectiveness -152-
2.8.6A.7 Implementability -153-
2.8.6A.8 Cost -154-
2.8.6B Alternative S-6 - Capping w/ Excavation & Onsite Treatment of
Principal Threat Waste
Option B - Offsite Disposal of Treated Principal-Threat Waste . -154-
2.8.6B.1 Description -154-
2.8.6B.2 Overall Protection of Human Health and the Environment
-157-
2.8.6B.3 Compliance with ARARs -159-
2.8.6B.4 Long-Term Effectiveness and Permanence -161-
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RECORD OF DECISION
TABLE OF CONTENTS
2.8.6B.5 Reduction of M/T/V Through Treatment -161-
2.8.6B.6 Short-Terra Effectiveness -162-
2.8.6B.7 Implementability -162-
2.8.6B.8 Cost -163-
2.9 WETLAND SEDIMENT ALTERNATIVE ANALYSIS -163-
2.9.1 Alternative W-l — No Action -164-
2.9.1.1 Description -164-
2.9.1.2 Overall Protection of Human Health and the Environment
-164-
2.9.1.3 Compliance with ARARs -164-
2.9.1.4 Long-Term Effectiveness and Permanence -166-
2.9.1.5 Reduction of M/T/V Through Treatment -166-
2.9.1.6 Short-Term Effectiveness -166-
2.9.1.7 Implementability , -166-
2.9.1.8 Cost -166-
2.9.2 Alternative W-2 - Capping with Clean Fill and Off-Site Creation of
Wetlands -167-
2.9.2.1 Description -167-
2.9.2.2 Overall Protection of Human Health and the Environment
-167-
2.9.2.3 Compliance with ARARs -168-
2.9.2.4 Long-Term Effectiveness and Permanence -170-
2.9.2.5 Reduction of M/T/V Through Treatment -170-
2.9.2.6 Short-Term Effectiveness -171-
2.9.2.7 Implementability -171.
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RECORD OF DECISION
TABLE OF CONTENTS
2.9.2.8 Cost -172-
2.9.3 Alternative W-3 - Excavation & Revegetation/Restoration of Wetlands
Option A - Regrading With Clean Fill -172-
2.9.3A.1 Description -172-
2.9.3A.2 Overall Protection of Human Health and the Environment
; -173-
2.9.3A.3 Compliance with ARARs -174-
2.9.3A.4 Long-Term Effectiveness and Permanence -175-
2.9.3A.5 Reduction of M/T/V Through Treatment -175-
2.9.3A.6 Short-Term Effectiveness -175-
2.9.3A.7 Implementability -176-
2.9.3A.8 Cost -176-
2.9.3B Alternative W-3 -Excavation & Revegetation/Restoration of Wetlands
Option B ~ Regrading with Biosolid Compost Material -176-
2.9.3B.1 Description -176-
2.9.3B.2 Overall Protection of Human Health and the Environment
-178-
2.9.3B.3 Compliance with ARARs -178-
2.9.3B.4 Long-Term Effectiveness and Permanence -179-
2.9.3B.5 Reduction of M/T/V Through Treatment -179-
2.9.3B.6 Short-Term Effectiveness -180-
2.9.3B.7 Implementability -181-
2.9.3B.8 Cost . -181-
2.10 COMPARATIVE ANALYSIS OF ALTERNATIVES -181-
2.11 SELECTED REMEDY -185-
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RECORD OF DECISION it
TABLE OF CONTENTS
2.12 STATUTORY DETERMINATIONS _193_
2.12.1 Overall Protection of Human Health and the Environment -193-
2.12.2 Compliance with Applicable or Relevant and Appropriate Requirements
(ARARs) _194_
2.12.3 Cost-Effectiveness -196-
2.12.4 Utilization of Permanent Solutions and Alternative Treatment (or
Resource Recovery) Technologies to the Maximum Extent Practicable
• • -197-
2.12.5 Preference for Treatment as a Principal Element -197.
2.12.6 Five-Year Requirements _199_ ••
3.0 RESPONSIVENESS SUMMARY _199_
3.1 RESPONSIVENESS SUMMARY OVERVIEW -199.
3.2 SUMMARY OF MAJOR QUESTIONS AND COMMENTS RECEIVED BY THE
ROSSVBLLE COMMUNITY _200-
3.3 SUMMARY OF THE MAJOR QUESTIONS AND COMMENTS RECEIVED BY
THE "GROUP" _200.
APPENDIX A PROPOSED PLAN
»
APPENDIX B LETTERS OF CONCURRENCE
»-
APPENDIX C TRANSCRIPT OF NOVEMBER 30,1998 PUBLIC MEETING
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RECORD OF DECISION
TABLE OF CONTENTS
Figure 2-1 Site Location Map -2-
Figure 2-2 Site Layout -3-
Figure 2-3 100 Year Flood Plain Map -15-
Figure 2-4 Wetlands Delineation -16-
Figure 2-5 Regional Cross-Section .". -18-
Figure 2-6 Cross-Section Locations -21-
Figure 2-7 Cross Section A-A' and B-B' -22-
Figure 2-8 Cross Section Locations - 1997 Borings -23-
Figure 2-9 Cross Section A-A', 1997 Borings -24-
Figure 2-10 Cross Section B-B', 1997 Borings -25-
Figure 2-11 Potentiometric Surface Map - October 1, 1990 -26-
Figure 2-12 Potentiometric Surface Map - November 1996 -27-
Figure 2-13 Extent of Lead in Surface Soils -31-
Figure 2-14 Maximum Lead Results in Sediment (TAL Analysis - Ecological Investigation)
, -32-
Figure 2-15 Contaminant Contour in Wetlands - March 1998 -33-
Figure 2-16 Extent of Lead in Subsurface Soils -34-
Figure 2-17 Total Lead Concentrations - Water -37-
Figure 2-18 Lead Results in Surface Water (TAL Analysis - Ecological Investigation) ... -39-
Figure 2-19 Fate and Transport -40-
Figure 2-20 Conceptual Site Model -49-
Figure 2-21 Site and Reference Area Location Map -83-
Figure 2-22 Cleanup Goals v. Excavation Required -98-
Figure 2-23 Contaminant Contour in Wetlands -99-
Figure 2-24 Alternative S-2 Capping -108-
Figure 2-25 Alternative S-3 Capping with Pavement in Place -116-
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RECORD OF DECISION
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TABLE OF CONTENTS
Figure 2-26 Alternative S-4 Capping with Construction of Above-Ground Cell .. -124-
Figure 2-27 Alternative S-5A Treatment and On-Site Disposal .133.
Figure 2-28 Alternative S-6A Treatment w/On-Site Disposal of Treated Principal Threat Waste
-148-
Figure 2-29 Alternative S-6B Treatment w/Off-Site Disposal of Treated Principal Threat
Waste
-158-
Figure 2-30 Excavation Contours ' -189-
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RECORD OF DECISION
TABLE OF CONTENTS
Table 2-1 Non-Hazardous Waste Removed Offsite -7-
Table 2-2 Hazardous Waste Removed Offsite -8-
Table 2-3 Summary of Chemicals of Concern ... -51-
Table 2-4 Cancer Slope Factor -54-
Table 2-5 Reference Dose -55-
Table 2-6 Process Area: Future Risk Summary -59-
Table 2-7 Process Area: Future Use Risk Summary (w/o Groundwater Pathway) -60-
Table 2-8 Process Area: Exposure to Lead -62-
Table 2-9 Process Area: Exposure to Lead (w/o Groundwater Pathway) -63-
Table 2-10 Landfill: Future Risk Summary -64-
Table 2-11 Landfill: Future Risk Summary (w/o Groundwater Pathway) -65-
Table 2-12 Landfill: Exposure to Lead -67-
Table 2-13 Landfill: Exposure to Lead (w/o Groundwater Pathway) -68-
Table 2-14 COCs Distribution and Hazard Quotient Calculations -71-
Table 2-15 Ecological Exposure Pathways of Concern -79-
Table 2-16 COC Concentrations Expected to Provide Adequate Protection of Ecological Receptors
-92-
Table 2-17 Remedial Goals -94-
Table 2-18 Summary of Soil Alternatives Evaluation -103-
Table 2-19 Summary of Wetland Sediment Alternatives Evaluation -165-
Table 2-20 Comparative Analysis of Soil Alternatives -182-
Table 2-21 Comparative Analysis of Wetland Sediment Alternatives -183-
Table 2-22 Excavation Standards -188-
Table 2-23 Capital Costs for Selected Remedy -191-
Table 2-24 Operation and Maintenance Costs for Selected Remedy -192-
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Record of Decision
Ross Metals OU#1
1.0 DECLARATION
SITE NAME AND LOCATION
Ross Metals, Operable Unit #1
100 North Railroad Street
Rossville, Fayette County, Tennessee
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for the Ross Metals Site, Operable Unit #1, in
Rossville, Fayette County, Tennessee. This action is. chosen in accordance with CERCLA, as amended by
SARA, and, to the extent practicable, the National Contingency Plan. This decision is based on the
Administrative Record for this Site.
The State of Tennessee concurs with the Selected Remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this Site, if not addressed by implementing the
response action selected in this ROD, may present an imminent and substantial endangerment to public health,
welfare, or the environment.
DESCRIPTION OF THE REMEDY
This operable unit is the first action of at least two operable units that are planned for the Site.
This operable unit remedy addresses source materials (soil, sediment, waste, pavement, and debris) through
treatment and off-Site disposal of principal and low-level threat wastes.
The major components of the remedy include:
• Decontamination, demolition, and off-Site disposal of pavement and buildings with recycling of metal
debris;
• Excavation of contaminated soil, landfilled slag, and contaminated sediment with appropriate
confirmation sampling;
• Backfill of excavated subsurface-soil areas and landfill with clean soil;
• Stabilization/solidification/fixation of contaminated soil, stockpiled slag, landfilled slag, and wetlands
sediment;
Declaration -1
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Record of Decision
Ross Metals OU#1
• Off-Site disposal of soils, slag and sediment at a RCRA-nonhazardous waste disposal facility;
• Application of a layer of biosolids over the Site. Grass seeding of the facility and landfill areas; and
revegetation of the Site wetlands according to the wetlands revegetation plan developed by EPA, 1998.
• Development of a maintenance and monitoring plan to assess the effectiveness of the cleanup action.
STATUTORY DETERMINATIONS
The Selected Remedy is protective of human health and the environment, complies with Federal and State
requirements that are legally applicable or relevant and appropriate to the remedial action, and is cost-effective.
This remedy utilizes permanent solutions and alternative treatment technologies, to the maximum extent
practicable for the Site. This Remedy satisfies the statutory preference for treatment as a principal element.
Because this Remedy will not result in hazardous substances remaining on-Site above health-based levels that
allow for unlimited use and unrestricted exposure, a five-year review will not be required for this remedial
action.
ROD DATA CERTIFICATION CHECKLIST
The following information is included in the Decision Summary section of this Record of Decision. Additional
information can be found in the Administrative Record file for this Site.
• Chemicals of Concern (COCs) and their respective concentrations;
• Baseline risk represented by the COCs;
• Cleanup levels established for COCs and the basis for the levels;
• Current and future land and ground-water use assumptions used in the baseline risk
assessment and ROD;
Land use that will be available at the Site as a result of the Selected Remedy;
• Estimated capital, operation and maintenance O&M), and total present worth costs; discount
rate; and the number of years over which the Remedy cost estimates are projected; and
• Decisive factors that led to selecting the Remedy (i.e., description of how the Selected Remedy
provides the best balance of tradeoffs with respect to the balancing and modifying criteria).
Date Richard D. Green, Director
Waste Management Division
Declaration - 2
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Record of Decision
Ross Metals OU#1
2.0 DECISION SUMMARY
2.1 SITE NAME, LOCATION, AND DESCRIPTION
The RM facility is located at 100 North Railroad Street in Rossville, Fayette County, Tennessee, (see
Figure 2-1). The facility's geographic coordinates are 35°02' 57" North latitude and 89° 32' 55" West
longitude, as shown on the U.S. Geological Survey (USGS) topographic map quadrangle for
Rossville, Tennessee (U.S. Geological Survey [USGS] 1965). The Site includes contaminated
wetlands to the north and northeast of the process area and the landfill. It is bordered by residential
property to the east, the Southern Railroad tracks to the south, and a municipal wastewater treatment
plant to the west. A Site layout is presented in Figure 2-2.
2.2 SITE HISTORY AND ENFORCEMENT ACTIVITIES
From 1978 until June 20,1992, RM operated a secondary lead smelter at the Site. Prior to 1978, the
property was undeveloped. RM produced specification alloyed lead that was sold for use in
manufacturing vehicle batteries, lead shot pellets, and sheet lead (radiation shields) (Ogden
Environmental Energy Services Company [Ogden] 1994). The facility received spent lead acid
batteries, spent lead plates, lead oxide, scrap metal, and other lead waste and material from various
businesses and industries, including battery crackers and battery manufacturers. The primary material
used for the recycling process was spent lead acid batteries, with automotive and industrial batteries
accounting for 80 percent of the raw material processed. The remaining 20 percent consisted of other
lead-bearing materials, such as recycled dross, dust slag, and factory scrap. Facility operations
included not only the smelting of lead and other scrap metals but a variety of other products, such as
crushed drums, limestone, steel, and cast iron. These materials were added to the blast furnace as
flux to create a reducing atmosphere. Wastes generated from the process included slag, plastic chips,
waste acid, lead emission control dusts, and lead-contaminated stormwater (Black & Veach Waste
Science, Inc. [B&V] 1996).
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NMfinphis
Not to Scale
Chattanooga
Ross Metals Site
Rossville, TN
Federal Programs Corporation
4 tabtUtv otcunp Dmitri UcKmlx.
Site Location
Figure No.:
2-1
10/98
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ill
ill
BLAST SLAG MONOFILL
8" CONCRETE
SLAB
NORTH STORM WATER
COLLECTION SUMf»
SLAG
FIXATION
CONTAINER
2 BAG
HOUSE
4 BAG
HOUSE
CENTRALv
FACILITY t3
WASTE WATER
TREATMENT
CENTER
FURNACE
RAW MATERIALS
REFINERY
EAST STORM WATER
COLLECTION SUMP
LANDFILL AREA
FEN CELINE
WETLAND AREA
240'
SCALE IN FEET
Ross Metals Site
Rossville, Tennessee
CDM Federal Programs Corporation
A tutoUay el Canp f\tn* t I'rn Hie.
Site Layout
Figure No.
2-2
7/98
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Record of Decision
Ross Metals OU#1
Upon receipt, batteries were stored on pallets located east and southeast of the facility; each pallet
held about 50 batteries. The batteries were then conveyed to the wrecker building for the battery
breaking operation. Wastewater used for battery breaking operations conducted inside the wrecker
building was managed by an on-Site wastewater treatment system. Water was used to separate lead
from other battery components based on its density. After separation, lead was transported to the
blast furnace slag area, where lead materials were passed through a smelter. According to facility
representatives, 99 to 99.5 percent of the lead content was recovered. The molten lead product was
then moved to the refinery area. The refinery area consisted of four kettles that received molten lead
and formed ingots. The ingots were then moved to the finished storage area until they were shipped
to customers (B&V 1996).
Acid and sludge obtained during the battery breaking operation contained residual amounts of lead
and lead acid; the acid and sludge were transferred to the wastewater treatment unit to reclaim the
remaining lead. Lead was reclaimed by allowing it to settle further in aboveground collection tanks.
This lead sludge, collected prior to neutralization, was transferred to the blast furnace area and
immediately fed into the furnace. The remaining acid was neutralized with liquid caustic soda. Upon
neutralization, the solution was held for additional settling to precipitate dissolved metals. Sludge
resulting from the neutralization process was also collected in settling tanks and recycled into the
blast furnace with other lead scrap. The pH of the waste stream generated by the facility was further
adjusted, and sludge-free effluent was discharged to the Rossville Municipal Sewage Treatment
Facility (Tibbels 1983).
Several areas of the operating facility contained large volumes of lead-bearing materials. With the
exception of the container storage area, the lead-bearing materials were not containerized; instead,
they were placed on the asphalt foundation of the facility or directly on facility soils.
From 1979 until December 1988, blast slag that had accumulated as a part of the smelting process
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Record of Decision
Ross Metals OU#1
was disposed of in an on-Site landfill. On November 3, 1986, RM submitted a petition for
registration for an existing industrial landfill used to dispose of blast furnace slag; RM considered the
slag a nonhazardous industrial waste. On November 8, 1988, RM submitted a RCRA Part B
application stating tbat slag had been deposited on Site. Diagrams included in the application show
slag piles both inside and outside of the area designated as the landfill. EPA's RCRA Compliance
Section conducted a sampling investigation on December 7,1988, to determine if the waste generated
at the facility should be regulated. On December 20,1988, the Tennessee Department of Health and
Environment (TDHE) suspended all further processing of the request until results from the EPA
sampling event could be assessed and the EPA could determine whether the blast 'slag was a
nonhazardous waste (B&V 1996). Several references in the EPA files for the RM Site debate the
status of blast slag as a hazardous waste. File material also indicates that on April 20, 1990, RM
applied for a solid waste classification variance for the blast slag. RCRA also conducted a sampling
investigation on May 9, 1990, to determine if smelting and landfilling activities at the facility were
causing adverse environmental impacts. The variance was denied on June 6, 1990, because EPA
determined that blast slag was a hazardous waste and subject to the full extent of RCRA regulations.
In September of 1990, RCRA issued a Complaint and Compliance Order against Ross Metals. After
several months of extensive negotiations, the parties reached an agreement to settle the case.
However, the company never signed the Consent Agreement, because of its precarious financial
condition. In 1992, Ross Metals, Inc. received an Administrative Dissolution under Articles of
Incorporation. There is no known successor entity. Because of this, all State and Federal RCRA
enforcement actions at the Site ceased.
Once negotiations failed with Ross Metals and all operations ceased at the facility, the Site was
referred to EPA's ERRB. In a letter dated October 25,1993, ERRB notified TDEC that the Site was
eligible for a removal action. Prior to any ERRB clean-up activities, TDEC was approached by an
interested third party, Greyhound Finance Services (GFS), regarding the possible clean-up of the Site.
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Record of Decision
Ross Metals OU#1
EPA and TDEC decided a State Lead RCRA Closure performed by GFS would be beneficial to all
parties. An agreement concerning the RCRA Closure was never reached, therefore the Site was
referred back to ERRB in June of 1994.
On June 15, 1994, ERRB conducted a Site visit. Based upon ERRB's file review and Site visit, the
Ross Metals Site met the criteria for a high priority removal action. The removal action began in
September 1994 and was completed in June 1995. The removal consisted of segregating, staging,
or removing forty-six wastestreams. The wastestreams, descriptions, and approximate volumes of
each is listed in the Tables 2-1 and 2-2.
Approximately 6,000 cubic yards (CY) of lead bearing blast slag was staged in on-Site buildings. The
removal action was completed in August 1995. During the removal action, EPA was also conducting
a Site investigation for the NPL listing process. In October 1996, the North Site Management Branch
began remedial investigations. The Site was listed on the final National Priorities List March 31,
1997.
An Engineering Evaluation/Cost Analysis (EE/CA) was finalized in February 1998. In considering
the information presented in the EE/CA and the statutory limits which apply to non-time critical
removal actions, EPA determined that a Remedial Investigation/Feasibility Study Report that
develops appropriate remedial action alternatives was needed for this Site.
On March 24th, 1998, EPA sent general notice letters to the Potentially Responsible Parties (PRPs).
The threat of human exposure and reports of trespassing caused EPA to perform a removal action
in June and September of 1998. About 10,000 CY of slag are landfilied in an unlined and unsecured
area located just north of the facility process area. About 6,000 CY of stockpiled lead slag material
are still stored at the facility inside deteriorating sheet metal buildings. The buildings are no longer
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:'"'"1 "''%, "}'<<',*?,"'*': , '^^^/^^^^Oia^^9^^^^^€^^St "<
Quantity Removed
Not Applicable
230 cubic yards
2 each
371 gallons
Not Applicable
850 cubic yards
88 containers
20 cubic yards
17 cubic yards
Dates Removed
9/26-10/10/94
10/3 - 12/20/94
10/21/94
10/25/94
10/31/94
11/05-11/18/94
11/11/94
11/30/94
12/12/94
Type of Waste Removed
c
battery cracking
equipment; ingot casting
conveyor, baghouse
blower, 1 7 colling
crucibles, battery saw,
conveyor belt, tumbler
and associated
framework.
construction-type debris
baghouses
diesel fuel
baghouse equipment:
baghouse frame and
associated ductwork,
screen
conveyor, cross members,
catwalk and ladder, scrap
metal
laboratory chemicals
old tires
soda ash
Type of Disposal
Facility
Reclamation Facility
Landfill
Reclamation Facility
Reclamation Facility
Reclamation Facility
Recycling Facility
Facility Local
High School Local
Landfill Recycling
Facility
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- S# V*J ss&*ik S^JW?;^ ^ 5? r$ $|
Quantity Removed
250 cubic yards
34,430 Ibs
288 cubic yards
307,220 Ibs
330 gallons
330 gallons
90 gallons
110 gallons
3500 gallons
Dates Removed
11/14-11/15/94
12/02 - 12/12/94
12/08 - 12/19/94
12/12 - 12/21/94
12/16/94
12/16/94
12/16/94
12/16/94
12/16/94
d^»^dtCS6^te' ^''/* "?->.
Type of Waste Removed
battery chips/leaded
debris
leaded tank sludges
((D008.D006)
leaded debris; debris,
soil, floor dust, rags,
PPE, cinderblocks
(D008)
raw materials
(K069.D008)
base-neutral liquid
motor oil
hydrochloric acid
sodium hydroxide
sodium hydroxide
Type of Disposal
Facility
Regional TSDF
Local TSDF
Regional TSDF
Reclamation Facility
Local TSDF
Local TSDF
Local TSDF
Local TSDF
Local TSDF
-8-
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Record of Decision
Ross Metals OU#1
providing protection from weather conditions because of deterioration. Data collected in the
investigation revealed lead-contaminated surface soils (outside the fenced facility - approximately 8.58
acres). This area is adjacent to residential property and is located within a designated wetland. The
removal action consisted of placing tarpaulins over the 6,000 CY of stockpiled lead slag and installing
security fencing around the contaminated surface soils and landfill.
The Remedial Investigation/Feasibility Study was finalized in November 1998
2.3 HIGHLIGHTS OF COMMUNITY PARTICIPATION
Local officials have said that area residents have been fairly quiet about the presence of an NPL Site
in the community. A Fayette County Health Department representative said they have received very
few questions regarding health concerns.
A Fact Sheet was issued January 1997, prior to a Public Availability Session, which was conducted
by EPA and the Tennessee Department of Environment and Conservation. The Availability Session
was conducted January 6,1997. No citizens attended.
A fact sheet was released immediately after the Site was placed on the NPL. The Site was placed on
the NPL on March 31, 1997.
The Agency for Toxic Substances and Disease Registry (ATSDR), after reviewing the available
environmental data suggested that people were possibly exposed to metals in on-Site and off-Site
surface soils and water. Therefore, ATSDR decided to conduct an Exposure Investigation (El) to
determine the lead level present in the soil of the adjacent residences and offered blood-lead level
testing to the residents adjacent to the Site. The El also included soil and dust testing for lead in
residential areas. The El conducted was to investigate a possible public health problem and develop
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Record of Decision
Ross Metals OU#1
plans for its control.
Following the issuance of notices to Potentially Responsible Parties (PRPs), EPA held an
informational public meeting on April 14, 1998. During that meeting, citizens were encouraged to
form a Community Advisory Group (CAG).
ATSDR held a community meeting with residents of Railroad Street to explain the purpose of the El
on April 21, 1998. Prior to the community meeting, ATSDR distributed flyers throughout the
community and coordinated media outreach with local newspapers in the area. In conjunction with
the Tennessee Department of Environment and Conservation, ATSDR collected blood, soil and wipe
samples from identified residents on May 30, 1998.
The Rossville CAG, composed of approximately 10 citizens, met for the first time in May 1998. The
CAG meets the first Tuesday of each month, as needed. Their mission statement is "The Rossville
Community Advisory Group exists to insure that the cleanup of the Ross Metals Superfund Site
protects human health and the environment."
A Proposed Plan Fact Sheet was released to the public which described EPA's preferred remedial
alternative and invited public comments about the alternatives. The Administrative Record file was
made available November 18,1998. The file can be found at the information repository maintained
at the EPA Docket Room in Region 4 and Rossville City Hall. The Notice of Availability of these
two documents was published in the Commercial Appeal on November 18,1998. A public comment
period was held from November 18, 1998 to December 18, 1998. An extension to the public
comment period was requested. As a result, it was extended to January 19, 1998. In addition, a
public meeting was held on November 30,1998 to present the Proposed Plan to a broader community
audiences than those that had already been involved at the Site. At this meeting, the Tennessee
Department of Environment and Conservation answered questions about problems at the Site and the
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Record of Decision
Ross Metals OU#1
remedial alternatives. EPA also used this meeting to solicit a wider cross-section of community input
on the reasonably anticipated future land use. Public comments were received during this period.
A transcript of the public meeting is included in the Responsiveness Summary, which is part of this
ROD.
This decision document presents the selected remedial action for the Ross Metals OU#1 in Fayette
County Tennessee. The remedial action chosen, is in accordance with CERCLA, as amended by
SARA, and, to the extent practicable, the National Contingency Plan. The decision for this Site is
based on the Administrative Record.
2.4 SCOPE AND ROLE OF OPERABLE UNIT
As with many Superfirad sites, the problems at the Ross Metals OU #1 are complex. As a result,
EPA organized the work into two operable units (OUs). These are:
• OU #1: Contamination in the source materials.
• OU#2: Contamination in the aquifer.
The scope of this response action is to cleanup contaminated soil, wetlands, buildings and waste.
Incidental ingestion of soil and the physical hazards pose the major risks to human health. Sediment
poses an acute risk to ecological receptors. The cleanup of the source materials is proposed to
prevent exposure to contaminated source materials and prevent contamination of groundwater and
surface water. This response action is the first of two operable units that will be used to address the
contamination of the entire Site.
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Record of Decision
Ross Metals OU#1
Operable Unit #1 will address:
• Waste Slag (landfilled and stockpiled)
• Contaminated soil (in facility area and landfill area)
• Buildings
• Demolition debris (pavement)
• Contaminated sediment (in wetlands)
EPA generally expects to use treatment to address principal threats posed by a site, wherever
practicable. Principal threat wastes are those source materials considered highly toxic or mobile that
cannot be reliably contained or would present a significant risk to human health or the environment
should exposure occur. For the Ross Metals Site, principal threat wastes conservatively include
approximately:
• 600 cubic yards of soil
• 8,200 cubic yards of sediment
• 6,000 cubic yards of stockpiled slag
• 10,000 cubic yards of landfilled slag
Operable Unit #2 will require additional Site characterization studies in order to determine the nature
and extent of potential groundwater contamination. A Feasibility Study may be required to identify
and evaluate possible groundwater remedial actions.
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Record of Decision
Ross Metals OU#1
2.5 SITE CHARACTERISTICS
2.5.1 Land Use
The area surrounding the Site is primarily rural or residential. A municipal wastewater treatment
plant is located adjacent to the western Site boundary, and no other known industries would have
contributed contamination to the Site. The towns of Rossville, Rossville Junction, and New Bethel
are located within a 4-mile radius of the Site; the total population within the 4-mile radius is 1,947.
The nearest school is located 0.3 miles southeast of the Site.
Current and reasonably anticipated future land uses and current and potential beneficial ground-water
uses are discussed in Sections 2.6.1.2 and 2.6.1.5.
2.5.2 Climatology
The RM Site is located in southwest Tennessee, about 30 miles west of Memphis. This area has an
average annual daily temperature of about 62.3 ° F. The normal daily minimum and maximum
temperatures are 52.4 °F and 72.1 °F, respectively. Annual precipitation is 52.10 inches. (Source:
National Weather Service Historic Data for Memphis, 1961-1990).
2.5.3 Physiography
The RM Site is located in the Gulf Coast Plain Physiographic Province of western Tennessee, which
is characterized by unconsolidated near-surface sands, silts, and clays. Elevations within the
surrounding area vary from 290 to 470 feet National Geodetic Vertical Datum (NGVD) (USGS
1965). Ground elevations within the Site boundaries range from about 315 NGVD near the main
office building to about 310 NGVD at the northeast corner of the fenced portion of the Site. The RM
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Record of Decision
Ross Metals OU#1
Site is located about 0.5 miles south of the Wolf River.
The RM Site consists of an old fenced facility area enclosing about 5.5 acres and a blast slag landfill
covering about 2.5 acres north of the old fenced area, and contaminated wetlands located north and
east of the facility and landfill areas, approximately 8.58 acres. The fenced area includes several
buildings, most of which are constructed of sheet metal. Most of the area inside the fenced facility
area is paved with either concrete or asphalt, and an asphalt curb is.located just inside the fence. The
curb was apparently constructed to divert storm water runoff to the storm water collection sump in
the northeast corner of the property. Several stockpiles of waste slag are located in various buildings,
including the wrecker building, the slag fixation container, the furnace raw materials refinery building,
and the shipment building. The buildings are generally in poor condition, and some are in danger of
collapsing.
The landfill area was constructed in a wetland area north of the fenced area. Several soil-covered
mounds ranging up to 6 feet high are located in the landfill area. An 8-inch-thick concrete slab is
located just north of the gate in the landfill area; however, evidence suggests that some slag may be
buried beneath the concrete slab. An estimated 10,000 CY of slag is buried throughout the landfill
at thicknesses of up to about 4 feet. About 1 to 2 feet of fill material has been placed over the slag
throughout the landfill.
As indicated on Figure 2-3, the RM facility and the wetlands north and east of the facility are located
in a 100-year floodplain. Figure 2-4 illustrates the type of wetlands that are part of the RM Site.
2.5.4 Surface Water
Storm water runoff from the entire facility drains into a basin located at the northeastern corner of
the fenced facility. The basin discharged to a small wetland area located north and northeast of the
-14-
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APPROXIMATE LOCATION
ROSS METALS, INC.
Legend:
100 Year Flood
NOTES:
1. Flooding effects from Wolf River
2. Flood information taken from Flood
Insurance Rate Map for the town of
Rossville, Fayette County, Tennessee.
O1
Scale
250'
500'
Ross Metals Site
RossviUe, TN
Federal FVograms Corporation
A iutwM»y of Ctmp Dauar t UcKoa Inc.
100 Year Flood
Plain Map
Figure No
2-3
10/98
-------
liond Community T>p«
U,V) Scrub/Shrub
Zj £>nergent
3rood-L«ov4d Deeiduout Forest
ED -Jcea<-L«ovi(i Deciuuous
-Bold Cvpr«3i Forest
GRAPHIC SCALE
«» .-0 100 XO
Ross Metals Site
Rossville, Tennessee
wetlands Delineation
CDM Federal Pro|rtm9 Corporktioa
-------
Record of Decision
Ross Metals OU#1
facility area. During an inspection on October 14, 1993, the holding dike of the storm water basin
was observed to be overflowing, and storm water was apparently not being collected in on-Site
storage tanks for wastewater treatment. Runoff from the landfill also drained to the wetland located
north and northeast of the landfill; in addition, the landfill has no documented run-on, run-off, or
collection facilities. The landfill is documented to lie adjacent to a wetland area; however, the
wetlands are not delineated on the National Wetland Inventory (NWI) map.
The wetlands and wooded area extend to the north and ultimately drain to the Wolf River, which is
the main drainage body for the region. The Wolf River flows west, through Memphis, and into the
Mississippi River.
The Rossville municipal wastewater treatment plant is located west of the RM Site. The outfall for
the treatment plant is located on the Wolf River at the Highway 194 bridge, about 1.5 miles upstream
of the facility. The outfall and the treatment plant are not expected to have any adverse effect on the
wetland located north and northeast of the Site.
2.5.5 Geology and Hydrogeology
The Site is located in the Gulf Coast Plain Physiographic Province of Western Tennessee, which is
characterized by unconsolidated near-surface sands, silts, and clays. Included in this sequence of
unconsolidated sediments is the Memphis Sand, which contains an important water-bearing zone
known as the Memphis aquifer. The Memphis Sand consists of a thick body of sand that contains
clay and silt lenses or beds at various horizons. The sand ranges from very fine to very coarse (B&V
1996). A regional cross-section is provided as Figure 2-5.
Recharge of the Memphis aquifer generally occurs along the outcrop of the Memphis Sand. Recharge
results from precipitation and from downward infiltration of water from the overlying fluvial deposits
-17-
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Sboby County LHIaCvpww loowrratcWa Rfcer
fcyetl* County canal canal
Low* and fluvial dtpeiiU /Wuvfum ro:0-32
Ross Metals Site
Rossvffle, Tennessee
COM Federal Programs Corporation
Regional Cross-Section
Figure No.
2-5
9/98
-------
Record of Decision
^ • Ross Metals OU#1
and alluvium, where present. In the outcrop-recharge belt, the Memphis aquifer is under water-table
conditions (unconfined), and the configuration of the potentiometric surface is complex and generally
conforms to the topography. West of the outcrop-recharge belt, the aquifer is confined by other
members of the Claiborne Group containing clay, silt, sand, and lignite. Groundwater in the
unconfined portion of the Memphis aquifer typically flows to the west. Transmissivities of the
Memphis aquifer in the Memphis area range from about 20,000 to 42,800 square feet per day.
However, USGS literature referenced only one test conducted in Fayette County (the location of the
RM facility); the test indicated a transmissivity of 2,700 square feet per day. (B&V 1996).
The RM facility was constructed in part of a wetland; RM reportedly spread and compacted several
feet of clay prior to constructing the facility. A1987 memorandum written by the State of Tennessee
indicates that clayey silt was present in the area of the industrial landfill before its construction; the
clayey silt was present from 0 to 3 feet, and a silty clay was present from about 3 to 7 feet.
In May 1988, five monitoring wells were installed by RM's contractor. The borings for the
monitoring wells indicated the presence of about 11 feet of silty clay and clayey silt overlying sands
of the Memphis Sand aquifer. In May 1997, eight additional monitoring wells were installed at the
Site. A soil boring (T-4) was also drilled in the southwest comer of the Site, but it was not completed
as a monitoring well. Monitoring well depths ranged from 23 to 28 feet below ground surface (bgs).
Soil samples collected during soil boring activities revealed that Site stratigraphy conformed generally
to the May 1988 data collected by the RM contractor. The predominant soil type observed in
surficial to shallow soil intervals (within 10 feet bgs) consists of gray, mottled, dry to moist clay. The
clay unit contains a high percentage of silt (except in the western portion of the Site, where it grades
to sandy clay); exhibits low plasticity and variable organic content; and occasionally exhibits a brown
to tan coloration. The clay unit extends from ground surface to depths ranging from 7 to 20 feet bgs
and is generally thickest in the western portion of the Site.
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Record of Decision
Ross Metals OU#1
Sands encountered at the Site are fine-grained and grayish-white in color. Sands are generally well
sorted and exhibit a fine to medium texture with occasional clay lenses and very little silt. Sand
textures generally coarsen with increasing depth, becoming mediumto coarse in texture below 20 feet
bgs. A trend toward a decrease in the degree of sorting and an increase in the coarse sand fraction
was also observed in samples collected from below 20 feet bgs.
Groundwater at the Site is encountered in the upper portion of the sand section. The aquifer
possesses a degree of hydrologic confinement due to the pervasive upper clay section, and water
levels in Site monitoring wells rise above the base of the clay unit.
Information collected during the 1988 and 1997 investigations conducted by the RM contractor and
PRC, respectively, conflict somewhat with a Tennessee memorandum written in 1987 concerning the
actual depth of clay beneath the Site. However, it can be assumed that at least 7 feet of silty clay and
clayey silt are present directly under the Site; it remains undetermined how much, if any, of it is native
material. Some of the clay may be part of the base of the Cook Mountain Formation or a clay lens
within the upper part of the Memphis Sand. Occurrences of the overlying members of the Claiborae
Group in the area of the Site may be thin or absent above the Memphis Sand. Figures 2-6 and 2-7
present cross-section information obtained from the EPA Site investigations. Additional cross-
sections were prepared for this RI/FS report using boring logs from monitor wells constructed in
1997. The 1997 boring cross-section locations are illustrated on Figure 2-8. The 1997 cross-
sections are presented on Figures 2-9 and 2-10.
Although regional groundwater flows to the west, measurements collected fromSite monitoring wells
in 1990 indicate that shallow groundwater movement is north towards the Wolf River. However,
measurements collected from the monitoring wells in 1996 suggest a more northwesterly movement
of groundwater. Figures 2-11 and 2-12 present groundwater flow based on measurements collected
in an October 1990 investigation, and November 1996 investigation, respectively. Two municipal
-20-
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BLAST SLAO MONOFI
NORTH STORM WATER
COLLECTION SUM?-,
SLAG
FIXATION
CONTAINER
OUST 12
FURNACE IHOU
WA
HOLDING
TANKS
WASTE WATER
O *•! TREATMENT
CENTER
FURNACE
RAW MATERIALS
REFINERY
EAST STORM
COLLECTION
LEGEND
0 150'
300'
SCALE IN FEET
'A CROSS SECTION
LOCATION
5 TEMPORARY WELLS
> MONITOR WELL
LOCATION
— LANDFILL AREA
—- FENCELINE
WETLAND AREA
Ross Metals Site
Rossville, Tennessee
CDM Federal Programs Corporation
A Kttifay cf Camp Dnmr * HcX* tic.
Cross—Section Locations
Figure No
2-6
7/98
-------
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LEGEND
J), TEMPORARY 'WELLS
J», MONITOR WELLS
LANDFILL AREA
—- FENCEUNE
•*• WETLAND AREA
K%/J REMOVAL AREA
200'
SCALE IN FEET
Boas Metals Site
Rossville, Tennessee
COM Federal Pruranu C»n>oi.Uo»
» iw ^
Cross Section Locations—1997 Borings
Figure No.
2-8
8/98
-------
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Ross Metals Site
Rossville, Tennessee
COM Federal Proerams Corporation
A MMfay «/ Carp Dnmr * HcXtt *t
Cross Section A-A', 1997 Borings
Figure No.
2-9
8/98
-------
•ft,
hi
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0 5Q' 100'
=a
HORIZONTAL SCALE
Ross Metals Site
Rossville, Tennessee
CDM Federal Programs Corporation
4 K&tay ef Cmp Onatr t Ucftt tot
CLAYEY SAND
ORGANIC LAYER
Cross Section B-B', 1997 Borings
Figure Ho.
2-10
8/98
-------
SLAG
FIXATION
CONTAINER
NORTH STORM WATER
COUECTICN SUMR-
3O&3
2 BAG
HOUSE
2 BAG
HOUSE
4BAG
HOUSE ._ .
TORU WA
__,,-. .-.'HOLDING
O O OO TANKS
..WASTE WATER
FURNACE
RAW MATERIALS
REFINERY
I TREATMENT
CENTER
503
308.5
309
150'
ES
SCALE IN FEET
300'
Ross Metals Site
Ross-ville, Tennessee
COM Federal Programs Corporation
* ***fay if Coop Cnatr * IttW he
GROUNDWATER CONTOUR LINE
GROUNDWATER ELEVATION
MONITOR WELL LOCATION
LANDFILL AREA
FENCELINE
WETLAND AREA
Potentiometric Surface Map
October 1. 1990
Figure No
2-11
7/98
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-------
Record of Decision
Ross Metals OU#1
supply wells and three industrial production wells are located within 0.75 mile of the Site and are
screened in the Memphis aquifer.
2.5.6 Previous Investigations
EPA has conducted numerous sampling investigations at the RM Site. A discussion of sample results
from these investigations is presented in Section 2.5.7.
In May and November 1990, EPA Region 4 conducted RCRA investigations that included the
collection of groundwater, surface water, surface soil, and slag samples.
From September 22 through December 29, 1994, the EPA Emergency Response and Removal
Branch (ERRB) conducted an emergency time-critical removal of hazardous substances at the RM
Site. Source materials, structures, and debris were removed and disposed of off Site. Approximately
4,400 gallons, 170 tons, and 1,700 CY of waste were removed. Groundwater and surface soil
samples were also collected during this event.
During the week of June 13,1995, EPA conducted a Site Investigation for Hazard Ranking System
purposes. Groundwater, surface and subsurface soil, sediment, and surface water samples were
collected.
In November 1996, EPA conducted site characterization studies that included surface and subsurface
soil, groundwater, surface water, and wipe samples from the buildings.
During the weeks of May 19 and May 26,1997, EPA conducted additional field sampling at the Site.
EPA completed the installation and sampling of nine monitoring wells, including borehole soil
sampling. Two additional groundwater samples were collected from on-Site temporary wells, and
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Record of Decision
Ross Metals OU#1
one groundwater sample was collected from a well at the wastewater treatment plant on adjacent
property located west of the RM Site. Soil samples from the landfill and a composite sample of slag
stockpiles were also collected for analysis. ,
The presence of lead-based paint in homes near the Site has been documented. File material indicates
that children living near the Site have had elevated levels of lead in their blood. The children were
moved by Housing and Urban Development. Although the documentation is not strong enough to
establish an observed release, the findings are significant because of the proximity of adjacent
residences and the history of the RM Site. Soil samples collected adjacent to nearby homes
indicated 1,170 parts per million (ppm) of lead. An EPA time-critical removal (1994) of soils was
performed at this residence.
In April 1997, EPA collected surface water, sediment, plant tissue, grasshopper, and frog tissue
samples as part of the completion of an ecological risk assessment for the Site. All the sediment
samples were analyzed for arsenic, cadmium, copper, and lead via field portable x-ray fluorescence
(XRF). In addition, several of the surface water and sediment samples collected for the ecological
risk assessment were analyzed for TAL metals by an offsite laboratory. Samples from two of the
surface water and sediment locations analyzed for TAL metals also were analyzed for volatile organic
compounds (VOCs), base neutral acids (BNAs) and pesticide/PCBs. Surface water and sediment
results are discussed in Section 2.5.7.1 and 2.5.7.3.
In December 1997, EPA/ERTC collected and performed on-Site analysis of soil samples for metals
contamination, to delineate contaminant levels in the wetlands. Additionally, the effort involved the
completion of treatability studies to evaluate soil treatment, and the completion of a wetlands
excavation and revegetation plan to provide a design for wetlands restoration. Target elements were
arsenic, cadmium, lead, and zinc. A reference grid was established on the Site and surface samples
were collected at the grid nodes. The grid included the wetlands located north and east of the Site.
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Record of Decision
Ross Metals OU#1
The results of 29% of the samples were confirmed by Inductively Coupled Plasma (ICP) analysis.
In June and September 1998, EPA conducted a second time-critical removal. The removal action
included fencing the soils which contained lead above 400 ppm; covering the waste piles with
tarpaulins; and posting the Site as a Superfimd Site.
2.5.7 Nature and Extent of Contamination
2.5.7.1 Soil and Sediment
Surface soil and sediment samples were collected at depths of up to 2 feet bgs. Lead-contaminated
surface soil is present across the Site and in the wetlands north and east of the facility. Lead
concentrations in most surface soil and sediment samples collected throughout the Site exceeded 400
ppm. In addition, aluminum, antimony, arsenic, barium, cadmium, copper, iron, manganese, selenium,
and vanadium were detected above risk-based remedial goal option (RGO) levels. Figure 2-13 and
2-14 illustrate the extent of surface soil lead contamination throughout the Site. Additional samples
collected as part of an ecological risk assessment and analyzed using both XRF analysis and ICP
procedures showed a widespread presence of lead and other COCs defined in the risk assessment
above RGO levels in the wetlands north and east of the Site. Figure 2-15 illustrates lead
concentration contours in the wetlands based on XRF and TAL samples collected in December 1997.
The highest levels of subsurface soil contamination were found in two isolated locations at the Site;
east of the wrecker building, and southeast of the truck wash. Figure 2-16 illustrates the extent of
subsurface soil lead contamination at the Site. Elevated lead concentrations were collected at depths
ranging from 18 to 40 inches beneath the pavement near the wrecker building and the truck wash and
at depths of up to 5.5 feet in the landfill; however, as Figure 2-16 indicates, none of the soil samples
collected from beneath the buried slag exhibited lead concentrations in excess of the RGO level.
-30-
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LEGEND
0-400 mg/kg
> 4OO mg/kg
INTERPRETED ISOCONTOUR LINE,
400 mg/kg INTERVAL
LEAD CONCENTRATION, mg/kg
SOIL SAMPLE LOCATION
ERRB SOIL SAMPLE LOCATION
ESD SOIL SAMPLE. PRE '96
COMPOSITE SOIL SAMPLE. CONCENTRATION
INSIDE (ERRB SAMPLE)
COMPOSITE SOIL SAMPLE. CONCENTRATION
INSIDE (ESD SAMPLE)
PRE-REMEDIAL SOIL SAMPLE
LANDFILL AREA
WETLAND AREA
110'
220'
SCALE IN FEET
Ross Metals Site
Rossville, Tennessee
CDM Federal Programs Corporation
- « MB**7 «/ C«v CtUBt * UlSl «c
Extent of Lead in Surface Soils
Figure No.
2-13
8/98
-------
30
N
.31
.11
.32
U1I-S
.22
•
a 26
11*49
LEGEND
TAL ANALYSIS SAMPLE LOCATION
SAMPLE LOCATION
TEMPORARY WELL
MONITOR WELL
LANDFILL AREA —
FENCELINE -
WETLAND AREA
REMOVAL AREA
0 150'
555
SCALE IN FEET
TW-I
«
MW-1
300'
Ross Metals Site
Rossville, Tennessee
CDM Federal Programs Corporation
-4 MMfey ef t*rf Cnatf t IkZtt he.
Maximum Lead Results in Sediment
(TAL Analysis -
Ecological Investigation)
Figure No
2-14
7/98
-------
LEGEND
/\ Sample Location
Wetland Community Types
(23 Scrub/Shrub
[••Av] Emergent
l=-ll Brood-Leaved Deciduous Forest
l^^l N«edle- Leaved Deciduous
(Bold Cypress) Forest
eod Concentration Contour (mg
GRAPHIC SCALE
100 200
J—t
Scale in Feel
Ross Metals Site
Rossville, Tennessee
COM Federil Profrarai Corporation
J MM* * CM* 0™» A MA* at
Conlaminant Contour in
Wetlands
March 1998
Figure No.
2-15
8/98
-------
.
LEGEND
EH
l-'F'M
^jjjfjffl
m
N
!
0-400 mg/kg ' • INTERPRETED ISOCONTOUR LINE I
400 mg/kg INTERVAL I
40, -800 mg/kg „,. ^ CONCENTRAT|ON mg/|
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Record of Decision
Ross Metals OLF#1
In addition to soils, other solid media were sampled during previous investigations. Waste slag
samples contained total lead concentrations ranging from 18,500 to 94,800 milligrams per kilogram
(mg/kg). Total lead and TCLP lead concentrations in a floor wipe sample collected from the furnace
and raw materials refinery building were 14,700 mg/kg and 574 mg/L, respectively.
.:•
2.5.7.2 Groundwater
Analytical results of groundwater samples revealed the presence of several inorganic compounds at
concentrations that either exceed the primary or secondary drinking water standards or the State of
Tennessee domestic water supply criteria. Aluminum, arsenic, barium, cadmium, chromium, iron,
lead, manganese, nickel and vanadium were detected above respective guidance concentrations and/or
RGO levels. Lead concentrations in filtered groundwater samples ranged from nondetectable to 770
micrograms per liter (ug/1); the EPA action level for lead in groundwater is 15 wg/L.
Using only the filtered data set from the May 1997 sampling event, it appears that groundwater lead
contamination is limited to an area just east and downgradient of the RM wrecker building. Under
this assumption, the horizontal extent of the contaminant plume is about 300 feet by 200 feet. In
contrast, using groundwater quality data from all historic unfiltered samples, combined with unfiltered
and filtered data from the May 1997 sampling event, it could be interpreted that groundwater
contamination is Site-wide. In this case, the entire Site would be considered a source. Under this
assumption, the horizontal extent of the contaminant plume is at least 800 feet by 450 feet and
extends off Site.
Although EPA Region 4 policy is to use only unfiltered sample results for risk assessment and
determining extent of contamination, the difficulty in using the historic unfiltered sample data and
even the May 1997 unfiltered sample data is that the turbidity of these samples does not meet EPA
Region 4 Standard Operating Procedure goal of less than 10 NTU. The results from the unfiltered
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Ross Metals OU#1
samples with high turbidity are not representative of lead concentrations in fully developed water
supply wells because water supply wells in regular use do not produce water with high turbidity due
to the development of a natural filter pack around the well screen (EPA 1998d). In addition, the
results for MW5 presented on Figure 2-17 indicate that recent samples do not confirm earlier sample
results. Reported lead concentrations declined from 500 ug/1 to 3 ug/1 in seven years. This decline
is difficult to explain because lead is not degradable and the source has not been removed. The lower
levels present in the more recent sampling events suggest that the earlier data may not be valid.
The high turbidity associated with the unfiltered samples collected at the RM Site means that the
horizontal extent of contamination remains undefined. It may be much less than the current data
indicate. Field measurements collected during the 1997 sampling event suggest that measurements
with acceptably low turbidity could be attained at this Site with longer development periods.
In addition, the vertical extent of groundwater contamination has not been determined since there are
no deep wells or cluster wells at the Site which could be used to determine the vertical hydraulic
gradient. Without this information, vertical extent of contamination cannot be defined. It is
important to have an understanding of the vertical extent of contamination to effectively evaluate
potential remedial alternatives to use in the remediaiton of the contamination.
