United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R04-86/013
Sept 1986
SEPA
Superfund
Record of Decision
Gallaway Ponds, TN
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TECHNICAL REPORT DATA
(Please ,ead Instructions on the ,evene before completing)
,. REPORT NO. r. 3. RECIPIENT'S ACCESSION NO.
EPA/ROD/R04-86/013
4. TITLE ANO SUBTITLE 5. REPORT DATE
SUPERFUND RECORD OF DECISION _L 'J<:: 1QR~
Gallaway Ponds, ':m 6. PERFORMING O""RGAN'ZATION COOE
7. AUTHORIS) 8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADORESS 10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME ANO ADDRESS 13. TYPE OF REPORT AND PERIOD COVERED
u. S. Environmental Protection Ag ency 1;';n:>l Dr\n. n -~
401 M Street, S.W. 14. SPONSORING AGENCY CODe""
Washington, D.C. 20460 800/00
15. SUPPLEMENTARY NOTES
16. ABSTRACT
The Gallaway Ponds site is located 2.3 miles northeast of Gallaway, Fayette County, ..
TN. The site lies near the top of a low ridge composed mainly of gravel, sand, afrd clay
terrace deposits. The ridge has been extensively mined for sand and gravel, producing a
landscape dotted with water-filled pits up to 50 feet deep. The site encompasses the
land area adjacent to and including nine ponds located within a currently inactive
(5-acre) portion of a larger (50-acre) active sand and gravel operation. One pond,
designated Pond 1, was used for the disposal of liquid and solid waste, including
pesticides, glass jars containing solid waste, and dr urns. Some pits have been used for
the disposal of residential trash, demolition debris, and appliances. Disposal of
hazardous materials at the site occurred for an undetermined period of time, probably in
the 1970 s or early 1980s. Drums containing liquid waste were disposed of by emptying
the drums into a small pond or by placing the entire drum into the pond. Small glass
bottles containing "quality control" samples from pesticide blending operations were
disposed of directly to the small pond. No disposal activities at this site have ever
been permitted by State or local authorities. I n October 1983, the EPA conducted an
emergency cleanup of Pond 1, consisting of the excavation and offsite disposal of
contaminated sludges and the onsite treatment of the water in the pond. The treated
water was subsequently discharged to Ponds 2 and 3, located east of Pond 1. The primary
(See Attached Sheet)
17. KEY WORDS AND DOCUMENT ANALYSIS
OESCRIPTORS b.IOENTIFIERS/OPEN ENDED TERMS C. COSA TI Field/Group
a.
Record of Decision
r:.;allaway Ponds, TN
Contaminated Media: soils, sediments, sw
Key contaminants: pesticides, inorganics,
organics
18. DISTRIBUTION STATEMENT 19. SECURITY CLASS (TlJis Report) 21. NO. OF PAGES
Nnn/3 JIg
20. SECURITY CLASS (TlJis page) 22. PRICE
Nr\n/3
EPA '01",2220-1 (R.".4-77)
PIIIEVIOUS EOITION IS OBSOLETE
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EPA/ROD/R04-86/013
Gallaway Ponds, TN
16.
ABSTRACT (continued)
contaminants of concern include:
toxaphene.
The selected remedial action includes: excavation of contaminated
sediments from Ponds 2 and 5 with onsite disposal in Pond 1; proper site
closure under Subtitle C of RCRA; dilution of water from ponds 1,2, and 5
with city water to meet Ambient Water Quality Criteria and subsequent
discharge to unnamed tributary; institutional controls which will be fully
identified during remedial design; ground water monitoring; inspection and
maintenance of the cap. The estimated capital cost is $344,735 with 30-year
O&M present worth_costs of $163,265.
pesticides, inorganics, chlordane, and
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REroRD OF D&::1S1oo
REMEDIAL AUI'ERNATlVE SELECrION
srrE
Gallaway Ponds site, Gallaway, Tennessee
rx:x:tMENI'S REVIEWED
I am basing my decision prinarily CI1 the following documents describing
site specific conditions and the analysis of cost-effectiveness of remedial
alternatives for the Gallaway Ponds site:
- Gallaway Ponds Remedial Action Master Plan
- Gallaway Ponds Focused Remedial Investigation
- Gallaway Ponds Focused Feasibility Study
- Fennal Review by the Agency for Toxic Substances and
- Gallaway Ponds Hazardoos Waste Site Clean~ Report
- Staff Reo:mnendations
Disease Registry
DE:S:RIPI'ION CF '!HE SE:LEC1'ED REMEIJ.{
.