Based on the groundwater information, EPA has divided the Site into Operable Units with the source
materials being the first Operable Unit and the groundwater being the second. Additional data will
be necessary for defining the nature and extent of groundwater contamination.
2.5.7.3 Surface Water
Analytical results of surface water samples revealed concentrations of several inorganic compounds
that exceeded background concentrations. Significant inorganic contaminants included antimony,
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FURNACE
OKSVBRAW MATERIALS
REFINERY
LEGEND
ffi TEMPORARY WELLS
rv-i
j» ^ONITOR WELLS
GROJJND WATER DATA BOX, RESULTS u«/L
i no)
LANORLL AREA
FENCEUNE
WETLAND AREA
X - E» MOULTS
X - BO NKSU.T3
AMY IMO)
(MMMOI tH
• SURFACE WATER. ESO, ug/L Pb
O PRE-REMED1AL SURFACE WATER SAMPLE
ffl REMOVAL AREA
100' 200'
••
SCALE IN FEET
NOTE;?
ESO ENVIRONMENTAL SERVICES DMS10N
ERRB EMERGENCY RESPONSE AND REMOVAL BRANCH
HRS HAZARD RANKING SYSTEM
U UNFILTERED
F FILTERED
ugA M1CROGRAMS PER LITER (UNITS FOR ALL
WATER SAMPLES)
(*) NOTE - TW-10 AND MW-10 SAME BORING,
SAMPLES TAKEN AT DIFFERENT DEPTHS.
TW - SHALLOW SAMPLE COLLECTED DURING BORING.
MW - WELL SAMPLE COLLECTED AFTER COMPLETION
Ross Metals Site
Rossville. Tennessee
COM Federal PrOfrejxu Corporation
* i nij «c»»*•»•••*»*« *^
Total Lead Concentrations - Water
Figure No.
2-17
7/08
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Record of Decision
Ross Metals OU#1
arsenic, cadmium, iron, lead, and manganese. Figure 2-17 and 2-18 illustrate lead concentrations
in surface water.
2.5.7.4 Contaminant Fate And Transport
Metals, notably lead, are the primary contaminants of concern (COC) associated with the Site; these
contaminants are found in soils, structures, groundwater, and surface water. These contaminants are
not typically highly mobile in the environment and move primarily by soil/sediment or wind transport.
Primary mechanisms available for contaminant transport away from the RM Site are rainwater runoff,
rainwater infiltration to groundwater, and windblown dust movement. A conceptual site model is
presented in Figure 2-19. The following transport mechanisms have affected contaminants at the RM
Site:
Rainwater Infiltration to Groundwater: Rain falling directly on Site or as runon
to the Site moves through contaminated soils and structures. This water picks up
soluble contaminants, such as metals, and during periods of heavy rainfall, moves
sediments containing contaminants. Most of the area is paved and a concrete curb,
which was built some years after the facility began operation, extends around most of
the old fenced area. However, much of the pavement is in poor condition, allowing
water seepage at the pavement discontinuities and infiltration to groundwater. A
storm water collection sump located in the northeast corner of the old fenced area,
apparently overflows during rain events creating runoff flow at the northeast corner
of the property. Runoff appears to continue to migrate east and northeast of the old
fenced area, where it enters the groundwater by infiltration. Within the landfill area,
water flowing through contaminated material (buried slag) infiltrates into
groundwater.
Windblown Dust Movement: The old fenced portion of the RM Site is essentially
devoid of vegetative cover. During dry periods, high winds could transport
contaminants away from the Site with windblown dust. When the facility was in
operation, wind could have transported contaminants in air coming from the exhaust
stack away from the Site.
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30
11
KTW-10
.32
\MW-7
r
i®
IMW-S
12S
~i
14
BLAST SLAG MONOF1U.
•.20
19.
..17
i.26
LEGEND
TAL ANALYSIS SAMPLE LOCATION
SAMPLE LOCATION
TEMPORARY WELL
MONITOR WELL
LANDFILL AREA
FEN CELINE
WETLAND AREA
REMOVAL AREA
0 150'
SCALE IN FEET
»2e
.1
TW-1
«
MW-1
300'
Ross Metals Site
Rossville. Tennessee
CDM Federal Programs Corporation
A MMby ef Cam Cnttte * Uc& he.
Lead Results in Surface Water
(TAL Analysis -
Ecological Investigation)
Igure No,
2-18
6/98
-------
SOUTH
KEU.OGC'S CITY Or
PRODUCTION ROSSWLLE
WELL WELLS
0«I25 gpm 0-42 9pm
SILTY CLAY/CLAYEY SILT
Kv«=2.5 X 10 -'cm/see
n-0,42
SAND
KH-LS X 10-Jcm/aec (?) (P
Kv=2.5 X 10-* cm/see
n=0.39
1-0.0019
MEMPHIS SAND
>600' THICK
ior
LEGEND
gpm - GALLONS PER MINUTE
151' ppm - PARTS PER MILLION
cm/sec » CENTIMETER PER S
mg/L = MILLIGRAMS PER LITE
245'
•>-!*.'
09/L = MICROGRAMS PER LIT
R
NOT TO SCALE
NORTH
LEAD-18.500 ppm
iTCLP-TiOmgA
RAINFALL
52"/YEAR
SURFACE DEPOSITION OF
LEAD CONTAMINATED OUST.
- SOILS. WASTE, AND SEDIMENT
PAVEMENT•
POSSIBLE
LEACHING
\ [LEAD (0-6-) 63-j9iOM_pjjjj]
--*•. [LEAD (>6") 7j-~6oo ppm 1
i.\fc'" • • . .. -.-. -I
BORING 8
LEAD CONTAMINATED
SOIL BELOW SLAG
GROUNDWATER FLOW
NORTH TO WOLF RIVER
KH - HORIZONTAL HYDRAULIC CONDUCTIVITY
Kv - VERTICAL HYDRAULIC CONDUCTIVITY
n - POROSITY
I - HYDRAULIC GRADIENT
ND
POTENTIOMETRIC SURFACE
DEPTH AT WHICH WATER IS ENCOUNTERED
NOT DETECTED
Ross Metals Site
Rossville, Tennessee
COM Federal Programs Corporation
A xtlHay of Crnif DrKMr * Ucffi Ac.
Fate and Transport
figure No.
2-19
8/98
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Ross Metals OU#1
• Transport by Rainwater Runoff: During rainfall, water moves through
contaminated media on the Site. Much of the storm-water runoff within the fenced
portion of the Site is routed to the collection sump in the northeast corner and
discharges off Site at this location. In addition, no stormwater collection facilities
exist for the landfill area, and stormwater either infiltrates to groundwater or is routed
north and east of the landfill. Runoff to the west is prevented due to the presence of
the City of Rossville wastewater treatment ponds. These ponds are bermed, and
runoff towards this area is routed north of the Site. Runoff from the Site may carry
contaminated soils, as well as dissolved contaminants, into the Wolf River located
about 0.5 miles north of the Site, although no data have been collected to support this
conclusion. The Wolf River flows west, through Memphis, and into the Mississippi
River.
The RM facility likely released lead in spills of battery acid, metallic or oxidized lead from improper
storage or disposal of battery plates or casings, airborne fallout from the smelter, and the smelter slag.
The solubility of lead minerals and complexes increases aspH decreases (Lindsay 1979). No specific
pH data for Site soils are available; however, a sustained leak of battery acid would neutralize soil
alkalinity, lowering the soil pH and increasing lead mobility in the soil. At the RM Site, spills of
battery acid may have transported lead deep into the soil profile and to the aquifer.
Lead was released to the environment as metallic lead or lead oxide. Metallic lead oxidizes slowly
to lead oxide, and lead from airborne fallout is probably released to the environment as lead oxide.
Lead oxides are relatively soluble when compared to lead sulfates, phosphates, and carbonates. The
smelter slag contained very high concentrations of lead; however, the slag is relatively inert.
Metal mobility in soil-waste systems is determined by the type and quantity of soil surfaces present,
contaminant concentrations, concentrations of competing ions and ligands, pH, and redox status. For
this reason, the use of literature or laboratory data that do not mimic the specific Site soil and waste
system are not generally adequate to describe or predict the behavior of the contaminant. In order
to help determine the fate of lead contamination at the RM Site, several Site fate and transport models
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Ross Metals OU#1
were completed as part of the EE/CA completed for the Site.
A one-dimensional geochemical model was used to evaluate (1) the migration of lead in soil beneath
the smelter slag (2) the migration of lead below the contaminated soil near the wrecker building, and
(3) a subsurface soil removal action level. The model suggested that the slag material is a potential
source of contamination to groundwater; because it predicted that lead will migrate to groundwater
in six years and the concentration of lead in groundwater will exceed 15 ug/1 in 55 years. In addition
the geochemical model suggested that soils near the wrecker building are acting as a continuing
source of contamination to groundwater and that lead concentration in groundwater will continue to
increase (reaching a maximum of 23,600 ug/1 in 57 years) unless the source is removed.
AHydrologic Evaluation of Landfill Performance (HELP) quasi-two-dimensional hydrologic model
of water movement across, into, through, and out of landfills, coupled with the results of the
geochemical modeling suggest that the construction of a geosynthetic cap will effectively eliminate
the potential for future groundwater contamination.
Finally, a Random-Walk model was completed to simulate the progress of remediation for the various
remediation scenarios developed for the WHPA modeling. The Random-Walk modeling suggested
that a 15 ug/1 groundwater action level for lead cannot be attained under a "no action" scenario.
However, the results of the Random-Walk modeling must be considered cautiously.
While the modeling efforts completed for the EE/CA and the RI/FS provide more Site-specific
information regarding the fate and transport of lead contamination, the results should be used
cautiously. The completed modeling applications are considered interpretive. Interpretive models
are useful as a framework for studying system dynamics and for analyzing flow and transport in
hypothetical or assumed hydrogeologic systems.
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In addition to lead, other inorganics also were identified as human health or ecological COCs.
Aluminum's behavior in the environment depends on its chemistry and surrounding conditions. In
soils, a low pH generally results in an increase in aluminum mobility. Plants vary in their ability to
remove aluminumfromsoils. Biomagnification of aluminumin terrestrial food chains does not appear
to occur (ASTDR 1990).
Antimony's adsorption to soil and sediment is primarily correlated with'iron, manganese, and
aluminum content (ASTDR 1991). Antimony can be reduced and methylated by microorganisms in
anaerobic sediment, releasing volatile methylated antimony compounds into water (ASTDR 1991).
Arsenic has four valence states (-3, 0, +3, +5) but rarely occurs in its free state in nature. Inorganic
arsenic is more mobile than organic arsenic and poses greater problems by leaching into surface
waters and groundwaters.
Lead does not magnify to a great extent in food chains. Older organisms typically contain the highest
tissue lead levels (Eisler 1988). Plants can uptake lead through surface deposition in rain, dust, and
soil, or by uptake through roots. A plant's ability to uptake lead from soils is inversely related to soil
pH and organic matter content.
2.5.8 Treatability Studies
2.5.8.1 Dewatering Study, December 1997
A bench-scale dewatering treatability study on sediment was performed to evaluate different methods
of reducing the water content of the untreated sediments and identify a treament which would
improve the material handling qualities of the sediment such that free liquids are not released during
transport and disposal.
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The results of the initial dewatering tests determined that it would be difficult to effectively dewater
these sediments. Silty materials have finer particle sizes resulting in less free drainage when
dewatering. The gravity drainage test clearly demonstrated the difficulty encountered when
attempting to use gravity to dewater these sediments. The silt fines prohibited the drainage of
significant quantities of water from the sediments.
The most effective dewatering technique tested in terms of increasing the total solids in the sediment
and removing the largest quantity of liquid, was filter press. The cake that resulted from the filter
press test demonstrated why dewatering would not be the most effective treatment method for these
sediments. The bottom layer (closest to the filtration device) was most effectively dewatered.
Sediment above this layer had much higher water contents and would not have passed the liquid
release test. This was a demonstration that the high fines in the silty material prohibit effective
dewatering. In addition, the dewatering process took more than two hours using the filter press
dewatering method.
The Buchner funnel test demonstrated that moderate success could Likely be achieved using a belt
filter press. However, the percent solids in the sediment only increased to 56 percent using this
technique (untreated sediment 46 percent solids).
If dewatering is to be considered for sediment, additional testing using conditioning agent such as
diatomaceous earth which would enhance the dewatering process would need to be used. While
diatomaceous earth will not reduce leachability of the lead, it should enhance the release of free
liquids from the sediments.
Given the high silt contents of these sediments, consideration of stabilization of these sediments is
recommended. The stabilization process can be designed to improve the material handling
characteristics of the sediment and reduce teachability of the sediment. Additional testing would be
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Ross Metals OU#1
required to identify effective stabilization reagent(s).
2.5.8.2 Stabilization Study, March 1998
A stabilization study was performed to evaluate stabilization reagents that would 1) reduce the
teachability of lead in treated sediment and 2) improve the material handling qualities of the sediment
so that free liquids are not released during transport or disposal. The results of the treability study
have determined that sediment can be treated using biosolids reagent N-Viro or phosphoric acid to
reduce the teachability of lead. Treatment using N-Viro material absorbed free liquids after curing
for 5 days and resulted in a material that could be excavated and transported for disposal.
Treatment using phosphoric acid, while reducing the teachability of lead, resulted in a material with
free liquids and a noxious sulfide odor. Reduction in the addition rate of phosphoric acid did not
reduce the sulfide odor.
The teachability of lead was decreased when the lower addition rates of CKD, LKD, and Fly Ash/PC
were added to the sediment. Given the amphoteric nature of lead, it is possible that the solubility of
lead in the sediment increased with the higher reagent addition rates. It is possible that the
teachability would be reduced further if a 5 percent or lower addition rate was used. With the high
water content in the sediment, an inert absorbent would be required along with the stabilization
reagent to improve the handling characteristics.
The results of the stabilization study have demonstrated that this treatment process will effectively
reduce the teachability of lead and improve the handling characteristics of the sediment.
Considerations should be given to the method which the reagent is added to the sediment (in-situ or
ex-situ) and the ultimate deposition of the treated sediment.
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Ross Metals OU#1
2.5.8.3 Biosolids Study, November 1998
The bench-scale column treatability study was performed to evaluate different methods of reducing
lead contamination by adding biosolids material. Results indicate the lead concentration in the liquid
fraction decreased from 5,400 to 2,100 ppb with an increase of biosolids to sediment ratio. Greater
than 61.1 percent of lead concentration was reduced from biosolids to sediment rations of 0:5 and
1:4 which is less than the TCLP regulatory level [5.0 ppm ]. The lead concentration remained the
same (2,100 ppb) for biosolids to sediment ratios of 1:4 and 2:3. For another sample, the results
indicate the lead concentrations in the liquid fraction were 230, 530, and 440 ppb for biosolids to
sediment ratios of 0:5, 1:4, and 2:3, respectively. Based on this data and the 800 ppm goal,
application of biosolids on the sediments appears to be feasible to sorb lead that may leach from the
contaminated wetlands. Additional studies and tests will be required for confirmation.
2.6 SUMMARY OF SITE RISKS
2.6.1 Human Health Risk Assessment Summary
The primary purpose of this baseline risk assessment (BRA) is to provide a quantitative and
qualitative understanding of the actual and potential risks to human health posed by the Ross Metals
(RM) Site if no further remediation or institutional controls are applied. The BRA consists of both
a human health evaluation and an ecological risk assessment.
2.6.1.1 Data Evaluation
Data used in this risk assessment were obtained from the following sources: May and November
1990, Environmental Services Division (BSD) Resource Conservation and Recovery Act (RCRA)
investigations; 1994 Emergency Response and Removal Branch (ERRB) investigation during a time-
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Ross Metals OU#1
critical removal action; 1995 Black & Veatch pre-remedial investigation; November 1996 ESD
investigation; May 1997 PRC investigation; and 1997 Emergency Response Team Center (ERTC)
investigation. These data were evaluated by ESD personnel and determined to be of acceptable
quality for use in a Baseline Risk Assessment.
Because of the nature of the plant's operations, the majority of the samples were analyzed for Target
Analyte List (TAL) parameters (inorganics) only. Two samples collected by ERTC were analyzed
for the entire Target Compound List/Target Analyte List (TCL/TAL) parameters.
The laboratory results were validated by EPA Region 4 ESD personnel using standard data validation
procedures. They concluded that with the exception of a small percentage of the data that were
rejected for a variety of technical reasons, the overall data package can be accepted with confidence.
The data were then summarized to show all inorganic and organic chemicals that were positively
identified in at least one sample. Included in this group were unqualified results and results that were
qualified with a "J" which means the chemical was present but the concentration was estimated.
These values were listed as actual detected concentrations which may have the effect of under- or
over-estimating the actual concentration. Tentatively identified compounds (qualified with an "N")
were included if there was reason to believe that they were present. For example, if a compound was
positively identified in other locations, the tentative identification was considered sufficient.
These positively identified chemicals were then screened to exclude chemicals that, although present,
are not important in terms of potential health effects. The screening criteria fall into three categories:
(1). Inorganics whose maximum detected concentration did not exceed two times the average
background concentration were excluded;
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Ross Metals OU#1
(2). Inorganics that are essential nutrients or are normal components of human diets were
excluded. Calcium, magnesium, potassium, and sodium were excluded because they are
essential nutrients, with no known toxic effects at any relevant dosage level; and
(3). Inorganic and organic chemicals whose maximum concentration was lower than a risk-based
concentration corresponding to an excess cancer risk level of 1 x 10"6 or a Hazard Quotient
(HQ) level of 0.1, as determined by EPA Region 3 toxicologists using residential land use
assumptions, were excluded (EPA 1998b).
Since the overall site risk is the sum of risks from all relevant exposure routes (inadvertent ingestion
of soil, dermal contact with soil, inhalation of dust, and ingestion of groundwater), eliminating one
or more routes has the effect of reducing the apparent risk. The groundwater data that were used in
this assessment contribute a significant degree of uncertainty to the overall assessment. Among the
factors that should be considered is the substantial difference between the filtered and unfiltered
samples (taken at the same location and time). This difference adds to the uncertainty in the exposure
concentration and subsequent risk estimates. If this difference is due to turbidity, then the
concentration of lead and other COPCs would change as the turbidity changes. This would result in
an increase or decrease in the exposure concentration and resultant risk.
2.6.1.2 Exposure Pathways
The conceptual site model for this assessment is presented in Figure 2-20. As seen in this figure,
metals, notably lead, are the primary contaminants of concern (COC) associated with the Site; these
contaminants are found in soils, structures, groundwater, and surface water. These contaminants are
not typically highly mobile in the environment and move primarily by sediment or wind transport. No
specific pH data for Site soils are available; however, low pH will, in general, make metals more
soluble and, therefore, more easily transportable from the Site, and more bioavailable.
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Figure 2-20
Conceptual Site Model
Ross Metals Site
Rossville, Tennessee
Primary
Source
Primary
Release
Mechanisms
Secondary Secondary
Sources Release
Mechanisms
Migration
Pathways
Exposure Receptors
Routes
NA
Soil
Ingestion
Dermal
Contact
Visitor
Resident
Worker
Lead Smelter
Air Emissions,
Landfilling
Contaminated
Soil
Stormwater
Runoff or
Aquifer
Connection to
Wetland
^
Surface
Water and
Sediments
Ingestion
Dermal
Contact
>
Visitor
Leaching
»
Groundwater
Ingestion
^»
Resident
Worker
'Dust Generation
EI
Wind
Inhalation
'>•
Visitor
Resident
Worker
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Record of Decision
Ross Metals OU#1
Based on this understanding of the fate and transport of contaminants, and the potential for human
contact, the following media/receptors were examined:
(1) Surficial soil/sediment in the Landfill Area and Wetland/Woodland Area. Potential receptors
are Site visitors. In the future, residents and/or workers are potential receptors in the Process
Area and Landfill Area.
(2) Surface water in the Wetland/Woodland Area. Potential receptors Site visitors.
(3) Groundwater beneath the Process Area and the Landfill Area. Potential receptors are future
residents and/or workers.
are:
Potentially complete exposure pathways examined in the risk assessment
inadvertent ingestion of soil,
dermal contact with soil,
inhalation of dust,
inadvertent ingestion of surface water,
dermal contact with surface water, and
ingestion of groundwater.
Reasonable maximum exposure (RME) point concentrations for soil/sediment, and surface water
were calculated according to EPA Region 4 guidance using the lesser of the 95 percent upper
confidence limit (UCL) on the arithmetic average for a lognormal distribution or the maximum
detected value (EPA 1992a and 1995a). Where a chemical of concern was not detected at a given
location, one-half the sample quantitation limit was used as a proxy concentration; however, if both
the proxy concentration and the upper confidence limit exceeded the maximum detected value, the
maximum detected value was used as the RME concentration. The RME concentrations for
chemicals of concern are presented in Table 2-3.
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f
*
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s s
\
f;:^S'':^
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,% '.•£'•'
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Process Area
Soil
Antimony
Arsenic
Barium
Cadmium
Copper
Lead
Selenium
7
3
19
0.1
6
6
1
730
479
790
99
712
97,700
48
21/21
25/26
21/21
16/26
18/21
29/29
7/21
217
99
157
99
238
97,700
8
; !5:'v^<:- ." . : t'.-.-:. :v':!..-;^r !:ir ^lindMArea !..-'• " ": .. . ':.-":-
Soil
Soil
Antimony
Arsenic
Cadmium
Lead
Manganese
Aluminum
Antimony
Arsenic
Barium
Cadmium
Copper
Iron
Lead
Manganese
Selenium
Vanadium
75
8
1
35
380
3,390
1
4
53
1
8
4,790
67
25
2
10
75
76
22
42,400
1,100
and/Woodls
24,000
1,350
681
610
18
465
40,000
98,100
1,500
84
63
1/4
4/4
3/4
11/11
4/4
46/46
14/42
46/46
46/46
28/46
45/46
46/46
52/52
46/46
13/46
46/46
75
76
22
42,400
1,100
13,331
32
41
147
6
43
19,576
5,827
752
4
31
95% UCL
95% UCL
95% UCL
Max
95% UCL
Max
95% UCL
Max
Max
Max
Max
Max
95% UCL
95% UCL
95% UCL
95% UCL
95% UCL
95% UCL
95% UCL
95% UCL
95% UCL
95% UCL
95% UCL
-51-
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Site
(Cpncentratipiis m ppb)
Surface Water
Groundwater
Aluminum
Antimony
Arsenic
Cadmium
Copper
Iron
Lead
Manganese
Mercury
Selenium
Thallium
Zinc
Aluminum
Arsenic
Barium
Cadmium
Chromium
Iron
Lead
Manganese
Nickel
Vanadium
168
18
313
36
229
0.2
13
39
380
21
11
39
1,300
130
45
1,300
150
554
120
140
42,700
16,000
5,520
0.4
11
13
568
23,000
40
380
39
64,000
1,600
5,600
160
49
7/10
7/10
9/10
6/10
9/10
10/10
10/10
10/10
4/10
2/10
3/10
7/10
9/14
2/24
14/14
3/14
1/14
10/14
18/24
10/14
4/14
3/14
UCL: Upper Confidence Limit
Max: The highest detected concentration
Ave: Average concentration within the plume
f
1,300
150
554
120
140
42,700
16,000
5,520
0.4
13
568
2,608
20
90
12,126
196
1,472
24
Max
Max
Max
Max
Max
Max
Max
Max
Max
95% UCL
Max
Max
Ave
Ave
Ave
Ave
Ave
Ave
Ave
Ave
Ave
Ave
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2.6.1.3 Toxicity Values
* The RfDs and CSFs used in this assessment were primarily obtained from EPA's IRIS database (EPA
1998c). Values that appear in IRIS have been extensively reviewed by EPA work groups and thus
represent Agency consensus. If no values for a given compound and route of exposure were listed
in IRIS, then EPA's HE AST (EPA 1995b) were consulted. Where no value was listed in either IRIS
or HEAST, EPA's National Center for Environmental Assessment (formerly the Environmental
Criteria and Assessment Office) was consulted. Tables 2-4 and 2-5 summarize the toxicity values
for carcinogenic and non-carcinogenic COCs, respectively.
Neither a CSF nor an RfD is available for lead. Instead, blood lead concentrations have been
accepted as the best measure of exposure to lead. Because children are the most vulnerable to lead
toxicity, EPA has developed an integrated exposure uptake biokinetic model (IEUBK) to assess
chronic, non-carcinogenic exposures of children to lead. When this model is used, and the detected
concentrations are shown to be acceptable to the most vulnerable group in the population (children),
it is not necessary to address adult exposure.
To characterize risk associated with dermal exposure, the toxicity values presented in Tables 2-4 and
2-5 were adjusted from administered to absorbed toxicity factors according to the method described
in Appendix A to RAGS (EPA 1989a). The following oral absorption percentages were employed:
80 percent for VOCs, 50 percent for semi-volatile organics, and 20 percent for inorganics (EPA
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Aluminum
Antimony
NA
20%
NA
NA
NA
D
Arsenic
1.5E+00 i
100%
NA
NA
Skin
Barium
NA
20%
NA
NA
NA
D
Cadmium
NA
20%
NA
6.3E+00 i
Lung
Bl
Chromium
NA
20%
NA
4.2E+01 i
Lung
Copper
NA
20%
NA
NA
NA
D
Iron
NA
20%
NA
NA
NA
D
Lead
NA
20%
NA
NA
Kidney
B2
Manganese
NA
20%
NA
NA
NA
D
Mercury
NA
20%
NA
NA
NA
D
Selenium
NA
20%
NA
NA
NA
D
Thallium
NA
20%
NA
NA
NA
D
Vanadium
NA
20%
NA
NA
NA
D
Zinc
NA
20%
NA
NA
NA
D
Source:
i-IRIS
CSFo - Cancer Slope Factor (oral), (mg/kg/day)-l
CSFd - Cancer Slope Factor (dermal), (mg/kg/day)-l
ABSeff- Absorption efficiency: 20% inorganics, 50%
semivolatiles, 80% volatiles. Based on RTY policy.
CSFi - Cancer Slope Factor (inhalation), (mg/kg/day)-l
NA - Not Applicable
EPA Cancer Classes
A - Human carcinogen
B - Probable human carcinogen
C - Possible Human carcinogen
D - Not classifiable as a human carcinogen
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Aluminum
lE+OOn
20%
2E-01
NA
Not specified
Antimony
4E-04i
20%
8E-05
NA
Longevity, blood glucose
Arsenic
3E-04 i
100%
3E-04
NA
Hyperpigmentation
Barium
7E-02i
20%
1E-02
NA
Incr. blood pressure
Cadmium (water)
5E-04i
20%
1E-04
NA
Proteinuria
Cadmium (food)
1E-03 i
20%
2E-04
NA
Proteinuria
Chromium
5E-03 i
20%
1E-03
4.2E+01 i
NOAEL
Copper
4E-02 n
20%
8E-03
NA
Not'specified
Iron
3E-01 n
20%
6E-02
NA
NOAEL
Lead
NA
20%
NA
NA
CNS effects, blood
Manganese (soil)
7E-02 TV
20%
1E-02
1.43E-05
NOAEL
Manganese
(water)
2.4E-02 IV
20%
NA
NA
Neurotoxicity
Mercury
3E-04i
20%
6E-05
NA
Neurortoxicity
Selenium
5E-03 i
20%
1E-03
NA
Clinical selenosis
Thallium
9E-05 i
20%
2E-05
NA
Incr. SCOT and LDH
Vanadium
7E-03 i
20%
1E-03
NA
Deer, hair cystine
Zinc
3E-01 i
20%
6E-02
NA
Deer. ESOD
Sources:
i - IRIS
n - NCEA (National Center for Environmental Assessment)
IV - The RfDo for manganese in IRIS is 1.4E-1 mg/kg/day based on the NOAEL of 10 mg/day. For soil exposure, Region IV policy is
to subtract the average daily dietary exposure (5 mg/d) from the NOAEL to determine a "soil" RfDo. When this is done, a "soil" RfDo
of 7E-2 mg/kg/day results. For water exposure, a neonate is considered a sensitive receptor for the neurological effects of manganese.
Thus caution, (in the form of a modifying factor) is warranted until more data are available. Using a modifying factor of 3 results in a
"water" RfDo of 2.4E-2 mg/kg/day.
RfDo - Reference Dose (oral), (mg/kg/day)
RfDd - Reference Dose (dermal), (mg/kg/day)
ABSeff - Absorption efficiency: 20% inorganics, 50%
semivolatiles, 80% volatiles. Based on RTV policy.
RfDi -Reference Dose (inhalation), (mg/kg/day)
NA - Not Applicable
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1995a). The only exception to this was for arsenic. According to recently released EPA Region 4
guidance, the gastrointestinal absorption rate of arsenic may be considered 100 percent (Koporec
1998). Thus, when considering dermal exposure to arsenic, no adjustment is necessary.
2.6.1.4 Risk Characterization
The final step of the baseline risk assessment is the risk characterization. Human intakes for each
exposure pathway are integrated with EPA reference toxicity values to characterize risk.
Carcinogenic, non-carcinogenic, and lead effects are estimated separately.
To characterize the overallpotential for non-carcinogenic effects associated with exposure to multiple
chemicals, EPA uses a Hazard Index (HI) approach. This approach assumes that simultaneous
subthreshold chronic exposures to multiple chemicals that affect the same target organ are additive
and could result in an adverse health effect. The HI is calculated as follows:
Hazard Index = ADDl/EfDl + ADD2/RfD2 +...ADD/RfD,
where: ADD; = Average Daily Dose (ADD) for the ith toxicant
RfD; = Reference Dose for the ith toxicant
The term ADDj/RfDj is referred to as the Hazard Quotient (HQ).
Calculation of an ffl in excess of unity indicates the potential for adverse health effects. Indices
greater than one will be generated anytime intake for any of the Chemicals of Potential Concern
(COPC). However, given a sufficient number of chemicals under consideration, it is also possible to
generate an HE greater than one even if none of the individual chemical intakes exceeds its respective
RfD.
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Ross Metals OU#1
Carcinogenic risk is expressed as a probability of developing cancer as a result of lifetime exposure.
For a given chemical and route of exposure, excess lifetime cancer risk is calculated as follows:
Risk = Lifetime Average Daily Dose (LADD) x Carcinogenic Slope Factor (CSF)
These risks are probabilities that are generally expressed in scientific notation (i.e., 1 x 10'6 or 1E-6).
An incremental lifetime cancer risk of 1 x 10^ indicates that, as a plausible upper-bound, an individual
has a one-in-one-million chance of developing cancer as a result of Site-related exposure to a
carcinogen over a 70-year lifetime under the specific exposure conditions at the Site. For .exposures
to multiple carcinogens, EPA assumes that the risk associated with multiple exposures is equivalent
to the sum of their individual risks.
Process Area: Current Use Risk Summary
The Process Area presents physical and chemical risks to human health. The Site contains numerous
unstable structures that pose physical risks to trespassers. Incidents involving unstable structures are
potentially fatal and represent significant risk associated with the Site. The condition of the structures
will worsen over time, with a corresponding increase in associated hazards.
Apart from the physical hazards noted above, exposure to contaminants in soil in the Process Area
is curtailed by the asphalt pavement that covers the great majority of the Site and exposure to
contaminated soils is not possible. Also, there are no groundwater wells in use that tap the
contaminated zone of the aquifer. Thus, for these reasons, current exposure routes are incomplete.
Process Area: Future Use Risk Summary
In the future, the Site may be redeveloped for either residential or commercial/industrial use based
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Ross Metals OU#1
on dialogue with local land use planning officials and citizens. Such redevelopment would expose
the contaminated soils that exist beneath the pavement. Potential receptors would be Site visitors,
Site workers, child residents, adult residents, and lifetime residents. Exposure routes potentially
complete in such a scenario are:
• inadvertent ingestion of soil;
dermal contact with soil; and
• inhalation of dust
• ingestion of groundwater
Table 2-6 summarizes the cancer and noncancer risks for these receptors. The total incremental
lifetime cancer risk estimates range from 3 x 10E-9 for the Site visitor to 5 x 10E-4 for the lifetime
resident. In addition to the lifetime resident, risk estimates for the child resident and adult resident
are above EPA's target range for Superfund sites. Arsenic in groundwater accounts for the excess
cancernsk. Noncancer effects are possible for Site workers, child, adult, and lifetime residents based
on His of 2,25,7, and 10 respectively. Exposure to antimony, arsenic, and iron, and manganese in
groundwater account for the majority of the potential non-cancer effects. Table 2-7 summarizes the
cancer and noncancer risks for these receptors when the ingestion of groundwater route is eliminated.
Process Area: Exposure to Lead
In the future, the Site may be redeveloped for either residential or commerical/industrial use. Such
redevelopment would expose the contaminated soils that exist beneath the pavement. Potential
receptors would be Site visitors, Site worker, child residents, adult residents, and lifetime residents.
In this future scenario, ingestion of groundwater from wells developed from within the contaminant
plume is considered as an additional exposure route for Site workers, child residents, adult residents,
and lifetime resident. Exposure routes potentially complete in such a scenario are:
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Table 2-6
Summary of Cancer and Noncancer Risks by Exposure Route
Future Use Scenario
Process Area
Ross Metals Site
Rossville, Tennessee
Exposure
Route
Ingestion Groundwatcr
Inadvertent Ingestion Soil
Dermal Contact Soil
Inhalation Dust
TOTAL RISK
SiteN
Cancer
NA
NA
NA
3E-009
3E-009
'isitor
1 ™
NA
0.3
0.1
0.0001
0.4
Site VI
Cancer
1E-004
NA
NA
3E-008
1E-004
/orker
I in
2
0.5
0.2
0.0004
7
Child I
2E-004
NA
NA
3E-008
?P 0(14
esidcnt
12
13
1
0.001
*>c
25
Adult Resident
cancer
3E-004
NA
NA
4E-008
3E-U04
Ml
5
t
03
0.001
7
Lifetime
Cancer
5E-004
NIA
NA
7E-008
SE-004
Resident
HI
7
01
.j
0.001
10
Cancer: Excess cancer risk level
HI: Hazard index (non-cancer risk)
NA: not applicable
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Table 2-7
Summary of Cancer and Noncancer Risks by Exposure Route
Future Use Scenario (w/o Groundwator Pathway)
Process Area
Ross Metals Site
Rossvillc, Tennessee
Exposure
Route
Inadvertent Ingestion Soil
Dermal Contact Soil
Inhalation Dust
TOTAL RISK
Site Visitor
Cancer
NA
NA
3E-009
3E-009
HI
0.3
0.1
0.0001
0.4
CifA VUnrlrnr
Cancer
NA
NA
3E-008
3E-008
HI
0.5
0.2
0.0004
i
/-"KIM f> »_i. A
Ciiila 1'
Cancer
NA
NA
3E-008
it? nno
tiisiuuni
HI
13
1
0.001
13
Adult F
Cancer
NA
NA
4E-008
4E-008
Icsidcnt
HI
I
0.3
0.001
2
Lifetime
Cancer
NA
NA
7E-008
7E-OQ8
Resident
HI
4
0.3
0.001
4
Cancer: Excess cancer risk level
HI: Hazard index (non-cancer risk)
NA: not applicable
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• inadvertent ingestion of soil,
• dermal contact with soil,
• inhalation of dust, and
• ingestion of groundwater.
Lead was detected in all Process Area soil samples at concentrations ranging from 6 to 97,700 ppm;
the average concentration was 8,788 ppm. Lead was also detected in Site groundwater at
concentrations of 3 to 1,600 ug/l; the average concentration was 196 ug/l. These values were input
into version 0.99d of the IEUBK model. The results are summarized in Table 2-8. An additional
model run was conducted with a default value of 4 ug/l for groundwater as an input. The results are
summarized in Table 2-9. EPA uses a level of 10 ug lead per deciliter (dl) blood as the benchmark
to evaluate lead exposure. As can be seen, the projected blood lead levels exceeded this threshold
for all age groups, indicating that lead concentrations are above the acceptable range.
Landfill Area: Future Risk Summary
In the future, the Landfill Area may be redeveloped for commercial/industrial use or it may be
converted to residential use. Ingestion of groundwater is an additional exposure route that may exist
in a future use scenario. Table 2-10 summarizes the cancer and noncancer risks for the Site visitor,
Site worker, child resident, adult resident, and lifetime resident. The total incremental lifetime cancer
risk estimates range from 8 x 10'10 for the Site visitor to 5 x 10"4 for the lifetime resident. In
addition to the lifetime resident, the risk estimate for the adult resident is above EPA's target range
for Superfund sites. Arsenic in groundwater accounts for the excess cancer risk. Noncancer effects
are possible for Site workers, and child, adult, and lifetime residents based on His of 2, 18, 6, and
8, respectively. Exposure to arsenic, antimony, and cadmium in soil and arsenic, iron, and manganese
in groundwater account for the majority of the potential non-cancer effects. Table 2-11 summarizes
the cancer and noncancer risks excluding the groundwater pathway.
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Table 2-8
Projected Blood Lead Levels by Age Group
Process Area
Ross Metals Site
Rossvilic, Tennessee
Year
0.5-1
40.5
Blood Lead Levels (ug/dl)
Year
1-2
47.4
Year
2-3
45.7
Year
3-4
45.4
Year
4-5
41.4
Year
5-6
38
Year
6-7
35.4
Source: Integrated Exposure Uptake Biokinetic Model for Lead in Children, version 0.99d.
Assumptions:
Air concentration: 0.200 ug Pb/m3 (default)
Diet (default)
Soil and dust: 8,788 ug/g (average lead concentration in soil); Multiple Source Analysis
Drinking water: 196 ug/1 (average concentration in plume)
Paint intake: 0.00 ug Pb/day (default)
Maternal contribution: Infant model (default)
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Table 2-9
Projected Blood Lead Levels by Age Group
Process Area (w/o Ground water Pathway)
Ross Metals Site
Rossvillc, Tennessee
Blood Lead Levels (ug/dl)
Year
0.5-1
38.4
Year
1-2
43.9
Year
2-3
42.0
Year
3-4
41.7
Year
4-5
37.2
Year
5-6
33.3
Year
6-7
30.5
Source: Integrated Exposure Uptake Biokinetic Model for Lead in Children, version 0.99d.
Assumptions:
Air concentration: 0.200 ug Pb/m3 (default)
Diet (default)
Soil and dust: 8,788 ugVg (average lead concentration in soil); Multiple Source Analysis
Drinking water: 4 ug/1 (default)
Paint intake: 0.00 ug Pb/day (default)
Maternal contribution: Infant model (default)
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Table 2-10
Summary of Cancer and Noncancer Risks by Exposure Route
Future Use Scenario
Landfill Area
Ross Metals Site
Rossvillc, Tennessee
Exposure
Route
Ingcslion Groundwater
Inadvertent Ingeslion Soil
Dermal Contact Soil
Inhalation Dust
TOTAL RISK
Site Visitor
Cancer
NA
NA
NA
8E-010
8E-010
HI
NA
0.1
0.02
0.003
0.2
Site Worker
Cancer
Ui-004
NA
NA
7E-009
1E-004
HI
2
0.2
0.1
0.01
2
Child Resident
Cancer
2I--004
NA
NA
6H-009
2E-004
HI
12
6
0.2
0.04
18
Adult Resident
Cancer
3E-004
NA
NA
1E-008
3E-004
HI
5
1
0.1
0.02
6
Lifetime Resident
Cancer
5H-004
NA
NA
2E-008
5E-004
HI
7
2
0.1
0.02
8
Cancer: Excess cancer risk level
HI Hazard index (non-cancer risk)
NA: not applicable
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Table 2-11
Summary of Cancer and Noncanccr Risks by Exposure Route
Future Use Scenario (w/o Groundwatcr Pathway)
Landfill Area
Ross Metals Site
Rossville, Tennessee
Exposure
Route
Inadvertent Ingestion Soil
Dermal Contact Soil
Inhalation Dust
TOTAL RISK
Site Visitor
Cancer
NA
NA
8E-010
8E-010
HI
0.1
0.02'
0.003
0.2
Site Worker
Cancer
NA
NA
7E-009
7E-009
HI
0.2
0.1
0.01
0
Child Resident
Cancer
NA
NA
6E-009
6E-009
HI
6
0.2
0.04
6
Adult Resident
Cancer
NA
NA
1E-008
1E-008
HI
1
0.1
0.02
1
Lifetime Resident
Cancer
• NA
NA
2E-008
2E-008
HI
2
0.1
0.02
2
Cancer: Excess cancer risk level
HI: Hazard index (non-cancer risk)
NA: not applicable
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Landfill: Exposure to Lead
Lead was detected in all Landfill Area soil samples at concentration ranging from 35 - 42,400 ppm;
the average concentration was 5,964 ppm. Lead was also detected in Site groundwater at
concentrations of 3 to 1,600 |ig/l; the average concentration was 196 p.g/1. These values were input
into version 0.99d of the IEUBK model. The results are summarized in Table 2-12. Also, a default
value of 4 ug/1 for groundwater was input into the model. The results are summarized in Table 2-13.
EPA uses a level of 10 u.g lead per deciliter (dl) blood as the benchmark to evaluate lead exposure.
As can be seen, the projected blood lead levels exceeded this threshold for all age groups, indicating
that lead concentrations are above the acceptable range.
Wetland/Woodland Area
Future development in the Wetland/Woodland Area is unlikely due to its location in a 100-Year
Floodplain and wetlands. Therefore, the only receptors that may come into contact with
contaminants are Site visitors. Exposure routes potentially complete are:
• inadvertent ingestion of soil,
• dermal contact with soil,
• inhalation of dust, and
• inadvertent ingestion of surface water
Wetland/Woodland Area: Exposure to Lead
Due to the intermittent exposure to lead in the Wetland/Woodland Area, the IEUBK model cannot
be directly used to estimate blood lead levels. However, if a child were to visit this area as little as
once per week (the same exposure frequency assumed for the Site visitor), the child would establish
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Table 2-12
Projected Blood Lead Levels by Age Group
Landfill Area
Ross Metals Site
Rossvillc, Tennessee
Year
0.5-1
33.4
Year
1-2
39.6
Blood Lead Levels (ug/dl)
Year
2-3
38.3
Year
3-4
38.1
Year
4-5
34.9
Year
5-6
32.1
Year
6-7
29.9
Source: Integrated Exposure Uptake Biokinetic Model for Lead in Children, version 0.99d.
Assumptioas:
Air concentration: 0.200 ug Pb/m3 (default)
Diet (default)
Soil and dust: 5,964 ug/g (average lead concentration in soil); Multiple Source Analysis
Drinking water: 196 ug/1 (average concentration in plume)
Paint intake: 0.00 ug Pb/day (default)
Maternal contribution: Infant model (default)
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Table 2-13
Projected Blood Lead Levels by Age Group
Landfill Area (w/o Groundwatcr Pathway)
Ross Metals Site
Rossvillc, Tennessee
Year
0.5-1
30.9
Year
1-2
35.4
Blood Lead Levels (ug/dl)
Year
2-3
33.9
Year
3-4
33.6
Year
4-5
29.7
Year
5-6
26.4
Year
6-7
24.0
Source: Integrated Exposure Uptake Biokinctic Model for Lead in Children, version 0.99d.
Assumptions:
Air concentration: 0.200 ug Pb/ni3 (default)
Diet (default)
Soil and dust: 8,788 ug/g (average lead concentration in soil); Multiple Source Analysis
Drinking water: 4 ug/1 (default)
Paint intake: 0.00 ug Pb/day (default)
Maternal contribution: Infant model (default)
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a steady state blood lead level, and the risk to this child would be over EPA's acceptable level. This
is because the lead concentration in the Wetland/Woodland Area (average concentration 4,555
mg/kg) is more than seven times the lEUBK-based residential remedial level for lead (400 rag/kg).
2.6.2 Ecological Risk Assessment Summary
An ecological risk assessment was conducted to determine the potential for ecological risk at the Site.
This section summarizes the approach that was followed and the conclusions that were drawn.
The risk assessment was designed to evaluate the potential threats to ecological function from
exposure to Site contaminants and to establish Site-specific clean-up levels for the contaminants of
concern (COCs). The problem formulation process included the identification of COPCs, the
identification of exposure pathways, a determination of the assessment endpoints for the Site, the
formulation of testable hypotheses, the development of a conceptual model, and the determination
of the measurement endpoints.
2.6.2.1 Identification of Chemicals of Concern
A screening-level risk assessment was conducted in which the maximum concentrations of
contaminants detected in the surface water and sediment at the Site were compared to various
benchmark values in order to identify chemical of potential concern (COPCs). Metals had previously
been identified as contaminants at the Site, based on knowledge of the industrial history of the facility,
as well as the results from a variety of United States Environmental Protection Agency (U.S. EPA)
sampling investigations. The metals and organics data were screened using a risk characterization
process that relates exposure concentrations to concentrations that potentially cause adverse effects.
The exposure concentrations were the highest concentration detected for each contaminant in the
sediment and surface water samples collected on Site (not including the reference samples). The
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benchmark concentrations used in the screening-level risk assessment were the U.S. EPA Region 4
Waste Management Divison Screening Values for Hazardous Waste Sites. If a Region 4 screening
value was not available for a particular contaminant, the U.S. EPA Region 3 Screening Level, if
available, was used (U.S. EPA 1995).
An elevated hazard quotient (greater than one) resulting from the screening-level risk assessment
indicates that exposure to the contaminant may cause an adverse effect. However, more assessment
is needed to determine if the contaminants exceeding the benchmark values pose a risk to ecological
receptors at the Site. The contaminants for which maximum concentrations of compounds exceeded
benchmarks for water and/or sediment at the Ross Metals Superfund Site are summarized next and
in Table 2-14.
Many inorganic compounds exceeded the benchmark values for surface water and/or sediment. The
maximum surface water concentrations recorded at the Site exceeded the benchmark values for the
following compounds: aluminum, antimony, cadmium, copper, iron, lead, thallium and zinc. The
maximum sediment concentrations recorded at the Site exceeded the benchmark values for the
following compounds: antimony, arsenic, cadmium, copper, lead, mercury, nickel, silver, and zinc.
In addition, twelve inorganic compounds for which no sediment benchmark exists were detected in
sediment. These compounds are aluminum, barium, beryllium, calcium, cobalt, iron, magnesium,
potassium, selenium, sodium, thallium, and vanadium (Table 2-14).
The listing of COPC was further refined by conducting a Site-specific ecological risk assessment.
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Table 2-14
COCs Distribution and Hazard Quotient Calculations
Contamina
nt
Maximum Concentrations in Sediment
Maximum
Sediment
Concentration
Detection
s/Samples
Screenin
g Value
Referen
ce
Source
HQ
Metals mg/kg (dry weight)
Aluminum
Antimony
Arsenic
Cadmium
Copper
Iron
Lead
Mercury
Nickel
Silver
Thallium
Zinc
17,800
1,350
681
99.1
712
32,300
98,100
1.1
127
2.1
5.5
629
21/21
18/21
21/21
14/21
21/21
21/21
21/21
4/21
21/21
2/21
1/21
21/21
NB
12
7.24
1
18.7
NB
30.2
0.13
15.9
0.733
NB
124
NB
d
d
d
d
NB
d
d
d
d
NB
d
NB
113
94
99
38
NB
3,2
48
8
8
3
NB
5
Maximum Concentrations in Water (Filtered)
Maximum
Water
Concentratio
n
Detectio
ns/Sampl
es
ug/1
506
31.1
165
5.9
226
17,600
924
U
34
U
18
783
5/5
5/5
4/5
2/5
5/5
5/5
5/5
0/5
4/5
0/5
2/5
5/5
Screen!
ng
Value
Reference
Source
87
160
190
0.66
6.54
1,000
1.32
0.012
87.81
0.012
4
58.91
d
d
d
d
d
d
d
d
d
d
d
d
HQ
6
0.19
0.9
9
35
18
700
0
0.4
0
45
13
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2.6.2.2 Ecological Exposure Assessment
Setting
The wetlands delineated on the Site were both naturally formed and human-made. Wetlands on the
landfill and within the RM Site boundary are considered human-made. The remaining wetlands
identified and delineated are considered natural systems.
Four wetland areas were identified and delineated at the RM Site. Two of the wetland areas were
isolated emergent wetlands delineated on the landfill in the northern portion of the RM Site. One
isolated emergent wetland was identified in the southwest portion of the RM Site. The areas to the
east and north of the RM Site are classified as wetland. This wetland complex included an emergent
wetland located in the southeastern portion of the landfill. Wetlands east of the Site consisted of
emergent wetlands that were replaced in succession by broad-leaved deciduous scrub/shrub and
broad-leaved deciduous forested wetlands as you proceeded north and east. Wetlands north of the
Site consisted of broad-leaved deciduous forested wetlands. Needle-leaved deciduous (baldcypress)
forested wetlands replaced the broad-leaved deciduous forested wetlands as you proceeded north and
northeast from the study area. These wetlands are part of a large wetland complex associated with
the Wolf River floodplain.
Vegetation
Five vegetation types/communities (was one upland community and four wetland) were
identified in the investigation area. The classification of wetlands followed Cowardin et al.
(1979).
1) Upland field
2) Palustrine emergent (PEM)
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3) Palustrine broad-leaved deciduous scrub/shrub (PSS1)
4) Palustrine broad-leaved deciduous forested (PFO1)
5) Palustrine needle-leaved deciduous (baldcypress) forested (PFO2)
Note that the survey was conducted after fall dieback of vegetation. Therefore, the
identification of herbaceous species was limited.
Upland field
The southern/southeastern portion of the RM Site contained an area of open field.' Common
species included Poa spp., broomsedge (Andropogon spp.) and foxtail (Setaria spp.).
Palustrine emergent wetland
Four separate emergent wetland areas were identified at the Site. Three were isolated
wetlands. Two of these are located on the landfill. The third isolated wetland is located
within the southeastern portion of the RM Site. The fourth emergent wetland is located to
the east of the RM facility area and is part of a large wetland complex associated with the
Wolf River.
Dominant plant species for these areas included soft rush (Juncus effusus), cattail (Typha
spp.), cutgrass (Leersya spp.) and a variety of sedges, grasses and herbaceous species, most
of which could not be identified due to the time of the Site visit (following fall dieback of
vegetation).
Palustrine broad-leaved deciduous scrub/shrub (PSS1)
This wetland type was found east and northeast of the RM Site, and was a transition between
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the PEM and forested wetlands within the study area.
Common sapling species include green ash (Fraxinuspennsylvanicd), willow oak (Quercus
phellos), sweet gum(Liquidambarstyraciflua), red maple (Acerrubrum) and box elder (Acer
negundo). Common shrub species included buttonbush (Cephalanthus occidentalis) and
Rubus species (Rubus spp.). Understory species included most of those identified in the PEM
wetlands. Other common species included Japanese honeysuckle (Lonicerajaponica), field
garlic (Allium spp.) and unidentified grasses and asters.
Palustrine broad-leaved deciduous forested fPFOI)
c,
This wetland type was identified to the north of the landfill and to the east and north of the
PSS1 wetlands. Common tree species included sweet gum, willow oak, overcup oak
(Quercus lyrata), American elm (Ulmus americana), river birch (Betula nigra), and fed
maple. Common shrub species included common winterberry (Ilex verticillata), and a
honeysuckle species (Lonicera spp.). The sparse groundcover included numerous seedlings,
birdbill spikegrass (Chasmanthium ornithorhynchum), sensitive fern (Onocleasensibilis), and
nettles. Greenbriars (Smilax spp.) were a common woody vine.
Palustrine needle-leaved deciduous fbaldcypress) forested (PFO2)
This wetland type was located north of the PFO1 wetlands. Baldcypress (Taxodium
distichum) was the only tree species in this wetland type. Virginia willow (Itea virginica) was
the only shrub species found, and was restricted to elevated mounds scattered in the wetland
area. Herbaceous species were lacking.
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Soils
Soil color was generally a reliable indicator of wetland (hydric) and nonwetland areas at the
Site and adjacent areas. Gleying, oxidized root channels, and accumulation of organic matter
in the top 12 inches of the soil surface were all positive indicators of hydric soils in wetland
areas. The soil profiles suggested alluvial soils. This is consistent with the Fayette County
soil survey mapping for the area (Flowers 1964)
Upland soils lacked mottles and hydric color, and were generally a brighter color than hydric
soils in wetlands.
Hydrologic Conditions
Direct evidence of wetland hydrologic conditions in the form of standing water, and soil
saturation or free water within twelve inches of the soil surface in soil borings, was recorded
at the wetland sample stations during Site visits. Emergent wetlands contained standing water
and saturation to the soil surface. The scrub/shrub and deciduous forested wetlands generally
had saturation and/or free water within 10 inches of the soil surface. The baldcypress
wetlands contained standing water.
Indirect indicators of wetland hydrologic conditions included a lack of accumulated litter in
forested wetland areas and water stained leaves. This suggests that the area may be flooded
by the Wolf River.
Other Waters
Two drainage features were identified within the study area. One of these is a drainage swale
(slough) north of the Site that conveys surface water to the north into a baldcypress swamp.
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It is associated with an area of emergent wetland. This drainage feature likely receives runoff
from the RM Site that gathers in the northeast comer of the Site and from portions of the
landfill that slope towards the east and northeast.
The second drainage feature, a ditch located north of the Site, is the remnant of an historic
stream that was originally located along the western edge of the Site, and may have been part
of the Site. There are no defined channels connecting this ditch with the RM Site.
Another ditch is located east of the Site, just to the east of the boundary of the PFO1 wetland
along the eastern edge of the study area. The ditch bends towards the west as it proceeds
north, eventually discharging into the baldcypress swamp north of the RM Site. No defined
channels from the RM Site discharge into this ditch.
These three drainage features join in the baldcypress swamp north of the RM Site, and
eventually discharge into the Wolf River, which is a tributary of the Mississippi River.
Exposure Pathways
Prior to the initiation of the ecological risk assessment, it was known that elevated levels of
contaminants were present in the sediment, water, and possibly the biota on and adjacent to the Site.
The contamination was not only present within the facility boundaries, but also extended
approximately 300 feet east and 200 feet north of the facility boundaries. The degree of
contamination further away from the facility was not known prior to conducting this risk assessment.
A drainage ditch flows from a stormwater collection sump in the northeast corner of the facility area
into the wetland area approximately 380 feet due northeast. This ditch could act as a pathway for
contamination to continue migration northeast of the facility, especially during heavy rain events. It
was also not know whether the contamination had migrated into the Wolf River, approximately '/2-
mile north of the facility. Therefore, the wetlands north and east of the facility, the Wolf River, and
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the facility itself were identified as areas of concern prior to this risk assessment.
Chemical analyses of sediment, water, and biota were used to determine the levels of contaminants
in each area. The maximum concentration and the arithmetic mean of each contaminant concentration
were calculated from the resulting analytical data and used in the risk assessment to.represent the
conditions of Site-specific exposure.
On-Site receptors are potentially exposed to contaminants in abiotic matrices through direct contact,
intentional ingestion (e.g., consumption of water and food items), and incidental ingestion (e.g.,
sediment adhered to food items). Transfer of the contaminants to receptors could also occur through
processes of bioaccumulation through the food chain, whereby higher trophic level receptors are
exposed to Site contaminants through the ingestion of contaminated prey items.
Summary of field studies and modeling: A field investigation was conducted to obtain Site-specific
contaminant concentrations in water, sediment, and biological tissue that would provide data
necessary for the completion of the Site risk assessment. Surface water and sediment samples were
collected along a suspected contamination gradient (based on XRF data) in the adjacent wetlands and
submitted for Target Analyte List (TAL) metals analysis. The sediment samples were also submitted
for toxicity evaluations. Analytical data from the Wolf River, a water body connected to the wetland
system, was collected to assess potential risk to that system. Three locations were identified along
the Wolf River, "upstream," "midstream," and "downstream," from which sediment samples were
collected and submitted for TAL metals analysis. Site-specific tissue concentrations were also
obtained for use in food chain modeling. Plant, grasshopper, and frog samples were collected and
submitted for tissue analysis of TAL metals. These Site-specific tissue residue levels were used to
predict the amount of contaminant transfer through trophic levels and subsequently, to the ecological
functioning of the system.
Solid-phase toxicity evaluations were conducted to determine the effects of direct contact with Site
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contaminants to aquatic organisms. The underlying premise of these toxicity evaluations was that the
organism response can be associated with the contaminant levels determined by the chemical analyses.
The endpoints for these evaluations were survival and growth (measured as body length for H.
azteca and body weight for C. tentans). The methods used to conduct these studies are described
in the final toxicological evaluation reports. In addition, measured concentrations of each
contaminant of concern in surface water were compared to literature-based values on the toxicity to
early life stages of amphibians. This provided a qualitative assessment of the risk of the Site
contamination to amphibians.
Finally, the results of the analyses of water, sediment, and tissue (food items) were use'd in a food
chain model to predict exposure dosages for each contaminant of concern to upper trophic levels.
For the purposes of the model, it was assumed that the food of herbivorous species (meadow vole)
comprised 100 percent soft rush, the food of insectivorous species (red-winged blackbird, short-tailed
shrew) comprised 100 percent grasshoppers, and the food of carnivorous species (green heron, mink)
comprised 100 percent green tree frogs, since these were the food items collected from the Site and
analyzed. The resulting exposure dosages were divided by an effect concentration derived from the
literature to provide a hazard quotient for each contaminant of concern and each receptor species.
2.6.2.3 Ecological Effects Assessment
A review of the wetland and surrounding habitats provided information for the selection of
assessment endpoints. A variety of invertebrates, vertebrates, and plants inhabit the wetland. In
addition, many birds and mammals from adjacent habitats could prey on the wetland flora and fauna.
Therefore, the assessment endpoints will focus on these biological groups. The assessment endpoints
relate specifically to viability of avian, mammalian, and wetland invertebrate, vertebrate and plant
populations as well as organism survivability were selected as assessment endpoints for this risk
assessment. Listed next and summarized in Table 2-15 are the specific assessment endpoints selected
followed by the supporting measurement endpoint:
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Table 2-15
Ecological Exposure Pathways of Concern
Exposure Media
Sediment/Surface Water
Sedjmenl/Surface Water
Soil/Sediment/Surfacc
Waler
Sediment/Surface Water
Soil/Sediment/Surface
Water
Soil/Sediment/Surface
Water
Soil/Sediment/Surface
Water
Exposure Routes
Incidental sediment ingeslion
Direct contact with sediment
Accumulation in forage
Direct contact with surface water
Incidental sediment ingeslion
Direct contact with sediment
Accumulation in forage
Direct contact with surface water
Incidental soil/sediment ingestion
Direct contact with soil/sediment
Accumulation in forage
Ingestion of surface water
Incidental soil/sediment ingeslion
Direct contact with soil/sediment
Accumulation in forage
Ingestion of surface water
Incidental soil/sediment ingestion
Direct contact with soil/sediment
Accumulation in plant forage
Ingestion of surface water
Incidental soil/sediment ingeslion
Direct contact with soil/sediment
Accumulation in forage
Ingestion of surface water
Incidental soil/sediment ingestion
Direct contact with soil/sediment
Accumulation in forage
Ingeslion of surface water
Assessment Endpoinls
Protection of benthic
invertebrate community
structure and (unction.
Protection of amphibians from
adverse effects on growth,
survival, and/or reproductive
success.
Protection of insectivorous
birds from adverse cflixts on
growlh, survival, and/or
reproductive success,
Protection of carnivorous
birds from adverse effects on
growlh, survival, and/or
reproductive success.
Protection of herbivorous
mammals from adverse effects
on growth, survival, and/or
reproductive success.
Protection of insectivorous
mammals from adverse effects
on growlh, survival, and/or
reproductive success.
Protection of carnivorous
mammals from adverse effects
on growlh, survival, and/or
reproductive success
Measurement Endpoinls
Toxicity of sediments to
Chironomus teutons and
Hyalella azteca
Comparisons with literature-
based values on the toxicity of
surface water concentrations
to early life stages of
amphibians
Dietary exposure studies were
selected to evaluate risk to
insectivorous bird species that
use the site.
Dietary exposure studies were
selected to evaluate risk to
carnivorous bird species thai
use Ihe site.
Dietary exposure studies were
selected lo evaluate risk to
herbivorous mammals that
use (he site.
Dietary exposure studies were
selected to evaluate risk to
insectivorous mammals that
use the site.
Dietary exposure studies were
selected to evaluate risk to
carnivorous mammals that
use the site.
Receptor
Chironomus
lenlans and
Hyalella azteca
Green tree frog,
Hyla cinerea
Red-winged
blackbird,
Agclaius
phoeniceus
Green heron,
Butorides
striatus
Meadow vole,
Microtus
pcnnsylvanicus
Short-tailed
shrew, Blarina
brevicauda
Mink, Muslela
vison
Endangered or Threatened Species
No
No
No
No
No
No
No
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Protection of benthic invertebrate community structure and function.
Toxicity evaluations using sediment and benthic invertebrate species were conducted
to determine if contaminant levels in the sediment have an adverse effect on survival
and growth, measured as body weight and body length. The midge, Chironomus
tentans, and the amphipod, Hyalella azteca, were selected to represent benthic
invertebrates.
Protection of amphibians from adverse effects on growth, survival, and/or
reproductive success.
Comparisons with literature-based values on the toxicity of surface water
concentrations to early life stages of amphibians were used to evaluate risk to
amphibian species that use the Site. The green tree frog, Hyla cinerea, was selected
to represent an amphibian.
Protection of insectivorous birds from adverse effects on growth, survival, and/or
reproductive success.
Dietary exposure studies were selected to evaluate risk to insectivorous bird species
that use the Site. The red-winged blackbird, Agelaius phoeniceus, was selected to
represent an insectivorous bird. Appropriate food items were identified and a
contaminant dose calculated based on the ingestion of contaminated prey
(grasshoppers) and water.
Protection of carnivorous birds from adverse effects on growth, survival, and/or
reproductive success.
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Dietary exposure studies were selected to evaluate risk to carnivorous bird species
that use the Site. The green heron, Butorides striatus, was selected to represent a
carnivorous bird. Appropriate food items were identified and a contaminant dose
calculated based on the ingestion of contaminated prey (frogs), sediment, and water.
* Protection of herbivorous mammals from adverse effects on growth, survival, and/or
reproductive success.
Dietary exposure studies were selected to evaluate risk to herbivorous mammal
species that use the Site. The meadow vole, Microtus pennsylvanicus, was selected
to represent a herbivorous mammal. Appropriate food items were identified and a
contaminant dose calculated based on the ingestion of contaminated food (plants),
sediment, and water.
4 Protection of insectivorous mammals from adverse effects on growth, survival, and/or
reproductive success.
Dietary exposure studies were selected to evaluate risk to insectivorous mammals that
use the Site. The short-tailed shrew, Blarina brevicauda, was selected to represent
an insectivorous mammal. Appropriate food items were identified and a contaminant
dose calculated based on the ingestion of contaminated prey (grasshoppers), sediment,
and water.
* Protection of carnivorous mammals from adverse effects on growth, survival, and/or
reproductive success.
Dietary exposure studies were selected to evaluate risk to carnivorous mammals that
use the Site. The mink, Mustela vison, was selected to represent a carnivorous
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mammal. Appropriate food items were identified and a contaminant dose calculated
based on the ingestion of contaminated prey (frogs), sediment, and water.
Summary ofToxicity Tests: The results of the 10-day sediment toxicity test using the amphipod,
Hyalella azteca, are summarized in the Ecological Risk Assessment. Survival was significantly
reduced in only the treatment for Location 3 (see Figure 2-21) when compared to both the laboratory
control and Reference 1. There were no significant reductions in growth for any location compared
to either Reference 1 or the laboratory control. Therefore, sediment from Location 3 was acutely
toxic to Hyalella, but no chronic toxicity was detected in any of the locations. The final report for
this test can be found in the Ecological Risk Assessment.
The results of the 10-day sediment toxicity test using the midge, Chironomus tentans, are summarized
in the Ecological Risk Assessment. When compared to the reference, survival was significantly
reduced only in the treatments for Location 3. When compared to the laboratory control, survival
in the treatments for Locations 2, 3, and 12 were significantly reduced. Since this Risk Assessment
is based on comparisons to the reference area, it can be concluded that only the sediment from
Location 3 was acutely toxic to Chironomus tentans. The final reports for these tests can be found
in the Ecological Risk Assessment.
Summary of Food Chain Model Results: The hazard quotient method (Bamthouse et al. 1986;
U.S. EPA 1989) was employed to predict the effects of surface water and sediment contamination
at the Site with regard to assessment endpoints. The hazard quotient method compares exposure
concentrations to ecological endpoints such as reproductive failure or reduced growth. The
comparisons are expressed as ratios of potential intake values to population effect levels. In addition,
due to the magnitude of the concentrations of lead in sediment and water collected at the Ross Metals
Site, an acute hazard quotient was also calculated for lead using an acute toxicity value. The effect
level values are based on studies published in the literature. The exposure concentrations were
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LEGEND
• SAMPLE LOCATION
• SAMPLE LOCATION
(XRF ONLY)
GRAPHIC SCALE
900 1000
1 Inch
1003t
U.S. EPA ENVIRONIIENTAI RESPONSE TEAM CENTER
c pence*!**; AMD JWALYTIEX. CDNTHUCT
FIGURE 2-21
SITE AND REFERENCE
AREA LOCATION MAP
ROSS METALS SUPERFUND SITE
ROSSVILLE, FAYETTE COUNTY. TN
JANUARY 1998
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estimated by employing a food chain model for each receptor species. In these food chain models,
ingestion rates of each contaminant of concern for each receptor species are determined based on
known or estimated water, sediment, and food ingestion rates and body weights of each receptor
species, as well as the measured concentrations of each contaminant in water, sediment, and food
items collected at the Site. The exposure concentrations and toxicity values are entered into the
hazard quotient equation, and a hazard quotient is calculated. If the hazard quotient for a particular
contaminant is greater than one based on an acute value, this indicates that there is an acute risk from
that contaminant to the ecological receptor in question. If the hazard quotient is greater than one
based on a No Observed Adverse Effects Level (NOAEL), this indicates that there is a potential
chronic risk from that contaminant to the ecological receptor in question. If the hazard quotient is
greater than one based on a Lowest Observed Adverse Effects Level (LOAEL) for a particular
contaminant, this indicates a more serious risk in that the Site levels of that contaminant have the
potential to produce an actual adverse effect on survival, reproduction, or growth of the ecological
receptor in question. The hazard quotient should be interpreted based on the severity of the effect
reported.
In addition to determining whether each contaminant poses a risk to the selected assessment
endpoints, preliminary ecotoxicologically-based remedial goals were established for those
contaminants which were determined to be risks. These remedial goals are for sediment, and they
are based on the premise that if the concentration of a contaminant is decreased in sediment, its
concentration would subsequently decrease in surface water and biota. The characteristics of the Site
were such that the surface water above the sediment was only a few centimeters deep. This would
presumably allow for rapid equilibrium of contaminants between the sediment and water at the Site.
Using these assumptions, a watensediment contaminant ratio and a biota:sediment contaminant ratio
were calculated for the Site based on mean concentrations of each contaminant at the Site. The sump
area was excluded from the sediment denominator in the water:sediment and plant:sediment ratios,
because no water or plant samples were collected from the sump area. The ratios were applied to
the food chain model described previously, and the sediment concentration in the model was changed,
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thus changing the water and biota concentrations according to the calculated ratios until the hazard
quotient was just less than one. This calculation was performed for both the NOAEL and LOAEL
values, thus providing a preliminary ecotoxicologically based remedial goal for each contaminant
presenting a risk and for each assessment endpoint.
Results and Conclusions of the Acute Risk Characterization for Lead
The food chain model and acute hazard quotient calculations for lead and the five assessment
endpoints evaluated using this model are presented in the Ecological Risk Assessment. Using the
mean and maximum lead concentrations in sediment, no acute risk from lead to insectivorous birds,
carnivorous birds, or carnivorous mammals was calculated. However, for insectivorous mammals,
both the mean and maximum lead concentrations in sediment calculated an acute risk from lead. In
addition, an acute risk to herbivorous mammals was calculated when the maximum lead concentration
in sediment was used, but not when the mean concentration was used. These results indicate that an
acute risk is posed to herbivorous and insectivorous mammals from the lead contamination at the
Ross Metals Superfund Site.
When the sediment concentration of lead was adjusted so that the acute hazard quotient was just less
than one, as described previously, a lead concentration of 9310 mg/kg in sediment was calculated for
herbivorous mammals and 2160 mg/kg for insectivorous mammals. Therefore, a lead concentration
of less than 2160 mg/kg in sediment at the Ross Metals Superfund Site is expected to be protective
of an acute threat to the avian and mammalian receptors evaluated in this risk assessment.
Results and Conclusions of the Chronic Risk Characterization for Insectivorous Birds
The food chain model and chronic hazard quotient calculations for insectivorous birds are presented
in the Ecological Risk Assessment. Using the maximum concentrations for each contaminant of
concern and the NOAEL, it was determined that a potential risk is associated with lead at the Ross
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Metals Superfund Site. Additionally, the mean contaminant concentrations and the NOAEL also
calculated a potential risk from lead at the Site. When the maximum contaminant concentrations and
the LOAEL were used in the model, a risk was still calculated from lead. However, when the mean
contaminant concentrations and the LOAEL were used in the model, no risk was calculated from any
contaminant.
When the sediment concentration of lead was adjusted so that the hazard quotient was just less than
one, as described previously, a NOAEL of 933 mg/kg and a LOAEL of 93 30 mg/kg were determined.
Therefore, a preliminary ecotoxicologically-based'target remedial goal of 933 mg/kg - 9330 mg/kg
for lead in sediment was determined for the protection of insectivorous birds.
Results and Conclusions of the Chronic Risk Characterization for Carnivorous Birds
The food chain model and chronic hazard quotient calculations for carnivorous birds are presented
in the Ecological Risk Assessment. Using the maximum concentrations for each contaminant of
concern and the NOAEL, it was determined that lead poses a potential risk at the Ross Metals
Superfund Site. The mean contaminant concentrations and the NOAEL also calculated a potential
risk from lead at the Site. When both the maximum and the mean contaminant concentrations were
used with the LOAEL in the model, a risk was still calculated from lead.
When the sediment concentration of lead was adjusted so that the hazard quotient was just less than
one, as described previously, a NOAEL of 133 mg/kg and a LOAEL of 1330 mg/kg were determined.
Therefore, a preliminary ecotoxicologically-based remedial goal of 133 mg/kg - 1330 mg/kg for lead
in sediment was determined for the protection of carnivorous birds.
Results and Conclusions of the Chronic Risk Characterization for Herbivorous Mammals
The food chain model and chronic hazard quotient calculations for herbivorous mammals are
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presented in the Ecological Risk Assessment. Using the maximum concentrations for each
contaminant of concern and the NOAEL, it was determined that aluminum, arsenic, cadmium, lead,
and nickel pose a potential risk at the Ross, Metals Superfund Site. When the mean contaminant
concentrations and the NOAEL were used in the model, no risk from nickel was calculated, but a
potential risk was still calculated from aluminum, arsenic, cadmium, and lead. When the maximum
contaminant concentrations and the LO AEL were used in the model, a risk was still calculated from
aluminum, arsenic, cadmium, and lead. When the mean contaminant concentrations and the LOAEL
were used in the model, no risk was calculated from arsenic or cadmium, but a risk was still evident
from aluminum and lead.
When the sediment concentration of aluminum was adjusted so that the hazard quotient was just less
than one, as described previously, a NOAEL of 123 mg/kg and a LOAEL of 1230 mg/kg were
determined. Therefore, a preliminary ecotoxicologically-based remedial goal of 123 mg/kg -1230
mg/kg for aluminum in sediment was determined for the protection of herbivorous mammals.
When the sediment concentration of arsenic was adjusted so that the hazard quotient was just less
than one, as described previously, a NOAEL of 0.16 mg/kg and a LOAEL of 1.6 mg/kg in sediment
were established. Therefore, a preliminary ecotoxicologically-based remedial goal of 0.16 mg/kg -
1.6 mg/kg for arsenic in sediment was determined for the protection of herbivorous mammals.
When the sediment concentration of cadmium was adjusted so that the hazard quotient was just less
than one, as described previously, a NO AEL of 0.25 mg/kg and a LOAEL of 2.5 mg/kg in sediment
were established. Therefore, a preliminary ecotoxicologically-based remedial goal of 0.25 mg/kg -
2.5 mg/kg for cadmium in sediment was determined for the protection of herbivorous mammals.
When the sediment concentration of lead was adjusted so that the hazard quotient was just less than
one, as described previously, aNOAEL of 556 mg/kg and a LOAEL of 5560 mg/kg were determined.
Therefore, a preliminary ecotoxicologically-based remedial goal of 556 mg/kg - 5560 mg/kg for lead
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in sediment was determined for the protection of herbivorous mammals.
When the sediment concentration of nickel was adjusted so that the hazard quotient was just less than
one, as described previously, a NOAEL of 1.5 mg/kg in sediment was established. A LOAEL for
nickel in sediment was not determined because when the mean and maximum nickel concentrations
and a LOAEL were used in the original model, no risk was established. Therefore, the preliminary
ecotoxicologically-based remedial goal is an unbounded NOAEL of 1.5 mg/kg of nickel in sediment
for the protection of herbivorous mammals.
Results and Conclusions of the Chronic Risk Characterization for Insectivorous Mammals
The food chain model and chronic hazard quotient calculations for insectivorous mammals are
presented in the Ecological Risk Assessment. Using the maximum concentrations for each
contaminant of concern and the NOAEL, it was determined that aluminum, arsenic, cadmium, lead,
and nickel pose a potential risk at the Ross Metals Superfund Site. When the mean contaminant
concentrations and the NOAEL were used in the model, no risk from cadmium or nickel was
calculated, but a potential risk from aluminum, arsenic, and lead was still evident. When both the
mean and maximum contaminant concentrations and the LOAEL were used in the model, a risk was
still evident from aluminum, arsenic, and lead.
When the sediment concentration of aluminum was adjusted so that the hazard quotient was just less
than one, as described previously, a NOAEL of 53.3 mg/kg and a LOAEL of 533 mg/kg were
determined. Therefore, a preliminary ecotoxicologically-based remedial goal of 53.3 mg/kg - 533
mg/kg for aluminum in sediment was determined for the protection of insectivorous mammals.
When the sediment concentration of arsenic was adjusted so that the hazard quotient was just less
than one, as described previously, a NOAEL of 0.14 mg/kg and a LOAEL of 1.4 mg/kg were
determined. Therefore, a preliminary ecotoxicologically-based remedial goal of 0.14 mg/kg - 1.4
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mg/kg for arsenic in sediment was determined for the protection of insectivorous mammals.
When the sediment concentration of cadmium was adjusted so that the hazard quotient was just less
than one, as described previously, aNOAEL of 0.46 mg/kg in sediment was established. A LOAEL
for cadmium in sediment was not determined because when both the mean and maximum cadmium
concentrations and a LOAEL were used in the original model, no risk was established. Therefore,
the preliminary ecotoxicologically-based remedial goal is an unbounded NOAEL of 0.46 mg/kg of
cadmium in sediment for the protection of insectivorous mammals.
When the sediment concentration of lead was adjusted so that the hazard quotient was just less than
one, as described previously, a NOAEL of 129 mg/kg and a LOAEL of 1290 mg/kg were determined.
Therefore, a preliminary ecotoxicologically-based remedial goal of 129 mg/kg -1290 mg/kg for lead
in sediment was determined for the protection of insectivorous mammals.
When the sediment concentration of nickel was adjusted so that the hazard quotient was just less than
one, as described previously, a NOAEL of 1.40 mg/kg in sediment was established. A LOAEL for
nickel in sediment was not determined because when the mean and maximum nickel concentrations
and a LOAEL were used in the original model, no risk was established. Therefore, the preliminary
ecotoxicologically-based remedial goal is an unbounded NOAEL of 1.40 mg/kg of nickel in sediment
for the protection of insectivorous mammals.
Results and Conclusions of the Chronic Risk Characterization for Carnivorous Mammals
The food chain model and chronic hazard quotient calculations for carnivorous mammals are
.presented in the Ecological Risk Assessment. Using the maximum concentrations for each
contaminant of concern and the NOAEL, it was determined that aluminum, arsenic, and lead pose
a potential risk at the Ross Metals Superfund Site. When the mean contaminant concentrations and
the NOAEL were used in the model, a potential risk was still calculated from aluminum, arsenic, and
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lead. When the maximum contaminant concentrations and the LOAEL were used in the model, a risk
was still calculated from arsenic and lead. When the mean and LOAEL were used, no risk to
carnivorous mammals was evident from any of the contaminants.
When the sediment concentration of aluminum was adjusted so that the hazard quotient was just less
than one, as described previously, a NOAEL of 321 mg/kg in sediment was established. A LOAEL
for aluminum in sediment was not determined because when the mean and maximum aluminum
concentrations and a LOAEL were used in the original model, no risk was established. Therefore,
the preliminary ecotoxicologically-based remedial goal is an unbounded NOAEL of 321 mg/kg of
aluminum in sediment for the protection of carnivorous mammals.
When the sediment concentration of arsenic was adjusted so that the hazard quotient was just less
than one, as described previously, a NOAEL of 0.31 mg/kg and a LOAEL of 3.1 mg/kg in sediment
were established. Therefore, the preliminary ecotoxicologically-based remedial goal of 0.31-3.1
mg/kg of arsenic in sediment was determined for the protection of carnivorous mammals.
When the sediment concentration of lead was adjusted so that the hazard quotient was just less than
one, as described previously, a NOAEL of 4490 mg/kg and a LOAEL of 44,900 mg/kg in sediment
were established. Therefore, the preliminary ecotoxicologically-based remedial goal for lead in
sediment is 4490 - 44,900 mg/kg for the protection of carnivorous mammals.
2.6.2.4 Conclusions
The results of the analyses of the samples collected at the Site indicated that it has been heavily
contaminated with metals. Contamination extends both north and east of the Site and into the
adjacent wetlands. Of all the metals calculated to pose a potential risk, lead was determined to pose
the highest risk to ecological receptors. It was also determined that organic contaminants are present
at the Site; however, the magnitude and extent of this contamination remains uncertain because of
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the small sample size. Site-related contaminants have not been detected in the Wolf River.
The following sections present the conclusions that were drawn regarding the viability of avian,
mammalian, and wetland invertebrate, vertebrate and plant populations, as well as organism
survivability. NOAEL and LOAEL ranges for each receptor group are presented in Table 2-16.
2.7 REMEDIATION OBJECTIVES
2.7.1 Remedial Goals
For the protection of human health and ecological receptors, those COCs that are related to past
operations at the facility have been considered in the development of a soil/sediment remedial
alternative. These COCs include aluminum, antimony, arsenic, barium, cadmium, copper, iron, lead,
manganese, selenium, and vanadium. For ecological receptors, COCs include aluminum, antimony,
arsenic, cadmium, copper, iron, lead, mercury, nickel and zinc.
Development of a remedial effort specifically for contaminated surface water is not recommended if
the contaminant source is remediated. That is, if contaminated sediments are removed, surface water
would be remediated. Surface water quality could be monitored to determine the effectiveness of the
contaminant source remediation.
The geochemical model mention previously in Section 2.5.7.4 indicated that removal of lead to 100
ppm left a residual soil lead concentration of 31.71 ppm, which is near background levels. It predicts
that removal of lOOppm would be protective or groundwater for at least 90 years. However, the
conservative nature of this number, along with the uncertainty surrounding the modeling effort, make
it inappropriate to use as a subsurface soil cleanup goal.
The 100 ppm goal is based on the assumption of a 5,000 ppm surface load factor. However, the
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Table 2-16
COC Concentrations Expected to Provide Adequate Protection of Ecological Receptors
HabiuiType
Wetland/Creek
Welland/Soils
Wetlands/Soils
Wetlands/Soils
Wcllands/Soils
Wellands/Soils
Wetland/Creek
Exposure Medium
Sediment
Soil/Sedimenl
Soil/Sediment
Soil/Sediment
Soil/Sediment
Soil/Sediment
Surface Water
COC
Antimony
Arsenic
Cadmium
Copper
Lead
Mercury
Lead '
Lead
Aluminum
Arsenic
Cadmium
Lead
Nickel
Aluminum
Arsenic
Cadmium
Lead
Nickel
Aluminum
Arsenic
Lead
Aluminum
Arsenic
Cadmium
Copper
Iron
Lead
Zinc
Protective Level
Rings
19-70
10-45
3.2-3.3
15-68
2.790-13.098
1.5
53.3-533
0.14-1.4
>0.46
129-1290
>l.4
>321
0.31-3.1
4490-44,900
50
40
JO
40
30.000
40
10
Units
mg/kg.
ww
mg/kg.
ww
mg/kg.
ww
mg/kg,
ww
mg/kg.
ww
mg/kg.
ww
UE/L
Bads
Site specific NOAEI, to LOAEL range
Site specific NOAEL lo LOAEL range
Site specific NOAEL lo LOAEL range
Site specific NOAEL to LOAEL range
Silo specific NOAKI. lo IjOARL range
Site specific NOAEL to LOAEL range
Literature based loxicity information
Assessment Endpoint
Protection of bailhic invertebrate
community timeline and function.
Proteciion of insectivorous birds from
adverse effects on growth, survival,
and/or reproductive success.
Protection of carnivorous birds from
adverse effects on growth, survival,
and/or reproductive success.
Protection of herbivorous mammals
from adverse effects on growth,
survival, and/or reproductive success.
Protection of insecu'vorous mammals
from adverse effects on growth,
survival, and/or reproductive success.
Protection of carnivorous mammals
from adverse effects on growth,
survival, and/or reproductive success
Protection of amphibians from
adverse effects on growth, survival,
and/or reproductive success.
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establishment of a 400 ppm risk-based surface soil clean-up goal would mean surface soil
concentrations no greater than 400 ppm. With a surface soil concentration of 400 ppm and
considering the nature of the contamination, clean up of surface soils to 400 ppm in the area of the
wrecker building and truck wash should allow for the protection of groundwater.
Table 2-17 presents the risk-based (human health and ecological) remedial goals for surface soil,
subsurface soil, and sediment.
2.7.2 Remedial Action Objectives
The remedial action objectives (RAOs) for the Ross Metals Site are as follows:
Soil
prevent ingestion, inhalation, or direct contact with surface soil that contain concentrations
in excess of the Remedial Goals (RGs);
prevent further migration and leaching of contaminants in surface and subsurface soil to
groundwater that could result in groundwater contamination in excess of MCLs;
prevent further migration of contaminants in surface soil/sediment to surface water that could
result in groundwater contamination in excess of MCLs;
prevent ingestion or inhalation of soil that contain concentrations in excess of the RGs;
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Table 2-17
Remedial Goals
Contaminant of Concern
Surface Soil (mg/kg)
Aluminum
Antimony
Arsenic
Barium
Cadmium
Copper
Iron
Lead
Manganese
Selenium
Vanadium
Subsurface Soil (mg/kg)
Lead
Wetlands Sediment (mg/kg)
Aluminum
Antimony
Arsenic
Cadmium
Copper
Lead
Mercury
Nickel
Remedial Goals
11,620
3
5
505
7
293
16,100
400
559
37
51
400
8,860
28.4 - 104
5.58
0.37 - 3.73
22.4-101.5
192 - 1,925
ND - 0.21
9.10
Basis
Avg. Background Concentration
Hazard Quotient Level = 0.1
Avg. Background Concentration
Hazard Quotient Level = 0.1
Hazard Quotient Level = 0.1
Hazard Quotient Level = 0.1
Avg. Background Concentration
Protection of Human Health
Avg. Background Concentration
Hazard Quotient Level = 0.1
Hazard Quotient Level = 0.1
Protection of groundwater
Avg. Background Concentration
Protection of Ecological Receptors
Avg. Background Concentration
Protection of Ecological Receptors
Protection of Ecological Receptors
Protection of Ecological Receptors
Protection of Ecological Receptors
Avg. Background Concentration
Footnote: Values for protection of ecological receptors were obtained by using a mean percent moisture concentration (33%) to convert NOAJEL/LOAEL
ranges (wet weight basis) to a dry weight range.
ND- Not Detected
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Wetlands
• reduce potential for exposure of contaminated sediments/soils and surface waters to
ecological receptors;
prevent transport andmigration of Site contaminants to the adjacent uncontaminated wetlands
and the Wolf River,
• restore impacted wetland communities; and
• prevent further degradation of the wetlands and the adjacent areas.
2.7.3 Extent of Source Material Contamination Above Remedial Goals
To facilitate the evaluation of potentially applicable removal action alternatives for the Site, solid
media waste can be divided into four general categories based on physical and chemical
characteristics:
• Waste slag (landfilled and stockpiled on Site)
• Contaminated soil (in old fenced area and landfill area)
• Building ruins
• Demolition debris (pavement)
• Contaminated sediment (in wetlands)
Results from previous investigations suggest that lead will be the "driver" in any remediation effort
conducted at the Site. The presence of lead is sufficiently widespread that gearing a remediation
effort to lead will also remediate other COC contamination, meaning that the extent of lead
contamination serves as a good indicator of the extent of all the COC contamination at the RM Site.
In addition, the ecological risk assessment concluded that of all the metals calculated to pose a
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potential risk, lead was determined to pose the highest risk to the ecological receptors at the Site.
Contaminated Solid Media in Old Fenced Area and Landfill
Based on excavations performed in the landfill at the north end of the Site in November 1996, an
estimated 10,000 CY of buried landfill slag is present on Site. In addition, several stockpiles of waste
slag are located in various on-Site buildings (see Figure 2-2). The building labeled "furnace and raw
materials refinery" contains two waste slag stockpiles totaling about 700 CY. The buildings labeled
"wrecker," "slag fixation," and "shipment" contain waste slag stockpiles of about 2,600; 700; and
2,000 CY, respectively. The total combined volume of the stockpiled waste slag is about 6,000 CY.
Lead-contaminated surface and subsurface soil is present in the landfill at depths of up to 5.5 feet bgs.
Lead-contaminated surface soil is present throughout the fenced portion of the Site at depths of up
to 1.5 feet beneath the pavement. Based on an area of 450 by 525 feet, the volume of waste soil is
estimated as 13,125 CY.
Lead-contaminated subsurface soil was noted along the eastern edge of the wrecker building at depths
up to 40 inches bgs. Lead-contaminated subsurface soil was also noted near the southeastern corner
of the truck wash. Based on two 125-ft-square areas at depths from 1.5 to 3 feet, the volume of
contaminated subsurface soil is estimated as 2,500 CY. Figures 7-1 and 7-2 indicate the extent of
lead contamination in Site soils.
The deteriorating buildings are located within the fenced portion of the Site. The largest of the
buildings is a sheet metal building labeled "furnace and raw materials refinery;" the building is roughly
25 to 30 feet high, 180 feet long, and 100 feet wide. Alter demolition and compaction, the combined
volume of the building debris is not expected to exceed 27,000 cubic feet (CF) (1,000 CY). The
buildings are in poor condition and constitute a safety hazard.
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Additional demolition debris maybe generated at the Site depending on the remedial action selected.
About 20,000 square yards (SY) of asphalt and concrete pavement are located within the fenced
portion of the Site. An 8-inch-thick concrete pad located within the landfill area covers about 1,333
SY. Therefore, the total area of pavement at the Site is about 21,333 SY (including asphalt and
concrete). The volume of concrete and asphalt estimated for disposal is 3,700 CY.
Based on the estimated volumes of the landfilled and stockpiled slag, the total volume of slag is
estimated to be about 16,000 CY.
Contaminated Sediment in Wetlands
In December 1997, EPA ERTC conducted sediment sampling to determine the extent of lead
contamination in the wetland area adjacent to the old fenced area and landfill. Samples were collected
from 0 to 6 inches in depth and analyzed at the Site by field portable X-ray fluorescence (XRF) to
determine the extent of lead contamination above. Because RGOs based on protection of ecological
receptors are presented as ranges, an acceptable goal within the range must be selected in order to
calculate the volume of contaminated sediment in the wetlands. Because lead, as previously indicated,
is so widespread and presents the highest risk to ecological receptors; a cleanup goal established for
it that takes into account impact to wetlands, should also ensure cleanup of other COCs to acceptable
levels. To determine an acceptable goal, a chart plotting cleanup goals versus area of wetlands to
be excavated to obtain the cleanup goal was created and is shown in Figure 2-22. Figure 2-22
suggests that 800 mg/kg would be the most effective cleanup goal causing the least disturbance to
the wetlands. Based on the XRF results, there are approximately 5.7 acres of material contaminated
above 800 mg/kg lead. Figure 2-23 illustrates the contaminated wetlands.
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Figure 2-22
Cleanup Goals v. Excavation Required
10
9.02
fl.53/
5.7 5.7 5.7 5.7 5.7 5.7 5.7
5.5 5.5 5.5 6.5 5.5
6.19
Area requiring excavation In order to meet cleanup goal
i i i
1900 1800 1700 1600 1500 1400 1300 1200 1100 1000 900 800 700 600 500 400 300 200
Cleanup Goal (ppm)
-------
LEGEND
/\ Sample Location
K%% Removal Area
Wetland Community Types
I'."-I Scrub/Shrub
f-^1 Emergent
U-lJ Brood-leoved Deciduous Forest
i^) Needle-Leaved Deciduous
(Bold Cypress) forest
~N800--Leod Concentration Contour (mg/kg)
GRAPHIC SCALE
100 200
Scale in Feet
Ross Metals Site
Rossville, Tennessee
COM Federal Programs Corporation
t I I
Cohtaminant Contour in
Wetlands
March 1998
Figure No.
2-23
8/98
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Summary of Contaminated Solid Media
The total estimated volume of contaminated solid media includes the following components:
• Waste Slag
Landfill: 10,000 CY
Surface Slag: 6,000 CY
Lead-contaminated Surface Soil (volume includes areas contaminated with other COCs)
Wetlands (sediment): 9,300 CY (at 800 ppm level)
Old Facility Fenced Area: 13,125 CY (at 400 ppm level)
Landfill Area: 8,750 CY (at 400 ppm level)
Lead-contaminated Subsurface Soil 2,500 CY (at 400 ppm level)
Lead-contaminated Buildings 1,000 CY (at 10 ug/dl level)
• Demolition Debris 3,700 CY
The contaminated solid media at the RM Site can be considered source material because it includes
or contains hazardous substances, pollutants or contaminants that act as a reservoir for migration of
contamination to groundwater, to surface water, to air, or acts as a source for direct exposure.
Because the contaminated solid media is considered source material, the concept of principal threat
and low level threat wastes should be applied to the RM Site.
Principal threat wastes are those source materials considered to be highly toxic or highly mobile that
cannot be reliably contained or would present a significant risk to human health or the environment
should exposure occur. Although no "threshold level" of risk has been established to identify principal
threat waste, source materials with toxicity and mobility characteristics that pose a potential risk
several orders of magnitude greater than the acceptable risk level for current or future land use can
be considered principal threat wastes. For the RM Site, this would conservatively encompass solid
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media with lead concentrations ranging from 40,000 ppm, since the RGO for lead is 400 pprn in soil,
and wetland sediment with lead concentrations ranging from 1,900 mg/kg upward since acute risk
occurs at the LOAEL which is equal to 1,920 mg/kg.
Low level threat wastes are those source materials that generally can be reliably contained and that
would present only a low risk in the event of a release. They include source materials that exhibit low
toxicity, low mobility in the environment, or are near health-based levels.
The identification of principal threat and low level threat wastes is important because their presence
influences the development of appropriate remedial alternatives. Although exceptions apply, EPA
generally expects to use treatment to address the principal threats posed by a Site, wherever
practicable. On the other hand, the use of institutional controls, such as containment, is expected for
wastes that pose a relatively low long-term threat or where treatment is impracticable (EPA 1991).
A review of the sampling results suggests that some of the contaminated solid media present at the
RM Site can be considered principal threat waste based on the lead concentrations present. Waste
sample SL-01 and Site surface soil samples T4-LF/B12, 008SLA, and 013SLA all had lead
concentrations greater than 40,000 ppm. In addition, the soil associated with sample 020SLA could
be considered principal threat waste based on an arsenic concentration of 40 ppm.
Assuming an excavation depth of 1.5 ft bgs with a 50 foot x 50 foot excavation grid centered on each
of the Site soil samples exceeding 40,000 ppm lead, and each of the wetland sediment samples
exceeding 1,900 ppm lead, results in a volume of approximately 600 CY of contaminated soil and
8,200 CY of wetland sediment. Adding the 6,000 CY of stockpiled slag to this volume (based on the
results of waste sample WS-01), and the 10,000 CY of landfilled slag (based on similarity to the
stockpiled skg) results in a total volume of approximately 24,800 CY of the 53,275 CY of total
contaminated solid media that could be considered principal threat waste.
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2.8 DESCRIPTION OF SOURCE MATERIAL ALTERNATIVES
A summary of source material alternatives is provided in Table 2-18.
2.8.1 Alternative S-l - No Action
2.8.1.1 Description
Under this alternative, no action would be taken to remedy the contaminated surface soil, slag,
sediment, or other solid media at the Site. The alternative would only involve the continued
monitoring of structures, surface soil, slag, sediment, and surface water quality at the Site.
Approximately five wipe samples (from buildings) and ten surface soil and fifteen surface
water/sediment samples would be collected from the affected areas and analyzed for the PCOCs found
in each medium every five years for 30 years. Public health evaluations would be conducted every
five years and would allow EPA to assess the ongoing risks to human health and the environment
posed by the RM Site. The evaluations would be based on the data collected from media monitoring.
2.8.1.2 Overall Protection of Human Health and the Environment
The no action alternative does not eliminate any exposure pathways or reduce the level of risk of the
existing soil contamination.
jqu±
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r
Table 2-18
Summary of Soil AKcnuttva Evaluation
Remedial Alternative
1 - No Action
2 -Capping
3 -Capping With
""avement In Place
-Capping With
?onstruction of Above-
>«ind Disposal Cell
Overall Protection of Boutin
Health uid UK Environment
Does not eliminate exposure
pathways or reduce the level of
risk. Does not lifnh migration of
or remove contaminants.
Eliminates exposure pathways
and reduces the level of risk.
Isolates contamination sod
minimizes further migration.
Eliminates exposure pathways
«nd reduces the level of risk.
Isolates contamination ind
minimizes further migration.
Eliminate exposure pslhwiys
snd reduces the level of risk.
Isolates contamination and
minimizes further migration.
Compliance with
ARARs
Chemical-spccUic
ARARs in tat met
Location-and
action-specific
ARARs do DO(
apply.
All action-spcci£c
ARARs are expected
to be met. Location-
specific ARARs are
applicable and
would need to be
met.
All action-specific
ARARs are expected
to be met Location-
specific ARARs are
applicable and
would need to be
Ml action-specific
\RARs are expected
o be met Locatioo-
tpecific ARARs are
iplicable and
mild need to be
Lonj-Term Effectiveness
and Permanence
Tne contaminated material is
a long-tarn impact The
remediation goals are not met
Long-term public hearlh
threats associated with surface
soil and sediment are greatly
reduced No residual risks
tan the alternative. Long-
term erTecUveaess requires cap
maintenance
-ong.term public heahh
threats associated with surface
soil and sediment are greatly
reduced. No residual risks
ran the alternative. Lonj-
erm efiectiveness requires cap
maintenance
x»g-term public heahh
threats associated with surface
(oil and sediment are greatly
reduced. No residual risks
rom the alternative. Long-
£nn efiectiveness requires cap
'lintenance
Reduction of M/T/V Through
Treatment
No reduction of M/T/V is realized.
Reduction of mobility is realized but
ronUminant volume or taxicfty sre
DOtreduced. For the principal threat
waste at the Site, does not meet
EPA's expectation to treat principal
threat waste.
(eduction of mobility is realized but
contaminant volume or toxichy are
not reduced. For the principal
la-eat waste at the Site, does not
meet EPA's expectation to treat
principal threat waste.
{eduction of mobility is realized but
contaminant volume or toxjchy are
not reduced. For the principal
threat waste at the Site, does not
meet EPA's expectation to treat
principal threat waste.
Note: Option I includes excavated wetland sediment; Option 2 does not
Sfcort-Term Effectiveness
Level D protective equipment is
required during sampling.
Ttchnlcal/EnfUKcrinj
Considerations
Estimated Tim* for
Implementation (rears)
Level C and D protective
equipment required during Site
activities. Excavating and grading
may result in potential release of
dust Noise nuisance from use of
heavy equipment
Level C and D protective
equipment required during She
activities. Excavating and grading
may result in potential release of
dust Noise nuisance from use of
heavy equipment
Level C and D protective
equipment required during Site
ctivhies. Excavating and grading
may result in potential release of
dust Noise nuisance from use of
leavy equipment
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Remedial Alternative
5A- Excavation and
Onshe Treatment With
Solidification'
Stabilization and Onsite
Disposal
5B- Excavation and
3nshe Treatment With
Solidification/
Stabilization and Oflsite
Disposal
6A- Capping With
Excavation and Onsite
Treatment And Disposal
Of Principal-Threat
Waste
Excavation and Onsite
Treatment And Oflsite
Disposal Of Treated
Principal-Threat Waste
— — — ^— — ^— — _».
Vote: Option 1 includes excavi
— ^ — _ _
Threshold Cri
Overall Protection ofHumw
Health and the Environment
Eliminates exposure pathways
and reduces the level of risk.
Immobilizes contamination and
eliminate further migration.
Eliminates exposure pathways
and greatly reduces the level of
risk. Removes contamination
and mitigates further migration.
Eliminates exposure pathways
and greatly reduces the level of
risk. Removes contamination
and mitigates further migration.
liminales exposure pathways
and greatly reduces the level of
nsk. Removes contamination
and mitigate further migration.
terla
Compliance with
ARARi
Chemical-specific
ARARsiremet
Location- and
action-specific
ARARsare
applicable and
would need to be
met
ARARsare met
through onsite
treatment and oflsHe
disposal.
Chemical-specific
ARARsaremet
.ocation-and
ction-specific
ARARsare
pplicable and
would need to be
met
Chemical-specific
ARARsare met
.ocaiion- and
ction-specific
ARARsare
applicable and
ould need to be
et
^— .^••j
Lonj-Terra Effectiveness
and Permanence
Long-term public health
threats associated with surface
soil and sediment are
eliminated No residual risks
from the alternative. Requires
effective cap maintenance.
— — ^— . •
Long-term public hearth
threats associated with surface
soil and sediment are
eliminated. No residual risks
from the alternative.
-ong-term public health
threats associated with surface
oil and sediment arc
liminatcd. No residual risks
'om the alternative. Requires
ffective cap maintenance.
— • — .