The selected rerredy includes:
- Excavation of contaminated sediments fran Ponds 2 and 5 with onsite
disposal in Porrl 1.
:- Proper site closure under Subtitle C of RCRA.
- Dilution of water fran Ponds 1,2, and 5 with city water to meet
Ani:>ient Water <:uality Criteria and subsequent discharge to unnamed
tributary.
- Institutional controls, \totrich will be fully identified during
remedial design, will be inplemented.. These controls nay include,
but will not be limited to:
- fencing the remediated Pond 1 area,
- instituting a mining restriction on the remediated Pond 1
area, .
- ensuring future land uses canpatible with the remedy
- Operation and Maintenance (O&M) activities will incl\.rle:
- groundwater rronitoring
- inspection and naintenance of the cap
Additional O&M activities nay be identified during the Remedial Design.
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DOCIARATlOOS
Consistent with the Carprehensive Environmental Response, Catpensation,
and Liability Act of 1980 (CERCIA), and the National Contingency Plan (40
CPR, Part 300), I have determined that the above Description of the Selected
Renedy for the Gallaway FUnds site is a cost~ffective ranedy and provides
adequate protection of public health, \tJelfare, and the environment. '!he
State of Tennessee has been consul too and agrees with .the approved." remady .
I have also determined that the action being "taken .is appropriate when
balanced against the availability of Trust FUnd Monies for use at other
sites.
SEP 2 6 1986
~~£ ~~-
Regional Administrator
D3.te
.
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REOORD OF DECISIOO
SUMMARY OF REMEDIAL ALTERNATIVE SELEcrIOO
GALLAWAY PCNOO SITE
GALIAWAY, TENNESSEE
SITE UXATION AND DESCRIPTION
The Gallaway Ponds site is located 2.3 miles northeast of Gallaway,
Tennessee, in Fajette COlmty. The site lies near the top of a low ridge
canposed mainly of gravel, sand, and clay terrace deposits. The ridge
has been extensively mined for sand and gravel, prcxlucing a landscape
dotted with water-filled pits up to 50 feet deep. Sane of these pits
have been used for the disposal of residential trash, demolition debris,
and appliances.
The site as defined by the Remedial Investigation encompasses the land
area adjacent to and including nine ponds located within a currently
inactive (5 acres) portion of a larger (50 acres) active sand and gravel
operation. Ole pond designated as Pond 1 was used for the disposal of
liquid and solid waste (mainly pesticide or pesticide residtes), glass
jars containing solid waste, and drums (see Figure 1).
Land usage within about one mile of the. site is mainly agricultural. Of
three properties adjacent to the site, two are now or ~re recently used
for gravel mining operations silTIilar to those carried on at the site.
The remainder of the land not used for agricultural or mining purposes is
woOOed .
The nearest surface water, wi th the exception of abandoned gravel pits
that contain standing water, is an unnamed tributary of Cane Creek. Cane
Creek drains southward to the Loosahatchie River. Runoff from the site
is largely contained within the property and infiltrates to the water
table, rather than discharging to surface waterwazs (see Figure 2).
The formations significant to the hykogeologyof the site are the
. Jackson Formation and the overlying water-bearing deposits. The Jackson
Formation, which is rOl1Jhl y 90 feet in thickness, is iffil:X>rtant because it
h~raulically separates the water-table aquifer, which prodoces only
small domestic supplies, from the underlying, confined sands of the
Claiborne group, which is a major municipal water source (see Figure 3).
Based on available information, the nearest active private water supply
~lls are located about 1,600 feet west of the site. All of the well
logs examined indicated that these wells are screened in the water-
bearing sand zone which underlies the Jackson clay. Municipal wells
located about 2 miles to the southwest of the site supply water to the
town of Gallaway. The church, located adjacent to the site, is supplied
with water fran the Gallaway municipal water szstem.
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TENNESSEE
LOCATION MAP
GALLAWAY PONDS SITE, GALLAWAY, TN
SCALE: .I": 2ocx:l
FIGURE 2
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~
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~
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\\
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,...
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'~, B
'~, t
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\ '...
-...
I ,
/ I
, I
I
LEGEND
If
(? n
@
PONO NUMBER
- t ~
INTERMITTENT SURFACE WATERCOURSE
AND DIRECTION OF FLOW
POND LOCATIONS
GALLAWAY PONDS SITE,GALLAWAY,TN
SCALE c I" = 200'
FIGURE 1
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w
z
~
Ci
..J
U
u
2 UJ
z
0 w
Z > g
w
u a: w
ct ~
~
a: N
UJ
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)(
0 0
(.) ..