•ong-term public heahh
treats associated with surface
oil and sediment are
iminaled. No residual risks
om the alternative. Requires
ffective cap maintenance.
Reduction ofM/r/VThrotifh
Treatment
Mobility and toxichy are reduced.
however, treatment process will
increase volume. Meets EPA
expectation to treat principal threat
waste, but also treats (rather than
contains) low-level threat waste.
Mobility and toxichy are reduced,
however, treatment process will
increase volume. Meets EPA
expectation to treat principal threat
waste, but alto treats (rather than
contains) low-level threat wastes.
vlobilhy and toxichy are reduced,
lowever, treatment process will
increase volume. Meets EPA
expectation to treat principal-threat
waste and contain low-level threat
waste.
Mobility and toxichy are reduced,
lowever. treatment process will
increase volume. Meets EPA
xpectation to.treat principal-threat
•asle and contain low-level threat
aste.
Short-Tenn Effectiveness
Level C and D protective
equipment required during Site
activities. Excavating and grading
may result in potential release of
dust Noise nuisance from use of
heavy equipment
Level C and D protective
equipment required during Site
activities. Excavating and grading
may result in potential release of
dust Noise nuisance from use of
heavy equipment
Level C and D protective
equipment required during Site
activities. Excavating and grading
may result in potential release of
dust Noise nuisance from use of
heavy equipment
Level C and D protective
quipment required during Site
activities. Excavating and grading
may result in potential release of
ust Noise nuisance from use of
eavy equipment
IrapIementabaHy
Technical/Engineering
Capping in a floodplain.
None
Capping in a floodplain.
Capping in a floodplain
tfed wetland sediment; Option 2 does not
Estimated Time for
Implementation (yem)
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4 2.8.1.3 Compliance with ARARs
This alternative does not achieve the RAOs or chemical-specific ARARs established for surface soil.
Location- and action-specific ARARs do not apply to this alternative since further remedial actions
will not be conducted.
2.8.1.4 Long-Term Effectiveness and Permanence
The remediation goals derived for protection 'of human health and the environment would not be met.
Because contaminated soil remains under this alternative, a review/reassessment of the conditions at
the Site would be performed at 5-year intervals to ensure that the remedy does not become a greater
risk to human health and the environment.
2.8.1.5 Reduction of M/T/V Through Treatment
No reductions in contaminants M/T/V are realized under this alternative.
2.8.1.6 Short-Term Effectiveness
Since no further remedial action would be implemented at this Site, this alternative poses no short-
term risks to onsite workers. It is assumed that Level D personnel protection would be used when
sampling various media.
2.8.1.7 Implementability
This alternative could be implemented immediately since monitoring equipment is readily available
and procedures are in place.
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2.8.1.8 Cost
Minimal costs are associated with this alternative compared to other remedial action alternatives. No
capital costs are associated with this alternative. The estimated O&M costs for media sampling
associated with monitoring are approximately $100,247.
2.8.2 Alternative S-2 - Capping
2.8.2.1 Description
Capping the contaminated solid media at the RM Site would serve to prevent rainfall infiltration and
future leaching into the groundwater. In addition, capping also would limit direct contact exposure
to contaminated media under the cap. Varying degrees of capping can be implemented depending
on the severity of contaminants in the area. Caps can range from a simple natural soil cap to a
multilayer soil/synthetic cap. This alternative evaluates a geosynthetic cap for implementation. This
type of cap would produce a low permeability barrier sufficient to reduce contaminant migration.
This alternative includes the demolition of most of the on-Site pavement and buildings. The main
office building and the pavement immediately surrounding this building would remain on Site, and
landfilled slag would remain in place. Contaminated soil beneath the pavement would be excavated
up to a 3 ft maximum depth and consolidated with the stockpiled slag, pavement, and building debris.
This waste material would be disposed in an on-Site excavation that would extend from the existing
landfill to about 375 feet south of the landfill. This disposal area would be about 400 feet wide and
8 feet deep, although could be enlarged somewhat if necessary. A geosynthetic cap and underlying
1.5-ft soil cushion layer would be added above the waste and existing landfill to cover about 6.7
acres. A 1.2-ft soil cover and 6-inch topsoil layer would be placed over the entire Site. These
components are outlined as follows:
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Demolition of pavement and buildings;
Excavation of onsite contaminated soil (15,625 C Y);
• Excavation of an on-Site disposal area (375 ft long by 400 ft wide by 8 ft deep;
approximately 36,200 CY subsurface soil);
Compaction of 26,325 CY of waste material (15,625 CY of waste soil; 6,000 CY of
stockpiled slag; 3,700 CY of pavement; and 1,000 CY of building debris ) into disposal
area (Compaction of 35,625 CY of waste material if excavated wetland sediment is
consolidated with surface soil for final disposition);
Installation of 1.5-ft-deep soil cushion over the waste and existing landfill (20,300 CY);
• Installation of geomembrane liner and geotextile over soil cushion (6.7 acres);
• Soil cover (1.2 ft deep), topsoil cover (6 inches deep), and grass seeding over the Site (8
acres); and
• Land/deed use restrictions and fencing.
The topsoil layer of the cap would be graded to a minimum slope of 3% and a maximum of 5% to
promote surface drainage away from the waste cell and reduce infiltration. Surface drainage controls
would be constructed around the perimeter of the cap to collect surface water runoff.
Alternative S-2 would eliminate direct contact with contaminated media, eliminate on-Site physical
hazards, minimize contaminant migration to groundwater, and eliminate contaminant migration to
surface water from the Site. Figure 2-24 illustrates the components of the cap included in this
alternative as they would be applied to the RM Site.
2.8.2.2 Overall Protection of Human Health and the Environment
Successful implementation of this alternative would reduce risks to human health and the environment
and meet the removal action objectives by (1) eliminating exposure of residents and trespassers to
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SOUTH
DEPTH AT WHICH
GROUNDWATER ENCOUNTERED
WRECKER
BUILDING
NORTH
SURFACE DEPOSITION OF
LEAD CONTAMINATED DUST.
SOILS, AND SEDIMENT
6" TOPSOIL COVER/GRASS SEEDING
~_~-~_~_~_'1.5 SOIL CUSHION-
6.5' WASTE MATERIAL
.*.-»."•' ' '.'
— •_
DEPTH AT WHICH
GROUNDWATER ENCOUNTERED
MOT TO SCALE
CONTAMINATED
SOIL eaow SLAG
APPROXIMATE DIMENSIONS OF EXCAVATION: TOTAL DEPTH - 8 FT
LENGTH - 375 FT.
WIDTH - 400 FT.
NOTE: Conceptual design. Federal, state, and local
requirements regarding construction in o floodplain
must be considered and may affect design
Representation of waste material Includes excavated
wetland sediments.
Ross Metals Site
Rossville, Tennessee
COM Federal Programs Corporation
* x&Kfay at Camf Dmxr * JfcAW he.
Alternative 2 - Capping
Figure No.
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waste material by direct contact and airborne migration, (2) eliminating exposure of trespassers to
direct contact with on-Site physical hazards, and (3) minimizing the migration of contaminants to
groundwater and eliminating the migration of contaminants to surface water. Consolidation and
isolation of the waste material beneath a geomembrane cap would eliminate receptor routes of
exposure through ingestion and inhalation. Structures throughout the Site would be demolished and
disposed of in an excavated disposal area beneath the existing pavement. As a result, physical hazards
associated with deteriorating structures would be eliminated. In addition, geomembrane capping
would eliminate infiltration of precipitation and surface water that contributes to the migration of
contaminants to groundwater. However, because the waste material will remain on Site, contaminant
migration to groundwater cannot be discounted as an adverse effect. Nevertheless, the elimination
of surface water infiltration makes this scenario unlikely, and contaminant migration through surface
water runoff to the adjacent wetlands and the Wolf River would be eliminated.
The threat of direct human exposure to contaminated waste and physical hazards would be practically
eliminated by this alternative; however, the threat could return over the long term if cap integrity was
compromised. The potential for ingestion; dermal contact, and inhalation of soil containing metals
would be eliminated by successfully placing the geomembrane cap over the waste material.
2.8.2.3 Compliance with ARARs
The RCRA hazardous waste disposal facility requirements are potentially applicable. The RM Site
is located in a 100-year floodplain within a zone designated as A3, indicating that base flood
elevations and flood hazard factors have been determined for this area. The ARAR (40 CFR 264)
requires that disposal facilities be designed to withstand a 100-year flood. In addition, EPA's
regulations (40 CFR Part 6, Appendix A) for implementing Executive Order 11988 (Floodplains
Management) requires federal agencies to avoid or minimize adverse impacts of Federal actions upon
floodplains, and to preserve and enhance the natural values of floodplains. Specifically, when it is
apparent that a proposed or potential Agency action is likely to impact a floodplain or wetlands, the
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public should be informed through appropriate public notice processes. Furthermore, if a proposed
action is located in or affects a floodplain or wetlands, a floodplain/wetlands assessment shall be
undertaken, and a statement of findings explaining why the proposed action must be located in or
affect the floodplain or wetlands.
Regarding construction activities related to implementing the alternative, 40 CFR 6 Appendix A
requires that EPA-controlled structures and facilities must be constructed in accordance with existing
criteria and standards set forth under the National Flood Insurance Program (NFIP) and must include
mitigation of adverse impacts wherever feasible, including the use of accepted floodproofing and/or
other flood protection measures. To achieve flood protection, EPA shall wherever practicable,
elevate structures above the base flood level rather than filling land. In addition, the capped area may
be classified as a Tennessee Solid Waste Processing and Disposal (SWPD) Class II disposal facility.
If so, the substantive requirements of the SWPD rule regarding Class II disposal facilities (e.g., siting)
would apply to the Site. The SWPD rule (Rule 1200-1-7) and the Criteria for Classification of Solid
Waste Disposal Facilities and Practices (40 CFR 257) require that disposal facilities must not be
located in a 100-year floodplain, unless both of the following can be demonstrated:
• Location in the floodplain will not restrict the flow of the 100-year flood nor reduce the
temporary water storage capacity of the floodplain; and
• The facility is designed, constructed, operated, and maintained to prevent washout of any
solid waste.
Wetlands are located to the north and northeast of the facility and landfill, although these locations
are not identified on National Wetland Inventory (NWI) maps. The Protection of Wetlands Order
*
(40 CFR 6) requires that no adverse impacts to wetlands result from a remedial action. With
appropriate stormwater runon and runoff controls, the substantive requirements of this ARAR are
expected to be met. The SWPD rule requires that new landfills and lateral expansions shall not be *
located in a wetlands, unless the owner or operator can make the following demonstrations:
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• the presumption of a practicable alternative that does not involve wetlands is clearly
rebutted;
• the construction/operation of the landfill will not cause or contribute to violations of
applicable State water quality standards, any applicable toxic effluent standard or
prohibition under Section 307 of the Clean Water Act (CWA), and will not cause or
contribute to the taking of any endangered or threatened species or result in the destruction
or adverse modification of critical habitat of endangered or threatened species;
the landfill will not cause or contribute to significant degradation of wetlands;
• to the extent required under Section 404 of the CWA or Tennessee Water Pollution
Control Act (TWPCA), steps have been taken to attempt to achieve no net loss of
wetlands (as defined by acreage and function); and
• sufficient information is available to make a reasonable determination with respect to these
demonstrations.
The substantive requirements for stormwater discharges during construction activities as outlined by
the CWA are relevant and appropriate. However, a specific NPDES permit is not required for this
remedial action.
All action-specific ARARs are expected to be met. The Tennessee Air Pollution Control Regulations
(T APCR) dust suppression and control requirements (Rule 1200-3-8) apply to earth-moving activities
associated with this alternative. ARARs for the control of fugitive dust emissions would be met by
applying water to roads receiving heavy vehicular traffic and to excavation areas, as necessary.
2.8.2.4 Long-Term Effectiveness and Permanence
Under this alternative, the cap would have to be maintained to ensure that it continues to perform as
designed; consequently, long-term monitoring, inspection, and maintenance would be required. The
cap would be susceptible to settlement, ponding of surface water, erosion, and disruption of cover
integrity by deep-rooting vegetation and burrowing animals. The cover would need to be periodically
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inspected, and required maintenance would need to be implemented in order to maintain effectiveness.
The long-term effectiveness of capping the waste would be enhanced by selecting the proper cover
design and grading layout. In addition, access restrictions such as land use controls and fencing
would be required to prevent land uses incompatible with the Site; specifically, land uses that would
compromise the cap should be precluded.
2.8.2.5 Reduction of M/T/V Through Treatment
The primary objective of this alternative is to reduce contaminant mobility by isolating contaminants
from receptor contact; contaminant volume or toxicity would not be reduced. Contaminant mobility
would be reduced by installing an impermeable cap liner. The liner would eliminate surface water or
precipitation infiltration and would greatly reduce contaminant migration to groundwater in
conjunction with the existing clay unit beneath the Site. Consolidation and capping would isolate
waste source areas and would reduce contaminant mobility resulting from surface water transport and
wind erosion. Contaminant mobility is expected to be reduced to an extent that would result in
overall risk reduction from all pathways and exposure routes.
This alternative would not meet EPA's expectation to use treatment to address the principal threats
posed by a site, although in some situations, containment of principal threats is warranted (EPA
1991). Based on sample results collected during previous Site investigations, 600 CY of surface soil
and 16,000 CY of stockpiled and landfilled slag would be considered "principal-threat" waste.
Containment of principal threats maybe warranted where treatment technologies are not technically
feasible or available within a reasonable time frame; or where the volume of materials or complexity
of the site makes implementation of treatment technologies infeasible; or where implementation of
a treatment-based remedy would result in greater overall risk to human health and the environment
or cause severe effects across environmental media. A review of currently available technologies and
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Site conditions does not suggest that these situations Would apply to the RM Site.
2.8.2.6 Short-Term Effectiveness
The construction phase of this alternative would likely be accomplished within one field season;
therefore, impacts associated with construction would likely be short term and minimal. Short-term
impacts are associated with excavation and consolidation of waste soil and slag; however, these
potential, short-term impacts would be mitigated during the construction phase.
If the excavated material is diy, on-Site workers will be exposed to waste soil and slag dust during
excavation and consolidation activities. Additional exposure to lead dust may occur during the
demolition of building structures and pavement. Ingestion of dust could involve some health effects
because of the high level of metals in waste soil and slag.
On-Site workers would be adequately protected from short-term risks by using appropriate personal
protective equipment and by following proper operating and safety procedures. However, short-term
air quality impacts to the surrounding environment may occur during waste consolidation and
grading. Dust emissions would be monitored at the property boundaries. Fugitive dust emissions
would be controlled by applying water as needed to surfaces receiving heavy vehicular traffic or in
excavation areas. A measurable, short-term impact to the surrounding area would include increased
vehicular traffic and associated safety hazards, potential dust generation, and noise.
2.8.2.7 Implementability
Construction of a geomembrane surface cap is a standard construction practice. Other than the
capping of contaminated material in a floodplain, no significant construction issues are expected to
be encountered.
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k
No state or federal permits are expected to be required; however, advance consultation should occur
while planning the action to ensure that all involved agencies are allowed to provide input.
All services and materials for this alternative are readily available.
2.8.2.8 Cost
The total present worth for S-2 is approximately $1,735,804 for Option 1, which includes the
excavated wetlands sediment, and $1,712,412 for Option 2, which does not include the wetland
sediment. For Option 1, the estimated capital cost is approximately $1,575,908, and the estimated
O&M cost is approximately $159,895. For Option 2, the estimated capital cost is approximately
$1,552,516, and the estimated O&M cost is approximately $159,895.
2.8.3 Alternative S-3 - Capping With Pavement in Place
2.8.3.1 Description
Alternative S-3 differs from Alternative S-2 in that the waste is not disposed of in an excavation, but
rather spread over the existing pavement and capped in place with the existing landfill. Alternative
S-3 includes the demolition of most of the on-Site buildings. The main office building would remain
on Site, and the landfilled slag would remain in place. Contaminated soil from areas not covered by
pavement would be excavated and consolidated with the stockpiled slag and building debris, and
excavated wetland sediment. This waste material would be spread above the pavement that extends
from the existing landfill to about 375 feet south of the landfill. A geosynthetic cap and underlying
1.5-ft soil cushion layer would be added above the waste and existing landfill and would cover about
6.7 acres. The totsl height of the capped area would be and existing landfill and would cover
approximately 6.7 acres. The total height of the capped area would be approximately 5 feet. A 1-ft
soil cover and 6-inch topsoil layer would be placed over the entire Site. The components of this
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alternative are outlined as follows:
• Demolition of buildings;
Excavation of contaminated soil in southeastern corner of the Site (2,800 CY);
Compaction of 9,800 CY of waste material above pavement and landfill (2,800 CY of
waste soil; 6,000 CY of stockpiled slag; and 1,000 CY of building debris) (Compaction
of 19,100 CY of waste material if excavated wetlands sediment is consolidated with
surface soil for final disposition);
Installation of 1.5-ft-deep soil cushion over waste and existing landfill (20,300 CY);
Installation of geomembrane liner and geotextile over soil cushion (6.7 acres);
Soil cover (1 ft deep), topsoil cover (6 inches deep), and grass seeding over Site
(8 acres); and
• Land use/deed restrictions and fencing.
The topsoil layer of the cap would be graded to a minimum slope of 3% and a maximum of 5% to
promote surface drainage away from the waste cell and reduce infiltration. Surface drainage controls
would be constructed around the perimeter of the cap to collect surface water runoff.
Alternative S-3 would eliminate direct contact with contaminated media, eliminate on-Site physical
hazards, further minimize contaminant migration to groundwater, and eliminate contaminant
migration to surface water from the Site. Figure 2-25 illustrates the components of the cap included
under this alternative as applied to the RM Site.
2.8.3.2 Overall Protection of Human Health and the Environment
Successful implementation of this alternative would reduce risks to human health and the environment
and meet the removal action objectives by (1) eliminating exposure of residents and trespassers to
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SOUTH
WRECKER
BUILDING
DEPTH AT WHICH
GROUNDWATER ENCOUNTERED
NORTH
SURFACE DEPOSITION OF
LEAD CONTAMINATED DUST,
SOILS, WASTE, AND SEDIMENT
0'
6" TOPSOL COVER/GRASS SEEDING
GEOSYNTHETIC
UNER
tfl
o
CL
NOTE: Conceptual design. Federal, state, and local
requirements regarding construction In a floodplaln
must be considered and may affect design
Representation of waste material includes excavated
wetland sediments.
Ross Metals Site
Rossville, Tennessee
CDM Federal Programs Corporation
4 «*«**)' of Camp Chsoer i lfc*» he.
APPROXIMATE DIMENSIONS OF EXCAVATION: TOTAL DEPTH - 5 FT.
LENGTH - 600 FT.
WIDTH - 400 FT.
Alternative 3 - Capping With
Pavement in Place
Figure No.
2-25
8/98
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waste material by direct contact and airborne migration, (2) eliminating exposure of trespassers to
du-ect contact with on-Site physical hazards, and (3) further reduce the migration of contaminants to
groundwater over Alternative S-2 and eliminate the migration of contaminants to surface water
Consolidation and isolation of the waste material beneath a geomembrane cap would eliminate
receptor routes of exposure through ingestion and inhalation. Structures throughout the Site would
be demolished and disposed of in the disposal area above the existing pavement and landfill area The
waste material would be spread and compacted throughout the Site. Physical hazards associated with
deteriorating structures would be eliminated. In addition, geomembrane capping would eliminate
infiltration of precipitation and surface water that contributes to the migration of contaminants to
groundwater. However, because the waste material will remain on Site, contaminant migration to
groundwater cannot be discounted as an adverse effect. Nevertheless, the elimination of surface
water infiltration makes this scenario unlikely, and contaminant migration through surface water
runoff to the adjacent wetlands and the Wolf River would be eliminated.
The threat ^direct hunian exposure to contaniinated waste and physical hazards would be practically
eliminated by this alternative; however, the threat could return over the long tern if cap integrity was
compromised. The potential for ingestion, dermal contact, and inhalation of soil containing metals
would be eliminated by successfully placing the geomembrane cap over the waste material.
2.8.3.3 Compliance with ARARs
The RCRA hazardous waste disposal facility requirements are potentially applicable. The RM Site
is located in a 100-year floodplain within a zone designated as A3, indicating that base flood
elevations and flood hazard factors have been determined for this area. The ARAR (40 CFR 264)
requires that disposal facilities be designed to withstand a 100-year flood. In addition, EPA's
regulations (40 CFR Part 6, Appendix A)for implementing Executive Order 11988 (Floodplains
Management) requires federal agencies to avoid or minimize adverse impacts of Federal actions upon
floodplains, and to preserve and enhance the natural values of floodplains. Specifically, when it is
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apparent that a proposed or potential Agency action is likely to impact a floodpiain or wetlands, the
public should be informed through appropriate public notice processes. Furthermore, if a proposed
action is located in or affects a floodpiain or wetlands, a floodplain/wetlands assessment shall be
undertaken, and a statement of findings explaining why the proposed action must be located in or
affect the floodpiain or wetlands.
Regarding construction activities related to implementing the alternative, 40 CFR 6 Appendix A
requires that EPA-controlled structures and facilities must be constructed in accordance with existing
criteria and standards set forth under the NFIP and must include mitigation of adverse impacts
wherever feasible, including the use of accepted floodproofing and/or other flood protection
measures. To achieve flood protection, EPA shall wherever practicable, elevate structures above the
base flood level rather than filling land. In addition, the capped area may be classified as a Tennessee
SWPD Class II disposal facility. If so, the substantive requirements of the SWPD rule regarding
Class II disposal facilities (e.g., siting) would apply to the Site. The SWPD rule (Rule 1200-1 -7) and
the Criteria for Classification of Solid Waste Disposal Facilities and Practices (40 CFR 257) require
that disposal facilities must not be located in a 100-year floodpiain, unless both of the following can
be demonstrated:
• Location in the floodpiain will not restrict the flow of the 100-year flood nor reduce the
temporary water storage capacity of the floodpiain; and
• The facility is designed, constructed, operated, and maintained to prevent washout of any
solid waste.
Wetlands are located to the north and northeast of the facility and landfill, although these locations
are not identified on NWI maps. The Protection of Wetlands Order (40 CFR 6) requires that no
adverse impacts to wetlands result from a remedial action. With appropriate stormwater runon and
runoff controls, the substantive requirements of this ARAR are expected to be met. The SWPD rule
requires that new landfills and lateral expansions shall not be located in a wetlands, unless the owner
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or operator can make the following demonstrations:
the presumption of a practicable alternative that does not involve wetlands is clearly
rebutted;
the construction/operation of the landfill will not cause or contribute to violations of
applicable State water quality standards, any applicable toxic effluent standard or
prohibition under Section 307 of the CWA, and will not cause or contribute to the taking
of any endangered or threatened species or result in the destruction or adverse
modification of critical habitat of endangered or threatened species;
the landfill will not cause or contribute to significant degradation of wetlands;
to the extent required under Section 404 of the CWA or Tennessee Water Pollution
Control Act, steps have been taken to attempt to achieve no net loss of wetlands (as
defined by acreage and function); and
sufficient information is available to make a reasonable determination with respect to these
demonstrations.
The substantive requirements for stormwater discharges during construction activities as outlined by
the CWA are relevant and appropriate. However, a specific NPDES permit is not required for this
remedial action.
All action-specific ARARs are expected to be met. The TAPCR dust suppression and control
requirements (Rule 1200-3-8) apply to earth-moving activities associated with this alternative.
ARARs for the control of fugitive dust emissions would be met by applying water to roads receiving
heavy vehicular traffic and to excavation areas, as necessary.
2.8.3.4 Long-Term Effectiveness and Permanence
Under this alternative, the cap would have to be maintained to ensure that it continues to perform as
designed; consequently, long-term monitoring, inspection, and maintenance would be required. The
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o
cap would be susceptible to settlement, ponding of surface water, erosion, and disruption of cover
integrity by deep-rooting vegetation and burrowing animals. The cover would to need be periodically
inspected, and required maintenance would need to be implemented.
The long-term effectiveness of capping the waste would be enhanced by selecting the proper cover
design and grading layout. In addition, access restrictions such as land use controls and fencing
would be required to prevent land uses that,are incompatible with the Site; specifically, land uses that
would compromise the cap should be precluded.
2.8.3.5 Reduction of M/T/V Through Treatment
The primary objective of this alternative is to reduce contaminant mobility by isolating contaminants
from receptor contact; contaminant volume or toxicity would not be reduced. Contaminant mobility
would be reduced by installing an impermeable cap liner. The liner would eliminate surface water or
precipitation infiltration and would greatly reduce contaminant migration to groundwater in
conjunction with the existing clay unit beneath the Site. Consolidation and capping would isolate
waste source areas and reduce contaminant mobility resulting from surface water transport and wind
erosion. Contaminant mobility is expected to be reduced to an extent that would result in overall risk
reduction from all pathways and exposure routes.
This alternative would not meet EPA's expectation to use treatment to address the principal threats
posed by a site, although in some situations, containment of principal threats is warranted (EPA
1991). Based on sample results collected during previous Site investigations, 600 CY of surface soil
and the 16,000 CY of stockpiled and landfilled slag would be considered "principal-threat" waste. *
Containment of principal threats may be warranted where treatment technologies are not technically
feasible or available within a reasonable time frame; or where the volume of materials or complexity
of the site makes implementation of treatment technologies infeasible; or where implementation of Ml
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a treatment-based remedy would result in greater overall risk to human health and the environment
or cause severe effects across environmental media. A review of currently available technologies and
Site conditions does not suggest that these situations would apply to the RM Site.
2.8,3.6 Short-Term Effectiveness
The construction phase of this alternative would likely be accomplished within one field season;
therefore, impacts associated with construction would likely be short-term and minimal. Short-term
impacts are associated with excavation and consolidation of waste soil and slag; however, these
potential, short-term impacts would be mitigated during the construction phase.
If the excavated material is dry, on-Site workers will be exposed to waste soil and slag dust during
excavation and consolidation activities. Additional exposure to lead dust may occur during building
structure and pavement demolition. Ingestion of dust could involve some health effects because of
the high level of metals in waste soil and slag.
On-Site workers would be adequately protected by using appropriate personal protective equipment
and by following proper operating and safety procedures. However, short-term air quality impacts
to the surrounding environment may occur during waste consolidation and grading. Dust emissions
would be monitored at the property boundaries. Fugitive dust emissions would be controlled by
applying water to surfaces receiving heavy vehicular traffic or in excavation areas, as needed. A
measurable, short-term impact to the surrounding area would include increased vehicular traffic and
associated safety hazards, potential dust generation, and noise.
2.8.3.7 Implementability
Construction of a geomembrane surface cap is a standard construction practice. Other than capping
contaminated material in a floodplain, no significant construction issues are expected to be
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encountered.
No state or federal permits are expected to be required; however, advance consultation should occur *
while planning the action to ensure that all involved agencies are allowed to provide input.
All services and materials for this alternative are readily available.
2.8.3.8 Cost
The total present worth for Alternative S-3 is approximately $ 1,453,803 for Option 1, which includes
the excavated wetlands sediment, and $1,430,411 for Option 2, which does not include the wetland
sediment. For Option 1, the estimated capital cost is approximately $1,293,907, and the estimated
O&M cost is approximately $159,895. For Option 2, the estimated capital cost is approximately
$1,270,515, and the estimated O&M cost is approximately $159,895. «P
2.8.4 Alternative S-4 ~ Capping With Construction of Above-Ground Disposal Cell
2.8.4.1 Description
Alternative S-4 differs from Alternatives S-2 and S-3 in that waste is not disposed of in the area of
the existing pavement; instead, it is consolidated over the surface of the existing landfill and capped
in place. This method would result in a disposal cell approximately 15 feet high throughout the
landfill area. This alternative includes the demolition of most of the on-Site pavement and buildings.
The main office building and the pavement immediately surrounding this building would remain on *
Site, and landfilled slag would remain in place. Contaminated soil beneath the pavement would be
excavated up to a 3 ft maximum depth and consolidated with the stockpiled slag, pavement, and
building debris. This alternative includes the following components:
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• Demolition of pavement and buildings;
Excavation of onsite contaminated soil (15,625 CY);
Compaction of 26,325 CY of waste material (15,625 CY of waste soil; 6,000 CY of
stockpiled slag; 3,700 CY of pavement; and 1,000 CY of building debris) in existing
landfill area with a cell height of about 12 to 13 feet (Compaction of 35,625 CY of waste
material, with a cell height of 15 feet if excavated wetlands sediment are consolidated with
surface soils for final disposition;
• Installation of 1.5-ft-deep soil cushion over the waste and existing landfill (7,600 CY);
Installation of geomembrane liner and geotextile over soil cushion (2.5 acres);
Soil cover (1 ft deep), topsoil cover (6 inches deep), and grass seeding over the Site (8
acres); and
• Land use restrictions and security fencing.
Surface drainage controls would be constructed around the perimeter of the cap to collect surface
water runoff.
Alternative S-4 would eliminate direct contact with contaminated media, eliminate on-Site physical
hazards, minimize contaminant migration to groundwater, and eliminate contaminant migration to
surface water from the Site. Figure 2-26 illustrates the components of the cap included under this
alternative as applied to the RM Site.
2.8.4.2 Overall Protection of Human Health and the Environment
Successful implementation of this alternative would reduce risks to human health and the environment
and meet the removal action objectives by (1) eliminating exposure of residents and trespassers to
waste material by direct contact and airborne migration, (2) eliminating exposure of trespassers to
direct contact with on-Site physical hazards, and (3) further reduce the migration of contaminants to
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SOUTH
NORTH
KRECKER
BUILDING
SURFACE DEPOSITION OF
LEAD CONTAMIHATEO DUST.
SOILS, WASTE. AND SEDIMENT
DEPTH AT WHICH
15' HIGH DISPOSAL CELL
CEOSYNTHETIC-
UNER
6 TOPSOIL COVER/GRASS SEEDING
:-p^> 121 WASTE. MATERIAL' V T^X-?
DEPTH AT WHICH
GROUNDWATER ENCOUNTERED
NOTE: Conceptual design. Federal, state, and local
requirements regarding construction In a floodplaln
must be considered and may affect design
Representation of waste material Includes excavated
wetland sediments.
APPROXIMATE DIMENSIONS OF EXCAVATION: TOTAL DEPTH - 15 FT.
LENGTH - 200 FT.
WIDTH - 400 FT.
Ross Metals Site
Rossville, Tennessee
COM Federal Programs Corporation
A MtsUay a Cmt Oww « Htftt he.
Alternative 4 - Capping With
Construction of Above Ground
Disposal Cell
figure No.
2-26
8/98
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groundwater over Alternative S-2 and eliminate the migration of contaminants to surface water.
Consolidation and isolation of the waste material beneath a geomembrane cap would eliminate
receptor routes of exposure through ingestion and inhalation. Structures throughout the Site would
be demolished and disposed of in the disposal area above the existing pavement and landfill area. The
waste material would be spread and compacted over the landfill area. Physical hazards associated
with deteriorating structures would be eliminated. In addition, geomembrane capping would
eliminate infiltration of precipitation and surface water that contributes to the migration of
contaminants to groundwater. However, because the waste material will remain on Site, contaminant
migration to groundwater cannot be discounted as an adverse effect. Nevertheless, the elimination
of surface water infiltration makes this scenario unlikely, and contaminant migration through surface
water runoff to the adjacent wetlands and the Wolf River would be eliminated.
The threat of direct human exposure to contaminated waste and physical hazards would be practically
eliminated by this alternative; however, the threat could return over the long term if cap integrity was
compromised. The potential for ingestion, dermal contact, and inhalation of soil containing metals
would be eliminated by successfully placing the geomembrane cap over the waste material.
2.8.4.3 Compliance with ARARs
The RCRA hazardous waste disposal facility requirements are potentially applicable. The RM Site
is located in a 100-year floodplain within a zone designated as A3, indicating that base flood
elevations and flood hazard factors have been determined for this area. The ARAR (40 CFR 264)
requires that disposal facilities be designed to withstand a 100-year flood. In addition, EPA's
regulations (40 CFR Part 6, Appendix A) for implementing Executive Order 11988 (Floodplains
Management) requires federal agencies to avoid or minimize adverse impacts of Federal actions upon
floodplains, and to preserve and enhance the natural values of floodplains. Specifically, when it is
apparent that a proposed or potential Agency action is likely to impact a floodplain or wetlands, the
public should be informed through appropriate public notice processes. Furthermore, if a proposed
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action is located in or affects a floodplain or wetlands, a floodplain/wetlands assessment shall be
undertaken, and a statement of findings explaining why the proposed action must be located in or
affect the floodplain or wetlands. .
Regarding construction activities related to implementing the alternative, 40 CFR 6 Appendix A
requires that EPA-controlled structures and facilities must be constructed in accordance with existing
criteria and standards set forth under the NFIP and must include mitigation of adverse impacts
wherever feasible, including the use of accepted floodproofing and/or other flood protection
measures. To achieve flood protection, EPA shall wherever practicable, elevate structures above the
base flood level rather than filling land. In addition, the capped area may be classified as a Tennessee
SWPD Class II disposal facility. If so, the substantive requirements of the SWPD rule regarding
Class II disposal facilities (e.g., siting) would apply to the Site. The SWPD rule (Rule 1200-1 -7) and
the Criteria for Classification of Solid Waste Disposal Facilities and Practices (40 CFR 257) require
that disposal facilities must not be located in a 100-year floodplain, unless both of the following can
be demonstrated:
Location in the floodplain will not restrict the flow of the 100-year flood nor reduce the
temporary water storage capacity of the floodplain; and
The facility is designed, constructed, operated, and maintained to prevent washout of any
solid waste.
Wetlands are located to the north and northeast of the facility and landfill, although these locations
are not identified on NWI maps. The Protection of Wetlands Order (40 CFR 6) requires that no
adverse impacts to wetlands result from a remedial action. With appropriate stormwater runon and
runoff controls, the substantive requirements of this ARAR are expected to be met. The SWPD rule
requires that new landfills and lateral expansions shall not be located in a wetlands, unless the owner
or operator can make the following demonstrations:
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• the presumption of a practicable alternative that does not involve wetlands is clearlv
rebutted; J
• the construction/operation of the landfill will not cause or contribute to violations of
applicable State water quality standards, any applicable toxic effluent standard or
prohibition under Section 307 of the CWA, and will not cause or contribute to the taking
of any endangered or threatened species or result in the destruction or adverse
modification of critical habitat of endangered or threatened species;
• the landfill will not cause or contribute to significant degradation of wetlands;
• to the extent required under Section 404 of the CWA or Tennessee Water Pollution
Control Act, steps have been taken to attempt to achieve no net loss of wetlands (as
defined by acreage and function); and •
• sufficient information is available to make a reasonable determination with respect to these
demonstrations. H
The substantive requirements for stormwater discharges during construction activities as outlined by
the CWA are relevant and appropriate. However, a specific NPDES permit is not required for this
remedial action.
All action-specific ARARs are expected to be met. The TAPCR dust suppression and control
requirements (Rule 1200-3-8) apply to earth-moving activities associated with this alternative.
ARARs for the control of fugitive dust emissions would be met by applying water to roads receiving
heavy vehicular traffic and to excavation areas, as necessary.
2.8.4.4 Long-Term Effectiveness and Permanence
Under this alternative, the cap would have to be maintained to ensure that it continues to perform as
designed; consequently, long-termmonitoring, inspection, and maintenance would be required. The
cap would be susceptible to settlement, ponding of surface water, erosion, and disruption of cover
integrity by deep-rooting vegetation and burrowing animals. The cover would need to be periodically
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inspected, and required maintenance would need to be implemented.
The long-term effectiveness of capping the waste would be enhanced by selecting the proper cover
design and grading layout. In addition, access restrictions such as land use controls and fencing
would be required to prevent land uses that are incompatible with the Site; specifically, land uses that
would compromise the cap should be precluded.
2.8.4.5 Reduction of M/T/V Through Treatment
The primary objective of this alternative is to reduce contaminant mobility by isolating contaminants
from receptor contact; contaminant volume or toxicity would not be reduced. Contaminant mobility
would be reduced by installing an impermeable cap liner. The liner would eliminate surface water or
precipitation infiltration and would greatly reduce contaminant migration to groundwater in
conjunction with the existing clay unit beneath the Site. Consolidation and capping would isolate
waste source areas and reduce contaminant mobility resulting from surface water transport and wind
erosion. Contaminant mobility is expected to be reduced to an extent that would result in overall risk
reduction from all pathways and exposure routes.
Based on sample results collected during previous Site investigations, 600 CY of surface soil and the
16,000 CY of stockpiled and landfilled slag would be considered "principal-threat" waste. This
alternative would not meet EPA's expectation to use treatment to address the principal threats posed
by a site, although in some situations, containment of principal threats is warranted (EPA 1991).
Containment of principal threats may be warranted where treatment technologies are not technically
feasible or available within a reasonable time frame; or where the volume of materials or complexity
of the site makes implementation of treatment technologies infeasible; or where implementation of
a treatment-based remedy would result in greater overall risk to human health and the environment
or cause severe effects across environmental media. A review of currently available technologies and
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program prior to excavation activities.
On-Site excavation shall be backfilled and restored to a condition consistent with the intended iuture
use of the property. The backfill source must be prequalified to document its quality. Treatability
testing may be required to confirm the value of using a biosolid as a backfill.
The wetlands will be revegetated according to the Wetlands Revegetation Plan (ERRT 1998). The
facility area and landfill area (approximately 8 acres) will be grass seeded. Maintenance plans to
eliminate the intrusion of less desirable species and to promote success shall be developed and Site
monitoring will be required.
Excavated material may be stockpiled on-Site prior to off-Site transportation. All excavated material
shall be transported off-Site for disposal in an approved RCRA-permitted landfill. All transportation
and off-Site disposal activities shall be conducted in full accordance with all ARARs, including but
not limited to, RCRA regulations. Per the requirements of Phase IV Land Disposal Restrictions
(LDRs) - waste, soil, and debris classified as hazardous must be treated to Universal Treatment
Standards (UTS) prior to land disposal. Treatment of these materials shall use
solidification/stabilization/fixation to achieve UTS.
Summary of Estimated Remedy Costs
Table 2-23 provides a cost estimate for implementing the selected remedy.
Expected Outcomes of the Selected Remedy
The purpose of this response action is to eliminate and reduce risks posed by ingestion, inhalation,
or direct contact with soil/sediment/slag/buildings; minimize migration of contaminants to *
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Ross Metals Site
RpasviHe. Tennessee
LEGEND
A Somple Locoticn
Wetland Community .Types
IVJ Scrub/Shrub
ESI Emergent
C3 Brood-Leoved Deciduous Forest
03 Needle-Leoved Deciduous
(Bold Cypress) Forest
IS3 Excovotion lo BOOmgAg
U E«covation to lOOmjA?
Concentration Contour (nig/kg)
GRAPHIC SCALE
0 100 200
ifc=fc
Scale in Feet
Excavation Contours
Figure Ho.
2-30
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Table 2-22
Excavation Standards
Contaminant of Concern
Surface Soil (mg/kg)
Aluminum
Antimony
Arsenic
Barium
Cadmium
Copper
Iron
Lead
Manganese
Selenium
Vanadium
Subsurface Soil (mg/kg)
Lead
Wetlands Sediment (mg/kg)
Aluminum
Antimony
Arsenic
Cadmium
Copper
Lead
Mercury
Nickel
Slag
Excavation Standard
11,620
3
5
505
7
293
16,100
•400
559
-37
51
400'
8,860
28.4 - 104
5.58
0.37-3.73
22.4-101.5
800
ND - 0.21
9.10
Since the blast slag waste has unique
characteristics that make it easily
identifiable, removal of the landfill area slag
and stockpiled slag will be verified by visual
inspection and approved by EPA or its
representative.
ND - Not Detected
* - Modeling conducted during Remedial Design may indicate a less conservative clean-up goal is sufficient for protection of
groundwater.
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recycling facility. The equipment will be sold or donated to interested parties. All other debris will
be taken off Site to a nonhazardous disposal facility.
Soil/sediment with constituent concentrations greater than the excavation levels listed in Table 2-22
shall be excavated and disposed in an off-Site RCRA-permitted non-hazardous waste landfill. Figure
2-30 provides a map delineating the approximated areas where soil/sediment will be excavated based
upon data obtained during the RI field investigations. An estimated 33,674 cubic yards of
soil/sediment exceed the excavation standards. An estimated 16,000 cubic yards of slag exceed the
excavation standards. Approximately 1,000 cubic yards of lead-contaminated buildings constitute
a safety hazard. An estimated 3,700 cubic yards of demolition debris will be generated as a result of
the remediation activities, of which approximately 1,500 tons of metal debris/equipment will be
available for metal recycling.
Prior to excavation activities, a statistically-based sampling program shall be implemented within the
areas slated for removal to farther define those soils which exceed the applicable excavation
standards. EPA shall have a reasonable opportunity to review and comment on the proposed
statistical sampling program prior to implementation. Results of this sampling program shall be
reviewed and approved by EPA prior to excavation activities.
All excavation activities shall be conducted in a manner which provides adequate short-term
protection of on-Site workers, and minimizes disruptions to local businesses and adjacent residents.
Air monitoring during active excavation shall be implemented for the protection of on-Site workers
and to assess potential off-Site impacts. As warranted, dust and odor control measures shall be
instituted to mitigate adverse impacts in the active excavation areas, haul roads and adjacent off-Site
areas. An excavation confirmation sampling program shall be developed to verify that all soil,
sediment, and slag have been removed to the specified excavation standards. EPA shall have
reasonable opportunity to review the statistical methods employed by this confirmational sampling
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• On-Site excavation areas shall be backfilled and restored to the existing grade or better. The *
backfill source, biosolids, may require treatability testing to confirm the value of using biosolid
as a backfill; ^
• Stabilization/solidification/fixation of contaminated soil, stockpiled slag, landfilled slag, and
wetlands sediment;
• Off-Site disposal of soils, slag, and sediment to a RCRA-disposal facility;
• Application of a layer of biosolids to the entire Ross Metals Site. Grass seeding of the facility
and landfill areas; and revegetation of the Site wetlands according to the Wetlands Revegetation
Plan developed by EPA, 1998.
• Development of maintenance and monitoring plan to assess the effectiveness of the cleanup
action.
The total estimated construction costs associated with both alternatives are $ 7,390,687. The
estimated Operations and Maintenance costs are $30,045. The estimated total present worth costs
are $ 7,420,732. , ' .
Performance Standards
Demolition of most of the on-Site pavement and buildings. The main office building and the
pavement immediately surrounding this building will remain on Site. Appropriate testing and any
necessary decontamination of the main office building shall be performed. EPA shall have a
reasonable opportunity to review and comment on the proposed sampling and decontamination
program prior to implementation. The building debris, pavement, and equipment will be
decontaminated by steam cleaning. The decontaminated metal debris will be taken offSite to a metal
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agreement with the selected alternatives S-5B and W-3B. Please refer to the Responsiveness
Summary which contains a letter of concurrence from TDEC.
EPA received several letters from residents in the Town of Rossville which supported the selected
remedy proposed by EPA. During the public meeting on November 30, 1998, town residents and
local government officials expressed interest and support for the selected remedy presented by EPA.
Please see the Responsiveness Summary which contains these letters and a transcript of the public
meeting.
2.11 SELECTED REMEDY
The EPA Selected Remedy is Source Materials Alternative S-5B and Wetlands Alternative W-3B.
Based upon current information, this remedy appears to provide the best balance among the nine
criteria that EPA uses to evaluate alternatives. EPA has determined that the Selected Remedy would
be protective of human health and the environment; would attain the Site goals; comply with ARARs;
and would be cost effective.
/
The Selected Remedy shall include the following:
Demolition of most of the on-Site pavement and buildings. The main office building and the
pavement immediately surrounding this building will remain on Site. The building debris,
pavement, and equipment will be decontaminated by steam cleaning. The decontaminated metal
debris will be taken off Site to a metal recycling facility. The equipment will be sold or donated
to interested parties. All other debris will be taken off Site to a permitted disposal facility;
Excavation of contaminated soil, landfilled slag, and contaminated wetlands sediment that
exceed their corresponding cleanup standard;
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for each evaluation criterion. Each alternative's performance against the criteria (except for present
worth) was ranked on a scale of 0 to 5, with 0 indicating that none of the criterion's requirements
were met and 5 indicating all of the requirements were met. The ranking scores are not intended to
be quantitative or additive, rather they are only summary indicators of each alternative's performance
against the CERCLA evaluation criteria. The ranking scores combined with the present worth costs
provide the basis for comparison among alternatives.
For soil, Alternatives S-2 through S-7 all rank higher than Alternative S-l in overall protection of
human health and the environment, compliance with ARARs, long-term effectiveness and
permanence, and reduction of M/T/V. The three capping alternatives, Alternatives S-2, S-3, and S-4,
are ranked similarly with the exception that Alternative S-2 ranks lowest in long-term effectiveness
and permanence. The two treatment alternatives receive similar ranking in all criteria with the
exception Option B of Alternative S-5 ranks highest in compliance with ARARs long-term
effectiveness and permanence, and implementability. A comparison of the capping alternatives to the
treatment alternatives indicates that the treatment alternatives (Alternatives S-5 and S-6) rank slightly
higher than the capping alternatives (Alternatives S-2, S-3, and S-4) in overall protection of human
health and the environment and reduction of M/T/V, but are more costly.
For wetland sediment, both Alternatives W-2 and W-3 rank higher than Alternative W-l in overall
protection of human health and the environment, compliance with ARARs, long-term effectiveness
and permanence, and reduction of M/T/V. Both options under Alternative W-3 (Excavation,
Regrading and Wetlands Revegetation) rank higher than Alternative W-2 (Capping and Off-Site
Creation of Wetlands) in overall protection of human health and the environment, compliance with
ARARs, long-term effectiveness and permanence, and reduction of M/T/V.
EPA and the Tennessee Department of Environment and Conservation (TDEC) have cooperated
throughout the RI/FS process. The State has participated in the development of the RI/FS and
Proposed Plan by providing comments on planning and decision documents. EPA and TDEC are in
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Table 2-21
Comparative Analysis of Wetland Sediment Alternatives
Ross Mciais Site
Rossvillc, Tennessee
Remedial
Alternative
W-l- No Action
W-2- Capping with
Off-site Creation of
Wetlands
W-3 A — Excavation,
Regrading with
Clean Fill and
Wetlands
Revcgetation/
Restoration
W-3 B - Excavation,
Regrading with
Biosolid Compost
Material and
Wetlands
Rcvegctation/
Restoration
Overall Protection of
Human Health and
the Environment
0
3
5
5
Compliance
with ARARs
0
2
5
5
Criteria Rating '
Long-Term
Effectiveness and
Permanence
0
2
5
5
Reduction of
M/T/V Through
Treatment
0
3
4
5
Short-Term
Effectiveness
5
3
4
4
Implementability
5
4
4
3
Approximate
Present Worth
($)
5100,247
$611,762
$780,071
$699,548
'A ranking of "0" indicates noncompliance, while a ranking of "5" indicates complete compliance.
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Table 2-20
Comparative Analysis of Soil Alternatives
Ross Metals Site
Rossvitlc, Tennessee
Remedial Alternative
S-I -No Action
S-2 - Capping
SO - Capping With
Pavement In Place
S-4 - Capping With
Construction of Above-
Ground Disposal Coll
S-5A — Excavation and
Onsite Treatment With
S/ S and onsite Disposal
S-5B - Kxcavation and
Onsile 'I'rcalmonl With
SIS and oHsite Disposal
S-6A - Capping With
Uxcavation & Onsite
Treatment of Princ. Thrt
Waste & onsite disposal
S-6B -- Capping With
Excavation & Onsite
Treatment and Oflsite
Disposal of Principal
Threat Waste
Criteria Rating '
Overall Protection of
Human Health and the
Environment
0
4
4
4
5
5
5
5
Compliance
wlthARARs
0
4
4
4
4
5
4
4
Long-Terra
Effectiveness and
Permanence
0
2
3
3
4
5
4
4
Reduction of M/T/V
Through Treatment
0
3
3
3
5
5
5
5
Short-Terni
Effectiveness
5
4
4
4
4
4
4
4
Implementablllty
5
3
3
3
3
4
3
3
Approximate
Present Worth
($)
$100,247
Opt. 1-$ 1,73 5,804
Opt.2-$l,712,412
Opt. l-$ 1,453,803
Opt.2-$ 1,430,4 11
Opt. 1-$ 1,506,847
Opt.2-$ 1.48 1,865
Opl.l -$4,907,274
Opl.2-$4,244,992
Opl.l -$7,477, 199
Opt.2-$6,lKI,lf>0
Opt.l-$3,175,137
Opl.2-$2,729,543
Opt. 1 -$4,936,044
Opt.2-$4,OI3,508
'A ranking of "0" indicates noncompliance, while a ranking of "5" indicates complete compliance. Opt. 1 includes excavated wetland sediment; Opt. 2 docs not.
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2.9.3B.7 Implementability
The use of biosolid compost material to address metals contamination is an emerging technology with
limited Ml scale application. However, all services and materials for this alternative should be readily
available.
2.9.3B.8 Cost
The total present worth cost for Alternative W-3, Option B is approximately $699,548. The
estimated capital cost is $620,379. The estimated annual O&M cost is approximately $79,170.
2.10 COMPARATIVE ANALYSIS OF ALTERNATIVES
This section presents a comparative analysis of the surface soil/sediment and groundwater alternatives
based on the threshold and balancing evaluation criteria. The objective of this section is to compare
and contrast the alternatives.
The alternatives are presented here to give decision makers a range of potential actions that could be
taken to remediate this Site. These actions include:
Soil No Action (Alternative S- 1 )
Capping (Alternatives S-2, S-3, S-4, and S-6 )
Solidification/Stabilization (Alternatives S-5 and S-6)
Wetland Sediment No Action (Alternative W-l)
Capping and Off-site Creation of Wetlands (Alternative W-2)
Excavation, Regrading and Wetlands Revegetation/Restoration
(Alternative W-3)
Tables 2-20 through 2-2 1 present a summary of each remedial alternative along with ranking scores
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treatment.
2.9.3B.6 Short-Term Effectiveness
The construction phase of this alternative would likely be accomplished within one field season;
therefore, impacts associated with construction would likely be short-term and minimal. Short-term
impacts are associated with excavation; however, these potential, short-term impacts would be
mitigated during the wetlands restoration phase. The revegetation plan uses plant species which
should restore the system within one growing season, thereby limiting the impacts. Controls can be
implemented to reduce impacts on adjacent wetlands.
On-Site workers would be adequately protected by using appropriate personal protective equipment
and by following proper operating and safety procedures. However, short-term air quality impacts
to the surrounding environment may occur during waste consolidation and grading. Dust emissions
would be monitored at the property boundaries. Fugitive dust emissions would be controlled by
applying water to surfaces receiving heavy vehicular traffic or in excavation areas, as needed. A
measurable, short-term impact to the surrounding area would include increased vehicular traffic and
associated safety hazards, potential dust generation, and noise.
Short-term impact on biological communities in the wetlands caused by excavation will be notable
because of excavation of wetlands sediment. However, the goal of the wetland mitigation program
is to replace lost wetland vegetation so that wetland function and values either will be present
immediately following the completion of mitigation or will develop over time. In addition, a
consideration of breeding seasons, and control of erosion and sedimentation in terms of scheduling
activities should ease short-term impact.
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if a proposed action is located in or affects a floodplain or wetlands, a floodplain/wetlands assessment
shall be undertaken, and a statement of findings explaining why the proposed action must be located
in or affect the floodplain or wetlands.
The Protection of Wetlands Order (40 CFR 6) requires that no adverse impacts to wetlands result
from a remedial action. The wetlands revegetation component of this alternative includes a 2-to-l
creation-to-loss ratio to compensate for the loss of forested and scrub/shrub wetlands which is
expected to meet the wetlands mitigation requirements of CWA Section 404.
The substantive requirements for stormwater discharges during construction activities as outlined by
the CWA are relevant and appropriate. However, a specific NPDES permit is not required for this
remedial action.
All action-specific ARARs are expected to be met. The TAPCR dust suppression and control
requirements (Rule 1200-3-8) apply to earth-moving activities associated with this alternative.
ARARs for the control of fugitive dust emissions would be met by applying water to roads receiving
heavy vehicular traffic and to excavation areas, as necessary.
2.9.3B.4 Long-Term Effectiveness and Permanence
This alternative provides source control and removal of contaminated sediments in the wetlands. This
action would permanently remove contaminated sediments and thereby reduce risk to ecological
receptors and improve water quality. The revegetation plan will restore the wetlands to a high
functioning value which should support diverse ecological communities.
2.9.3B.5 Reduction of M/T/V Through Treatment
Mobility, toxicity, and volume of contaminants will be reduced through removal, not through
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acres where lead occurs above 800 mg/mg in sediment and which includes approximately 1.5 acres
of forested and scrub/shrub wetlands. To compensate for the loss of forested and scrub/shrub
wetlands; these areas will be replaced at a 2-to-l creation-to-loss ratio. The revegetation of the
wetlands is based on planting 3 acres of forested wetland and 9 acres of emergent wetlands. Forested
mitigation areas would be seeded (3 Ibs/acre) with a mixture of herbaceous plant species that do not
form a turf and minimize competition with planted trees and shrubs. Trees and shrubs would each
be planted at a density of 436 plants/acre. Emergent wetland areas would be seeded at a rate of 5
Ibs/acre and planted with plugs or bare root plantings at a density of 4,840 plants/acre.
Land use restrictions and security fencing may be placed on the Site while the remedial action takes
place. Monitoring would be required to assess the effectiveness of the remedial action.
2.9.3B.2 Overall Protection of Human Health and the Environment
Source control of surface runoifand sediment transport will effectively eliminate a source of loading
of contaminants to the adjacent wetlands. The removal of the contamination from the Site wetlands
will effectively protect the environment. Removal will also reduce risk to ecological receptors.
The RAOs for reduction of risk to ecological receptors will be met and the alternative will restore the
degraded wetlands1 structure and function.
2.9.3B.3 Compliance with ARARs
EPA's regulations (40 CFR Part 6, Appendix A) for implementing Executive Order 11988
(Floodplains Management) requires federal agencies to avoid or minimize adverse impacts of Federal
actions upon floodplains, and to preserve and enhance the natural values of floodplains. Specifically,
when it is apparent that a proposed or potential Agency action is likely to impact a floodplain or
wetlands, the public should be informed through appropriate public notice processes. Furthermore,
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2.9.3B Alternative W-3 -Excavation & Revegetation/Restoration of Wetlands
Option B — Regrading with Biosolid Compost Material
2.9.3B.1 Description
Option B is similar to Option A except that excavated areas would be backfilled with a biosolid
compost material rather than clean fill. The compost would serve as the fill material, a metal-binding
material and as a source of fertilizer to encourage revegetation/restoration. The compost material
may also serve to bind contaminated groundwater should it percolate through the wetland. As with
previous alternatives, a Site monitoring program would be implemented.
As is the case for Option A, excavated sediments would be stockpiled with contaminated surface
soils and final disposition of the contaminated wetlands sediment would follow the remedial
alternative selected for surface soils. In excavating the approximately 5.7 acres of sediment with lead
concentrations greater than 800 mg/kg to a depth of -one foot; approximately 9,300 CY of
contaminated sediment will be generated. Approximately 8,200 CY of the excavated sediment would
be considered principal-threat waste and 1,100 CY would be considered low-level threat waste.
Treatability testing may be required to determine if pre-treatment (e.g. dewatering or stabilization)
of the wetlands sediment would be required to decrease teachability of lead and improve handling
characteristics of sediment prior to transport and disposal in order to implement this alternative as
well as to confirm the value of using a biosolid backfill. If pre-treatment is required, the development
or selection of the process must consider the impact of the process on the wetlands community.
Excavated areas will be backfilled to the existing grade and revegetated according to the Wetlands
Revegetation Plan developed'for the RM Site wetlands (ERRT 1998). Maintenance plans to
eliminate the intrusion of less desirable species and to promote success will be developed and Site
monitoring would also be required. The revegetation of the wetlands is based on excavation of 5.7
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would be monitored at the property boundaries. Fugitive dust emissions would be controlled by
applying water to surfaces receiving heavy vehicular traffic or in excavation areas, as needed. A
measurable, short-term impact to the surrounding area would include increased vehicular traffic and
associated safety hazards, potential dust generation, and noise.
Short-term impact on biological communities in the wetlands caused by excavation will be notable
because of excavation of wetlands sediment. However, the goal of the wetland mitigation program
is to replace lost wetland vegetation so that wetland function and values either will be present
immediately following the completion of mitigation or will develop over time. In addition, a
consideration of breeding seasons, and control of erosion and sedimentation in terms ofscheduling
activities should ease short-term impact.
2.9.3A.7 Implementability
All services and materials for this alternative are readily available. Moderate difficulty is posed by
conducting operations in unstable sediment substrate. To avoid problems, excavation can be limited
to dry periods. Revegetation will be performed in the spring and will require one month for
completion.
2.9.3A.8 Cost
The total present worth cost for Alternative W-3, Option A is approximately $780,071. The
estimated capital cost is $700,901. The estimated annual O&M cost is approximately $79,170.
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ARARs for the control of fugitive dust emissions would be met by applying water to roads receiving
heavy vehicular traffic and to excavation areas, as necessary.
2.9.3A.4 Long-Term Effectiveness and Permanence
This alternative provides source control and removal of contaminated sediments in the wetlands. This
action would permanently remove contaminated sediments and thereby reduce risk to ecological
receptors and improve water quality. The revegetation plan will restore the wetlands to a high
functioning value which should support diverse ecological communities.
2.9.3A.5 Reduction of M/T/V Through Treatment
Mobility, toxicity, and volume of contaminants will be reduced through removal, not through
treatment.
2.9.3A.6 Snort-Term Effectiveness
The construction phase of this alternative would likely be accomplished within one field season;
therefore, impacts associated with construction would likely be short-term and minimal. Short-term
impacts are associated with excavation; however, these potential, short-term impacts would be
mitigated during the wetlands restoration phase. The revegetation plan uses plant species which
should restore the system within one growing season, thereby limiting the impacts. Controls can be
implemented to reduce impacts on adjacent wetlands.
On-Site workers would be adequately protected by using appropriate personal protective equipment
and by following proper operating and safety procedures. However, short-term air quality impacts
to the surrounding environment may occur during waste consolidation and grading. Dust emissions
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The RAOs for reduction of risk to ecological receptors will be met and the alternative will restore the *
degraded wetlands' structure and function.
m
2.9.3A.3 Compliance with ARARs
EPA's regulations (40 CFR Part 6, Appendix A) for implementing Executive Order 11988
(Floodplains Management) requires federal agencies to avoid or minimize adverse impacts of Federal
actions upon floodplains, and to preserve and enhance the natural values of floodplains. In addition,
EPA's regulations (40 CFR Part 6, Appendix A) for implementing Executive' Order 11988
(Floodplains Management) requires federal agencies to avoid or minimize adverse impacts of Federal
actions upon floodplains, and to preserve and enhance the natural values of floodplains. Specifically,
when it is apparent that a proposed or potential Agency action is likely to impact a floodplain or
wetlands, the public should be informed through appropriate public notice processes. Furthermore,
if a proposed action is located in or affects a floodplain or wetlands, a floodplain/wetlands assessment
shall be undertaken, and a statement of findings explaining why the proposed action must be located
in or affect the floodplain or wetlands.
The Protection of Wetlands Order (40 CFR 6) requires that no adverse impacts to wetlands result
from a remedial action. The wetlands revegetation component of this alternative includes a 2-to-l
creation-to-loss ratio to compensate for the loss of forested and scrub/shrub wetlands which is
expected to meet the wetlands mitigation requirements of CWA Section 404.
The substantive requirements for stormwater discharges during construction activities as outlined by
the CWA are relevant and appropriate. However, a specific NPDES permit is not required for this
remedial action.
All action-specific ARARs are expected to be met. The TAPCR dust suppression and control
requirements (Rule 1200-3-8) apply to earth-moving activities associated with this alternative.
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sediment would be considered principal-threat waste and 1,100 CY would be considered low-level
threat waste.
Treatability testing may be required to determine if pre-treatment (e.g. dewatering or stabilization)
of the wetlands sediment would be required to decrease leachability of lead and improve handling
characteristics of sediment prior to transport and disposal in order to implement this alternative. If
pre-treatment is required, the development or selection of the process must consider the impact of
the process on the wetlands community.
The revegetation of the wetlands is based on excavation of 5.7 acres where lead occurs above 800
mg/mg in sediment and which includes approximately 1.5 acres of forested and scrub/shrub wetlands.
To compensate for the loss of forested and scrub/shrub wetlands; these areas will be replaced at a 2-
to-1 creation-to-loss ratio. The revegetation of the wetlands is based on planting 3 acres of forested
wetland and 9 acres of emergent wetlands. Forested mitigation areas would be seeded (3 Ibs/acre)
with a mixture of herbaceous plant species that do not form a turf and minimize competition with
planted trees and shrubs. Trees and shrubs would each be planted at a density of 436 plants/acre.
Emergent wetland areas would be seeded at a rate of 5 Ibs/acre and planted with plugs or bare root
plantings at a density of 4,840 plants/acre.
Deed restrictions may be placed on the Site while the remedial action takes place. Monitoring would
be required to assess the effectiveness of the remedial action.
2.9.3A.2 Overall Protection of Human Health and the Environment
Source control of surface runoff and sediment transport will effectively eliminate a source of loading
of contaminants to the adjacent wetlands. The removal of the contamination from the Site wetlands
will effectively protect the environment. Removal will also reduce risk to ecological receptors.
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This alternative would not meet EPA's expectation to use treatment to address the principal threats
posed by a site, although in some situations, containment of principal threats is warranted (EPA
1 99 1 ). Based on sample results collected during previous Site investigations, 8,700 CY of sediment
would be considered "principal-threat" waste.
Containment of principal threats may be warranted where treatment technologies are not technically
feasible or available within a reasonable time frame; or where the volume of materials or complexity
of the site makes implementation of treatment technologies infeasible; or where implementation of
a treatment-based remedy would result in greater overall risk to human health and the environment
or cause severe effects across environmental media. A review of currently available technologies and
Site conditions does not suggest that these situations would apply to the RM Site.
2.9.2.6 Short-Term Effectiveness
The construction phase of this alternative would likely be accomplished within one field season;
therefore, impacts associated with construction would likely be short term and minimal.
On-Site workers would be adequately protected from short-term risks by using appropriate personal
protective equipment and by following proper operating and safety procedures.
The wetland system would be destroyed since application of the cap will alter grade and hydrology.
A measurable, short-term impact to, the surrounding area would include increased vehicular traffic
and associated safety hazards, potential dust generation, and noise.
2.9.2.7 Implementability
Construction of a soil cap is a standard construction practice and materials are readily available.
Other than the capping of contaminated material in a floodplain and wetland, no significant
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All action-specific ARARs are expected to be met. The TAPCR dust suppression and control
requirements (Rule 1200-3-8) apply to earth-moving activities associated with this alternative.
ARARs for the control of fugitive dust emissions would be met by applying water to roads receiving
heavy vehicular traffic and to excavation areas, as necessary.
2.9.2.4 Long-Term Effectiveness and Permanence
Under this alternative, the cap would have to be maintained to ensure that it continues to perform as
designed; consequently, long-term monitoring, inspection, and maintenance would be required. The
cap would be susceptible to settlement, ponding of surface water, erosion, and disruption of cover
integrity by deep-rooting vegetation and bun-owing animals. The cover would need to be periodically
inspected, and required maintenance would need to be implemented in order to maintain effectiveness.
The long-term effectiveness of capping the waste would be enhanced by selecting the proper cover
design and grading layout. In addition, access restrictions such as land use controls and fencing
would be required to prevent land uses incompatible with the Site; specifically, land uses that would
compromise the cap should be precluded.
The remedial action objectives of reduction of exposure and prevention of transport and migration
of Site contaminants, and prevention of degradation of adjacent wetlands will be achieved. However,
the restoration of wetland communities and elimination of further degradation of the Site wetlands
will not be achieved.
2.9.2.5 Reduction of M/T/V Through Treatment
This alternative will not remove or dispose of the contamination. Contaminated sediment will be left
intact but the pathway of exposure will be reduced for multiple receptors. Toxicity may be reduced
by limiting bioavailability. The volume of material at the Site will not be altered.
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temporary water storage capacity of the floodplain; and
The facility is designed, constructed, operated, and maintained to prevent washout of any
solid waste.
The Protection of Wetlands Order (40 CFR 6) requires that no adverse impacts to wetlands result
from a remedial action. With appropriate stormwater runon and runoff controls, the substantive
requirements of this ARAR are expected to be met. In addition, the off-Site creation of wetlands
component of this alternative to compensate for the loss of forested and scrub/shrub wetlands is
expected to meet the wetlands mitigation requirements of CWA Section 404. The SWPD rule
requires that new landfills and lateral expansions shall not be located in a wetlands, unless the owner
or operator can make the following demonstrations:
» the presumption of a practicable alternative that does not involve wetlands is clearly
rebutted;
» the construction/operation of the landfill will not cause or contribute to violations of
applicable State water quality standards, any applicable toxic effluent standard or
prohibition under Section 307 of the CWA, and will not cause or contribute to the taking
of any endangered or threatened species or result in the destruction or adverse
modification of critical habitat of endangered or threatened species;
« the landfill will not cause or contribute to significant degradation of wetlands;
« to the extent required under Section 404 of the CWA or Tennessee Water Pollution
Control Act, steps have been taken to attempt to achieve no net loss of wetlands (as
defined by acreage and function); and
» sufficient information is available to make a reasonable determination with respect to these
demonstrations.
The substantive requirements for stormwater discharges during construction activities as outlined by
the CWA are relevant and appropriate. However, a specific NPDES permit is not required for this
remedial action.
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2.9.2.3 Compliance with ARARs
The RCRA hazardous waste disposal facility requirements are potentially apph'cable. The RM Site
is located in a 100-year floodplain within a zone designated as A3, indicating that base flood
elevations and flood hazard factors have been determined for this area. The ARAR (40 CFR 264)
requires that disposal facilities be designed to withstand a 100-year flood. In addition, EPA's
regulations (40 CFR Part 6, Appendix A) for implementing Executive Order 11988 (Floodplains
Management) requires federal agencies to avoid or minimize adverse impacts of Federal actions upon
floodplains, and to preserve and enhance' the natural values of floodplains. Specifically, when it is
apparent that a proposed or potential Agency action is likely to impact a floodplain or Wetlands, the
public should be informed through appropriate public notice processes. Furthermore, if a proposed
action is located in or affects a floodplain or wetlands, a floodplain/wetlands assessment shall be
undertaken, and a statement of findings explaining why the proposed action must be located in or
affect the floodplain or wetlands.
Regarding construction activities related to implementing the alternative, 40 CFR 6 Appendix A
requires that EPA-controlled structures and facilities must be constructed in accordance with existing
criteria and standards set forth under the NFIP and must include mitigation of adverse impacts
wherever feasible, including the use of accepted floodproofing and/or other flood protection
measures. To achieve flood protection, EPA shall wherever practicable, elevate structures above the
base flood level rather than filling land. In addition, the capped area may be classified as a Tennessee
SWPD Class II disposal facility. If so, the substantive requirements of the SWPD rule regarding
Class II disposal facilities (e.g., siting) would apply to the Site. The SWPD rule (Rule 1200-1 -7) and
the Criteria for Classification of Solid Waste Disposal Facilities and Practices (40 CFR 257) require
that disposal facilities must not be located in a 100-year floodplain, unless both of the following can
be demonstrated:
• Location in the floodplain will not restrict the flow of the 100-year flood nor reduce the
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2.9.2 Alternative W-2 - Capping with Clean Fill and Off-Site Creation of Wetlands
2.9.2.1 Description
Capping the contaminated sediment in the wetlands at the RM Site would serve to prevent rainfall
infiltration and future leaching into the groundwater. In addition, capping also would limit direct
contact exposure to contaminated media under the cap. Varying degrees of capping can be
implemented depending on the severity of contaminants in the area. Caps can range from a simple
natural soil cap to a multilayer soil/synthetic cap. For the wetlands, a foot of topsoil would be placed
on the surface of the contaminated wetland sediment and graded evenly. Capping with a minimum
of one foot of clean fill would be required to eliminate multiple exposure pathways as identified in
the ecological risk assessment. The cap would be applied to the approximately 5.7 acres of wetlands
containing sediment with lead concentrations greater than 800 mg/kg. Because this action results in
a destruction of the wetlands by altering the grade and hydrology of the system, off-Site creation of
wetlands is required to compensate for the loss.
Alternative W-2 would eliminate direct contact with contaminated media, minimize contaminant
migration to groundwater, and eliminate contaminant migration. Land use restrictions and security
fencing may be placed on the Site while the remedial action takes place. Monitoring would be
required to assess the effectiveness of the remedial action.
2.9.2.2 Overall Protection of Human Health and the Environment
This alternative will not remove or contain the contaminated sediments but potentially limits multiple
exposure pathways to ecological receptors. Organisms utilizing portions of the wetlands below the
surface may potentially continue to be exposed. The volume and concentration in the wetland will
not be altered. Lead and other metals in the wetland sediment may continue to result in adverse
impacts.
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2.9.1.4 Long-Term Effectiveness and Permanence
The remediation goals derived for protection of ecological receptors would not be met. Because
contaminated wetland sediment remains under this alternative, a review/reassessment of the
conditions at the Site would be performed at 5-year intervals to ensure that the remedy does not
become a greater risk to human health and the environment.
2.9.1.5 Reduction of M/T/V Through Treatment
No reductions in contaminants M/T/V are realized under this alternative.
2.9.1.6 Short-Term Effectiveness
Since no further remedial action would be implemented at this Site, this alternative poses no short-
term risks to onsite workers. It is assumed that Level D personnel protection would be used when
sampling various media.
2.9.1.7 Implementability
This alternative could be implemented immediately since monitoring equipment is readily available
and procedures are in place.
2.9.1.8 Cost
Minimal costs are associated with this alternative relative to other remedial action alternatives. No
capital costs are associated with this alternative. The estimated O&M cost is approximately
$100,247.
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Table 2-19
Summary of Wetland Sediment Alternatives Evaluation
I Remedial Alternative
1 -No Action
2 —Capping w/Clean
Fill and Off-Site
Creation of Wetlands
3 A- Excavation «nd
RevegetauW
Restoration of Wetlands
andRegradingwhh
Clean Fill
SB-Excavation and
Revegeution'
Rcjteralico of Wetlands
ahdRegradtngwith
Biowlid Compost
Threshold Criteria
OveraQ Protection of Human
Health and the Environment
Doe not eliminate exposure
pathways or reduce the level of
risk. Does not limit migration of
or remove contaminant*.
Potentially eliminates multiple
exposure pathways to ecological
receptors. Organisms utilizing
portions of the wetlands below
the surface may potentially
continue to be exposed
Eliminates exposure pathways
and reduces the level of risk.
Remove] contamination and
restores functional value of
contaminated u-etlindt.
Eliminate! exposure pathways
and reduces the level of risk.
Removes contamination and
restores functional value of
ceMamiiuled wetlands.
Compliance Kith
ARARs
Chemical-specific
ARARs are not met
Location- and
action-specific
ARARs do not
apply.
Does not meet
ARARS for
protection of
wetlands.
All action-specific
ARARs are expected
o be met Location-
pecific ARARs are
applicable and
would need to be
met.
All action-specific
ARARs are expected
be met. Location-
specific ARARt are
applicable and
DuMnecdlobe
nut
Lont-Term Eflectivenen
and f ennanence
The contaminated material is
a long-term impact The
remediation goals are not met
Will reduce or eliminate
viable exposure pathway! and
prevent degradation of
adjacent wetlands No residual
risk* from the alternative.
Long -term effectiveness
requires cap maintenance
Long-term ecological threats
associated with sediment are
{really reduced. No residual
risks from the alternative.
Long -term effectiveness
require] cap maintenance
Long-term ecological threats
associated with jedimenl are
ptaUy reduced. No residual
rislct from the ahemuive.
Long -term effectiveness
requira cap maintenance
Balancing Criteria
Reduction of MOW Through
Treatment
No reduction of MOW 'a realized.
Reduction of mobility is realized but
contaminant volume or toxraty are
not reduced. For the principal threat
waste at the She, does not meet
EPA's expectation to treat principal
threat waste.
deduction of mobility, toricity, and
volume is achieved through
removal, not treatment
eduction ofmobility, Io.ticity,«nd
volume it achieved through
emoval. not treatment
Additionally, use ofbiosolid
conipoa reducej lankily by liaiiimg
oiviaability of conlininanU.
Short-Term EfTectiv«Ku
Level D protective equipment is
required during sampling.
Level C and D protective
equipment required during She
activities. Grading may result in
potential release of dust Noise
nuisance from use of heavy
equipment
Level C and O protective
equipment required during SHe
activities. Excavating and grading
may result in potential release of
dust Short-term impacts to the
wetlands from excavating activities
will occur.
.evel C and D protective
equipment required during Site
activities. Excavating and grading
oay result in potential release of
uL S)iorMcmi impacts to the
tmlands from excavating activities
wiBoccw.
ImpIementablUty
Technical/Engineering
ConsMerafloni
None
Capping in a floodplaia and
wetlands.
s'one
•one.
Estimated Time for
<1
<1
<1
y
Cost
Approi. Total Proent
Worth
_
S100.247
— _J
$611,752
$780.071 *"
-^— ^•^"— ^^-^_^_
K»^«
1
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creation of wetlands, composting/fixation of wetlands sediment with off-Site creation of wetlands,
capping with off-Site creation of wetlands, and excavation and grading with either clean fill or
composting and revegetation. Table 2-19 is a summary of the wetland alternatives considered.
2.9.1 Alternative W-l ~ No Action
2.9.1.1 Description
Under this alternative, no remedial action would be taken with respect to the wetlands. A monitoring
program would be implemented to address wetland sediments, surface water and associated uptake
by biota utilizing the affected area. The monitoring program would be developed in order to allow
for regulators to assess the migration of the contaminants from the wetlands and determine if remedial
actions might be necessary in the future. The monitoring program would take place on a yearly basis
with a risk evaluation conducted within 5 years to determine the effectiveness of this approach.
2.9.1.2 Overall Protection of Human Health and the Environment
The no action alternative does not eliminate any exposure pathways or reduce the level of risk of the
existing wetland sediment contamination.
2.9.1.3 Compliance with ARARs
This alternative does not achieve the RAOs or chemical-specific ARARs established for wetland
sediment. Location- and action-specific ARARs do not apply to this alternative since further remedial
actions will not be conducted.
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low level-threat material in a floodplain, no significant construction issues are expected to be
encountered.
Treatment of contaminated soil and slag is offered by numerous vendors. On-Site treatment utilizes
standard construction practices and material handling equipment. No significant construction issues
are expected to be encountered.
Treatment of the contaminated waste will likely increase the volume of the waste soil and slag
material; however, slight volume reductions may occur when some chemical reagents are used to treat
the material. Typical volume increases range from about 5 percent to as high as 100 percent,
depending upon the treatment method used. An increase in the volume of the treated waste material
will have an impact on the disposal volume required. Calculations used in the development of this
alternative utilized a volume increase estimate of 5 percent.
All services and materials for this alternative are readily available.
2.8.6B.8 Cost
The total present worth for Alternative S-6B is approximately $4,936,044 for Option 1, which
includes the excavated wetlands sediment, and $4,013,508 for Option 2, which does not include the
wetland sediment. For Option 1, the estimated capital cost is approximately $4,776,149, and the
estimated O&M cost is approximately $159,895. For Option 2, the estimated capital cost is
approximately $3,853,613 and the estimated O&M cost is approximately $159,895.
2.9 WETLAND SEDIMENT ALTERNATIVE ANALYSIS
The alternatives that were selected for surface soil at the RM Site include no action, institutional
controls and off-Site creation of wetlands, surface water and sediment control/diversion with off-Site
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This alternative would meet EPA's expectation to use treatment to address the principal threats posed
by a Site, as well as EPA's expectation to use containment to address low-level threats posed by a
site. Based on sample results collected during previous Site investigations, 600 CY of surface soil
and the 16,000 CY of stockpiled and landfilled slag would be considered "principal-threat" waste.
2.8.6B.6 Short-Term Effectiveness
The construction phase of this alternative would likely be accomplished within one field season;
therefore, impacts associated with construction would likely be short-term and minimal. Short-term
impacts are associated with excavation and consolidation of waste soil and slag; however, these
potential, short-term impacts would be mitigated during the construction phase.
If the excavated material is dry, on-Site workers will be exposed to waste soil and slag dust during
excavation and consolidation activities. Additional exposure to lead dust may occur during building
structure and pavement demolition. Ingestion of dust could involve some health effects because of
the high level of metals in waste soil and slag.
On-Site workers would be adequately protected by using appropriate personal protective equipment
and by following proper operating and safety procedures. However, short-term air quality impacts
to the surrounding environment may occur during waste consolidation and grading. Dust emissions
would be monitored at the property boundaries. Fugitive dust emissions would be controlled by
applying water to surfaces receiving heavy vehicular traffic or in excavation areas, as needed. A
measurable, short-term impact to the surrounding area would include increased vehicular traffic and
associated safety hazards, potential dust generation, and noise.
2.8.6B.7 Implementability
Construction of a geomembrane surface cap is a standard construction practice. Other than capping
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All action-specific ARARs are expected to be met. The TAPCR dust suppression and control
requirements (Rule 1200-3-8) apply to earth-moving activities associated with this alternative.
ARARs for the control of fugitive dust emissions would be met by applying water to roads receiving
heavy vehicular traffic and to excavation areas, as necessary.
2.8.6B.4 Long-Term Effectiveness and Permanence
Under this alternative, the cap would have to be maintained to ensure that it continues to perform as
designed; consequently, long-term monitoring, inspection, and maintenance would be required. The
cap would be susceptible to settlement, ponding of surface water, erosion, and disruption of cover
integrity by deep-rooting vegetation and burrowing animals. However, the cover would be
periodically inspected, and required maintenance could be implemented.
The long-term effectiveness of capping the waste would be enhanced by selecting the proper cover
design and grading layout. In addition, access restrictions such as land use controls and fencing
would be required to prevent land uses that are incompatible with the Site; specifically, land uses that
would compromise the cap should be precluded.
2.8.6B.5 Reduction of M/T/V Through Treatment
The primary objective of this alternative is to reduce contaminant mobility by isolating contaminants
from receptor contact; contaminant volume or toxicity would not be reduced. Contaminant mobility
would be reduced by installing an impermeable cap liner. The liner would eliminate surface water or
precipitation infiltration and would greatly reduce contaminant migration to groundwater in
conjunction with the existing clay unit beneath the Site. Consolidation and capping would isolate
waste source areas and reduce contaminant mobility resulting from surface water transport and wind
erosion. Contaminant mobility is expected to be reduced to an extent that would result in overall risk
reduction from all pathways and exposure routes.
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temporary water storage capacity of the floodplain; and
• The facility is designed, constructed, operated, and maintained to prevent washout of any
solid waste.
Wetlands are located to the north and northeast of the facility and landfill, although these locations
are not identified on NWI maps. The Protection of Wetlands Order (40 CFR 6) requires that no
adverse impacts to wetlands result from a remedial action. With appropriate stormwater runon and
runoffcontrols, the substantive requirements of this ARAR are expected to be met. The SWPD rule
requires that new landfills and lateral expansions shall not be located in a wetlands, unless the owner
or operator can make the following demonstrations:
• the presumption of a practicable alternative that does not involve wetlands is clearly
rebutted;
• the construction/operation of the landfill will not cause or contribute to violations of
applicable State water quality standards, any applicable toxic effluent standard or
prohibition under Section 307 of the CWA, and will not cause or contribute to the taking
of any endangered or threatened species or result in the destruction or adverse
modification of critical habitat of endangered or threatened species;
• the landfill will not cause or contribute to significant degradation of wetlands;
• to the extent required under Section 404 of the CWA or Tennessee Water Pollution
Control Act, steps have been taken to attempt to achieve no net loss of wetlands (as
defined by acreage and function); and
• sufficient information is available to make a reasonable determination with respect to these
demonstrations.
The substantive requirements for stormwater discharges during construction activities as outlined by
the CWA are relevant and appropriate. However, a specific NPDES permit is not required for this
remedial action.
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2.8.6B.3 Compliance with ARARs
The RCRA hazardous waste disposal facility requirements are potentially applicable. The RM Site
is located in a 100-year floodplain within a zone designated as A3, indicating that base flood
elevations and flood hazard factors have been determined for this area. The ARAR (40 CFR 264)
requires that disposal facilities be designed to withstand a 100-year flood. In addition, EPA's
regulations (40 CFR Part 6, Appendix A) for implementing Executive Order 11988 (Flo'odplains
Management) requires federal agencies to avoid or minimize adverse impacts of Federal actions upon
floodplains, and to preserve and enhance the natural values of floodplains. Specifically, when it is
apparent that a proposed or potential Agency action is likely to impact a floodplain or wetlands, the
public should be informed through appropriate public notice processes. Furthermore, if a proposed
action is located in or affects a floodplain or wetlands, a floodplain/wetlands assessment shall be
undertaken, and a statement of findings explaining why the proposed action must be located in or
Mi affect the floodplain or wetlands.
Regarding construction activities related to implementing the alternative, 40 CFR 6 Appendix A
requires that EPA-controlled structures and facilities must be constructed in accordance with existing
criteria and standards set forth under the NFIP and must include mitigation of adverse impacts
wherever feasible, including the use of accepted floodproofing and/or other flood protection
measures. To achieve flood protection, EPA shall wherever practicable, elevate structures above the
base flood level rather than filling land. In addition, the capped area may be classified as a Tennessee
SWPD Class II disposal facility. If so, the substantive requirements of the SWPD rule regarding
Class II disposal facilities (e.g., siting) would apply to the Site. The SWPD rule (Rule 1200-1-7) and
the Criteria for Classification of Solid Waste Disposal Facilities and Practices (40 CFR 257) require
that disposal facilities must not be located in a 100-year floodplain, unless both of the following can
be demonstrated:
•i
• Location in the floodplain will not restrict the flow of the 100-year flood nor reduce the
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SOUTH
NORTH
WRECKER
BUILDING
SURFACE DEPOSITION OF
LEAD CONTAMINATED OUST.
SOILS, AND SEDIMENT
LANDFILL
DEPTH AT WHICH
GROUNDWATER ENCOUNTERED
6" TOPSfflL
GEOTEXTILE
LINER
DEPTH AT WHICH
GROUNDWATER ENCOUNTERED
NOT TO SCALE
APPROXIMATE DIMENSIONS OF EXCAVATION: TOTAL DEPTH - 5 FT.
LENGTH - 250 FT.
WIDTH - 450 FT.
NOTE: Conceptual d««lgn. Federal, state, and local
r«qulr«m«nta regarding construction In a floodploln
must ba considered and mgy affect design
Representation of wavte material Includen excavated
wetland sediments.
Ross Metals Site
Rossville, Tennessee
CDM Federal Programs Corporation
X xMbfa? a/ tear Dnsxr i HcJ&f IK.
Alternative 6B
Treatment W/Offsite Disposal
of Treated Principal Threat
Waste
Figure No.
2-29
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Site physical hazards, minimize contaminant migration to groundwater, and eliminate contaminant
migration to surface water from the Site. Figure 2-29 illustrates the components of the cap included
under Alternative S-6B as applied to the RM Site.
2.8.6B.2 Overall Protection of Human Health and the Environment
Successful implementation of this alternative would reduce risks to human health and the environment
and meet the removal action objectives by (1) eliminating exposure of residents and trespassers to
waste material by direct contact and airborne migration, (2) eliminating exposure of trespassers to
direct contact with on-Site physical hazards, and (3) further reduce the migration of contaminants to
groundwater over Alternative S-2 and eliminate the migration of contaminants to surface water.
Consolidation and isolation of low level-threat waste material beneath a geomembrane cap would
eliminate receptor routes of exposure through ingestion and inhalation. Structures throughout the
Site would be demolished and disposed of in the disposal area above the existing pavement and
landfill area. The waste material would be spread and compacted throughout the Site. Physical
hazards associated with deteriorating structures would be eliminated. In addition, geomembrane
capping would eliminate infiltration of precipitation and surface water that contributes to the
migration of contaminants to groundwater. However, because the waste material will remain on Site,
contaminant migration to groundwater cannot be discounted as an adverse effect. Nevertheless, the
elimination of surface water infiltration makes this scenario unlikely, and contaminant migration
through surface water runoff to the adjacent wetlands and the Wolf River would be eliminated.
The threat of direct human exposure to contaminated waste and physical hazards would be practically
eliminated by this alternative; however, the threat could return over the long term if cap integrity was
compromised. The potential for ingestion, dermal contact, and inhalation of soil containing metals
would be eliminated by successfully placing the geomembrane cap over the waste material.
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• Offsite disposal of 34,335 tons of treated principal-threat waste (assuming 5% increase in
volume due to treatment) in RCRA Subtitle D landfill (47,250 tons if contaminated
wetlands sediment are excavated and consolidated with surface soil for final disposition);
• Installation of 1.5-ft-deep soil cushion over waste and treated material and low-level threat
material capped in place (20,300 CY);
Installation of geomembrane liner and geotextile over soil cushion (6.7 acres);
• Soil cover (1 ft deep), topsoil cover (6 inches deep), and grass seeding over Site
(8 acres); and
• Land use restrictions and security fencing.
The final treatment system would depend upon the outcome of treatability testing and would be
determined during the remedial design phase. The fixed material would be subjected to TCLP testing
to determine if treatment has been effective, prior to placement in the excavated disposal area. Note
that the components of this alternative are considered a conceptual design, but other designs may be
possible. The final design would be based on requirements regarding construction in a floodplain.
Treatability testing may be required to demonstrate contaminant immobilization for this treatment
process and to help determine the volume increase caused by the solidification/stabilization process.
Land use restrictions and security fencing may be placed on the Site while the remedial action takes
place. Monitoring would be required to assess the effectiveness of the remedial action.
The topsoil layer of the cap would be graded to a minimum slope of 3% and a maximum of 5% to
promote surface drainage away fromthe waste cell and reduce infiltration. Surface drainage controls
would be constructed around the perimeter of the cap to collect surface water runoff.
Option B of Alternative S-6 would eliminate direct contact with contaminated media, eliminate
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by steam/pressure cleaning. Onsite contaminated soil considered principal threat, and buried slag in
the landfill would be excavated and consolidated with the stockpiled slag. In addition, contaminated
soil from areas not covered by pavement, and non-principal-threat landfill soil would be excavated
for placement in the excavated onsite landfill. This low level-threat waste material would be disposed
in the excavated landfill area (450 x 250 ft x 5 ft deep). A geosynthetic cap and underlying 1.5-ft soil
cushion layer would be added above the waste and existing landfill and would cover about 2.5 acres.
A 1-ft soil cover and 6-inch topsoil layer would be placed over the entire Site.
For treatment, contaminants within soil and slag would be physically bound or enclosed within a
stabilized mass (solidification), or chemical reactions would be induced between a stabilizing agent
and the contaminant to reduce its mobility (stabilization). The decontaminated building debris would
be taken offsite to a metal recycling facility. The components of this alternative are outlined as
below:
Decontamination and demolition of buildings;
• Recycling of metal building debris;
Excavation of principal-threat contaminated soil (500 CY), landfilled slag (10,000 CY),
and non-principal threat landfill soil (6,500 CY) to allow access to landfilled slag.
(Excavation of an additional 8,200 CY of principal-threat contaminated wetland sediment
and 1,100 CY of non-principal threat contaminated wetland sediment if contaminated
wetland sediments are excavated and consolidated with surface soil for final disposition);
• Stabilization or solidification of principal-threat contaminated soil and wetland sediment,
stockpiled slag, and landfilled slag (about 32,700; 45,000 tons if contaminated wetland
sediments are excavated and consolidated with surface soils for final disposition);
• Excavation of on-site disposal area (450 ft long by 250 ft wide by 5 ft deep) in landfill area;
Compaction of 6,500 CY of low-level (non-principal threat) waste material (7,600 CY if
contaminated wetland sediments are excavated and consolidated with surface soil for final
disposition;
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depending upon the treatment method used. An increase in the volume of the treated waste material
will have an impact on the disposal volume required. Calculations used in the development of this
alternative utilized a volume increase estimate of 5 percent.
The on-Site disposal area for the treated waste may be classified as a Class II disposal facility. If so,
the substantive requirements of the SWPD rule regarding Class II disposal facilities would apply to
the Site.
All services and materials for this alternative are readily available.
2.8.6A.8 Cost
The total present worth for Alternative S-6A is approximately $3,175,137 for Option 1, which
includes the excavated wetlands sediment, and $2,729,543 for Option 2, which does not include the
wetland sediment. For Option 1, the estimated capital cost is approximately $3,015,241, and the
estimated O&M cost is approximately $159,895. For Option 2, the estimated capital cost is
approximately $2,569,647, and the estimated O&M cost is approximately $159,895.
2.8.6B Alternative S-6 - Capping w/ Excavation & Onsite Treatment of
Principal Threat Waste
Option B - Offsite Disposal of Treated Principal-Threat Waste
2.8.6B.1 Description
Option B is similar to Option A except that treated principal-threat waste is disposed offsite in a
RCRA subtitle D landfill rather than being capped onsite with the low-level threat waste. Like Option
A, Option B for Alternative S-6 includes the demolition of most of the on-Site buildings. The main
office building would remain on Site. The building debris and pavement would be decontaminated
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potential, short-term impacts would be mitigated during the construction phase.
If the excavated material is dry, on-Site workers will be exposed to waste soil and slag dust during
excavation and consolidation activities. Additional exposure to lead dust may occur during building
structure and pavement demolition. Ingestion of dust could involve some health effects because of
the high level of metals in waste soil and slag.
On-Site workers would be adequately protected by using appropriate personal protective equipment
and by following proper operating and safety procedures. However, short-term air quality impacts
to the surrounding environment may occur during waste consolidation and grading. Dust emissions
would be monitored at the property boundaries. Fugitive dust emissions would be controlled by
applying water to surfaces receiving heavy vehicular traffic or in excavation areas, as needed. A
measurable, short-term impact to the surrounding area would include increased vehicular traffic and
associated safety hazards, potential dust generation, and noise.
2.8.6A.7 Implementability
Construction of a geomembrane surface cap is a standard construction practice. Other than capping
treated and low level-threat material in a floodplain, no significant construction issues are expected
to be encountered.
Treatment of contaminated soil and slag is offered by numerous vendors. On-Site treatment utilizes
standard construction practices and material handling equipment. No significant construction issues
are expected to be encountered.
Treatment of the contaminated waste will likely increase the volume of the waste soil and slag
material; however, slight volume reductions may occur when some chemical reagents are used to treat
the material. Typical volume increases range from about 5 percent to as high as 100 percent,
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periodically inspected and maintained.
The long-term effectiveness of capping the waste would be enhanced by selecting the proper cover
design and grading layout. In addition, access restrictions such as land use controls and fencing
would be required to prevent land uses that are incompatible with the Site; specifically, land uses that
would compromise the cap should be precluded.
2.8.6A.5 Reduction of M/T/V Through Treatment
The primary objective of this alternative is to reduce contaminant mobility by isolating contaminants
from receptor contact; contaminant volume or toxicity would not be reduced. Contaminant mobility
would be reduced by installing an impermeable cap liner. The liner would eliminate surface water or
precipitation infiltration and would greatly reduce contaminant migration to groundwater in
conjunction with the existing clay unit beneath the Site. Consolidation and capping would isolate
waste source areas and reduce contaminant mobility resulting from surface water transport and wind
erosion. Contaminant mobility is expected to be reduced to an extent that would result in overall risk
reduction from all pathways and exposure routes.
This alternative would meet EPA's expectation to use treatment to address the principal threats posed
by a site, as well as EPA's expectation to use containment to address low-level threats posed by a site.
Based on sample results collected during previous Site investigations, 600 CY of surface soil and
the 16,000 CY of stockpiled and landfiUed slag would be considered "principal-threat" waste.
2.8.6A.6 Short-Term Effectiveness
The construction phase of this alternative would likely be accomplished within one field season;
therefore, impacts associated with construction would likely be short-term and minimal. Short-term
impacts are associated with excavation and consolidation of waste soil and slag; however, these
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the presumption of a practicable alternative that does not involve wetlands is clearly
rebutted;
the construction/operation of the landfill will not cause or contribute to violations of
applicable State water quality standards, any applicable toxic effluent standard or
prohibition under Section 307 of the CWA, and will not cause or contribute to the taking
of any endangered or threatened species or result in the destruction or adverse
modification of critical habitat of endangered or threatened species;
the landfill will not cause or contribute to significant degradation of wetlands;
to the extent required under Section 404 of the CWA or Tennessee Water Pollution
Control Act, steps have been taken to attempt to achieve no net loss of wetlands (as
defined by acreage and function); and
sufficient information is available to make a reasonable determination with respect to these
demonstrations.
The substantive requirements for stormwater discharges during construction activities as outlined by
the CWA are relevant and appropriate. However, a specific NPDES permit is not required for this
remedial action.
All action-specific ARARs are expected to be met. The TAPCR dust suppression and control
requirements (Rule 1200-3-8) apply to earth-moving activities associated with this alternative.
ARARs for the control of fugitive dust emissions would be met by applying water to roads receiving
heavy vehicular traffic and to excavation areas, as necessary.
2.8.6A.4 Long-Term Effectiveness and Permanence
Under this alternative, the cap would have to be maintained to ensure that it continues to perform as
designed; consequently, long-term monitoring, inspection, and maintenance would be required. The
cap would be susceptible to settlement, ponding of surface water, erosion, and disruption of cover
integrity by deep-rooting vegetation and burrowing animals. However, the cover would be
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action is located in or affects a floodplain or wetlands, a floodplain/wetlands assessment shall be
undertaken, and a statement of findings explaining why the proposed action must be located in or
affect the floodplain or wetlands.
Regarding construction activities related to implementing the alternative, 40 CFR 6 Appendix A
requires that EPA-controIled structures and facilities must be constructed in accordance with existing
criteria and standards set forth under the NFIP and must include mitigation of adverse impacts
wherever feasible, including the use of accepted floodproofing and/or other flood protection
measures. To achieve flood protection, EPA shall wherever practicable, elevate structures above the
base flood level rather than filling land. In addition, the capped area may be classified as a Tennessee
SWPD Class II disposal facility. If so, the substantive requirements of the SWPD rule regarding
Class II disposal facilities (e.g., siting) would apply to the Site. The SWPD rule (Rule 1200-1 -7) and
the Criteria for Classification of Solid Waste Disposal Facilities and Practices (40 CFR 257) require
that disposal facilities must not be located in a 100-year floodplain, unless both of the following can
be demonstrated:
• Location in the floodplain will not restrict the flow of the 100-year flood nor reduce the
temporary water storage capacity of the floodplain; and
• The facility is designed, constructed, operated, and maintained to prevent washout of any
solid waste.
Wetlands are located to the north and northeast of the facility and landfill, although these locations
are not identified on NWI maps. The Protection of Wetlands Order (40 CFR 6) requires that no
adverse impacts to wetlands result from a remedial action. With appropriate stormwater runon and
runoff controls, the substantive requirements of this ARAR are expected to be met. The SWPD rule
requires that new landfills and lateral expansions shall not be located in a wetlands, unless the owner
or operator can make the following demonstrations:
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groundwater over Alternative S-2 and eliminate the migration of contaminants to surface water.
Consolidation and isolation of the waste material beneath a geomembrane cap would eliminate
receptor routes of exposure through ingestion and inhalation. Structures throughout the Site would
be demolished and disposed of in the disposal area above the existing pavement and landfill area. The
waste material would be spread and compacted throughout the Site. Physical hazards associated with
deteriorating structures would be eliminated. In addition, geomembrane capping would eliminate
infiltration of precipitation and surface water that contributes to the migration of contaminants to
groundwater. However, because the waste material will remain on Site, contaminant migration to
groundwater cannot be discounted as an adverse effect. Nevertheless, the elimination of surface
water infiltration makes this scenario unlikely, and contaminant migration through surface water
runoff to the adjacent wetlands and the Wolf River would be eliminated.
The threat of direct human exposure to contaminated waste and physical hazards would be practically
eliminated by this alternative; however, the threat could return over the long term if cap integrity was
compromised. The potential for ingestion, dermal contact, and inhalation of soil containing metals
would be eliminated by successfully placing the geomembrane cap over the waste material.
2.8.6A,3 Compliance with ARARs
The RCRA hazardous waste disposal facility requirements are potentially applicable. The RM Site
is located in a 100-year floodplain within a zone designated as A3, indicating that base flood
elevations and flood hazard factors have been determined for this area. The ARAR (40 CFR 264)
requires that disposal facilities be designed to withstand a 100-year flood. In addition, EPA's
regulations (40 CFR Part 6, Appendix A) for implementing Executive Order 11988 (Floodplains
Management) requires federal agencies to avoid or minimize adverse impacts of Federal actions upon
floodplains, and to preserve and enhance the natural values of floodplains. Specifically, when it is
apparent that a proposed or potential Agency action is likely to impact a floodplain or wetlands, the
public should be informed through appropriate public notice processes. Furthermore, if a proposed
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SOUTH
NORTH
I
SURFACE DEPOSITION OF
LEAD CONTAMINATED DUST,
SOILS, AND SEDIMENT
LANDFILL
CONTAMINATE!
BELOW SLAG
DEPTH AT WHICH
GROUNDWATER ENCOUNTERED
>' TREATED AND '^' . V-"
'.. . LOW-L|VE'L THREAT .
MATERIAL (WETLANDS) •' » J
•"
PAVEMENT-
THREA W
DEPTH AT WHICH
GROUNDWATER ENCOUNTERED
NOT TO SCALE
APPROXIMATE DIMENSIONS OF EXCAVATION: TOTAL DEPTH (BELOW GROUND SURFACE) - 5 FT.
TOTAL HEIGHT (BELOW GROUND SURFACE) - 6 FT.
LENGTH - 250 FT.
YrtDTH - 450 FT.
NOTE: Conceptual design. Federal, state, and local
requirement* regarding construction in a floodplaln
must be considered and may affect design
Representation of waste material Includes excavated
wetland sediments.
Ross Metals Site
Rossville, Tennessee
CDM Federal Programs Corporation
K auteJfcry rf Camp Drnxr * MrAW fee
Alternative 6A
Treatment W/Onsite Disposal
of Treated Principal Threat Waste
Figure No.
2-28
8/98
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The final treatment system would depend upon the outcome of treatability testing and would be
determined during the remedial design phase. The fixed material would be subjected to TCLP testing
to determine if treatment has been effective, prior to placement in the excavated disposal area. Note
that the components of this alternative are considered a conceptual design, but other designs may be
possible. The final design would be based on requirements regarding construction in a floodplain.