..J N
i
1ft
en
1ft
,
8
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~ 30-=-70
FORMATION
.;:::~: Y:":'::.:~~I: ;~::,:;:{~~;
. ...~'r\.:~:~:
.'-.::: i~.:..:-;:"'..":'. :~.. ~;-~
:~;l:.i:,~~'::.:i~:~~,':~:.~: <~
. 1400 -FOOT SAND"
---------
----------
---------
----------
---------
----------
---------
----------
---------
----------
---------
----------
---------
----------
---------
----------
---------
----------
------.--
----------
LOWER CLAY
(FROM MOORE. 196~; CRINER. SUN. AND NYMAN. 1968 )
.... .-........,
a.AYTOO SAND
---------
----------
---------
----------
---------
----------
---------
----------
---------
----------
---------
PORTER'S CREEK CLAY
FIGURE
3
PARTIAL GEOLOGIC COLUMN . GALLAWAY. TN .AREA
GAu..AWAY PONDS SITE. GALLAWAY. TN
NOT TO SCALE
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-2-
SITE HISTORY
Disposal of hazardous materials at the site occurred for an undetermined
period of time, probably in the 1970's or early 1980's. Drums containing
liquid waste were disposed of by emptying the drums into a small pond or
by placing the entire drum into the pond. Also, small glass bottles
containing "quality control" samples from pesticide blending operations
were disposed of directly to the small pond. No disposal activities at
this site have ever been permitted by State or local authorities.
In January 1982, the Tennessee Division of Solid Waste Management (TDSWM)
received a report from a citizen concerning the dumping of drums and
smaller containers into a gravel pit near Gallaway, TN. This person also
indicated that there was a strong odor of pesticides in the area. TDSWM
personnel investigated the incident and noticed that labels on some of
the containers made reference to Arlington Blending and Packaging Company
(ABPC), a small pesticide blending company located in Arlington, TN.
TDSWM's inspection of the site revealed that sane of the containers had
been removed from the pond. They later learned that the owner of ABPC
had conducted the removal. During this inspection TDSWM personnel collected
water and sediment samples from the pit for analysis. The analytical
results showed elevated levels of pesticides.
The Gallaway Ponds site was proposed for the National Priorities List (NPL)
in December 1982, and was finalized in early 1983 with a MITRE score of
30.77. In October 1983, the EPA conducted an emergency cleanup of Pond
1, consisting of the excavation and offsite disposal of contaminated
sludges and the onsite treatment of the water in the pond. The treatment
process involved the carbon filtration of the pond water to limits established
by the Tennessee Department of Health and Environment (TDHE), Division of
Water Quality Control. The treated water was subsequently discharged to
Ponds 2 and 3, located east of Pond 1. In February 1984, EPA obligated
funds to conduct a Remedial Investigation/Feasibility Study (RI/FS).
NUS Corporation was tasked to perform the RI/FS. Based on extensive
discussions with the EPA On-Scene Coordinator for the federal clean-up action
and a review of site background data, it was determined that a focused RI
would be appropriate for this site.
The Focused Remedial Investigation Report was finalized in April 1986.
The draft Focused Feasibility Study was completed in June 1986. The public
cotment period ended on August 12, 1986.
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-3-
SITE CWNERSHIP
'!he site has been userl for sand and gravel mining for nany years.
Mr. Bermie Ibve, the forrrer site OIffier, leaserl the prq:lerty for mining
cperations and had no connection with the waste disposal practices
at anytiIre.
In 1984, Mr. Billy Ray a~uired the property. His intended use of the
50-acres was to mine the retraining gravel deposits. He was asked to
cease his active mining operations in the site ,investigation areas to
allcw for EPA rerredial investigation stwes. Mr. Ray is currently
re~ning gravel deposits in ITUch of the surrounding areas.
.
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-4-
CURRENT SITE STATUS
The Focused Remedial Investigation included a sanpling program for the
following environmental media: surface water and sediment, surface
soils and groundwater. The following sections describe the results of
this investigation:
ONSITE SURFACE WATER/SEDIMENT (Ponds 1-9)
Contaminants detected in the surface waters of Ponds 1, 2, 5, 8, and 9
exceed the acute Ambient Water Quality Criteria (AWQC) for the following
parameters (see Table 1): Pond 1 - chlordane, Pond 2 - toxaphene,
Pond 5 - cadmium, Pond 8 - arsenic, and Pond 9 - cadmium.
Chronic AWQC limits are exceeded in Ponds 1, 2, 3, 4, 8, and 9 for
pesticides and in Ponds 5, 8, and 9 for inorganics. These contaminant
levels are high enough to be harmful to aquatic life and probably preclude
the presence of many sensitive species in the ponds.
The sediment in Ponds 1, 2, 3, 4, 8, and 9 showed pesticide contamination.
Chlordane is the most prevalent contaminant, with a few occurrences of
dieldrin and toxaphene. The sediment, in Pond 7 contained cadmium above
background levels, while ponds 8 and 9 contained high levels of arsenic.
SURFACE SOILS
Chlordane was detected in the surface soils around the northern half of
Pond 1 and between Ponds 1 and 9. Arsenic and cadmium were also detected
in the surface soils. Similar levels of arsenic were detected over much
of the site, as well as in two background locations, and therefore its
presence may not be site-related. Cadmium was detected in a sample
located west of Pond 1, which was the same sample that contained the
highest chlordane value. Cadmium was also detected in a sample that was
located between Ponds 1 and 3 (see Table 2).
GR3UNDWATER
No pesticides were detected in the subsurface soil sample located
west of Pond 1. Samples were collected at 5-foot intervals from a depth
of 5 feet to a depth of 52 feet. As a class, pesticides have low
mobility and therefore, are unlikely to migrate to any great depth.
Chloroform, a cannon laboratory solvent, was estimated to be present at
very low levels (less than the contract-required detection limit) in the
upper 10 feet of the boring. Other volatiles, which were not found
elsewhere on site, were found in the deepest subsurface sample at a depth
of 51 feet. This sample was collected from within the top of the Jackson
clay. Cadmium was also present in this sample. It is possible that the
clay has concentrated the volatiles and cadmium from the groundwater,
although these contaminants were not detected in any of the groundwater
samples.
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Pond
Chlordanl
AWQC. 2.4/0.0043 uAII
MI.. Sid. MI.. SW
Conc. IDDbt Conc. IDDbt
TABLE 1
POND SAMPUNO DATA COMPARED TO
.-NT WARR QUAUTY CRrTIRIA
QAUAWAY PONDS SIR
QAUAWAY. RNNESS£E
Dllldrln
TORlDhlnl
Awoe . 2.5/0.0019 uall
Mil&. Sid. MI.. SW
Cone. ID"t ~. IDDbt
AWoe. 1.8/0.013 uall
MI.. Sid. MI.. SW
Conc. IDDbt Conc. IDDbt
31.000 2.8
500 (0.07) 2.900 17
890 10.13)
890 (0.12)
2
3
4
5
6
7
8
.
2.200
1.3
0.87
NO"I:
1.400
1.4
0.40
280
(1.8)
AWoe
SW
ppb
I )
- Ambllnt WI"r Quality Crltlrll (USEP,," October 1980 end USEP,," Flbrulry 1884) - AcUlIlChronic
- SUrflCI .atl'
- Panl plr billion (1',/.)
- Calculated valu.
- "ot de"cted In mldll or n01 calculated
AWoe 'or cldmlum II b..ld on hlrdnlss
-
"'Ienlc
AWoe . 140n2 uall
MI.. Sed. Ma.. SW
Conc. (DDbt Conc. (DDbt
Cadmium-
Awoelacu1.) . 10.73) 11811 - Pond 8
(ut ..all - Pond 5
Ma.. Sed. MI.. SW
Conc. IDDbt Conc. (Dollt
5.200 (14)
5.400 14
5.400 12
19.000 150)
5.000 (13)
8.100 18
7.300 (19) 5.5
28.000 200
2'.000 48
5.1
1.3
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TABLE 2
FREQUENCY AND OCCURRENCE OF CHEMICAL PARAMETERS
OALLAWAY PONDS SITE
RESULTS OF THE PHASE 1 - FOCUSED REMEDIAL INVESTIGATION
OALLAWAY. TENNESSEE
(Result* Reported hi ppb Unless mooted Otherwise)
Surf«c» Waler
Sediment
Chemical Parameter
Ring* ol
O«t*cllon>
(low/Hlghl
Surt«c« SoU
No. ol D«t*cllont/
No. ot S«mpl«i
Rang* of
Detections
(Low/High!
No. of Detection*/
No. of Semplet
Range of
Detection*
(Low/High!