Treatability testing may be required to demonstrate contaminant immobih'zation for this treatment
process and to help determine the volume increase caused by the solidification/stabilization process.
Land use restrictions and security fencing may be placed on the Site while the remedial action takes
place. Monitoring would be required to assess the effectiveness of the remedial action.
The topsoil layer of the cap would be graded to a minimum slope of 3% and a maximum of 5% to
promote surface drainage away from the waste cell and reduce infiltration. Surface drainage controls
would be constructed around the perimeter of the cap to collect surface water runoff.
Option A of Alternative S-6 would eliminate direct contact with contaminated media, eliminate on-
Site physical hazards, minimize contaminant migration to groundwater, and eliminate contaminant
migration to surface water from the Site. Figure 2-28 illustrates the components of the cap included
under Alternative S-6A as applied to the RM Site.
2.8.6A.2 Overall Protection of Human Health and the Environment
Successful implementation of this alternative would reduce risks to human health and the environment
and meet the removal action objectives by (1) eliminating exposure of residents and trespassers to
waste material by direct contact and airborne migration, (2) eliminating exposure of trespassers to
direct contact with on-Site physical hazards, and (3) further reduce the migration of contaminants to
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For treatment, contaminants within soil and slag would be physically bound or enclosed within a
stabilized mass (solidification), or chemical reactions would be induced between a stabilizing agent
and the contaminant to reduce its mobility (stabilization). The decontaminated building debris would
be taken offsite to a metal recycling facility. The components of this alternative are outlined as
below:
» Decontamination and demolition of buildings;
Recycling of metal building debris;
Excavation of principal-threat contaminated soil (500 CY), landfilled slag (10;000 CY),
and non-principal threat landfill soil (6,500 CY) to allow access to landfilled slag'
(Excavation of an additional 8,200 CY of principal-threat contaminated sediment and
1,100 CY of non-principal threat contaminated sediment if contaminated wetlands
sediments are excavated and consolidated with surface soils for final disposition);
Stabilization or solidification of principal-threat contaminated soil, stockpiled slag, and
landfilled slag (about 32,700 tons; 45,000 tons if principal-threat wetlands sediments are
included);
Excavation of on-Site disposal area (450 ft long by 250 ft wide by 5 ft deep) in landfill
area;.
Compaction of 23,825 CY of waste material; assuming a 5% increase in volume of
principal-threat material due to stabilization/solidification, and no increase in volume of
non-principal threat material (33,535 CY of waste material if contaminated wetlands
sediments are excavated and consolidated with surface soils for final disposition);
Installation of 1.5-ft-deep soil cushion over waste and treated material and low-level threat
material capped in place (20,300 CY);
Installation of geomembrane liner and geotextile over soil cushion (6.7 acres);
Soil cover (1 ft deep), topsoil cover (6 inches deep), and grass seeding over Site
(8 acres); and
Land use restrictions and security fencing.
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wetland sediment. For Option 1, the estimated capital cost is approximately $7,313,400, and the
estimated O&M cost is approximately $163,799. For Option 2, the estimated capital cost is
approximately $6,017,361, and the estimated O&M cost is approximately $163,799.
2.8.6A Alternative S-6 - Capping w/ Excavation & Onsite Treatment of
Principal Threat Waste
Option A - Onsite Disposal of Treated Principal Threat Waste
2.8.6A.1 Description
Alternative S-6 is similar to Alternative S-5 in that it also includes the excavation and treatment of
contaminated material via solidification/stabilization. However, Alternative S-6 differs from
Alternative S-5 in that treatment is limited to that material that is considered principal-threat. As
indicated in section 8.3, principal threat waste at the RM Site includes the landfiUed and stockpiled
slag, and approximately 500 CY of soil.
Option A for Alternative S-6 includes the demolition of most of the on-Site buildings. The main
office building would remain on Site. The building debris and pavement would be decontaminated
by steam/pressure cleaning. Onsite contaminated soil considered principal threat, and buried slag in
the landfill would be excavated and consolidated with the stockpiled slag. In addition, above the
RGO, contaminated soil from areas not covered by pavement, and non-principal-threat landfill soil
would be excavated for placement in the excavated onsite landfill along with the treated principal-
threat waste. This waste (and treated) material would be disposed in the excavated landfill area (450
x 250 ft x 5 ft deep). A geosynthetic cap and underlying 1.5-ft soil cushion layer would be added
above the waste and existing landfill and would cover about 2.5 acres. A 1-ft soil cover and 6-inch
topsoil layer would be placed over the entire Site. The capped disposal area would rise
approximately 6 ft above ground surface.
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2.8.5B.7 Implementability >.
Treatment of contaminated soil and slag is offered by numerous vendors. On-Site treatment utilizes
standard construction practices and material handling equipment. No significant construction issues
are expected to be encountered.
Treatment of the contaminated waste will likely increase the volume of waste soil and slag material;
however, a slight volume reduction may occur if a chemical reagent is used to treat the material.
Typical volume increases range from about 5 percent to as high as 100 percent, depending upon the
treatment methodology used. An increase in the volume of the treated waste material will have an
impact on the transportation costs to a disposal facility. Calculations used in the development of this
alternative assume a volume increase of 20 percent.
Wastewater may be generated during implementation of this alternative through water runoff
generated as a result of dust emission control. Wastewater may also be generated as a result of
decontamination activities required for both equipment and on-Site workers. Containment and
treatment or disposal of these wastewaters may be required. Depending upon the treatment
methodology selected, the wastewater may be able to be utilized in the soils treatment process.
No state or federal permits are expected to be required; however, advance consultation should occur
in planning the action to ensure that all involved agencies are allowed to provide input.
All services and materials for this alternative are readily available.
2.8.5B.8 Cost
The total present worth for Alternative S-5B is approximately $7,477,199 for Option 1, which
includes the excavated wetlands sediment, and $6,181,160 for Option 2, which does not include the
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1 6,000 CY of stockpiled and landfffled slag would be considered "principal-threat" waste. This
alternative meets EPA's expectation to use treatment to address the principal threats posed by a site
by treating all the contaminated soil, sediment, and slag. However, treatment of what would be
considered low-level threat waste does not meet EPA's expectation to use containment to address
such waste, although in some situations, treatment rather than containment of low-level threats is
warranted (EPA 1991).
2.8.5B.6 Short-Term Effectiveness
The construction phase of this alternative would likely be accomplished within one field season;
therefore, impacts associated with construction would likely be short term and minimal. Short-term
impacts are associated with excavation, consolidation and treatment of waste soil and slag; however,
these potential, short-term impacts would be mitigated during the construction phase
If the excavated material is dry, on-Site workers will be exposed to waste soil and slag dust during
excavation and consolidation activities. Additional exposure to lead dust may occur during the
decontamination and demolition of building structures and pavement. Ingestion of dust could involve
some health effects because of the high level of metals in waste soil and slag.
On-Site workers would be adequately protected from short-term risks by using appropriate personal
ProtectiveequipmentandbyfollowingProperoperatingandsafetyProcedures.However,short.term
air quality impacts to the surrounding environment may occur during waste consolidation and
grading. Monitoring ofdust emissions would be monitored at theproperty boundaries. Fugitive dust
emissions would be controlled by applying water as needed to surfaces receiving heavy vehicular
trafficorinexcavationareas.Ameasurable,shoil-tenninpacttothesurroundingareawouldinclude
increased vehicular traffic and associated safety hazards, potential dust generation, and noise.
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2.8.5B.3 Compliance with ARARs
All action-specific ARARs are expected to be met. The TAPCR dust suppression and control
requirements (Rule 1200-3-8) apply to earth-moving activities associated with this alternative. If
remedial equipment is used on Site, such as a pugmill mixer or crusher, dust and vapors generated
from the use of this equipment will be contained and treated before being discharged to the
atmosphere, if required. ARARs for the control of fugitive dust emissions would be met by applying
water to roads receiving heavy vehicular traffic and to excavation areas, as necessary.
2.8.5B.4 Long-Term Effectiveness and Permanence
Treatment and removal of the waste material would not require monitoring, inspection, or
maintenance for the Site. Treatment reagents are typically tested by MEP SW-846 Method 1320 to
measure long-term stability. The test is intended to approximate teachability under acidic conditions
over a 1,000-year time frame. Based on successful completion of bench-scale testing that would
include MEP analysis, this alternative is expected to provide adequate long-term effectiveness and
permanence. Access restrictions such as land use controls and fencing would likely not be required.
2.8.5B.S Reduction of M/T/V Through Treatment
The primary objective of this alternative is to reduce contaminant toxicity and mobility through
treatment; contaminant volume would not be physically reduced. Contaminant toxicity would be
reduced by altering the physical or chemical structure of the contaminant into a nonhazardous
material. Contaminant mobility would be reduced by binding or bonding the contaminant into a
nonleachable form. Subsequent removal would mitigate contaminant migration from the Site.
Contaminant volume would not be physically reduced under this alternative.
Based on sample results collected during previous Site investigations, 600 CY of surface soil and the
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(about 60,150 tons; or 78,750 tons if excavated wetlands sediment are consolidated with
surface soil for final disposition);
Off-Site disposal at nonhazardous disposal facility (63,158 tons assuming a 5 percent
increase in volume during treatment; 82,688 tons if excavated wetland sediment is
included); and
• Bacfill excavation, soil cover (1 ft deep), topsoil cover (6 inches deep), and grass seeding
over Site (8 acres).
Alternative S-5B would eliminate direct contact with contaminated media, eliminate on-Site physical
hazards, and eliminate contaminant migration to groundwater and surface water from the Site.
Deed restrictions may be placed on the Site while the remedial action takes place. Monitoring would
be required to assess effectiveness of the remedial action.
2.8.5B.2 Overall Protection of Human Health and the Environment
Successful implementation of this alternative would eliminate risks to human health and the
environment and meet the removal action objectives by (1) eliminating exposure of residents and
trespassers to waste material by direct contact and airborne migration, (2) eliminating exposure of
trespassers to direct contact with on-Site physical hazards, and (3) eliminating the migration of
contaminants to groundwater and surface water. The threat of direct human exposure to
contaminated waste and physical hazards would be eliminated by this alternative. Treatment and
removal of the waste material would eliminate contaminant exposure through the receptor routes of
ingestion and inhalation. Contaminated soil and slag would be treated and convened to a
nonhazardous material and transported to an off-Site disposal facility. Structures throughout the Site
would be demolished and either disposed of in an excavated disposal area beneath the existing
pavement or recycled. As a result, physical hazards associated with deteriorating structures would
be eliminated. Removal of waste would mitigate contaminant migration from the Site.
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estimated O&M cost is approximately $163,799. For Option 2, the estimated capital cost is
approximately $4,081,193, and the estimated O&M cost is approximately $163,799.
2.8.5B Alternative S-5 - Excavation And Onsite Treatment With Solidification/Stabilization
Option B - Offsite Disposal of Treated Material
2.8.5B.1 Description
Option B for Alternative S-5 is similar to Option A in that it also consists of the decontamination and
demolition of most of the on-Site pavement and buildings and on-Site treatment. The main office
building and the pavement immediately surrounding this building would remain on Site. The building
debris and pavement would be decontaminated by steam cleaning. The decontaminated building
debris would be taken off Site to a metal recycling facility. Contaminated soil throughout the Site,
and buried slag in the landfill would be excavated and consolidated with the stockpiled slag.
Contaminants in soil and slag would be physically bound or enclosed within a stabilized mass
(solidification), or chemical reactions would be induced between a stabilizing agent and the
contaminants to reduce mobility (stabilization). Solidification/stabilization treatment technologies
include the addition of cement, lime, pozzolan, or silicate-based additives or chemical reagents that
physically or chemically react with the contaminant. Option B differs from Option A in that after
treatment and confirmation that the soil is nonhazardous, the treated soil and slag would be hauled
off Site to a disposal facility. A 1.0-ft soil cover and a 6-inch topsoil layer would be placed over the
entire Site. These components ase outlined as follows:
• Decontamination and demolition of pavement and buildings; *
• Recycling of metal building debris;
• Excavation of contaminated soil (21,875 CY), and landfilled slag (10,000 CY); *
• Stabilization or solidification of contaminate^ soil, stockpiled slag, and landfilled slag 4fe
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the material. Typical volume increases range from about 5 percent to as high as 100 percent,
depending upon the treatment method used. An increase in the volume of the treated waste material
will have an impact on the disposal volume required. Calculations used in the development of this
alternative utilized a volume increase estimate of 20 percent.
The dimensions of the Site property are about 450 by 800 feet, including the existing landfill. The
waste storage capacity required for this alternative is 49,150 CY assuming a 20 percent volume
increase of the treated material. To meet the SWDP buffer zone siting standards, the excavation area
would be 700 by 250 feet, and with an 8-ft average depth, depending on the thickness of the clay unit.
The disposal area would be located beneath the existing pavement.
Wastewater may be generated during implementation of this alternative through water runoff
generated as a result of dust emission control. Wastewater may also be generated as a result of
decontamination activities required for equipment and on-Site workers. Containment and treatment
or disposal of these wastewaters may be required. Depending upon the treatment methodology
selected, the wastewater may be able to be utilized in the soils treatment process.
The on-Site disposal area for the treated waste may he classified as a Class II disposal facility. If so,
the substantive requirements of the SWPD rule regarding Class II disposal facilities would apply to
the Site.
»
All services and materials for this alternative are readily available. •
2.8.5A.8 Cost
The total present worth for Alternative S-5A is approximately $4,907,274 for Option 1, which
includes the excavated wetlands sediment, and $4,244,992 for Option 2, which does not include the
wetland sediment. For Option 1, the estimated capital cost is approximately $4,743,474, and the
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2.8.5A.6 Short-Term Effectiveness
The construction phase of this alternative would, likely be accomplished within one field season;
therefore, impacts associated with construction would likely be short term and minimal. Short-term
impacts are associated with excavation, consolidation, and treatment of waste soil and slag; however,
these potential, short-term impacts would be mitigated during the construction phase.
If the excavated material is dry, on-Site workers will be exposed to waste soil and slag dust during
excavation and consolidation activities. Additional exposure to lead dust may occur during the
decontamination and demolition of building structures and pavement. Ingestion of dust could involve
some health effects because of the high level of metals in waste soil and slag.
On-Site workers would be adequately protected from short-term risks by using appropriate personal
protective equipment and by following proper operating and safety procedures. However, short-term
air quality impacts to the surrounding environment may occur during waste consolidation and
grading. Dust emissions would be monitored at the property boundaries. Fugitive dust emissions
would be controlled by applying water as needed to surfaces receiving heavy vehicular traffic or in
excavation areas. A measurable, short-term impact to the surrounding area would include increased
vehicular traffic and associated safety hazards, potential dust generation, and noise.
2.8.5A.7 Implementability
Treatment of contaminated soil and slag is offered by numerous vendors. On-Site treatment utilizes
standard construction practices and material handling equipment. No significant construction issues
are expected to be encountered.
Treatment of the contaminated waste will likely increase the volume of the waste soil and slag
nrnterial;however,shghtvoliimereductionsW^
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animals. However, the cover would be periodically inspected, and required maintenance could be
implemented.
If the RM Site is not classified as a Class II disposal facility; monitoring, inspection, and maintenance
may not be required. Treatment reagents are typically tested by the Multiple Extraction Procedure
(MEP, SW-846 Method 1320) to measure long-term stability. The test is intended to approximate
teachability under acidic conditions over a 1,000-year time frame. Based on successful completion
of bench-scale testing that would include MEP analysis, this alternative is expected to provide
adequate long-term effectiveness and permanence. Access restrictions such as land use controls and
fencing may be required to prevent land uses incompatible with the Site.
2.8.5A.5 Reduction of M/T/V Through Treatment
The primary objective of this alternative is to reduce contaminant toxicity and mobility through
treatment; contaminant volume would not be reduced. Contaminant toxicity would be reduced by
altering the physical or chemical structure of the contaminant into a nonhazardous material.
Contaminant mobility would be reduced by binding or bonding the contaminant into a nonleachable
form that would eliminate contaminant migration from the Site. Contaminant mobility is expected
to be reduced to an extent that would result in overall risk reduction from all pathways and exposure
routes.
Based on sample results collected during previous Site investigations, 600 CY of surface soil and the
16,000 CY of stockpiled and landfilled slag would be considered "principal-threat" waste. This
alternative meets EPA's expectation to use treatment to address the principal threats posed by a site
by treating all the contaminated soil, sediment, and slag. However, treatment of what would be
considered low-level threat waste does not meet EPA's expectation to use containment to address
such waste, although in some situations, treatment rather than containment of low-level threats is
warranted (EPA 1991).
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defined by acreage and function); and
• sufficient information is available to make a reasonable determination with respect to these '
demonstrations.
The Protection of Wetlands Order (40 CFR 6) also requires that no adverse impacts to wetlands
result from a remedial action. Historical evidence suggests that the existing landfill was created in
a wetland. However, this area was not observed to contain standing water during sampling events
conducted in 1996 and 1997. It is not known whether the area of the existing landfill would be
classified as a wetland area.
The substantive requirements for stormwater discharges during construction activities as outlined by
the CWA are relevant and appropriate. However, a specific NPDES permit is not required for this
removal action.
All action-specific ARARs are expected to be met. The Tennessee Air Pollution Air Control
Regulations (TAPCR) dust suppression and control requirements (Rule 1200-3-8) apply to earth-
moving activities associated with this alternative. If remedial equipment is used on Site such as a
pugmill mixer or crusher, dust and vapors generated fromthe use of this equipment will be contained
and treated before being discharged to the atmosphere, if required. ARARs for the control of fugitive
dust emissions would be met by applying water to roads receiving heavy vehicular traffic and to
excavation areas, as necessary.
2.8.5A.4 Long-Term Effectiveness and Permanence
If the disposal area is classified as a Class II disposal facility, the area may have to be maintained to
ensure that it continues to perform as designed; consequently, monitoring, inspection, and
maintenance would be required. The soil cover area would be susceptible to settlement, ponding of
surface water, erosion, and disruption of cover integrity by deep-rooting vegetation and burrowing
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o
actions upon floodplains, and to preserve and enhance the natural values of floodplains. Specifically,
when it: is apparent that a proposed or potential Agency action is likely to impact a floodplain or
wetlands, the public should be informed through appropriate public notice processes. Furthermore,
if a proposed action is located in or affects a floodplain or wetlands, a floodplain/wetlands assessment
shall be undertaken, and a statement of findings explaining why the proposed action must be located
in or affect the floodplain or wetlands.
Regarding construction activities related to implementing the alternative, 40 CFR 6 Appendix A
requires that EPA-controlled structures and facilities must be constructed in accordance with existing
t
criteria and standards set forth under the NFIP and must include mitigation of adverse impacts
wherever feasible, including the use of accepted floodproofing and/or other flood protection
measures. To achieve flood protection, EPA shall wherever practicable, elevate structures above the
base flood level rather than filling land.
Wetlands are located to the north and northeast of the facility and landfill, although these locations
are not identified on NWI maps. The SWPD rule requires that new landfills and lateral expansions
shall not be located in a wetlands, unless the owner or operator can make the following
demonstrations:
the presumption of a practicable alternative that does not involve wetlands is clearly
rebutted;
the construction/operation of the landfill will not cause or contribute to violations of
applicable State water quality standards, any applicable toxic effluent standard or
prohibition under Section 307 of the CWA, and will not cause or contribute to the taking
of any endangered or threatened species or result in the destruction or adverse
modification of critical habitat of endangered or threatened species;
the landfill will not cause or contribute to significant degradation of wetlands;
to the extent required under Section 404 of the CWA or Tennessee Water Pollution
Control Act, steps have been taken to attempt to achieve no net loss of wetlands (as
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decontamination would eliminate contaminant migration from the Site.
2.8.5A.3 Compliance with ARARs
The State of Tennessee SWPD rules are potentially applicable. The State may classify the on-Site
disposal area for treated waste as a Class II (industrial waste) landfill facility. Class II facilities must
meet the same requirements as Class I (solid waste) disposal facilities unless a waiver of one or more
of the standards is obtained as set forth in SWPD Rule 1200-l-7-.01(5). Class I standards include
requirements for landfill liners, geologic buffers, leachate collection systems, and other requirements -
that may not be necessary for the RM Site to be protective of human health and the environment.
The SWPD rule also includes buffer zone standards for Class II facilities. These standards require
that new facilities be located so that fill areas are, at a minimum, 100 feet from all property lines and
500 feet from all residences unless the owner agrees in writing to a shorter distance. A disposal area
that is constructed to be about 700 feet by 250 feet would likely meet both the buffer zone and
capacity requirements for the RM Site.
The RM Site is located in a 100-year floodplain within a zone designated as A3, indicating that base
flood elevations and flood hazard factors have been determined for this area. The SWPD rule (Rule
1200-1 -7) and the Criteria for Classification of Solid Waste Disposal Facilities and Practices (40 CFR
257) require that disposal facilities must not be located in a 100-year floodplain, unless both of the
following can be demonstrated:
• Location in the floodplain will not restrict the flow of the 100-year flood nor reduce the
temporary water storage capacity of the floodplain; and
• The facility is designed, constructed, operated, and maintained to prevent washout of any
solid waste.
In addition, EPA's regulations (40 CFR Part 6, Appendix A)for implementing Executive Order 11988
(Floodplains Management) requires federal agencies to avoid or minimize adverse impacts of Federal
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SOUTH
DEPTH AT WHICH
GROUNDWATER ENCOUNTERED
WRECKER
BUILDING
NORTH
SURFACE DEPOSITION OF
LEAD CONTAMINATED DUST,
SOILS, AND SEDIMENT
1' ABOVE GROUND LEVEL
F-
T
R
4 .. . • -•*.'*• V 9' TREATED MATERIAL * . . & • . ." - ' . •> ' '
'':••''•• v«v'%:'.• :•••'• ••-';•'-."-••.> ^V'-v:^
'"I"" I " I I I I I I I I i i i i Ti * i i f ii i ---j 1 M- ; <. . >-
L.
a
DEPTH AT WHICH —-^
GROUNDWATER ENCOUNTERED
NOTE: Concepluol dastgn. Fodwd, slots, end loeol
r«juiremenU regarding conalrucllon lit a floodplota
must bo considered and may offset design
Repr«j*nlollon of woilo moltrlol Includes excavated
wellond sediments.
NOT TO SCALE
•11*
APPROXIMATE DIMENSIONS OF EXCAVATION: TOTAL DEPTH (BELOW GROUND SURFACE) - 8 FT.
TOTAL HEIGHT (ABOVE GROUND SURFACE) - 4.5 FT.
LENGTH - 700 FT.
WIDTH - 250 FT.
Ross Metals Site
Rossville, Tennessee
CDM Federal Programs Corporation
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Figure 2-27 illustrates the component of the on-Site disposal area included under Alternative S-5 A.
Treatability testing may be required to demonstrate contaminant immobilization for this treatment
process and to help determine the volume increase caused by the solidification/stabilization process.
One treatability study to evaluate stabilization reagents that would 1) reduce the teachability of lead
in treated woodland sediment and 2) improve the material handling qualities of the sediment so that
free liquids are not released during transport or disposal was completed in March 1998 (EPA 1998).
The results of that study demonstrated that a biosolid product produced by N-Viro effectively
reduced the leachibility of lead, absorbed free liquids and resulted in a material that could be
excavated and transported for disposal.
Deed restrictions may be placed on the Site while the remedial action takes place. Monitoring would
be required to assess the effectiveness of the remedial action.
2.8.5A.2 Overall Protection of Human Health and the Environment
Successful implementation of this alternative would eliminate risks to human health and the
environment and meet the removal action objectives by (1) eliminating exposure of residents and
trespassers to waste material by direct contact and airborne migration, (2) eliminating exposure of
trespassers to direct contact with on-Site physical hazards, and (3) eliminating the migration of
contaminants to groundwater and surface water. The threat of direct human exposure to
contaminated waste and physical hazards would be eliminated by this alternative. Treatment of the
waste material would eliminate contaminant exposure through the receptor routes of ingestion and
inhalation. Contaminated soil and slag would be treated and converted to a nonhazardous material.
Structures throughout the Site would be demolished and either disposed of in an excavated disposal
area beneath the existing pavement or recycled. As a result, physical hazards associated with
deteriorating structures would be eliminated. Waste immobilized by treatment or removed by
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Once treated and confirmed to be nonhazardous, the soil and slag would be consolidated with the
pavement debris and disposed of in an on-Site, unlined excavation. The decontaminated building
debris would be taken off Site to a metal recycling facility. The onsite disposal area would extend
from the northern boundary of the existing landfill to about 100 feet north of the Site entrance and
would be about 700 feet long, 250 feet wide and 8 feet deep. A 3.0-ft soil cover consisting of
uncontaminated soil excavated from the disposal area and a 6-inch topsoil layer would be placed over
the entire Site. The total height of the capped area would be approximately 4.5 feet. The
components of this alternative are outlined as follows:
• Decontamination and demolition of pavement and buildings;
• Recycling of metal building debris;
Excavation of contaminated soil (21,875 CY) and landfilled slag (10,000 CY);
• Stabilization or solidification of contaminated soil, stockpiled slag, and landfilled slag
(about 60,150 tons or 78,750 tons if excavated wetlands sediment are consolidated with
surface soil for final disposition);
• Excavation of on-Site disposal area (700 ft long by 250 ft wide by 8 ft deep);
Compaction of 40,817 CY of waste material (52,771 CY of waste material if wetland
sediment is included); assuming a 5% increase in volume due to stabilization/solidification;
Soil cover (3.0 ft deep), topsoil cover (6 inches deep), and grass seeding over Site (8
acres);
• Land use restrictions and security fencing.
Alternative S-5 would eliminate direct contact with contaminated media, eliminate on-Site physical
hazards, and eliminate contaminant migration to groundwater and surface water from the Site. The
final treatment system would depend upon the outcome of treatability testing and would be
determined during the remedial design phase. The fixed material would be subjected to TCLP testing
to determine if treatment has been effective, prior to placement in the excavated disposal area.
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No state or federal permits are expected to be required; however, advance consultation should occur
while planning the action to ensure that all involved agencies are allowed to provide input.
All services and materials for this alternative are readily available.
2.8.4.8 Cost
The total present worth for Alternative S-4 is approximately $ 1,506,847 for Option 1, which includes
the excavated wetlands sediment, and $1,481,865 for Option 2, which does not include the wetland
sediment. For Option 1, the estimated capital cost is approximately $1,346,951, and the estimated
O&M cost is approximately $159,895. For Option 2, the estimated capital cost is approximately
$1,321,970, and the estimated O&M cost is approximately $159,895.
2.8.5A Alternative S-5 - Excavation And Onsite Treatment With Solidification/Stabilization
Option A - Onsite Disposal of Treated Waste
2.8.5A.1 Description
Option A for Alternative S-5 includes the decontamination and demolition of most of the on-Site
pavement and buildings. The main office building and the pavement immediately surrounding this
building would remain on Site. The building debris and pavement would be decontaminated by
steam/pressure cleaning. Contaminated soil throughout the Site, and buried slag in the landfill would
be excavated and consolidated with the stockpiled slag. Contaminants within soil and slag would be
physically bound or enclosed within a stabilized mass (solidification), or chemical reactions would be
induced between a stabilizing agent and the contaminant to reduce its mobility (stabilization).
Solidification/stabilization treatment technologies include the addition of cement, lime, pozzolan, or
silicate-based additives or chemical reagents that physically or chemically react with the contaminant.
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Site conditions does not suggest that these situations would apply to the RM Site.
2.8.4.6 Short-Term Effectiveness
The construction phase of this alternative would likely be accomplished within one field season;
therefore, impacts associated with construction would likely be short-term and minimal. Short-term
impacts are associated with excavation and consolidation of waste soil and slag; however, these
potential, short-term impacts would be mitigated during the construction phase.
If the excavated material is dry, on-Site workers will be exposed to waste soil and slag dust during
excavation and consolidation activities. Additional exposure to lead dust may occur during building
structure and pavement demolition. Ingestion of dust could involve some health effects because of
the high level of metals in waste soil and slag.
On-Site workers would be adequately protected by using appropriate personal protective equipment
and by following proper operating and safety procedures. However, short-term air quality impacts
to the surrounding environment may occur during waste consolidation and grading. Dust emissions
would be monitored at the property boundaries. Fugitive dust emissions would be controlled by
applying water to surfaces receiving heavy vehicular traffic or in excavation areas, as needed. A
measurable, short-term impact to the surrounding area would include increased vehicular traffic and
associated safety hazards, potential dust generation, and noise.
2.8.4.7 Implementability
Construction of a geomembrane surface cap is a standard construction practice. Other than capping
contaminated material in a floodplain, no significant construction issues are expected to be
encountered.
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f
Table 2-23
Capital Coses for Selected Remedy
-j ITEM DESCRIPTION
SITE DECONTAMINATION/DEMOLITION
Building Demolition
Concrete/Asphalt Demolition
Building Demolition
Pavement Demolition
Recycling Metal Debris
loading and transportation
payment from recycling
Equipment
EXCAVATION
Soil and Sediment Excavation
(9.300+ 1 3. 125+8.750+2.500)
Dust Control & Placement in Staging Areas
(2 water trucks- each @S3 .500/rnomh)
Etcavau'on of Landfilled Slag
Excavation Monitoring
ON-SITE TREATMENT
Treatabilily Study
Treatment
~- {33.675 CYxl.5 + 16.000CYx2)
Treatment System Monitoring
Off-Site Disposal of Non-hazardous Material
(Assume 5% increase)
Backfill Landfill and sub-surface areas w/Clean Fill
(10,000+8.750+2.500)
Installation ot'Biosolids Throughout Site
Installation of Vegetative Cover on Facility Area
Plant Emergent Forested Area
Plant Forested Wetland Area
EQUIPMENT &. MATERIALS
Erosion Control
Health and Safely Equipment (30 people ©
$60/person/day) «•*••=>
UNITS
each
cf
<*
sf
sf
Ion
lump sum
cy
month
V
sample
lump sum
ton
sample
Ion
cy
acres
acre
acre
acre
*
day
QUANTITY
1
27.000
21.333
126.000
192.000
1.500
1.500
1
33.675
3
10.000
45
1
82.513
50
86,639
22,250
14
8
3
3
500
90
UNIT PRICE
DOLLARS
$30,000
$0.23
SIOJ7
$0.75
SO.S5
S20
$50
$25.000
S5
$7,000
S2
$500
$50.000
30
$500
$30.000
$10
$12.000
£2,000
$3,500
$5,500
$2.14
$1.800
Subtotal - Capital Cost
TOTAL COSTS
DOLLARS
$80,000
$6,210
$221,223
$94,500
$163,200
-$45,000
$25.000
$168,375
S2 1.000
S20.000
S22.500
$50,000
32.475,375
$25,000
$2.599.160
$222.500
$168.000
$16,000
$10,500
$16,500
$1,070
$162.000
56,523,113
Engineering* Administrative (3% of Capita! Cost) „._, „,
Subtotal
$6.718,806
Contingency ( 1O% of Subtotal)
tal CoBstructioa Cost
S7J90.6S7
[i .esent Worth O&M Cost
Tool Present Worth
. ___ __ 57,420,732
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ITEM DESCRIPTION
Wetlands and Lawn
Inspection
Wetlands and Lawn
Maintenance
Mowing: 8 Ac x 43.560 SF;
Fertilizing: 14 Acx 43.560
SF
Table 2-24
Operation and Maintenance Costs for Selected Remedy
UNITS
inspection
l.OOOSF
1,000 SF
QUANTITY
2/yr
5/yr
2/yr
UNIT PRICE
DOLLARS
$500
SI. 78
$2.10
TOTAL
ANNUAL COST.
DOLLARS
$1.000
3.101
2.561
OPERATION
TIME,
YEARS
5
5
5
PRESENT
WORTH
$4,100
12.714
10,500
Subtotal S5.662 $27,314
Contingency (10% of S566 S">731
Subtotal)
Total S6.228 $30,045
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groundwater; restore impacted wetland communities and prevent further degradation of the adjacent
wetlands. The remedy shall address all soils contaminated with contaminants of concern in excess
of their corresponding risk-based cleanup level. Since no Federal or State ARARs exist for
soil/sediment, the action levels were determined through a Site-specific risk analysis. Remediation
activities shall be monitored to ensure that clean-up levels are achieved. The Site is expected to be
available for industrial/residential/recreational land use as a result of the remedy.
2.12 STATUTORY DETERMINATIONS
Under CERCLA Section 121, EPA must select remedies that are protective of human health and the
environment, comply with applicable or relevant and appropriate requirements (unless a statutory
waiver is justified), are cost-effective, and utilize permanent solutions and alternative treatment
technologies or resource recovery technologies to the maximum extent practicable. In addition,
CERCLA includes a preference for remedies that employ treatment that permanently and significantly
reduces the volume, toxicity, or mobility of hazardous wastes as a principal element. The following
sections discuss how the selected remedy meets these statutory requirements.
2.12.1 Overall Protection of Human Health and the Environment
EPA's Selected Remedy protects human health and the environment through the excavation and
immobilization of lead-contaminated media followed by off-Site disposal.
Cancer risks, non-cancer risks and lead exposure to human receptors for future use at the Site will
be eliminated. The exposure levels will be reduced to within EPA's acceptable risk range of 10-4 to
10-6 for carcinogens; below the HI of 1 for noncarcinogens; and below EPA's acceptable blood lead
level of 10 ug per deciliter for lead. Protection of human health will be achieved by excavating,
treating, and shipping off-Site the soils, sediments, and wastes which pose future risks to a lifetime
resident, child resident, adult resident, and site worker.
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Acute and chronic risks to ecological receptors are mitigated. The exposure levels will reduced
below the HI of 1 for noncarcinogens.
f
2.12.2 Compliance with Applicable or Relevant and Appropriate Requirements (ARARs)
The selected remedy shall be in compliance with all Federal ARARs and any more stringent State
ARARs. It is important to note that the Selected Remedy is the only practicable alternative outside
the floodplain.. Executive Order 11988 - Floodplain Management emphasizes the importance of
evaluating alternatives to avoid effects and incompatible development in the floodplains; and those
alternatives located in the floodplain may not be selected unless a determination is made that no
practicable alternatives exist outside the floodplain. The Selected Remedy is considered a practicable
alternative outside the floodplain. The selection of any other alternative would require a floodplains
assessment and following methods to minimize potential harm to the floodplain.
The following ARARs will be attained by the selected remedy:
Action-Specific:
• RCRA requirements for identification, management and transportation of hazardous waste (40
CFR 261, 262 and 263).
• RCRA requirements pertaining to the land disposal of particular hazardous wastes (40 CFR
268).
Clean Water Act exceptional quality sludge criteria (40 CFR 5 03) for regulating sludge and sets
criteria for the safe use of sludge-derived products.
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Location-Specific:
• Protection of Wetlands and Floodplains are EPA regulations for implementing Executive Orders
11988 and 11990 (40 CFR Part 6, Appendix A).
L
RCRA requirements for hazardous waste facility locations (40 CFR 264).
Regulations Governing Solid Waste Processing and Disposal in Tennessee, Chapter 1200-1-7
establishes specific requirements for the operation and maintenance of solid waste landfill
disposal sites,
Tennessee Air Pollution Control Act, Chapter 1200-3-6 and 1200-3-8 sets nonprocess emission
standards and regulates fugitive dust emissions.
Other Criteria. Advisories, or Guidance To Be Considered (TBCs):
Floodplain Management Executive Order 11988 for avoiding adverse effects, minimize
potential harm, and restore and preserve natural and beneficial values of the floodplain.
Wetlands Management Executive Order 11990 for minimizing the destruction, loss or
degradation of wetlands.
Test Methods for Evaluating Solid Waste Physical/Chemical Methods, SW-846, 3rd Edition,
latest update, Chapter 9.
Methods for Evaluating the Attainment of Cleanup Standards Volume 1: Soils and Solid Media,
U.S. EPA.
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Guidance for Hazardous Waste Site Investigation, EPA QA/G-4HW.
2.12.3 Cost-Effectiveness
EPA's Selected Remedy is cost-effective and represents a reasonable value for the money to be spent.
In making this determination, the following definition was used: "A remedy shall be cost-effective if
its costs are proportional to its overall effectiveness." (40 CFR 300.430(f)(l)(ii)(D). This was
accomplished by evaluating the "overall effectiveness" of those alternatives that satisfied the threshold
criteria (i.e., were both protective of human health and the environment and ARAR compliant).
Overall effectiveness was evaluated by assessing three of the five balancing criteria in combination
(long-term effectiveness and permanence; reduction in toxicity, mobility, and volume through
treatment; and short-term effectiveness). Overall effectiveness was then compared to costs to
determine cost effectiveness. The relationship of the overall effectiveness of this remedial alternative
was determined to be proportional to its costs and hence represent a reasonable value for the money
to be spent.
For this Site, Alternative S-l is not cost-effective because it would not result in any reduction of the
toxicity, mobility, or volume of wastes nor would it be effective in the long-term at reducing site risks
in a permanent manner. Alternatives S-2, S-3, and S-4 were not considered to be cost-effective as
they would not result in treatment of principal threat waste and reduction of toxicity and volume is
not realized. Alternatives S-5A/B and S-6A/B were determined to be cost-effective. In evaluating
the incremental cost-effectiveness of these alternatives, the decisive factors considered were the time
frame required to construct the remedy, the time frame in which the remedial goals will be achieved,
long-term effectiveness and compliance with ARARs. EPA believes that the additional money
required to implement Alternatives S-5B merits the overall effectiveness of the remedy and represents
the best value for the money to be spent.
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2.12.4 Utilization of Permanent Solutions and Alternative Treatment (or Resource Recovery)
Technologies to the Maximum Extent Practicable
EPA has determined that the Selected Remedy represents the maximum extent to which permanent
solutions and treatment technologies can be utilized in a cost-effective manner for this Site. Of those
alternatives that are protective of human health and the environment and comply with ARARs, EPA
has determined that the Selected Remedy provides the best balance of tradeoffs in terms of the five
balancing criteria, while also considering the statutory preference for treatment as a principal element
and considering State and community preference.
The Selected Remedy treats the principal threats posed by the Site, achieving significant reductions
in toxiciry and mobility. Off-Site disposal will not require extensive monitoring, inspection, or
maintenance for the Site as compared to the other on-Site disposal alternatives. The other
alternatives considered would all require long-term monitoring, inspection and maintenance. The
capping alternatives would be susceptible to settlement, ponding of surface water, erosion and
disruption of cover integrity. The Selected Remedy satisfies the criteria for long-term effectiveness
by removing the source materials and stabilizing lead in contaminated media.
The Selected Remedy reduces toxicity, mobility, but not volume through treatment. There are no
short-term threats associated with the Selected Remedy that cannot be readily controlled. There are
no special implementability issues that sets the Selected Remedy apart from any of the other
alternatives evaluated. In fact, the administrative and technical issues associated with siting a landfill
in a floodplain will make the other alternatives considered more difficult to implement than the
Selected Remedy.
2.12.5 Preference for Treatment as a Principal Element
By treating the contaminated soils, sediment and slag through immobilization, the Selected Remedy
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addresses the principal threats posed by the Site. By utilizing treatment as a significant portion of the *"
Remedy, the statutory preference for remedies that employ treatment as principal element is satisfied.
2.12.6 Five-Year Requirements
Because this remedy will not result in hazardous substances remaining on-Site above health-based
levels, a five-year review will not be required for this remedial action.
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3.0 RESPONSIVENESS SUMMARY
The U.S. Environmental Protection Agency (EPA) held a public comment period fromNovember 18,
1998 to December 18,1998. An extension to the public comment period was requested. Asaresult,
it was extended to January 19,1998. The public comment period was held for interested parties to
comment on the Remedial Investigation/Feasibility Study (RI/FS) results and the Proposed Plan for
the Ross Metals Super-fund Site in Rossville, Tennessee.
The Proposed Plan included in Attachment A of this document, provides a summary of the Site's
background information leading up to the public comment period.
EPA held a public meeting at 6:30 pm on November 30, 1998 at the Rossville Christian Academy,
Rossville, Tennessee to outline the RI/FS and describe EPA's proposed remedial alternative for the
Ross Metals Site. All comment received during the public comment period have been considered in
the final selection of the remedial alternative.
3.1 RESPONSIVENESS SUMMARY OVERVIEW
During the public comment period, the Rossville community and local government officials expressed
their support of the EPA Selected Remedy. Four letters by the community were received during the
public comment period which supported the Selected Remedy. As evidenced in the November public
meeting transcript, the community and local government officials expressed their support of the
Selected Remedy during the meeting. Some of the major concerns expressed included the length of
time it is taking to clean up the Ross Metals Site and the length of time it may take to negotiate with
the PRPs to clean up the Site.
j
The PRPs submitted three different comment letters during the public comment period. In each of
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4»
these submittals, the PRPs disagreed with EPA's Selected Remedy. The main objection to EPA's
Selected Remedy is off-Site disposal.
f
3.2 SUMMARY OF MAJOR QUESTIONS AND COMMENTS RECEIVED BY THE
ROSSVILLE COMMUNITY
The public comments appear in bold text and the EPA response follows.
• EPA's Preferred Alternative, nor any of the other options, address the removal of lead-
contaminated sludge from Rossville Lagoon — Cell #1.
Comment acknowledged. EPA reviewed the waste-water treatment plant records and found sampling
results from Cell #1. It was determined by the State that the sludge in Cell #1 is non-hazardous.
Lead results ranged from 10 - 245 ppm. EPA's soil cleanup numbers for the Ross Metals Site are UK
400 ppm and 800 ppm. Lead results from the sludge are below EPA cleanup numbers.
EPA is considering the use of sludge from Cell #1 for use as backfill at the Ross Metals Site. EPA
will perform comprehensive sampling of Cell #1 to confirm the earlier lead results. Should the sludge
pass appropriate lead and other criteria, EPA with the City of Rossville's permission, will use this
material in the Superfund cleanup at Ross Metals. The City of Rossville would then be able to use
Cell #1 in their waste-water treatment system as they deem necessary.
3.3 SUMMARY OF MAJOR QUESTIONS AND COMMENTS RECEIVED BY THE
"GROUP" *
The Group's comments appear in bold text and the EPA response follows.
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An RI consistent with EPA protocols (EPA/540/-G-89/004) was not conducted.
• EE/CA investigation did not generate data sufficient to support an adequate FS or the
development of an RD.
• A pre-design investigation will be necessary as part of the RD stage to fill the data gaps.
• Existing data are not sufficient to estimate volumes of waste accurately.
EPA disagrees with these comments. The EE/CA investigation focused on soils, slag and
groundwater contamination. The EE/CAprovided adequate data to support a decision for soils, slag,
buildings and equipment. In addition to the EE/CA, a human health risk assessment, an ecological
risk assessment which included additional soils/sediment characterization, a stabilization treatability
study, a dewatering treatability study, and a biosolids treatability study were performed. The totality
of this information has provided sufficient data and is consistent with the RI/FS process. As indicated
in the RI/FS, additional information is needed to characterize groundwater. Volumes of waste have
been accurately estimated. Graphics depicting the results of trenching operations during the
November 1996 field work were inadvertently left out of the RI/FS. The graphics will be included
in the next Administrative Record update. Pre-Design investigations are a routine part of the
Remedial Design process.
• The selected remedy is inconsistent with EPA policy, as defined in Land Use in
Superfund Remedy Selection. Future development of the Site for residential purposes
is prohibited because it is zoned light industrial. EPA should consider current zoning in
the selection of remedial action levels.
EPA does not agree with this comment. EPA has followed the Land Use Directive by considering
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the information presented below. *
The Site is currently zoned as general industrial. The zoning specifically states that "this district is ^
not intended to allow uses which may be considered hazardous because of the use of, or production
of, toxic or highly flammable materials." It is important to note that Ross Metals, a secondary lead
smelter, produced a hazardous waste and was located in this district.
The zoning does not prohibit residential development. The Site is currently located immediately
adjacent to residences with children. The Site has used been for agriculture and a community park
in the past.
The Town of Rossville has not been able to attract new industry in recent years and does not
anticipate new growth patterns. The Site is also physically bound by it's surroundings and location -
it is located in the 100-year floodplain, adjacent to wetlands, a waste-water treatment plant, fltt
residences, and a railroad.
EPA has had discussions with local land use authorities and community members regarding future
land use for the Ross Metals Site. They have strongly expressed their desire for the Site to be used
in the future for the community, e.g., a park. The Town of Rossville and Fayette County officials are
interested in the Town of Rossville obtaining the Site property deed.
• EPA's selection of a 400 ppm lead-in soil performance criterion for subsurface soil is not
based on site-specific data and should instead be based upon additional studies, to be
performed during the remedial design, that would determine whether 400 ppm lead ,,
leaches dissolved lead to groundwater above the action level for lead in groundwater.
EPA acknowledges this comment and agrees that modeling conducted during the pre-design effort
may indicate that a less conservative clean-up goal will be sufficient for protection of groundwater. jg^
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As indicated in the FS, a one-dimensional geochemical model was used to evaluate the migration of
lead in soil beneath the smelter slag and the migration of lead below the contaminated soil near the
wrecker building. The model suggested that the slag material is a potential source of contamination
to groundwater. The model predicted that lead will migrate to groundwater in six years and the
concentration of lead will exceed 15 ppb in 55 years. In addition, the geochemical model suggested
that soils near the wrecker building are acting as a continuing source of contamination to groundwater
and the lead concentration in groundwater will continue to increase unless the source is removed.
Model output indicated that removal of lead to 100 ppm left a residual concentration of 3.71 ppm,
which is near background levels, and predicts that a removal action level of 100 ppm would be
protective of groundwater for at least 90 years. However, the conservative nature of this number,
along with the uncertainty surrounding the modeling effort, make it inappropriate to use as a
subsurface cleanup goal. The 100 ppm goal is based on the assumption of a 5,000 ppm surface load
factor. However, the establishment of a 400 ppm risk-based surface soil clean-up goal would mean
surface soil concentrations no greater than 400 ppm With a surface soil concentration of 400 ppm
and considering the nature of contamination, clean up of subsurface soils to 400 ppm in the area of
the wrecker building and truck wash should allow for the protection of groundwater.
Have not determined conclusively whether there has been an impact to groundwater
quality in the shallow aquifer resulting from the residual lead in soil or from the presence
of residual slag.
EPA agrees. Please see above comment regarding the slag and soils near the wrecker building. In
addition, lead results in groundwater samples collected to date suggest that the Site has impacted
groundwater quality. However, as the RI/FS indicates, recent results from MW5 do not confirm
earlier (higher) sample results, and the high turbidity associated with unfiltered samples collected as
the Site means the horizontal extent of contamination may be much less than the current data indicate.
Further definition impact to groundwater will be completed as part of the Operable Unit No. 2 RI/FS.
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• No investigation to determine whether lead in wetlands is attributable to mobilization of
dissolved lead in shallow groundwater and discharge into the wetland areas.
EPA disagrees with this comment. As indicated in the RI/FS, primary mechanisms available for
contaminant transport away from the Site are (1) transport by rainwater runoff, (2) rainwater
infiltration to groundwater, and (3) windblown dust movement. Existing data in the wetlands clearly
indicates the wetlands have been impacted by the Site contaminants. The Operable Unit No. 2 will
provide data regarding to what extent, if any, groundwater contamination is migrating to the
wetlands.
• Remedial action objectives for surface soil containing lead and other metals should be
based on exposure scenarios provided in the Risk Assessment Guidance for Superfund
(EPA/540/1-89/002), and should be consistent with agency-approved cleanup goals at
other secondary smelting Superfund sites in EPA Region 4, where a soil remedial action MB
objective of 1,000 ppm has been selected (e.g., DLCO Superfund Site).
The Risk Assessment was completed in accordance with the framework provided in the Risk
Assessment Guidance for Superfund. The guidance does not provide specific site exposure scenarios
to use in the completion of a site risk assessment. Cleanup goals at the Ross Metals Site are primarily
a function of managing risk in consideration of site-specific characteristics, not other secondary lead
smelting sites. Also note, that of the 22 sample results (within the fenced facility) illustrated on
Figure 7-1 that are above 400 ppm, 18 are also above 1,000 ppm. Excavation areas and resulting
volumes proposed for the various alternatives would not change because of the need to either create
a sufficient excavation for on-Site disposal or adequate regrading/revegetation of the Site for off-Site »
disposal.
.jt
• Selected remedy was not based on the regulatory provision that a remedial action can
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consist of any combination of treatment, remedial action, engineering and institutional
controls.
EPA disagrees with this comment. In developing the alternatives, EPA considered a variety of
technologies and process options. Please see RI/FS Section 9.0 and 10.0 which screens and evaluates
technologies and process options; and develops the range of alternatives selected for the Ross Metals
Site. Also, it is important to ndte.that the Selected Remedy allows for stabilization, solidification,
fixation, or composting processes. These processes may be used in any combination for the Site soils
and waste to meet the land disposal regulations.
• A floodplain assessment per OSWER Directive 9280.0-02 that requires EPA to assess the
effects of proposed alternatives on floodplains and floodplain protection was not
conducted as part of the EPA site investigations, nor was it considered in the FS.
EPA acknowledges this comment. EPA believes the commenters have misunderstood the Floodplain
Management Executive Order 1198. EPA's Selected Remedy will not be located in a floodplain and
will therefore, not adversely effect the floodplain. An Assessment would have been necessary had
the Agency chosen a remedy located in the floodplain.
• Long-Term Effectiveness and Permanence - On-Site disposal alternative could be
considered more effective because the Group will maintain specific control and
management of the treated materials, whereas there would be no control for specific
wastes at off-Site facilities.
EPA disagrees with this comment. The Group proposes to maintain specific control of the treated
materials by establishing a trust fund for the City to conduct O&M at the Site; yet the current status
of the City's WWTP berm - as reported by the Group - has eroding banks. The Group's comment
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that they will maintain specific control and then the comment that they will create a trust fund for
others to implement the long-term operation and maintenance activities is a contradiction. In
addition, if the Group's assertion that the preferred alternative merely transfers risks from one Site
to another, then the Group's alternate remedy leaves that risk on Site, and limits rather than increases
the number of options the community has in redeveloping the Site. Finally, the off-Site disposal of
wastes would occur at facilities where appropriate controls are in place.
• Short-Term Effectiveness - The short-term risk of injury or fatality to workers and
community members is significant for off-Site disposal alternatives. In addition, there
is an increased exposure to residents to particulates, ozone, and carcinogenic compounds
known to occur in diesel fuel exhaust.
EPA disagrees with this comment. A Site-specific Health and Safety Plan will be required before
implementation of the Remedial Action. There are no short-term threats associated with the Selected
Remedy that cannot be readily controlled. EPA has considered the costs for implementing dust
control measures, erosion control, personal protection and off-Site disposal. Please see the cost
estimates provided in RI/FS Appendix O.
In addition to transportation risks associated with the off-Site disposal of materials from
the Site, concern exists about the future, potential long-term liabilities that would be
incurred by those parties that agree to implement an off-Site disposal remedy that
involves disposal of material at a facility operated and managed by an independent
company.
EPA acknowledges this comment. Pursuant to Section 107 of CERCLA, 42 U.S.C. § 9607, "any
person who by contract, agreement or otherwise arranged for disposal or treatment..." is liable as
a potentially responsible party. However, mitigating factors are contemplated in Section 107 which
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provides certain defenses including:
1. Act of God,
2. Act of War, and
3. An act or omission of a third party whose act or omission occurs in connection with a
contractual relationship.
It appears that the Group is concerned about acts or omissions of a third party (landfill operator) who
takes over custody of the waste once it is shipped off Site. In order to establish the third defense,
a pany must establish that (a) he exercised due care with respect to the hazardous "substances
concerned, and (b) he took precautions against foreseeable acts or omissions of any such third party.
The risks posed by the hazardous waste in question is substantially reduced because prior to disposal
the waste will be treated on Site and thereafter will be in a non-hazardous state. The act of reducing
the toxicity of the contaminants is indicative of the exercise of due care. Further, if the Group
carefully selects an authorized RCRA landfill that has been in operation for a respectable period of
time, this should help to establish that they took precautions against foreseeable acts or omissions of
the landfill operator. Regardless, some long term potential liability exists whether the waste is
transported off Site or remains on Site. Given the extra precautions that will be taken and the public
perception factor, disposal of the waste off Site does not necessarily pose more risk.
Cost - EPA's costs in the FS for off-Site disposal might be substantially underestimated.
The costs for off-Site disposal will increase proportionally to the volume of material
requiring transportation and disposal The on-Site containment alternative costs do not
increase directly with volume.
Several on-Site disposal remedies for source materials, each of which is equally or more
protective that EPA's proposed remedy, could be implemented at a lower cost than
EPA's proposed remedy.
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EPA acknowledges this comment. On-Site containment alternatives are equally affected by increase
in volume of material requiring disposal. The size of required excavation, amount of materials
handling, and height of the required cap are all affected by volume of material requiring disposal, and
therefore all affect costs. In addition, the Group's alternate remedy would include pre-design costs
related to implementing a cap in a floodplain, as well as costs associated with additional engineering
considerations associated with capping in a floodplain; hydrogeologic investigations to site a landfill;
and long-term operations and maintenance costs into infinity.
The RI/FS report indicates that while certain onsite disposal remedies may be as effective as the
preferred alternative in overall protection of human health and the environment, and could be
completed at lower cost, they are not as effective as the preferred alternative in achieving compliance
with long-term effectiveness, reduction in toxicity, mobility, and volume through treatment, and
short-term effectiveness. Cost effectiveness is not determined merely by cost. Cost effectiveness is
the costs proportionality to its overall effectiveness. Although the Selected Remedy will cost more
to implement, the decisive factors considered were the time frame to implement the remedy, the time
frame in which the remedial goals will be achieved, long-term effectiveness and compliance with
ARARs. The additional money required to implement the Selected Remedy merits the overall
effectiveness of the remedy and represents the best value for the money to be spent.
• State Acceptance - The State would accept the alternate remedy (on Site with
provisions).
• TDEC was prepared to approve Ross Metals request to construct an on-Site landfill
while the facility was in operation.
EPA disagrees with this comment. The commenters apparently missed portions of State and EPA
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records. Ross Metals was issued a Notice of Violation for the existing disposal site on June 16,1986.
The Notice of Violation required Ross Metals to either register the Site or to close it. The facility's
landfill predated RCRA Subtitle D and was therefore not subjected to its current requirements. Ross
Metals chose to apply for a permit and submitted an application. As was the practice at that time,
TDEC's Division Geologist conducted a preliminary Hydrogeologic Review of the Site and
determined that the Site may have been suitable for a landfill. On December 20,1988, Paul Patterson
of the Memphis DS WM Office notified Ross Metals that the review of their landfill application would
be suspended until the status of the slag could be determined. They filed a RCRA Part B Permit
Application November 8, 1988. The Permit was never approved.
EPA disagrees with the Commenter's assertion that the State would accept the alternative remedy
with provisions. As evidenced by the State's letter of concurrence, the State concurred with EPA's
selected remedy. The letter is included in Appendix B.
• The scoring approach described in the FS was used to compare the Alternative Remedial
Action (ARA) and EPA's preferred remedial alternative selected in the Proposed Plan.
Based on the scoring, consistent with the NCP evaluation criteria, the ARA scores higher
than or equal to EPA's preferred remedial alternative for each threshold and primary
balancing criterion. As a result and consistent with the NCP, on-Site placement of the
treated material is the preferred remedy, which is also consistent with EPA's EE/CA,
conducted in December 1997.
EPA disagrees with this comment. Soil Alternative 6A, as presented in the FS, is the most similar
y to the Group's alternative remedy, with the exception of the end use of the Site. S-6A was ranked
lower than the Preferred Alternative in the areas of compliance with ARARs, long-term effectiveness
and permanence, and implementability. There is greater difficulty for S-6A because of capping in a
4?
floodplain. Additional ARAR requirements would need to be implemented if construction occurred
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in a floodplain and siting a landfill occurred. Also, there is additional risk of leaving untreated
material (low-level threat waste) on Site.
The EE/CA did not include a developed analysis of the ARAR requirements as compared to the FS.
The EE/CA did not include the ecological data, treatabih'ty studies, a baseline human health risk
assessment, or an ecological risk assessment. The EE/CA did not include the nine-criteria .analysis
as required by the NCP. The EE/CA combined with the additional studies, ARAR analysis, and nine-
criteria analysis were used in the RI/FS report. The fact that the EE/CA selected remedy differs from
the RI/FS selected remedy is a function of the more complete assessment that the RI/FS process
requires as compared to the EE/CA process. It was during the EE/CA report preparation that the
potential for selecting off-Site disposal as part of the RI/FS process became apparent. EPA
recognized that the additional assessment would be necessary so that unnecessary money would not
be spent performing an on-Site disposal removal, and then at a later date as a result of the remedial
process, potentially performing an off-Site disposal remedy.
The Group's proposed alternative on-Site disposal remedy will create a public park with
other environmentally beneficial features.
EPA acknowledges this comment. EPA will support the creation of a park in addition to the Selected
Remedy. EPA, DOI, and the City of Rossville are in favor of a park as future land use and will
coordinate with the Group in implementing such a community benefit.
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•#•
-------
This fact sheet will provide:
• An overall review of the
Site -
• The results of the Remedial
Investigation
• Possible health risk posed
by the Site
• A summary of treatment
technologies
• A summary of the
Feasibility Study
• A presentation of EPA's
preferred Alternative
• Announcement of Public
Comment Period
• Places to get information
PUBLIC MEETING
DATE: November 30, 1998
TIME: 6:30 p.m.
LOCATION:
Rossville Christian Academy
280 High Street
Rossville, Tennessee
United States Region IV
Environmental Protection 61 Forsyth Street
Agency Atlanta, GA 30303
Alabama, Florida, Georgia,
Kentucky, Mississippi,
North Carolina, South
Carolina, Tennessee
SUPERFUND FACT SHEET
PROPOSED PLAN FOR REMEDIAL
ACTION AT THE ROSS METALS
SUPERFUND SITE
Rossville, Tennessee
November 1998
Ross Metals
'Site
INTRODUCTION
This Proposed Plan Fact Sheet is issued
to describe the alternatives that the U.S.
Environmental Protection Agency (EPA)
has considered for the cleanup at the
Ross Metals National Priorities List
(NPL) Site located in Rossville,
Tennessee. 'This plan presents an
evaluation of the cleanup alternatives,
including the alternative preferred by
EPA. The cleanup alternatives for
contaminated soils, wetlands, landfill
waste, and buildings are summarized in
this Fact Sheet and are described in
greater detail in the Remedial
Investigation (RI) and Feasibility Study
(FS) reports. The RI and FS reports are
more complete sources of information
and are part of the Administrative
Record. The Administrative Record
consists of technical reports and
reference documents used by EPA to
develop the Proposed Plan. These
documents may be found in the
information repository located at the
Rossville City Hall in Rossville,
Tennessee.
Based on Site information, EPA has
divided the Site into Operable Units or
cleanup phases, with the source being
the first Operable Unit and the ground-
Note: Words that appear in the glossary
on page 10. are in italics the first time
they appear in the body of this fact sheet
-------
water being the second. This has been done to begin cleanup
of the contaminated source material, while continuing to
evaluate potential groundwater contamination. Operable
nit No. 1 will address the contaminated soils, landfill
waste, wetlands and buildings. Operable Unit No. 2 will
address the potential cleanup of groundwater contamination.
The Ross Metals RI/FS was prepared by CDM Federal
Programs Corporation, under contract with EPA. The
alternative EPA prefers for OU #1 represents a preliminary
decision, subject to public comment.
Section 117(a) of the Comprehensive Environmental
Response, Compensation and Liability Act (CERCLAJ of
1980, as amended by the Superfund Amendments and
ReauthorizationAct (SARA) of 1986, requires public notice
and a brief analysis of the EPA preferred alternative for Site
remediation.
EPA encourages the public to submit written comments on
all alternatives presented in this plan. Please see page 9 for
more information on where to submit written comments.
EPA will consider public comments as part of the final
decision-makingprocess for selecting the cleanup remedy for
the Site.
SITE BACKGROUND
The Ross Metals Site (herein after referred to as "the RM
site" or "the site") operated as a secondary lead smelter from
1978 to 1992, during which the facility processed spent lead-
acid batteries, lead dross, lead scrap, and other lead bearing
material into reusable lead alloy. The 13.7 acre site is
located in a rural and residential area of Rossville, Fayette
County, Tennessee. An unlined landfill containing about
10,000 cubic yards (CY) of blast slag is located in the
northern portion of the site. In addition, about 6,000 CY of
stockpiled slag is stored on site in several deteriorating
buildings. Lead-contaminated surface soil is located
throughout the site, and lead-contaminated subsurface soil is
present in isolated portions of the site.
The purpose of the Ross Metals RI/FS is to document the
nature and extent of contamination to develop and evaluate
remedial alternatives, as appropriate.
Results of sampling investigations were used to develop this
RI/FS and show that lead-contaminated surface soil is
present across the site and in the wetlands north and east of
the site. Lead concentrations in most surface soil and
sediment samples collected throughout the site exceeded 400
ppm. In addition, aluminum, antimony, arsenic, barium,
cadmium, copper, iron, manganese, selenium, and vanadium
were detected above their cleanup levels.
In addition, lead concentrations ranging from 1,000 ppm to
52,000 ppm were detected in subsurface soils in two isolated
locations at the site; east of the wrecker building, and
southeast of the truck wash. Blast slag samples contained
total lead concentrations ranging from 18,500 to 94,800
ppm. Total lead and lead leachate concentrations in a floor
wipe sample collected from the furnace and raw materials
refinery building were 14,700 ppm and 574 ppm,
respectively.
Sampling results of surface water samples and sediments
revealed concentrations of several inorganic compounds that
exceeded background concentrations. Significant inorganic
contaminants included antimony, arsenic, cadmium, iron,
lead, and manganese. Lead concentrations in surface water"
were found as high as 1,600 ppb. Lead concentrations in
sediment were found as high as 98,100 ppm.
SUMMARY OF SITE RISKS
As part of the RI/FS, an analysis was conducted to estimate
the human health or environmental problems that could
result if contamination at the Site is not cleaned up. This
analysis, known as a Baseline Risk Assessment, focused on
the current and future human health and environmental
effects from long-term direct exposure to the contaminants
found at the Site.
EPA has concluded that the major risks to human health at
the site would be incidental ingestion of contaminated soil.
The contaminant of greatest concern in these media is lead
which causes well known health effects, especially in young
children. At the present time, nc^ unacceptable exposure is
occurring because no one is drinking water from the
contaminated aquifer and no one is in regular contact with
contaminated soil.
Additional pathways were evaluated or considered, but the
current and future impacts were found to be within
acceptable risk levels. For example, direct contact exposure
to contaminants in soil, sediment, and surface water was
examined, but the risks associated with these pathways were
found to be negligible. Similarly, possible exposure to
surface water via inadvertent ingestion while wading and
exposure to soil via inhalation to dust were examined and
found to be unimportant in terms of potential health effects.
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SCOPE AND ROLE OF RESPONSE ACTION
As previously stated, this response action addresses only the
cleanup of the contaminated soils, buildings, and wetlands.
Tie cleanup of the source materials is proposed to prevent
xposure to the contaminated source materials and prevent
'further contamination of groundwater and surface water.
The preferred alternative will address:
Waste Slag (landfilled and stockpiled)
• Contaminated soil (in facility area and landfill area)
• Buildings
• Demolition debris (pavement)
• Contaminated sediment (in wetlands)
EPA generally expects to use treatment to address principal
threats posed by a site, wherever practicable. Principal
threat wastes are those source materials considered highly
toxic or mobile that cannot be reliably contained or would
present a significant risk to human health or the environment
should exposure occur. For the Ross Metals Site, principal
threat wastes would conservatively include:
• 600 cubic yards of soil
• 8,200 cubic yards of sediment
• 6,000 cubic yards of stockpiled slag
10,000 cubic yards of landfilled slag
Based on new information or public comments, EPA in
consultation with the State of Tennessee, may modify the
preferred alternative or select another response action
presented in the Proposed Plan and the FS Report. The
public is encouraged to review and comment on all
alternatives identified.
SUMMARY OF SOURCE MATERIAL
ALTERNATIVES
This section summarizes the 6 source material alternatives
that EPA evaluated.
Institutional controls (e.g., future land use restrictions, local
zoning ordinances, or permitting requirements) and security
fencing are common components to all the alternatives that
include capping (S-2, S-3, S-4, S-5A, S-6A and S-6B).
The alternatives that leave contamination on Site (S-l, S-2,
S-3, S-4, S-5A, S-6A, and S-6B) would involve continued
monitoring of the Site. EPA would assess the risks to human
health and the environment every five years.
Alternative S-l
No Action .
Under this alternative, no action would be taken to remedy
the contaminated surface soil, slag, sediment, or other solid
media.
Alternative S-2
Capping
This alternative includes the demolition of most of the on-
Site pavement and buildings. The main office building and
the pavement surrounding this building would remain on
Site, and landfilled waste would remain in place.
Contaminated soil beneath the pavement would be excavated
and consolidated with the stockpiled slag, pavement, and
building debris. This waste material would be disposed in
an on-Site excavation that would extend from the existing
landfill to about 375 feet south of the landfill. This disposal
area would be about 400 feet wide and 8 feet deep, although
it could be enlarged somewhat if necessary. A soil cushion
layer, a geosynthetic liner; a soil cover, and topsoil with
grass seeding would be placed over the buried contaminated
material. The new landfill would cover about 6.7 acres.
Alternative S-3
Capping with Pavement in Place
Alternative 3 differs from Alternative 2 in that the waste is
not disposed of in an excavation, but rather spread over the
existing pavement and capped in place with the existing
landfill. Alternative 3 includes the demolition of most of the
on-Site buildings. The main office building would remain on
Site, and the landfilled slag would remain in place.
Contaminated soil from areas not covered by pavement
would be excavated and consolidated with the stockpiled
slag and building debris, and excavated wetland sediment.
This material would be spread above the pavement that
extends from the existing landfill to about 375 feet south of
the landfill. A soil cushion layer, a geosynthetic liner, soil
cover, and topsoil with grass seeding would be placed over
the contaminated material. The new landfill would be about
6.7 acres.
Alternative S-4
Capping with Construction of/Above-Ground
Disposal Cell
Alternative 4 differs from Alternatives 2 and 3 in that waste
is not disposed of in the area of the existing pavement;
instead, it is consolidated .over the surface of the existing
landfill and capped in place. This method would result in a
disposal cell approximately 17 to 18 feet high throughout the
-------
landfill area. This alternative includes the demolition of on-
Site pavement and buildings. The main office building and
the pavement immediately surrounding this building would
remain on Site, and landfilled slag would remain in place.
Contaminated soil beneath the pavement would be excavated
.id consolidated with the stockpiled slag, pavement, and
building debris.' A soil cushion layer, a geosynthetic liner, a
soil cover, and topsoil with grass seeding would be placed
over the contaminated material. The new landfill would be
about 2.5 acres.
Alternative S-5
Excavation and On-Site Treatment with
Solidification/Stabilization
Option A - On-Site Disposal of Treated Waste
Option A for Alternative 5 includes the decontamination and
demolition of most of the on-Site pavement and buildings.
The main office building and the pavement surrounding this
building would remain on Site. The building debris and
• pavement would be decontaminated by steam/pressure
cleaning. Contaminated soil throughout the Site, and buried
slag in the landfill would be excavated and consolidated with
the stockpiled slag. Contaminants within soil and slag would
be physically bound or enclosed within a stabilized mass
(solidification), or chemical reactions would be induced
between a stabilizing agent and the contaminant to reduce its
mobility (stabilization). Solidification/stabilization treatment
technologies include the addition of cement, lime, pozzolan,
or silicate-based additives or chemical reagents that
physically or chemically react with the contaminant. Once
treated and confirmed to be nonhazardous, the soil and slag
would be consolidated with the pavement debris and
disposed of in an on-Site excavation. The decontaminated
building debris would be taken off Site to a metal recycling
facility. The on-Site disposal area would extend from the
northern boundary of the existing landfill to about 700 feet
south of the landfill (100 feet north of the Site entrance) and
would be about 250 feet wide and 8 feet deep. A soil cover
and topsoil with grass seeding would be placed over the
entire Site. The new landfill would be about four acres in
size.
Option B - Off-Site Disposal of Treated Material
Option B for Alternative 5 is similar to Option A in that it
also consists of the decontamination of most of the on-Site
pavement and buildings and on-Site treatment. The main
office building and the pavement immediately surrounding
this building would remain on Site. The building debris and
pavement would be decontaminated by steam cleaning. The
decontaminated building debris would be taken off Site to a
metal recycling facility. Contaminated soil throughout the
Site, and buried slag in the landfill would be excavated and
consolidated with the stockpiled slag. Contaminants in soil
and slag would be treated by solidification or stabilization.
Option B differs from^ Option A in that after treatment and
confirmation that the soil is nonhazardous, the treated soil
and slag would be hauled off Site to a disposal facility. A
soil cover and topsoil with grass seeding would be placed
over the entire site.
Alternative S-6
Option A - Capping with Excavation and OnSite .
Treatment of Principal Threat Waste
Alternative 6 is similar to Alternative 5 in that it also
includes the excavation and treatment of contaminated
material via solidification/stabilization. However,
Alternative 6 differs from Alternative 5 in that treatment is
limited to only that material that is considered a principal
threat. As previously stated, principal threat waste includes
the landfilled and stockpiled slag, anS approximately 500
cubic yards of soil.
Option A for Alternative 6 includes the demolition of most
of the on-Site buildings. The main office building would
remain on Site. The building debris and pavement would be
decontaminated by steam/pressure cleaning. Principal threat
wastes would be excavated and consolidated with the stock-
piled slag. Contaminants in the principal threat waste would
be treated by solidification or stabilization.
Contaminated soil from areas not covered by pavement, and
non-principal threat landfill soil would be excavated for and
placed in an on-Site landfill along with the treated principal
threat waste. This waste (and treated) material would be
disposed in the excavated landfill area (450 x 250 x 5 ft.
deep). A soil cushion layer, a geosynthetic liner, a soil
cover, and topsoil with grass seeding would be placed over
the entire site. The new landfill would be about 6.7 acres in
size.
Option B - Off-Site Disposal of Treated Principal
Threat Waste
Option B is similar to Option A except that treated principal
threat waste is disposed in an off-Site landfill rather than
being capped on Site with the low-level threat waste. Like
Option A, Option B for Alternative 6 includes the demolition
of most of the on-Site buildings. The main office building
would remain on Site. The building debris and pavement
would be decontaminated by steam/pressure cleaning. On
Site contaminated soil considered principal threat waste, and
-------
buried slag in the landfill would be excavated and
consolidated with the stockpiled slag. Contaminants in soil
and slag would be treated by solidification or stabilization.
Contaminated soil from areas not covered by pavement, and
in-principal threat landfill soil would be excavated for
.cement in an on-Site landfill. This low-level threat waste
material would be disposed in the excavated landfill area
(450 x 250 x 5 ft deep). A soil cushion, ageosynthetic liner,
a soil cover, and topsoil with grass seeding would be place
over the entire Site. The new landfill would be about 6.7
acres in size.
SUMMARY OF WETLAND ALTERNATIVES
This section summarizes the three wetland alternatives that
EPA evaluated.
Institutional controls (e.g., future land use restrictions,
local zoning ordinances, or permitting requirements) are
included as components for alternatives W-l and W-2.
Each of the alternatives include a site monitoring program.
Alternative W-l
No Action
Under this alternative, no remedial action would be taken
with respect to the wetlands. A monitoring program would
'6 implemented to address wetland sediments, surface water
.id associated uptake by biota utilizing the affected area.
The monitoring program would be developed in order to
allow for regulators to assess the migration of the
contaminants from the wetlands and determine if additional
action is necessary. The monitoring program would take
place on a yearly basis and an EPA evaluation conducted
every five years.
Alternative W-2
Institutional Controls and Creation ofOfT-Site
Wetlands
Under this alternative, a cap consisting of at least one foot
of natural soil would be placed over the 5.7 acres of
contaminated wetland sediment and graded evenly The
final component of this alternative is the creation of an off-
Site wetlands to mitigate the loss (due to contamination) of
the Site wetlands. The purpose of the off-Site creation of
wetlands is to match the functional value of the Ross
Metals Site wetlands where sediment is contaminated
greater than 800 ppm - approximately 5.7 acres. The
creation of an off-Site wetlands under this alternative
would involve the determination of the functional value of
he Site wetlands; acquisition of an appropriate type and
area of land to create the off-Site wetlands; and vegetation
of the off-Site land to match or better the functional value
of the Site wetlands.
Alternative W-3
Excavation and Revegetation/Restoration of
Wetlands
Option A - Regrading with Clean Fill
Alternative 6 involves the excavation of contaminated
wetland sediments to a depth of one foot, and under Option
A, replacing that material with clean soils. Excavated areas
will be backfilled to the existing grade and revegetated
according to the Wetlands Revegetation Plan developed for
the Site wetlands. Maintenance plans to eliminate the
intrusion of less desirable species and to promote success
would be developed and Site monitoring would also be
required. Excavated sediments would be stockpiled with
contaminated surface soils and final disposition of the
contaminated wetlands sediments would follow the Source
Material Alternative selected for surface'soils. In excavating
the approximately 5.7 acres of sediment with lead
concentrations greater than 800 ppm to a depth of one foot;
approximately 9,300 cubic yards of contaminated sediment
would be generated. Approximately 8,200 cubic yards of
the excavated sediment would be considered principal threat
waste and 1,100 cubic yards would be considered low-level
threat waste.
Monitoring would be required to assess the effectiveness of
the cleanup action.
Option B - Regrading with Biosolid Compost Material •
Option B is similar to Option A except that excavated areas
would be backfilled with a .biosolid compost material rather
than clean fill. The compost would serve as the fill material,
a metal-binding material and as a source of fertilizer to
encourage revegetation/restoration.
As is the case for Option A, excavated sediments would be
stockpiled with contaminated surface soils and final
disposition of the contaminated wetlands sediment would
follow the Source Material Alternative selected for surface
soils. In excavating the approximately 5.7 acres of sediment
with lead concentrations greater than 800 ppm to a depth of
one foot; approximately 9,300 cubic yards of contaminated
sediment will be generated. Approximately 8,200 cubic
yards of the excavated sediment would be considered
principal threat waste and 1,100 cubic yards would be
considered low-level threat waste.
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EVALUATION OF
ALTERNATIVES
The EPA preferred alternatives for
'ic Ross Metals Superrund Site,
perable Unit #1 is Source
Materials Alternative S-5B and
Wetlands Alternative W-3B. Based
on current information, these
alternatives provide the best balance
of the nine criteria that EPA uses to
evaluate alternatives. These criteria
are described on the next page. The
Evaluation of Cleanup Alternatives
Tables on pages 7-8 provide an
analysis and comparison of the
alternatives considered. The
following information is regarding
two of these criteria, State of
Tennessee and community
acceptance, that is not fully
addressed on the evaluation table.
State of Tennessee Acceptance
The State of Tennessee has assisted
EPA in the review of reports and
Site evaluation. The State has
tentatively agreed with the proposed
remedy and is awaiting public
comment before final concurrence.
Community Acceptance
Commuity acceptance of the various
alternatives will be evaluated during
the 30-day public comment period
and will be described in the Record
of Decision (ROD) for the Site.
CRITERIA FOR EVALUATING REMEDIAL ALTERNATIVES
EPA always uses the following nine criteria to evaluate alternatives identified in the Feasibility Study. The remedial
alternative selected for a Superfund site must achieve the two threshold criteria as well as attain the best balance among
the five evaluation criteria. The nine criteria are as follows:
THRESHOLD CRITERIA
Overall Protection of Human Health and trie Environment: Degree to which each alternative eliminates, reduces, or controls
threats to public health and the environment through treatment, engineering methods or institutional controls.
" f x
Compliance with Applicable or Relevant and Appropriate Requirements (ARARs): Alternatives are evaluated for compliance
'with all state and federal environmental laws and regulations and^are determined to be applicable or relevant ;and
ppropriate to the she conditions. •.?;.-'.'. ••••V1'
EVALUATING CRITERIA ; ;
Cost: The benefits of a particular remedial alternative are weighed against the cost.
Implementability: Technical feasibility (e.g., hp.w difficult the alternative is to construct and operate) and administrative
ease (e.g., the amount of coordination with ;o,th0r government agencies that is needed) of a remedy, including the
availability of necessary materials and services.
Short-Term Effectiveness: The length of time needed ,to implement each alternative andjthe "risks that may be posed to
workers and nearby residents during construction and implementation.
.'•'•• '„',""' '' . " , * ' ' ><
Long-Term Effectiveness: The ability to maintain reliable protection of public health and the environment over time once
the cleanup goals have been met.
; Reduction of Toxlcrty. Mobility, and Volume: Degree to which an alternative reduces (1) the harmful nature of the
contaminants, (2) their ability to move through the environment, and (3) the volume or amount of contamination at the
- site/ :/ • '.;" ':< "i'y i; , ' - -% f, ,„ ^ r "
'•'• MODIFYING CRITERIA
State Acceptance: EPA requests state comments on the Remedial Investigation and Feasibility Study reports, as well as
the Proposed Plan, and must take into consideration whether the state concurs with, opposes, or has no comment on
EPA's preferred alternative. :
Community Acceptance: To ensure that the public has an adequate opportunity to provide input, EPA holds a public
.omment period and considers and responds to all comments received from the community prior to the final selection of
a remedial action.
6 . '
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EVALUATION OF SOURCE .AL CLEANUP ALTERNATIVES
Alternative
S-1- No Action
% v
S-2- Capping
S-3~ Capping with
Pavement In Place
S-4- Capping with
Construclion of Above-
Ground Disposal Cell
S-5A - Excavation and
On-Slte Treatment with
SoHdification/Stablfizatlon
and On-Slte Disposal •
-• • ...:...
S-5B - Excavation arid"
On-Slte Treatment with
Solidification/Stabilization
and Off-Site Disposal
S-6A -Capping with :
Excavation and On-Sile
Treatment and On-Slte
Disposal... .; . .
S-6B - Capping with
Excavation and On-Slte
Treatment and Off-Site :
Disposal of Treated
Principal Threat Waste
OvBral Protection of
Human Healtti and
Environment
NO
YES
YES
YES
YES
YES
: YES
YES
Compilancewih .
- ARARs'
NO
YES
YES
YES
YES
YES
YES
YES
ReduclkxiofToxfcity.Mobitityand
. / Volume (TWy) ;::;;:-
Does not affect TMV.
Toxlctty and volume unchanged.
Mobility significantly reduced.
Does not meet expectation for
treatment.
Toxic'rty and volume unchanged.
Mobility significantly reduced.
Does not meet EPA expectation
for treatment.
Toxtclty and volume unchanged.
Mobility significantly reduced.
Does not meet EPA expectation
for treatment.
Toxlclty and mobility virtually
eliminated. Volume may increase
Meets EPA expectation for
treatment.
Toxloity and mobility virtually
eliminated. Volume may Increase
Meets EPA expectation for
treatment
Toxlclty and mobility virtually
eliminated. Volume may increase
Meets EPA expectation for
treatment.
Toxictty and mobility virtually
eliminated. Volume may increase
Meets EPA expectation for
treatment.
'. ' Short-Term Effectiveness, .
Does not achieve goals2
0 years
Goals achieved. Protective
equipment required. Noise
nuisance.
6 months
Goals achieved. Protective
equipment required. Noise
nuisance.
6 months
Goals achieved. Protective
equipment required. Noise
nuisance.
6 months
Goals achieved. Protective
equipment required. Noise
nuisance.
6 months
Goals achieved. Protective
i equipment required. Noise
nuisance.
6 months
Goals achieved. Protective
equipment required . Noise
nuisance.
6 months
Goats achieved. Protective
equipment required. Noise.
nuisance.
6 months
. .. -..-• Imptementabllity '•• ,-. •:
Routine monitoring. Readily
Implemented.
Technology readily available and
constructed. Capping In a floodplaln
and wetlands.
Technology readily available and
constructed. Capping In a floodplaln
and wetlands.
Technology readily available and
constructed. Capping In a floodplain
and wetlands.
Technology readily available.
Moderately complex to Implement.
Capping In a floodplaln.
Technology readily available.
Moderately complex to Implement.
Technology readily available.
Moderately complex to Implement..
Capping in a floodplaln.
Technology readily available.
Moderately complex to Implement.
Capping in a floodplain.
Present Net
Worth
(•w/wetlands)
$100,247
$1.712.412
$1,735,804*
$1.430.411
$1,453.803'
$1.481.865
$1.505,847'
$4,244,992
$4,907.274'
$6,181,160
$7.477,199'
$2,729.543
$3,175,137'
$4.013,508
$4,936,044'
Ranked
Preferable
Alternative
S
7
5
6
4
1
2
3
Notes: ' ARARs - Applicable or Relevant and Appropriate Requirement; * Goals (prevent human contact and further degradation of groundwater).
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Alternative
W-2 - Capping w/Clean Fill
and Off-Sile Creation of
Wetlands . ..•
W-3A- Excavation and
Revegetalfon/Restoratlon of
Wellands and Regrading
w/CleariFIII ' . : -"••
W-3B-'Excvallonand .
RevegetattorVRestoratfon of •
Wetlands and Regrading with
Biosplid Compost . . •.';."".
Overall '
Protection of
Human Health
and .
Environment
NO
Potentially
YES
YES
Compttencevrfth
ARAR31
NO
NO
YES
YES
EVALUATION OF WETLAND
ReducfcnofToxtcJty.Mobityond
VotumefJMV)
No reduction of TMV
No reduction in toxlcity or volume.
Reduction of mobility. Does not
meet EPA expectation of treat-
ment
TMV virtually eliminated.
TMV virtually eliminated.
S CLEANUP ALTERNATIVES
Short-jerm Eff
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EPA's PREFERRED ALTERNATIVE
"Tie EPA preferred alternatives are Source Materials
temative S-5B and Wetlands Alternative W-3B.
.cased upon current information, these alternatives
appear to provide the best balance "among the nine
criteria that EPA uses to evaluate alternatives., EP. A
has determined that the preferred alternatives wouldte
protective of human health and the environment;
would attain the Site goals; comply with ARARs; and
would be cost effective. ;.
The preferred alternative consists of the following-
• Decontamination/ demolition of pavement and
buildings with recycling of metal debris;^
• Excavation of contaminated soil, landfill ed
slag, and contaminated wetlands sediment and
appropriate confirmation soil sampling;
Backfill of excavated soil areas and landfill
with clean soil;
V- Stabilization or solidification of contaminated
; soil,: stockpiled slag, landfilled slag, and
•'"• , wetlands sediment;
• Off-Site disposal of soils, slag, and sediment
'.. at nonhazardous disposal facility,
r : Application of a layer of biosolid compost to
! ''; the entires Ross ;MetaIs Site. Grass seeding of
:';> thefacnlii^and landfill areas;andrevegetation
of the Site wetlands according to the wetlands
',•••- revegetation plan developed by EPA, 1998.
• • Development of maintenance and monitoring
plan to assess the effectiveness of the cleanup
action.
The total estimated construction costs associated
with both alternatives are $ 7,736,897. The
•estimated Operations and Maintenance costs are
$242,969. The estimated total present worth costs
are $ 7,979,866.
THE NEXT STEP: THE COMMUNITY'S ROLE IN
THE SELECTION PROCESS
EPA solicits input from the community on the cleanup
alternatives proposed for each Superfund site. EPA has set
a public comment period from November 18, 1998
through December 18, 1998, to encourage public
participation in the selection process. The comment period
includes a public meeting at which EPA will present the
RI/FS Report and Proposed Plan, answer questions, and
receive both oral and written comments.
The public meeting is scheduled for 6:30 PM, November
30,1998, and will be held at Rossville Christian Academy
inRossville.
EPA is required to extend the comment period, for a
minimum of 30 days, upon receipt of a timely request to do
so. At the end of the public comment period, a summary of
all the questions and comments received from the public and
EPA's responses will be provided in the Responsiveness
Summary. The Responsiveness Summary is included in
EPA's Record of Decision (ROD), which is the document
that presents EPA's final selection for Site cleanup.
The public can send written comments to or obtain further
information from:
Beth Brown
Remedial Project Manager
U.S. EPA Region IV
61 Forsyth Street, S.W.
Atlanta, Georgia 30303-3104
1-800-435-9233 or
• 404-562-8814
The Proposed Plan and the RI/FS Reports have been placed
in the information repository and Administrative Record for
the Site. These documents are available for public review
and copying at the following location:
Rossville City Hall
360 Morrison Road
Rossville, Tennessee 38066
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GLOSSARY
Administrative Order on Consent: A legal and enforceable
ment signed between EPA and Potentially Responsible
; (PRPs) whereby PRPs agree to perform or pay the cost
3 investigation.
Biosolids: Organic matter (e.g., wood ash, compost, or waste-
water treatment plant sludge) that can be used with topsoil for
stablizing slopes, reducing erosion, and providing a nutrient-rich
invironmcnt for vegetation. . '..-
Blast Slag: A by-product or waste that is generated during the
lead smelting process.
Comprehensive, Environmental Response, 'Compensation,
and Liability Act (CERCLA): A federal law passed in 1980
and amended in 1986 by the Superfund Amendments 'land ,.'•
Reauthorization Act. This law created; a special tax that goes •"
into a trust fund, commonly known as Sluperr^d,;to'investigat^ •
and clean up abandoned or uncontrolled hazardbus^asls sit«. •! ' ;
Under the Superfund .program," EPA can either., pay for 'site ";
cleanup when the responsible parties cannot be located pr'^are ' :
unwilling or unable to perform the work, or take legal action^ ; :
force responsible parties to clean up the site or reimburse EPA "
for the cost of cleanup.
Feasibility Study (FS): A Feasibility Study evaluates different .
remedial alternatives for site cleanup and recommends .the "•
alternative that provides the best balance or profectiveness
f -Uveness, implementabilhy, and cost. ' ; ; ;V.:-':
i synthetic Liner: A man-made textile that significantly
reduces rainwater from passing throgh its 'tightly woven
structure of plastics and clay.
Groundwater: Water beneath the earth> surface that .fills
spaces among soil, sand, rock, and gravel. Precipitation, such
as rain, reaches the ground and then slowly moves tfarpugh soil :
sand, gravel, and rock into small cracks and creyices'telowjthe ':
ground surface. During a 'process that can take'inaiiy :ye4rs : ":-'!:
groundwater has the potential of becoming" a /drinking water
SOUrce.: _-= ...-,•• •• .H^^^rryiT-'l^sv-;. '.
Institutional Controls: Legal mechanisms to prevent human' ^
exposure to contamination remaining on hazardous ; waste : sites. :
.when .\yater:
!and collects
Lcachate: A contaminated liquid jresultingX
percolates or trickles through waste materials"1
components of those wastes.
Monitoring: The continued collection of information atout the
enwonmcntthat helps gauge the effectiveness of a:cleanup:i-
National Priorities List (NPL): EPA's list of the most serious
uncontrolled or abandoned hazardous waste sites identified for
possible long-term remedial action under Superfund.
Parts Per Billion (ppb or /zg/L): A unit of measurement used
to describe levels of contamination. For example, one gallon of
a liquid in one billion gallons of water is equal to one part per
bilhon. .
Parts Per Million (ppm or mg/L): A unit of measurement
used to describe levels of contamination. For example one
gallon of a liquid in one million gallons of water is equal to one
.'part per .million.
Preferred Alternative: EPA's selected best alternative based
on mformatiori collected to date, to address contamination at a
site.'.";!.:.;.:;;;'. •'-..-.:
;• Prop/osed Plan: A fact sheet summarizing EPA's preferred
•; cleanup strategy for a Superfund siteV the rationale for the
preference,; and a review of the alternatives developed in the
;RI/FSprocess, ' ' ' :" ; '":-.:.
Resource Conservation and Recovery Act (RCRA): A law
that established a regulatory system to track hazardous
substances from the time of generation to disposal. Provides
closure and post-closure minimum requirements for landfills^
Record of Decision (ROD): A public document that explains
which Cleanup alternative will be used at an NPL site and the
reasons for choosing that cleanup alternative over other
possibilities.
Remedial Alternatives: A list of the most technologically
feasible alternatives for a cleanup strategy. •
Rem^diaJ, Design: An engineering phase that follows the
•• •999S?.*? Decision when technical drawings and specifications
?r? ye$5lppe'd for the cleanup action at a Superfund Site" ••
:;^?.??5^'-lllvestiga*i.o;n';' (HI)1 A Remedial Investigation
,exarnuies the. nature and extent of .contamination problems at a
Responsiveness Summary: A summary of written or oral
:; comments;:received by EPA during a public comment period.
: Superfund: A term commonly used to describe'-the Federal
program established by CERCLA.
Superfund Amendments and Reauthorization Act (SARA)-
Amendments to CERCLA enacted on October 17, 1986.
Treatability Study: A study to evaluate the effectiveness of a
technology in remediating contamination.
10
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STATE OF TENNESSEE
DEPARTMENT OF ENVIRONMENT AND CONSERVATION
MEMPHIS ENVIRONMENTAL FIELD OFFICE
SUITE E-645, PERIMETER PARK
2510 MT. MORI AH
MEMPHIS, TENNESSEE 38115-1520
February 3, 1999
Ms. Beth Brown
Remedial Project Manager
U.S. Environmental Protection Agency
Region 4 ,
61 Forsyth Street, SW •
Atlanta, GA 30303-3104
RE: Ross Metals Superfund Site (TND 09-607-0396)
Rossville, Fayette County, Tennessee • •
ELM, Inc. and Leed Environmental, Inc. Comments on proposed ROD
Dated January 18, 1999
Dear Ms. Brown:
I have reviewed the copy of the comments you forwarded to this office
and have some responses concerning these comments. Specifically, I
will address the areas covered by the Regulations Governing Solid
Waste Processing and Disposal in Tennessee, Rule Chapter 1200-1-7.
The commenters state that the facility is not in the 100 year flood
plain. Additionally, they state that the Rossville POTW is not
included on the FEMA flood maps. The July 5, 1983 Flood Insurance
Rate Maps for Rossville and surrounding Fayette County show that this
facility is in the 100 year flood plain and clearly show the
Rossville POTW. -Portions of the facility may have been raised above
the 100 year flood, but the existing disposal area is in the 100 year
flood plain. While the Tennessee Regulations do not preclude the
placement of a landfill unit in the 100 year flood plain, the
standard practice has been to totally remove the facility from the
flood plain by constructing a levee. In no case would any facility
be located in the flood way. Additionally, Rule 1200-1-7-.04(3)(a)4.
requires a 200 foot buffer between a fill area and the normal
boundaries of springs, streams, and lakes. The commenters claim that
the proposed off-site landfills are also located in the 100 year
flood plain, without a list of the proposed facilities I can not make
a global assertion, however no currently operational Class I
(Sanitary) landfill in Tennessee within 100 miles of this facility
are located in a 100 year flood plain.
The existing on site landfill predates the RCRA.Subtitle WD"
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Ms. Beth Brown
February 3, 1999
Page 2
compliant Tennessee Regulations and is therefore -not subject to them.
Any new waste disposal activity would have to fully comply with the
Regulations. This would include the requirements for a geologic
investigation and a design that included a synthetic liner. The
proposed alternate plan does not appear to include these in it's cost
estimate.
Of particular concern to the Tennessee Division of Solid Waste
Management is this facility's location in the recharge zone for the
"Memphis Aquifer". Numerous private and public wells are located
down gradient from this facility. While a geologic buffer is
indicated on the bore logs for the on-site monitoring wells/ the
permeability of the underlying soils has not been established.
The commenters apparently missed some portions of the record. Ross
Metals was issued a Notice of Violation for the existing disposal
site on June 16, 1986. The Notice of Violation required Ross Metals
to either register the site or to close it. Ross Metals chose to
apply for a permit and submitted an application. As was the practice
at that time/ the Division Geologist conducted a preliminary
Hydrogeologic Review of the site and determined that the site, may
have been suitable for a landfill. On December 20, 1988, Paul
Patterson of the Memphis DSWM Office notified Ross Metals that the
review of their landfill application would be suspended until the
status of the slag could be determined.
Considering the sites susceptibility to inundation, the presence of
wetlands, and the facility's location in the recharge zone for the
Memphis Aquifer, on-site disposal of the slag, as proposed, presents
the potential for harm to the public health and the environment.
Specifically, the plan does not describe any liner and leachate
collection system.
Should you have any questions about this letter or the Regulations .
Governing Solid Waste Processing and Disposal in Tennessee, please
feel free to contact me at (901) 368-7948.
Sine
Boatrightj, P.E.
^vision of Solid Waste Management
JWB\79019034\ag
c: DSWM MEAC File
DSWM NCO File
Jordan English, TDSF/MEAC
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United States Department of the Interior
FISH AND WILDLIFE SERVICE
446 Neal Street
Cookeville, TN 38501
January 22,1999
Ms. Beth Brown
U.S. Environmental Protection Agency
Atlanta Federal Center
61 Forsyth Street
Atlanta, Georgia 30303-8960
Dear Ms. Brown:
U.S. Fish and Wildlife Service (Service) personnel have reviewed the Remedial
Investigation/Feasibility Study (RJ/FS) for the Ross Metals Superfund Site in Rossville Fayette
County, Tennessee. We have been actively involved with wetland and ecological risk issues
regarding this site and commend the Environmental Protection Agency (EPA) for its close
coordination with this office and Service representatives in Edison, New Jersey.
The Service supports the preferred Source Materials (S-5B) and Wetlands (W-3B) alternatives for
remediation of contamination at the site. Based on the comments presented by the representatives
of the primary responsible parties (PRPs) at the January 19th meeting in Atlanta, we could if
necessary, a^o consider other alternatives for the final disposition of lead contaminated soil and
l^r6^"8 S?dleS SUggeSt that °n-site disP°sa! of «cavnted soil and sediment is
, potential additional wetland impacts should be fully evaluated and mitigated Since onlv
*1? *? reSt°rati0n Plan ^ °ffered by ** PRP'S *P^ntatives, we Lommend that a
h 7 T dT!?lon;res!ora!lon'^^
s be developed. This plan should consider and incorporate the technical information previously
provided by Roy F. Weston, Inc. (U.S. EPA Work Assignment No.: 2-284) and the US EPA
Environmental Response Team Center, as well as any field data subsequently generated during
hydrogeological studies of the Ross Metals site. A final plan should then be included ^
appropriate decision document and provided to this office for further review.
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We appreciate the opportunity to comment. Upon receipt of a ROD, the Service will evaluate the
effectiveness of the proposed remedy and whether a covenant not to sue for damages to Service trust
resources is appropriate. Should you have any questions or need technical assistance regarding
wetland issues at the site, please contact Steve Alexander of my staff at 931/528-6481, ext. 210.
Sincerely,
Lee A. Barclay, Ph.D.
Field Supervisor
xc: James H. Lee, DOI, Atlanta
Nancy Firdey, FWS, Edison, New Jersey
Allen Robison, FWS-ES, Atlanta
Patricia Cortelyou-Hamilton, DOI, Atlanta
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STATE OF TENNESSEE
DEPARTMENT OP ENVIRONMENT AND CONSERVATION
MEMPHIS ENVIRONMENTAL FIELD OFFICE
SUITE E-645. PERIMETER PARK
2510 MT. HORIAH
MEMPHIS, TENNESSEE 36115-1520
March 31, 1999
Ms. Beth Brown
Environmental Project Manager
United States Environmental Protection Agency
Region IV, Waste Management Division
61 ForsythSt.
Atlanta, GA 30303
Re: Concurrence for the Record of Decision for the Ross Metals siie, Rossville, Fayette
County, Tennessee, April 1999, TDSF $24-501.
Dear Ms. Brown:
The Tennessee Division of Supeifund (TDSF) has reviewed the draft Record of Decision for the
Ross Metals site. Kossville, hsyette County, Tennessee, received in this office on March 16,
1999.
The Tennessee Department of Environment and Conservation (TDF.r.) is in concurrence with
this ROD. The level of cooperation that has occurred among all agencies with regard to this site
has been extremely good. TDEC is hopeful that this cooperation will serve 05 a model for future
relationships between die State Of Tennessee and EPA.
Sincerely,
James W. Ha>nes. Director
Tennessee Division of Superfund
C: TDSF, NCO file
TOSH, EAC-M file
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February 9, 1999
Cindy Gibson
Community Involvement Coordinator
North Site Management Branch
United States Environmental Protection Agency
Region 4
Atlanta Federal Center
61 Forsyth Street
Atlanta, Georgia 30303-8960
Dear Cindy:
Enclosed please find the transcript of the U.S.
Environmental Protection Agency's public meeting on November
30, 1998, at the Rossville Christian Academy in Rossville,
Tennessee.
I have made the few corrections that you requested
that I make and am returning this copy to you. Since the
time of this hearing, I have received and updated my
computer software. This new update changed the format of my
programming, and therefore changed the page layout of this
transcript. Because of this I have gone ahead and reprinted
the entire transcript rather than just the few pages that
needed corrections. I draw your attention to this simply
because you are still in possession of the original
transcript, and the pages will no longer match.
I hope this transcript now meets with your
approval and will serve the purposes for which you had it
recorded. If I can be of any further assistance to you,
please feel free to contact me.
Sirfcerely,
-x
'Debra A. Dibble
Alpha Reporting Corporation
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EPA SUPERFIND SITE
ROSS METALS, INCORPORATED
ROSSVILLE, TENNESSEE
at the Rossville Christian Academy
November 30, 1998
ALPHA REPORTING CORPORATION
Debra A. Dibble, C.S.R., R.P.R.
Suite 210-A - 100 North Main Building
Memphis, TN 38103
(901) 523-8974
ALPHA REPORTING CORPORATION - (901) 523-8974
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PROCEEDINGS
MS. BARRETT: EPA is going to present a brief
history about the site, findings from the remedial
investigation, and the various options for cleaning up the
soil and the wetland area-here at the site.
My name is Diane Barrett. I'm a community
involvement coordinator with EPA.
Cindy Gibson is the community involvement
coordinater for this site, and usually — she is on an
extended holiday with her family, so she'll be back to the '
office soon.
I would like to, first of all, introduce you to EPA
participants.
Beth Brown. If you'll stand, please. She is the
site project manager.
Harold Taylor, he is the chief of the
Kentucky/Tennessee section in Atlanta.
Marlene Tucker. She is the attorney for the site.
And Andy Hey, who's a paralegal specialist also
working on the site.
So we thank you both — all of you.
Are there any officials with us tonight?
I guess there is. Thank you for being here.
Are there any other officials? Quite a few I
don't know. City and county officials.
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1 AUDIENCE: Curry Morris.