No. of Detection*/
Mo. ot Sample*
Monocvclk Aromatic*
ethylbeniene
toluene
toUl xylanes
Hatogenated Aliphatic*
1. 1. 1 -tricldoroethane
m«thyl*n« chloride
chloroform
K»ton«i
•c*lon«
2 butanon*
Polvnuclair »rom«llci
b«nio(i)«nthrtc(n«
Phth»l»t»
380
430
2/15
400
Wt(2-«thv«Miivl)phlh«Ul«
dl-n-octyl phlhiUI*
P«»tlcld«i/PCB»
chlordin*
dtaidrtn
•ndrin
•ndrtn ktton*
toxtphcn*
067
040
0.05
0.11
2.6
1.4
0.14
0.25
17
4/15
2/15
2/15
2/15
1/15
500
2.300
70
100
14.000
280
2.900
3/13
1/13
1/13
7/13
2/13
1/13
1.000
1/12
46
4.500
3/12
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TABLE 2
FREQUENCY AIm OCCURRENCE OF CHEMICAl PARAMETERS
GAUAWAY PONDS SITE
RESUlTS Of nfE PHASE 1 - FOCUSED REMEDIAlINVEST1OAT1ON
GAUAWAY. nM'8:SSEE
IRe'" R8p0rt8d In ppb UnIn. 1ncIc118d Otherwt..t
,AGE 1WO
Surfici Wlt,r Sldlmenl Surllce SolI
Ringe of Ringe of Ring. o'
Det.ctlon. No. 0' D.tecllon.1 Detecllon. No. 0' Detectlon.1 Delectlon. No. 0' DellCllon./
Chemical Plrlmeler (lowlHlahl No. o. Simple. (lowlHlahl No. 0' Simpl.. (lowlHlahl No. of S.mple.
Miscelleneous c-.DOUnds
propenol 5 1/t3
b.nzolc Kid '00 1113
h.lI8ndlolc .cld. dloctyf ..t.r 800 3.000 3/13
prom.lryne 1.000 1/13
(mglkgt (m8l'gt
Inora8R~' . 15,000
.Iumlnum 100 20,000 15/15 5.800 13/13 8.300 2',000 13113
.rs.nlc 12 200 8/15 5. 28 11113 2.8 30 12113
b.rtum 30 250 1.115 55 150 13113 38 130 12113
b.rylllum 0.7 1.8 ./15 0.'7 1.1 11113 0.4' 0.88 11113
cadmium 5.1 5.5 3/15 5.5 1113 3.2 U 2113
c.lclum 2.700 32.000 15115 800 5.500 13113 720 '0.000 12113
chromium '.8 56 10115 U 28 13113 10 20 13113
cob.1I 13 15 2115 8 18 13/13 5.8 13 12113
copper 5.3 80 13/15 '.2 45 13/13 8.7 27 12113
Iron 100 51.000 15115 12.000 34.000 13/13 13:000 30.000 13113
leld 3 38 12115 7.5 58 13/13 U 20 13113
m.gn"lum 1.500 12.000 15/15 1.200 2.800 13/13 880 3.200 12113
mang...... 12 2.800 15115 180 1,100 13/13 130 740 13113
m.rcury 0.2 .0.3 7113 0.2 0.3 2/13
nickel 8.4 280 10115 8.7 21 13/13 7.' 21 12113
p01.lIlum 1.'00 3.800 14115 1.000 1.400 4/13 750 1.300 7113
.odlum 2.800 11 .000 15115 800 8.000 8113 3.000 4.000 10113
"Inldlum 5.7 88 8115 18 .. 13113 21 .. 13113
zinc 20 180 12115 35 170 13113 20 84 13113
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TABLE 2
fREQUENCY AND OCCURRENCE Of CHEI8CAl PARAM£TERS
GAllAWAY PONDS SITE
RESUlTS Of THE PHASE 1 - FOCUSED REMEDIAl INVEST1OATION
GAllAWAY. TENNESSEE
(Reaultl Reported In ppb Unlell lndIc.ted Oth8fWlse)
PAGE ntAEE
Chemlc.1 Paramet.,
Subsurf.ce 5011
Ranae o'
Detection.
IlowlHlgh)
Groundwater
R.nga o'
Delactlon.
. IlowlHlgh)
No. 0' Detectlon.'
No. 0' Samples
No. o. Oelectlon.'
No. 0' Sampla.
Monocycllc Arom.tlc.
ethylben18ne
tolu-
total IIV'-'
21 1111
.0 1111
It 1111
13 1111
3.8 U 3111 3.1 .3.8 218
3.8 1111
H.loa8n.ted AlIDh.tlu
" '.' -trlchloroeth.ne
methylene chloride
chloro'orm
Ketone.