2 MS. BROWN: Let's point out one thing. We do have
3 a court reporter, so she's recording everything that's said
4 at the meeting, so that if at any point you'd like to review
5 what's been said at the meeting, you can.
6 So we just ask that if you do speak, that you bear
7 in mind we're trying to record it.
8 MS. BARRETT: I was going to say that, but further
9 on down. You beat me to it. But I should have said it
10 earlier.
11 Other officials?
12 AUDIENCE: I'm Ken Spencer, Alderman.
13 AUDIENCE: Ben Farley, Alderman.
14 . MS. BARRETT: Also, we have Sally Spencer here in
15 the community.
16 . Representing from the state? State people?
17 AUDIENCE: Phil Davis.
18 MS. BARRETT: Anybody else? That's got all of
19 these people, and then all interested citizens that are
20 here. We welcome you and thank you for coming. Thank you
21 very much for coming. This is an important meeting.
22 In order to help me relay to you, and I'm not —
23 Is this anyone's first time to attend a meeting?
24 All right, let's just cut to the chase.
25 AS you entered the room tonight, I hope you all
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1 got your information, got a fact sheet. It's what we're
2 going to be discussing.
3 Also, this packet is what Beth is going to be
4 reviewing with everyone, so this will help you follow along.
5 It makes good night-time reading.
6 And then we have information on capping and
7 immobilization. These are two of the alternatives that are
8 being considered.
9 And then lastly, is what is a superfund process.
10 And so that's kind of what I'm going to go through real
11 quickly with you.
12 Also, as Beth did say earlier, this is an official
13 meeting, and it is being recorded by our court reporter, so
14 as we speak, if you would, when it comes to the question and
15 answer period, if you'd just give your name so that she can
16 make sure she gets it accurately.
17 A transcript will be made of this meeting and
18 placed in the repository. And usually we'll get that back
19 about 14 working days — 10, 14 working days, and it will be
20 placed in the repository for you to look at.
21 Right now, we are — you can't see this real good,
22 but we are right here in the public comment period area.
23 And after the public — after this meeting tonight, the
24 proposed planning meeting, we will take all of the comments
25 from this public comment period, which is from November the
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1 18th through December the 18th. All comments received
2 tonight, and in writing, a responsiveness summary will be
3 prepared which will address all of the comments we received.
4 And this responsivness summary will also be placed in the
5 official document which is called the record of decision.
6 And once that has been completed, then we will, at
7 that time, start renegotiations with the potential
8 responsible parties, and see who will, EPA or they, will pay
9 for and conduct the rest of the process, which is the design
10 and the actual physical construction of whatever treatment
11 process we anticipate having.
12 During this time, during the process of selecting a
13 remedy, we always have to make sure it is, first of all,
,14 protective, efficient, implementable, and cost effective for
15 handling all of the contamination at the site.
16 These, the steps that we have remaining, will take
17 about maybe twelve plus months, so it will be maybe the year
18 2000, a little after the first of the year 2000 that actual
19 cleanup activities might occur at this site. And so Beth
20 will go into that more as a projection, but at this time,
21 that's kind of an estimate.
22 And that about concludes what I've got to say as far as
23 community relations.
24 As this chart indicates, community relations
*
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The information repository is housed there in the city hall
so all of the documents should be in there as they are
developed.
We're holding public meetings, presenting fact
sheets.
Another thing that will occur is that once the
process has been collected, the record of decision has been
signed, then we will have a notice in the newspaper
announcing that collection, and it will be based on all of
10 the data that we have, all of the comments, you know. That
11 will be how we will select the technology.
12 I guess that's it.
13 Are there any comments or questions at this point?
14 Okay. I thank you for your attention. I will 'turn it
15 over to Beth now. And as she said, when you do get ready to
16 voice your comments, please speak up so our court reporter
17 can hear. Thank you.
18 MS. BROWN: Well, thanks for coming tonight. I know
19 it's probably tough to get back in the swing of things after
20 Thanksgiving.
21 It's been a long time getting to this point in the
22 process, and I'm pleased to say that we're at the decision
23 point. And we'd like you to comment on it if you have any
24 comments at all. Like Diane said, there's information over
25 at city hall.
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1 There's probably, I don't know, five or six
2 volumes like this worth of information, and I'm going to try
3 and condense it down at about the next ten minutes. I don't
4 want to overwhelm you tonight. I gave you a lot of
5 information at the last meeting, that has some of the data
6 results. Tonight is just going to be a real brief overview
7 of how we got here.
8 Tonight I'd like to focus more on what the cleanup
9 alternatives are. So this is basically what I'll be
10 covering. The site history, what EPA has done to date,
11 brief summary of the sampling results, what kind of cleanup
12 alternatives we've come up with, and probably what you guys
13 want to know most, when we're going to actually move some
14 dirt.
15 You folks probably know the operational history as well
16 or better than I do. It started operating in 1978 through
17 1992. It's my understanding that they formed a — or
18 administrative dissolution?
19 MS. TUCKER: The company was actually
20 administratively dissolved. And basically when a company
21 violates a corporate law of the state, the state
22 administratively dissolves the corporation, so it's — it
23 was involuntarily dissolved, not voluntarily dissolved.
24 MS. BROWN: And I don't mind questions in between
25 if you do have them, so just let me know.
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1 Ross Metals actually was producing an alloy that they
2 later sold, and in doing so they accepted wastes from other
3 industries as well as automotive batteries.
4 So far EPA has performed two removal actions, the first
5 one was in 1994-1995, where a pretty large volume of
6 hazardous wastes were removed from the site, and some
7 temporary security measures were taken.
8 At the last meeting in the spring, some of the
9 citizens voiced concerns, and appropriately so, that they
10 wanted — we had temporarily stored all of the waste, the
11 slag, blast slag in the buildings. And since then the
12 buildings were falling down, they were deteriorating, and
13 they also wanted some additional security measures.
14 It was pointed out that people were actually
15 breaking in the property, for what reason we don't know.
16 So in the summer we actually put up additional
17 fencing and we covered the wastes with tarps, another
18 temporary measure until we take our final action.
19 We've actually conducted at least three or four
20 investigations in the last three years. We've collected
21 soil samples, sediment samples, ground water, surface water.
22 We've done a lot of laboratory evaluations to find out
23 whether or not the contaminants out there would pose a risk
24 to the bugs and critters out there.
25 We also have to do human health risk assessments
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1 to determine whether or not there would be an impact to
2 human beings should they come in contact with the waste, or
3 the soils.
A That's about it.
5 Wipe samples. We actually took samples from the
6 building by just taking a cloth and wiping the buildings and
7 then analyzing that.
8 So that's about it.
9 So as a result of our investigation, EPA's determined
10 that we've got a lot of contaminated media out there. The
11 slag, about 16,000 cubic yards, surface soil about 32,000
12 cubic yards. Very small amount of subsurface soil. The
13 buildings are obviously contaminated, and we've got a lot of
14 construction debris out there that we need to take care of.
15 Ground water, the data has been misleading. We're not
16 sure that we even have a ground water problem.
17 Unfortunately, we're going to split that out.
18 We're going to go ahead and take an immediate action, or an
19 action on the solid medias, all of these, slag, soils,
20 buildings, and demolition debris. In the meantime, we'll go
21 ahead and collect additional ground water data.
22 We decided to look at the site in two ways. The source
23 materials, which are what's out on the actual asphalt and
24 concrete pad where the buildings are, and the wetland
25 sediments is another issue. And so we determined that the
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most appropriate alternatives to consider are capping;
excavation; immobilization, which is basically just
solidifying it with a type of cement; and disposal, which is
either on site or off ^site.
We're actually required to look at a no action
alternative, just to give us a comparison of whether the
site poses a risk if we don't do anything verses if we do,
you know, one or some of these type of technology.
Wetland sediments. We considered certain types of
surface water diversion, sediment control to keep the water''
from going into the wetlands and letting them dry up. We
looked at capping it, excavating it, treating it with some
type of solidification, or mitigation is a term that's used
for when you contaminate a wetlands. EPA requires that you
either restore that wetlands on site, or you have to go
somewhere else and create a brand new wetlands.
And it's some ratio depending on how important
that wetlands is. If it's a really important wetland you
might, have to, say, if you have five acres of contaminated
wetland, you may have to buy 15 acres somewhere else and
revegitate it with all of these wetland type of plants. So
it gets into a more expensive option when you get into
off-site mitigation.
In your handout there's actually some pictures of what
some of these alternatives look like. And actually, there
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1 are pictures of all of them except for 5-B.
2 I'm trying to find my handout. Here it is.
3 The first one is, you know, the no action, which,
4 again, EPA requires us to evaluate, for really a comparison
5 purpose.
6 The second one is capping. And if you'll look at your
7 handout. And mine, of course, are not in order.
8 AUDIENCE: 10-10.
9 MS. BROWN: Yeah. The first capping, the S-2.
10 The capping alternative really looks at leaving everything
11 in place as it is now, and just capping over it with a type
12 of soil and clay, and then revegetating it so it would
13 prevent, you know, contact with what's there, but the waste
•14 remains there in place.
15 The next alternative is capping with pavement in place,
16 and on this alternative, as you can see, we would go in and
17 excavate some of the surface soils and then compile it all
18 back on the landfill — and where the pavement exists now,
19 and build a cap over that. So you end up with a cap that's
20 about five feet above ground, and it's about 600 feet long,
21 verses the first alternative, which was about eight feet
22 tall and about 375 feet long.
23 The next alternative looks at excavating all of the
24 surface soil, and then piling it up on the back part of the
25 property, which is the landfill area, so you actually end up
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with a pretty tall disposal cell, about 15 feet. But the
advantage of that is you end up with only a disposal cell
that's about 200 feet long, 400 feet wide.
Alternative 5a and 5b involve treatment with
solidification or stablization. And again, solidification
and stabilization is basically adding some kind of additive
that will chemically or physically bind the contamination so
that it's no longer mobile. It looks like a big concrete
mass.
And we evaluated it for disposing of that. Everything
on site, the soils, the sediments and waste, we would treat
it and leave it on site, or treat it and ship it off site.
And the last alternative 6, a and b, involves treating
the waste that poses the most risk, and shipping it off
site, which is option b, or leaving the treated principal
waste and leaving it on site.
So all of these alternatives either involve capping it
and not treating it, or treating it and capping it, or
treating and shipping it off.
AUDIENCE: Do we have a picture of 5b?
MS. BROWN: No. Because everything is gone.
Everything is treated and shipped off. The buildings, the
demolition debris, the pavement, it's all shipped off.
AUDIENCE: It's not hazardous to ship it?
MS. BROWN: We hope to achieve that so that the
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1 cost will go down, because if you don't treat it you still
2 have a hazardous waste. Number one, it's expensive, and
3 it's difficult to ship it off. We have requirements when
4 you treat it to reach certain levels.
5 Unfortunately, I didn't make an overhead of the
6 comparative analysis. Does everybody have a copy of this?
7 This is action where we look at the criteria that EPA
8 is required to in order to evaluate the different
9 alternatives.
10 Is everybody there?
11 As Diane pointed out, in order for EPA to select an
12 alternative, first it has to be protective of human health
13 and the environment, and secondly, it needs to comply with
14 all of the laws and regulations, because if it doesn't, we
15 have to do a waiver, and we prefer not to do that. We
16 prefer to comply with all of the laws and regs.
17 Then we look at whether or not it reduces the toxicity
18 and mobility or volume of the waste, which is EPA's
19 preference. And some of these don't effect the toxicity,
20 volume, or the mobility. Some do parts of it, some do all
21 of it.
22 And then we have to look at short-term effectiveness.
23 You know, how does it affect the workers? Can we control it
24 from negatively affecting the workers? How quickly can we
25 reach our clean up goals? We look at the implementability.
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Is this a difficult technology to implement, or is it fairly
easily, you know, fairly easy to obtain. And we also look
at the cost.
And for some reason, I don't know if I ran out of
room on this table, we also look at the long-term
effectiveness, which is, you know, in the long term, you
know, how much is it going to cost us to keep looking at
this remedy. Or if we shipped everything off, we don't have
any costs.
And then the ranking is based on criteria. These
criteria and how the contractors are viewed, the
alternatives with respect to each of these criteria. You
can come up with your own method of ranking the criteria,
okay? This is somewhat subjective.
We've chosen alternative 5b for the source materials.
We feel like it provides the best balance of the nine
criteria.
It's a technology that's fairly common. It removes the
problem,. There is no monitoring requirements. And the cost
of it to physically go out there and remove everything is
about 7.4 million.
Okay.
AUDIENCE: The next closest to that is about two
million less?
MS. BROWN: Which one are you looking at?
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I AUDIENCE: 5a, 6a, and 6b.
2 MS. BROWN: Right. 16:54:07
3 AUDIENCE: So all four of them achieve the goals? 18:54:07
4 MS. BROWN: Correct. 18:54:08
5 AUDIENCE: The two and a half million more to haul 18:54:08
6 it Off Site? 18:54:11
7 MS. BROWN: Correct. So it gets into how 18:54:12
8 important is it to remove everything, verses contain it on _18:54:14
9 Site. 18:54:19
10 AUDIENCE: How much would the monitoring cost, •' 18:54:21
11 say, over 20 years? 18:54:24
12 MS. BROWN: I think we came up with about 200,000. 18:54:24
13 AUDIENCE: So 20 years of monitoring for 200,000? 18:54:27
14 MS. BROWN: Right. 18:54:31
15 AUDIENCE: Two and a half million to haul it off? 18:54:31
16 MS. BROWN: .Correct. 18:54:33
I"7 You have some other problems, and that's the flood 18:54:33
18 plain issue and the wetland issue. I didn't mention this, 18:54:35
19 but that whole site is in a 100-year flood plain, and most ie:S.4:4i
20 of these alternatives are going to involve construction in a 18:54:43
21 flood plain, which the Corps of Engineers and FEMA are not 18:54:47
22 advocating any more at all. 18:54:55
23 And actually, we had a lot of discussions with 18:54:55
24 them about what we would have to do on this site to meet the 18:54:57
25 requirements. 18:55:04
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1 Anything we do out there is going to have to be
2 flood proof. It's going to have to be built a foot above
3 the base flood elevation.
4 We also have the problem of it being a wetlands.
5 We've already contaminated a wetlands, and if we leave it
6 there contaminated, we're going to have to go off site and
7 create a new wetlands.
8 And EPA has a preference for one, not building in
9 a flood plain. It's actually a policy, on building in a
10 wetland.
11 MR. TAYLOR: I just want to add something to that.
12 States learned from other sites that the soils in
13 the area, most of west Tennessee, erodes very easily. And
14 caps, anything above grade, which is basically anything
15 above ground surface down there at Ross Metals is going to
16 erode. There is a lot of costs associated with that.
17 And you can look at the long-term cost to the site
18 and just say, Well, look at 20 years or look at 30 years.
19 If you put that remedy in place, it's forever. It's going
20 to be there forever. And any costs associated with
21 maintaining that site, or monitoring that site will be there
22 for eternity. If you look at costs in that perspective, I
23 think you can stand the extra cost on the early phase.
24 We had a similar site at Gallaway that was continually
25 eroded. It was a stabilized site. All the waste was
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1 solidified, stabilized, but we kept having erosion problems.
2 Just couldn't deal with it. It was costing us 20 to $30,000
3 a year just to keep the site accessible and presentable
4 where it would keep the waste in the cap. It just didn't —
5 I didn't feel like it was worth the headache. Potential
6 failure.
7 MS. BROWN: Okay. ' And there's a more in-depth
8 analysis in the RI/FS.
9 The wetland alternatives, again, we had to look at no
10 action, for comparison purposes.
11 We also looked at capping. Leaving the contaminated
12 sediment in place, capping over it with clean fill and
13 creating an off-site wetlands. And it's a hard cost to come
14 up with, because we'd have to work with the Department of
15 Interior to come up with what value they place with — for
16 that wetlands. So we did the best we could with costing it,
17 but you actually don't know until you go into purchasing the
18 property.
19 And lastly, we looked at excavating all of the
20 sediments, and revegetating it, and restoring it based upon
21 a plan that Fish and Wildlife came up with. And we looked
22 at two options, both of which are good. One is regrading
23 with clean fill and then revegetating on top of it, or
24 regrading it with compost.
25 Are most of you familiar with compost?
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AUDIENCE: I know what compost is, and it was on
the back sheet of terminology, but there was no explanation
for clean fill. So my question is —
MS. BROWN: Clean fill is just dirt.
AUDIENCE: Just dirt. So compost seems the most
desirable of the two then?
MS. BROWN: Right.
AUDIENCE: Correct?
MS. BROWN: Mm-hmm.
AUDIENCE: All right.
MS. BROWN: There's different kinds of compost,
which you may be interested in as a citizen, because
different kinds of compost may have more smells than others.
We haven't specified at this point what type of
compost we want, whether we want it to be wood ash, whether
we want it to be sludge from the treatment ponds next door,
that are very organic rich and provide a very healthy
habitat for growing the grasses and different types of
vegetation.
AUDIENCE: This definition on the glossary thing
back here on the back of this sheet that came out said wood
ash compost or waste water treatment plant sludge.
Is that — so we're, at this point, optional on
which type —
MS. BROWN: Right.
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1 AUDIENCE: — of compost, but it would be compost?
2 MS. BROWN: Right. If that's something you would
3 like to comment on, there is some information available on
4 the internet.
5 AUDIENCE: I have no comment 'other than that I'm
'. 6 pleased that biosolids was better than clean fill.
7 MS. BROWN: Right. Yeah. And it would be very
8 nice if we could just use the sludge from next door. It
9 would be much cheaper.
10 AUDIENCE: The only problem (inaudible) —
11 MS. BROWN: You're right. You're absolutely
12 right.
13 AUDIENCE: What was the statement?
14 MS. BROWN: He said the odor would be a problem.
15 MS. TUCKER: Obnoxious.
16 MS. BROWN: And again, I did not make an overhead
17 of the evaluation of the wetland cleanup alternatives.
18 The only one, obviously, that doesn't meet protection
19 of the environment is the no action alternative. In both W,
20 alternative two and three, they both reduce — I'm sorry,
21 they both reduce the mobility, but alternative two does not
22 reduce the toxicity, or volume, because we're leaving it on
23 site.
24 So we're looking at, alternative two and three, at
25 costs of both about half a million, and we choose
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alternative 3b.
So we're looking at a grand total cost of about 7.7
million, and monitoring costs of about 240.
AUDIENCE: Is that over the cost to date?
MS. BROWN: Are you talking about present worth
cost?
AUDIENCE: No, the costs that have been incurred
to date?
MS. BROWN: No. No.
Oh, yes, you're right, this is in addition to what
we've already spent.
AUDIENCE: And it doesn't cover the groundwater?
MS. BROWN: Correct.
AUDIENCE: And it's not the grand total? The
ground water is still out of picture?
MS. BROWN: Right. I think, if we actually have
to do ground water cleanup, the highest cost we've seen
would be about half a million. We think that if we have to
clean up ground water there may be some more innovative type
technology that we should take a look at rather than the
traditional pump-and-treat . Ground water pump and treat.
AUDIENCE: Do you have a ballpark of what the
costs have been incurred to date?
MS. BROWN: No.
AUDIENCE: Ballpark?
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MS. BROWN: I'm sorry, no. Do you guys have any
idea?
MS. TUCKER: Total costs incurred?
AUDIENCE: Costs incurred to date?
MS. TUCKER: At the site?
MS. BROWN: For the —
See, we've done the removal and the investigation of —
MS. TUCKER: I think in the region of 1.4, I
think.
AUDIENCE: What was that figure on the estimates
of ground water, if indeed you think it might need some
treatment?
MS. BROWN: Pump and treat we looked at numbers of
about half a million.
All of the information on the ground water that we have
to date is still in the RIFS. We've just chosen at this
point to break it off, and we're going to collect more data.
So the numbers are all in the RIFS.
That brings up another point I wanted to make.
We've actually, as of this week, been able to put the RI —
well, the RIFS, on the internet. So I have a web address,
most everything in volume one is available. We're working
on volume two. It also has the proposed plan on there.
Why don't I go ahead and give you guys that
internet address.
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1 And I did not come up with this address.
2 We're still working on volume one. There may be
3 some figures or tables that still aren't available.
4 Okay, this is still one and this is — I'm not
5 misspelling this, it is under Ross M-E-T-L.
6 MR. TAYLOR: Beth, you might want to make those
7 dots a little bigger so people won't ...
8 MS. BROWN: Okay. Diane went over this so, just
9 to reemphasize the importance of your role, here in the next
10 30 days you have an opportunity either — actually in this
11 meeting as well, I will respond to your verbal comments in
12 this document called the responsiveness summary. I'll also
13 respond to any written comments. We haven't talked about
14 this, but you can request an extension as long as it's done
15 in a timely manner, and that would give you an additional 30
16 days.
17 AUDIENCE: That's 30 days from the end of —
18 MS. BROWN: December 1 through January 18th.
19 Okay. After the comment period is over, I write a
20 formal document that's called a record of decision. It's
21 actually about 40 pages or so long. It will also include
22 the responsiveness summary, which I hope won't be bigger
23 than the record of decision.
24 Then the next step is we will notice — PRPs is an
25 acronym for potentially responsible parties.
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Although Ross Metals owned the property, they did
business with a lot of folks, and we noticed them back in
the spring to let them know that we have their names, that
they may be potentially responsible for the contamination at
the Ross Metals site. So they are aware that we are about
to write a record of decision.
Once that's written up we'll send an official
notice letter to them and begin an official investigation.
Those typically run from three to six months, at
which point they will either decide not do the cleanup, or '
they will do the cleanup, with EPA's oversight, and we'll
sign a document, an official document, and EPA will be very
involved with the project even though the PRPs will actually
be spending their money to do the cleanup.
So — yeah?
AUDIENCE: I may not be remembering this
correctly, but it was my understanding this was being done
last time we met, six months ago.
MS. BROWN: Right. You're absolutely right. We
had noticed them back in the spring, which is actually when
we met .
Actually, the day we met with you was the day we
met with the responsible parties. They have actually been
waiting on EPA to write this record of decision. And once
we've done that, which will be in December, that is our
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legal — that's a — legally we can now notice them to do
the cleanup.
MS. TUCKER: This is all done through the regs and
statute. We can't notice them without having done the
remedy, selecting a remedy to clean up the site.
AUDIENCE: It was my understanding that was what
we were doing last time. And it was my understanding — as
a matter of fact I recall well, on the subject, which would
be 60 days from now we're going to do this and we'll do
that.
MS. BROWN: Right.
AUDIENCE: Obviously that hasn't happened. This
is still going on. How do we know if it really goes on?
How can we check on —
MS. BROWN: You're absolutely right. When I met
with you in the spring I said in July we will have a record
of decision. And at that point I had a remedial
investigation feasibility study, and it went through a peer
review. And one of the ground water hydrologists found
problems with our ground water .data. And so for the next
couple of months we were trying to figure out whether or not
we could go ahead and declare a pump and treat, or a cleanup
technology for ground water or not. So we actually spent
several months on that issue.
AUDIENCE: Well, if we run into something similar
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to that again, is there any way we, as the city and citizens
in general, will be notified of that, or is there anything
we can do to help it along?
MS. BROWN: I've been negligent. I should have
sent you guys fact sheets when I'm not meeting my schedule
with you.
AUDIENCE: I didn't mean to jump on Beth. I'm
trying to find out how we can —
MS. BROWN: I take responsibility.
AUDIENCE: — to make it work.
MS. BROWN: Fortunately, at this point I can say
with confidence, the record of decision will be written by
mid January. And I would like it to be written in December.
If no one requests an extension to the public comment
period, I can write it by December. And then really we'll
notice the PRPs in January. But if I have to wait until mid
January, we're not going to notice the PRP's until mid
January.
AUDIENCE: What value would it be to us if we had
an extension? Is that just simply to allow more people to
comment?
MS. BROWN: Right. If you don't feel like you've
had adequate time to review the documents, then you should
request an extension.
Now, how it will actually happen is, when you
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write your comments, if you have technical comments that
impact the decision that we've made. Say someone, you know,
writes some incredible, you know, dissertation on why we
should have chosen capping verses excavation and off-site
treatment, and they have a solid technological reason for
it, we have to consider it.
AUDIENCE: So assuming — you're going to have to
8 talk layman to me.
9 MS. BROWN: Sure.
10 AUDIENCE: My understanding is that the PRPs were
11 notified that they were responsible. What they are now, and
12 waiting for, is the amount of money that they are
13 responsible for. Is that correct?
14 MS. BROWN: Partially.
15 AUDIENCE: Because you didn't tell them — you
16 simply told them you're responsible?
17 MS. BROWN: Right.
18 AUDIENCE: But you didn't tell them how much money
19 they were going to have to come up with?
20 MS. BROWN: We didn't tell them what they were
21 going to have to do. We just said you're potentially
22 responsible, and we'll notice you at a later date that
23 here's what we want you to do.
24 So this record of decision will say, EPA has
25 selected, you know, treatment and off-site disposal. PRP's,
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AUDIENCE: All right. Now, my question is — all
right. If you — if the public comment period is over by
December the 18th, and you have a month there until the
middle of January to get this long, drawn-out, epistle
written, then you would notify these people in mid January,
and they now have three to six months? The three to six
months bothers me because, you know, I'm struggling here
with a Tag group that was fussing over why didn't we get
.•
cancelled in July, and August, and September, and October,
and November, and you say three to six months, and I don't
understand why three to six months.
MS. TUCKER: That is statutorily required as well.
I mean, it says so in the statute, you have 120 days to
negotiate.
AUDIENCE: If the negotiations period would be,
let's say I'm a PRP, I negotiate with you how much of that
millions of dollars I am willing or can spend? Is that
what we're negotiating?
MS. TUCKER: No. I think typically we're offering
you the opportunity to do the work, and that's the ultimate
statement. You do the work or we'll do the work.
MS. BROWN: But you're actually partially correct,
because they'll also be on the hook for everything EPA has
spent to date, so we have to negotiate that.
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1 Plus there's, in total, I think about 600 of them,
2 of which, you know, they all have to coordinate, and we have
3 to coordinate meetings with them.
4 So a lot of — unfortunately, a lot of it becomes
5 logistics between a large group of people. And you can
6 imagine with, you know, say 100 different people, they have
7 different interests.
8 AUDIENCE: Can they ask for an extension period of
9 more than six months?
10 MS. BROWN: That — yes, they can.
11 MS. TUCKER: They can, but it's gotten really
12 difficult to grant extensions. We try to stick to the
13 schedule of 120 days. And we have to have a good reason.
14 MR. TAYLOR: They ask for it, but we don't have to
15 say yes.
16 AUDIENCE: But in my public comment sheet that I
17 have here, then one of my public comments could be that no
18 extension be given to these PRPs. Is that correct?
19 MS. BROWN: Sure.
20 AUDIENCE: I mean, I assume I can say,anything I
21 want to, but ...
22 MS. TUCKER: You're entitled to.
23 AUDIENCE: And I won't have a problem with that.
24 However, you know, if we give them an extension
25 of, in addition to six months more then we are looking at
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beyond the year 2000, and personally I've waited 15 years,
and I'm not willing to wait another bunch.
MS. TUCKER: Well, we'll take that into
consideration then. This has been taking long, and we
really wouldn't want an extension to further delay the
project.
AUDIENCE: Because at this point, now, I see here
it says actual field work, September 1999, but what Beth
said was 2000.
MS. BROWN: Oh, Diane did.
MS. BARRETT: I was anticipating —
MS. BROWN: This is optomistic. And I came up
with four months of negotiations, and then a period of about
four months for designing the actual cleanup.
AUDIENCE: I thought the cleanup was designed.
MS. BROWN: No, the basic — let me explain that
part.
From the remedial investigation feasibility study,
that's all the information we've collected to date.
And now, say we had chosen to cap. Well, you can't
just go out there and build a cap. We don't have plans for
exactly how they should build it. You know, how much, how
high. These are conceptual diagrams that I've put in there,
but they're not engineering specifications.
AUDIENCE: I guess my question is, why in the
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world are we not just going ahead with figuring out what the
design will be, in December, January, and April? Why must
we wait for August if, in fact, you do go with these W-3b
and S-5b?
What's the reason for waiting until all of this
period of time has progressed before we go ahead with the
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design process? ' 19:14:49
It seems to me you could go ahead with that at
this point if, in fact, these are the two options that are
selected, and at least move the thing along by a few months.
MS. BROWN: That is an excellent question.
Unfortunately, I don't think you're going to like the
answer.
AUDIENCE: Oh, well all right, give it to me and
let me grump about that in my comments.
MS. BROWN: EPA has a preference for not spending
the superfund money, the EPA money. We have a preference
for the PRPs to spend their money.
*
So we have to — I don't know if it's statutorily
required.
MS. TUCKER: We have to do. We have to offer them
the opportunity to do the work.
MS. BROWN: I believe it's a policy, though, isn't
it?
So once you identified these group of people,
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which we now have, by law we are required to give them the 1S:15:37
opportunity. So you can't — 19:15:39
AUDIENCE: So what you're saying is —
MS. BROWN: Until we let them — 19:15:42
AUDIENCE: That these PRPs could essentially do 19:15:44
the work, or have the work done on this site themselves, and 19:15:50
the EPA would merely monitor what they do? 19:15:52
MS. BROWN: Right. 19:15:56
AUDIENCE: As opposed to the EPAs selecting people 19=15:58
tO do the Work? -19:16:00
MS. BROWN: Right. But everything that PRP does 19:16:01
is subject to EPA approval. If they select a contractor, I 19:16:03
have to approve it. If they submit a plan, I have to 19:16:08
approve it. 19:16:11
If they're out here doing field work, there's an 19:16:11
EPA representative on site most of the time. 19:16:16
AUDIENCE: All right. So is that the real big 19:16:17
advantage of having a TAG coordinator there? Is that the 19:16:21
big advantage? 19:16:2"?
MS. BROWN: Can you ask me one more time? I'm not 19:16:28
sure I understood. 19:16:31
AUDIENCE: If the PRPs do the work? 19:16:31
MS. BROWN: Mm-hmm. 19:16:33
AUDIENCE: Let's assume that. And the CAG group 19:16:39
gets a TAG grant? 19:16:39
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MS. BROWN: Okay.
AUDIENCE: Then is that essentially the biggest
advantage of having the TAG grant, and having that TAG
person on site to see that it's monitored?
MS. BROWN: It's certainly additional oversight.
AUDIENCE: But you have EPA do all of that?
MS. BROWN: Right.
AUDIENCE: And you may want to explain what the
TAG grant is. Some of the people may not know.
MS. BROWN: I'm going to let Diane answer that
one.
MS. BARNETT: A TAG grant is one that is offered
to a community, a work community, and each superfund site.
The site is on the national priorities list, so it does
apply. It is applicable for a group to request to receive a
TAG grant.
A TAG grant is, $50,000, and that's like -- it's
put into an account for the group, and then they would
select a consultant that would work with the group to go
over all of the documents, explain the documents to it, and
submit comments to EPA.
And as the work is done, then monies will be drawn
down from the account to pay the accountant — or the
consultant, excuse me.
Also, in a TAG grant, the group would put in like,
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I think it's been reduced down to about 10 to 15 percent
in-kind services, whereas like if you had an accountant that
would want to take care of the records, voluntarily, then
that would be in-kind service. So what the process, if you
are interested in that, you can submit a letter of intent to
the EPA.
AUDIENCE: I've already done that.
MS. BARNETT: Well, if Cindy has it, then she's
got that in process.
MS. BROWN: Any other questions?
Please feel free, because this is an important
meeting for you guys.
AUDIENCE: If you say that you're going to give
the PRPs the opportunity to clean this up. What's the
recourse if they don't do it?
MS. BROWN: Well, I'll let Marlene address that
one .
MS. TUCKER: If they refuse to do the work, EPA
Superfund's money will be used to do the work. Then, after
spending our funds, we will sue them for reimbursement of
all of the cost.
MS. BROWN: Three times? Not three times?
MS. TUCKER: Another option that we have — thanks
for reminding me.
We can issue a UAL, which is a Unilateral
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Administrative Order to order them to do the work. That's
another option.
MS. BROWN: We can ask them to do it. They may
agree, if we sign a certain kind of document. And if they
don't agree to it we can actually order them to do it. And
then if they still don't comply with this order, we can
actually sue them for three times the cost of our cleanup.
So in this case it would be, you know, $22 million.
MS. TUCKER: We actually have two other options.
We can do .the work ourselves, then sue them later, or we can
issue an order to force them to do it.
AUDIENCE: Up to this point it seems like we're
spending a mighty lot of time giving them the opportunity to
clean it up. I don't understand why they might want to
consider it.
MS. BROWN: In fairness to this group of
potentially responsible parties, most of them, the first
time they even heard about the site was in the spring of
this year.
AUDIENCE: I doubt that.
AUDIENCE: Has the delay until now been a result
of PRPs activities?
MS. BROWN: I still don't understand.
AUDIENCE: Has the delay from June until now been
the responsibility of the PRPs?
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MS. BROWN: No. It's been EPA's responsibility.
The PRPs actually have been waiting for this date and to be
notified to do the cleanup.
MR. TAYLOR: In fact, to the PRPs credit, they
have been doing what we've asked them to do so far. That
is, organizing themselves in a group, and getting ready for
this next notice letter which they know they're going to be
getting.
You know, if we had — if each of you were a PRP,
it would take a while for all of you to come together to
agree on how to do something. We noticed 128 of them. So
it naturally takes them a while to organize the group.
They have done that, and I think they're pretty
much ready for this letter to come. That is called the
special notice letter. It starts the negotiations for the
actual cleanup.
MS. BROWN: And some of these folks are folks that
sent their batteries to Ross Metals. They were battery
recyclers. Some of it was waste from their plants that they
sent to Ross Metals to recover the lead.
AUDIENCE: All these possibilities that they had at—
I don't know a better word other than stalling.
In other words, they could refuse to do the.work,
they could be cited and all of those different things.
Those are very time-consuming things, as I understand it.
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MS. BROWN: You're absolutely correct.
THE WITNESS: I'm still back on the 2000 problem.
MS. TUCKER: I just wanted to add, if we issue a
unilateral administrative order, it's effective in 30 days.
AUDIENCE: So if you tell them they must clean
up —
MS. TUCKER: That alternative won't create any
delay. In fact, it would expedite it.
MS. BROWN: Realistically, I mean, you're right.
If they enter in negotiationss with us, but they don't have
any intentions of doing a cleanup, but they're just, you
know, requesting an extension. You know, we have to
evaluate their requests —
MS. TUCKER: — in good faith?
MS. BROWN: — requesting this extension in good
faith? Are they really interested in doing the work?
At some point during this three to four months
we're going to have to decide, and if we don't think they're
acting in good faith, or we don't think maybe they are
acting in good faith but they can't come together, we'll
issue an order and then that really starts the clock
ticking, because if they don't comply with it within 30
days, EPA can hire a contractor to begin the design.
AUDIENCE: Whatever happened to the actual owners
that made the mess?
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MS. BROWN: There's rumors, but I don't know
anything for sure.
MR. TAYLOR: Well, Malcolm Ross is — the owner,
is dead. His son —
MS. TUCKER: His son I have spoken to, and I can
contact him. I don't have an address for him, but he has
called the 1-800 number and has spoken to me about
background of the ownership.
There is David Johnson, who appears to be a major
player as far as past owners. He has not been forthright in
his involvement, so he is someone what we'll end up deposing
so we can get on record the truth and have a document that
we can use in a court situation.
AUDIENCE: (Inaudible) — don't have any assets?
MS. TUCKER: As far as I know. You know, that's
something that, you know, I think we will eventually find
out more about.
AUDIENCE: Is David Johnson the son that you're
referring to?
MS. BROWN: No, Steve Ross. Steve Ross is the
son,
David Johnson, I think was the president of the
company for a while. When Malcolm Ross stepped out of the
picture, David Johnson and Steve ran the company.
AUDIENCE: I heard at one time, I thought maybe
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somebody in the family had gone to Mexico and maybe set up
an operation.
MS. BROWN: Yeah, we've heard they set up an
operation. Actually they were operating in Mexico; And do
you have any information?
AUDIENCE: They ran a joint project with another
company in Mexico.
MS. BROWN: And they cracked open the batteries in
Mexico. Again, this is — I've only heard this. They
cracked open the batteries in Mexico, and sent them to
Galviston where they then reclaim the lead.
AUDIENCE: In answering your question about
whether they have money, we're still looking?
MS. TUCKER: Right. It's hard to tell at this
point, but it's going to take deposing these parties and
swearing them under oath.
AUDIENCE: There's nothing to hook them on. If
there's anything to hook them on, we will, but if there's
nothing to hook, what can we do?
MS. TUCKER: In the meantime, we have 128 major
parties that we can get and try to get them to do the work.
And they also, these parties, once they sign on to
agree to do the work, they have a cause of action against
the owners if they have assets. So we'll just have to see
how it plays out.
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But for now we are more interested in getting to
the parties that we have, and know that they're doing things
and getting them to do the work. And we'll see who else
falls into that.
MS. BROWN: And it's a way of keeping you
informed. We can issue a fact sheet, you know, after the
negotiations are through to let you know who's signed on to
do the work, whether it's fallen to the early or whether
we —
Yes, sir?
AUDIENCE: As a matter of public comment, it seems
to me, the importance of the red tape is more important than
the need in our community. There's something wrong with our
system on this.
The people that have left the lead have all of the
opportunities to get out of it, and we have all - of the
opportunities to consume more lead.
The town is not big enough to do anything about it.
We've asked the federal government to help, and I can't tell
if the bigger pollutant is lead or red tape.
MS. BROWN: You know, I think most of us have been
working in the Superfund for a while, and I don't think
you'll hear any disagreements on our part.
AUDIENCE: I don't understand it. There's no
realistic question, in anybody's mind here, whether or not
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you're going to be able to collect any money from these
people. It won't happen. But still we go through this
dance, while we live here with the lead, and pay taxes to
support the Superfund.
MS. BROWN: Yeah. You're right.
I guess the only good news I have for you is that
there are no current risks to human health at the site.
There are, however, acute risks to the bio, the
bugs and the bunnies. We're taking action based on the
future risks, if someone should come into contact with the
waste or the soils, and the acute risks and chronic risks to
the bugs and bunnies.
AUDIENCE: Because we're looking at another year
MS. BROWN: Yes, ma'am.
AUDIENCE: —before anything happens, and it
makes me angry that there is all this time consumed in
giving these people an opportunity to delay it, and you know
darn good and well if you were one of these PRPs, you would
delay as long as possible, whether or not — you know, it's
a question of who we can get a hold of. And if Mr. Ross is
not get-a-holdable, then you'll go after the next fella down
the line.
And personally, it's going to come out of my
pocket one way or another, any way you look at it. YOU are
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not controlling the Superfund, you are controlling my pocket
book, and I'm ready to spend it.
MS. BROWN: Right.
AUDIENCE: And I resent the fact that these people
seem to have more rights than I do. And I — you know, this
is silly. I'm not joking.
Fifeen years is long enough, and you're telling me
now, that it ' s going to be another year and a couple of
months before the first possibility that you could actually
get your shovel in the dirt —
MS. BROWN: Right.
AUDIENCE: T-- is about to happen, and that's just
flat out unacceptable.
I mean, it is. It really is.
And I understand they have 30 days, they have 60
days, they have 120 days. They have been having 30, 60, and
120 days since last June.
MS. BROWN: I understand your point. I mean, I
guess that, again, EPA did take care of what we considered
the immediate risks.
AUDIENCE: And I appreciate that. In the last
meeting when we voiced all of the comments about the
dilapidated buildings and all of that, that you did come
right behind it and take care of that, and I do appreciate
that. Because I'm close enough to the site to be able to
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look at it out my back yard.
However, I know darn good and well that this little
town is expanding. We have 100 and some odd houses going up
here. We have a school here, and it's impossible for us, as
a community, to get more and more people here if they know
about it.
MS. BROWN: Well, if is an eye sore, there is no
doubt.
AUDIENCE: The eye sore is not the concern. In
other words, not all of these 100 and so houses know that we
have a superfund site less than four blocks away from their
houses. If they did, they might not be so anxious to plop
down $114,000 for a house.
MS. BROWN: We can help you out with that. That's
a matter of education. Because you guys are all aware of
the carrier plant in Collierville? That's a Superfund
site, and it certainly hasn't impacted Collierville1s
growth.
And every time that there is a business that wants
to locate next to that site, they write a letter to EPA, or
make a phone call, and I write a letter to them. And it
hasn't impacted their growth.
So it is possible to live next to a Superfund
site, and as long as we keep everyone informed and educated,
you know, you can survive the economic, you know, growth or,
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1 you know, you can encourage the growth.
2 AUDIENCE: You say that you have got it contained
3 in the fact it's piled on the concrete slabs?
4 MS. BROWN: Right.
5 • AUDIENCE: And it's covered with tarp?
6 MS. BROWN: Temporarily, yes.
7 AUDIENCE: What about all of that that's buried
8 out under the ground under the back? There is no cap or no
9 anything. These many years leads have been leaking out.
10 MS. BROWN:, We took samples above the slag, took
11 samples of the slag, and took samples below the slag. It's
12 not migrating very fast. We anticipate that it would take
13 about 70 years for the lead in that slag to impact ground
14 water.
15 AUDIENCE: Well, we've got 15 working on it.
16 MS. BROWN: I know. Unfortunately, folks, I don't
17 know that I — I'm not going to have any answer for you
18 tonight that's going to make you more comfortable with the
19 schedule at all.
20 I mean, I understand.
21 AUDIENCE: How come your late is September '99
22 date for the actual field work? -Is that pretty firm?
23 MS. BROWN: No. That's optimistic.
24 AUDIENCE: Wow.
25 MS. BROWN: I think if you talk to a lot of
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communities that have lived near a Superfund site, probably
the biggest complaint we hear is about how long it takes us.
It is the most common one I hear.
AUDIENCE: The good point is that things are in .
motion. Something is going to happen. There is a set
schedule, maximum is three, four, five years down the road.
It's going to be cleaned up.
MS. BROWN: Yes, it is.
AUDIENCE: Beth, is it all going to be off site?
MS. BROWN: That's EPA's preference.
AUDIENCE: Who makes the decision?
MS. BROWN: I do, with my management's approval.
I'm sure I'm going to have to respond to comments,
you know, for those that aren't in favor of treating it on
site and shipping it off, but we chose this on very firm
ground. We can back it up.
AUDIENCE: You're going to dig it out of the
ground and haul it off?
MS. BROWN: As far as I know. I can't think of
any argument that anyone would have that would make EPA
change their mind. And if, you know, the long shot, that
were to happen or information were to be, you know, to come
available to EPA, we'd have to come to you again.
AUDIENCE: When you get through with it we'll be
able to use it for anything we want to? Like a park or
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i5-.32-.os
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anything?
MS. BROWN: That's really going to depend on
whether EPA does the clean up, or whether the PRPs do the
clean up, and who actually will have control of the
property.
My understanding is there isn't a whole lot of
interest in that property ever being industrial. I mean,
it's in a wetlands, it's in a flood plain.
AUDIENCE: The history of the property is —. it
10 used to be in a park.
11 MS. BROWN: Right.
12 AUDIENCE: The city is interested in taking up a
13 study to see if it can be made into a park again.
14 ' - MS. BROWN: EPA would love that, and we're, if we
15 do it, I think, you know, it will happen. If the PRPs do
16 it, we'll work with the community and encourage the PRPs to
17 do that with the property.
18 AUDIENCE: Do you mean if the PRPs do it then they
19 will not necessarily have to do it to your specifications?
20 You mean —
21 MS. BROWN: As far as what the future use of the
22 property is?
23 MR. TAYLOR: He's talking about clean up levels.
24 AUDIENCT: From the answer that you gave me, that
25 if you do the job it would be done right. If the PRPs do
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the job, it might be done right or it may not be done right. 19:34:05
MS. BROWN: No, it will be done right, but the 19:34:17
difference is who owns the property after the clean up. 19:34:17
That was your question, right? 19:34:17
AUDIENCE: Well, no. I wanted to know about the 19:34:22
Clean up. 13:34:22
MS. BROWN: Clean up is going to be done right 19:34:22
whether we do it or the PRPs do it. 19:34:26
AUDIENCE: I want to know, according to you, other 19:34:26
than I would like to see it done correctly, and whomever " 19:34:29
owns it, the property could do with it whatever they want 19:34:31
tO. 19:34:34
MS. BROWN: After it's cleaned up — 19:34:36
AUDIENCE: After it's cleaned up. 19:34:38
MS; BROWN: Go ahead. 19:34:38
AUDIENCE: First of all, since I've been so ugly 19:34:40
to you, I want to tell you that these two options are the 19:34:42
ones I chose. I read this eleventy-seven times. Let's see 19:34:45
her type that. 19:34:50
MS. BROWN: How many typos did you find? 19:34:52
AUDIENCE: Well, being an English teacher, I did 19:34:54
pretty well and didn't look for that. 19:34:59
But these options were the two that I chose before 19:35:00
I read the back page to see which ones you had chosen. So 19:35:04
these were, without question, the two better options. 19:35:09
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47
1 My surprise, when we talked before the meeting began,
2 was that if the PRPs clean this property up, then
3 essentially it does provide them with ownership.
4 MS. BROWN: Well, actually — not ownership.
5 They're going to have to take control of the property
6 temporarily to do the cleanup. But then it's a matter of
7 who owes the back taxes, and all of that. And I think that
8 the county is going to have to put it up for sale.
9 AUDIENCE: Okay, the city and the CAG group, the
10 CAG group has already gone on record, but I want to make
11 sure that I make a statement tonight, that the CAG group
12 choice was that the property be turned over, purchased by,
13 or whatever legal requirements were necessary, by the City
14 of Rossville, to be used as community property, the entire |
15 tract of 7.5 acres. And that it be used — isn't that j
t
16 correct, 7.5?
17 MS. BROWN: You're talking about just the facility
18 record and the backfill?
19 AUDIENCE: Well, that plus the wetlands.
20 MS. BROWN: The landfill and the facility is about
21 eight, and then the wetlands is about another eight.
22 MS. BROWN: Right. Of about a 242-acre parcel.
23 AUDIENCE: Correct. That the entire tract of land
24 be turned over to the City of Rossville to do with for
25 community property; parks, recreational areas, community
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area.
And that, you know, that was our request in the
very back — or the very beginning of this.
MS. BROWN: And I think that's a great idea. And
maybe it's a matter of getting the county mayor — is it
still Jim Voss? — involved, because I'm not sure how your
local laws work with the —
AUDIENCE: When I talked to him he assured me if
the property was available, and the cost of it was back
taxes, that the city of Rossville would have no difficulty
in acquiring the property.
MS. BROWN: Would they have to bid against
other —
AUDIENCE: According to Mr. Voss, at that time,
no.
MS. BROWN: We need to look into that.
AUDIENCE: Because of the back taxes, and some
legal ramifications that were involved, that the city could
basically assume it.
MS. BROWN: Hmm. Let's get it cleaned up first.
AUDIENCE: I do care who owns it, very much.
MS. BROWN: For those of you that arrived late,
we're not trying to heat — make you guys hot, but we turned
the heat off so we could actually hear each other.
AUDIENCE: Who owns that property now?
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MS. BROWN: It's — nobody.
AUDIENCE: Well, somebody.
MS. BROWN: Back taxes are owed.
AUDIENCE: The company did?
MS. TUCKER: The company still owns it as far as
we know.
AUDIENCE: I thought you said it was
administratively dissolved.
MS. TUCKER: The corporation. It doesn't mean
that they don't own the property.
MS. BROWN: I mean, I've been told, you know, off
the record, that it's actually Greyhound that owns it.
AUDIENCE: You mean the bus?
MS. BROWN: They're a financial service that was
interested in taking over the property.
MS. TUCKER: I think they loaned —
MS. BROWN: In redeveloping it.
MS. TUCKER: They loaned the money to David
Johnson to purchase it from Malcolm, so somehow they have a
financial investment in the property.
MS. BROWN: All I know is the county called me
about two years ago wanting to foreclose on it for back
taxes, and decided not to because it was a Superfund site,
and they didn't know that this — if they bought the
property today they might get a letter saying you have to
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1 clean it up.
2 AUDIENCE: So Greyhound actually, on the record
3 book, owns it at this point?
4 MS. BROWN: I can't say for sure.
5 MR. TAYLOR: I think, on the record book, if you
6 went up to the courthouse, I think you would see Ross
7 Metals, Incorporated is the official owner.
8 But, again, that company has been administratively
9 dissolved, and the taxes have not been paid, and I think
10 that's what you're referring to.
11 AUDIENCE: Is it possible that Greyhound have
12 mortgage interests in the property?
13 MS. TUCKER: I believe that may be the case, yeah.
14 MS. BROWN: Greyhound actually looked into
15 cleaning it up themselves a number of years ago when we were
16 doing the removal, and the deal fell through. EPA
17 negotiated with them.
18 Well, I tell you what, we'll hang around here if
19 anybody, else would have any questions they have for us.
20 So, you know, as far as the official meeting,
21 thank you very much for coming.'
22 MS. BARNETT: One quick question.
23 MS. BROWN: Sure.
24 MS. BARNETT: Did everybody sign in?
25 And the reason I ask this is that if you did not
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get mail, and if you want to receive information about the
site in the future, be sure to sign this so I can make sure
you're on the mail list to receive it.
So I just want to make sure you sign this.
That's all.
MS. BROWN: Thanks again.
(Whereupon, the public meeting
was concluded at 7:40 p.m.)
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