.cetone
2 bul8none
Polynuclear arom.tlc.
benrot.lanthracene
Phth.l.te bt8fl
blst2 -e'hylhe..,t)phth.I.,.
dl-n-octyt phth...te
230
310
3/11
Pe.tlcld../PCSI
chlord.ne
dieldrin
endrtn
endrln ....one
touphene
Ra.ld.n,I.1 Well.
Ranga o.
Detection.
(LowlHlght
No. of Oetectlon.'
No. of S.mpI..
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TABLE 2
FREQUENCY AND OCCURRENCE OF CHEMICAI PARAMETERS
GAUAWAY PONDS SCTE
RESULTS OF THE PHASE 1 - FOCUSED REMEDIAL MVEST1OAVION
GAUAWAY. TENNESSEE
(Results ItoponMl hi ppb Untott Indicated Otherwise)
PAGE FOUR
Chemical Parameter
Miscellaneous Compounds
propanol
bmzolc •eld
hexandtolc KM. dloctyl ester
prometryne
Inorganics
•lumlnum
arsenic
barium
beryllium
cadmium
calcium
chromium
cobalt
copper
Iron
toad
magnesium
manganese
marcury
nickel
potassium
sodium
vanadium
zinc
Rang* of
Detections
(Low/High)
Suhmuriace Soil
No. of Detections/
No. of Samples
Range of
Detections
flow/High)
Groundwatar
No. of Detections/
MO of Samples
Range of
Detections
(Low/HlQht
R«ildantlal Walls
No. of Detections/
No. of Samples
(mg/kg)
1.200 13.000
10
4.300
5
10
20
20
IB
20
18.000
17
•00
30
140
11/11
1/11
4/11
11/11
11/11
8/11
4/11
0/11
320
13.000
10
28
900
56
3.300
52
94
3.300
21.000
IS
1.100
120
41.000
23
140
6.500
7.4
20.000
370
0.2
140
3.800
82,000
82
8/8
1/8
878
4/8
8/8
8/8
2/8
7/8
B/B
1/8
7/8
2/8
B/B
678
17
3.800
2
1.700
14.000
IS
180
S.O
6.000
12
6.000
3
4.600
110
2300
20.000
21
3/3
1/3
3/3
1/3
1/3
2/3
3/3
1/3
1/3
3/3
in
Note:
Sampling performed by NUS Corporation In January and May 1985.
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-5-
The groundwater beneath the site currently appears to be free of site-
related contaminants and does not appear to present any risk to offsite
receptors.
OFFSITE
No site-related contaminants were detected in offsite surface waters.
One offsite sediment sample, located in a tributary of Cane Creek south
of the site, contained chlordane and dieldrin. The presence of pesticides
in this sediment sample may be the result of either erosion of onsite
soils or the local agricultural application of pesticides. No site-related
contaminants were detected in offsite drinking water.
HYDRCGBOLOGY
Ground Water Characteristics. The water-table gradient is fairly flat
across the site, although the depth to the water table surface varies
with topography. The depth from the ground surface to the water table in
the monitoring wells ranged from approximately 25 feet to 45 feet.
Groundwater generally flows from, east to west beneath the site. A
groundwater divide may exist on site such that groundwater in the northern
half of the site tends to flow to the northwest, whereas groundwater in
the southern half of the site tends to flow to the southwest. The
groundwater flow direction may be controlled to sane extent by discharge
into the nearby stream headwaters.
TRANSPORT ROUTES
Due to the behavior of these pesticides in soils, they would tend to
adsorb to the sediments and remain in-place. Table 3 lists the relative
mobilities of several pesticides in soils. The pesticides of interest,
chlordane, dieldrin, and toxaphene, are immobile. Aside from the chemical
structure of these pesticides, soil properties also influence adsorption.
The low permeability of the pond bottoms does not favor infiltration of
contaminants into the groundwater. Clay and organic matter content tend
to be highly correlated with pesticide adsorption. Soil/sediment adsorption
coefficients of the pesticides found on site also indicate that the
pesticides are not readily transported in solution to groundwater but
tend to adsorb to soil particles.
The tendency of pesticides to leach from soils is inversely related to
their potential for adsorption. Strongly adsorbed molecules are not
likely to move downward through the soil profile. Therefore, conditions
which encourage such adsorption will discourage leaching.
Therefore, if the contaminanted soils were to be transported offsite it,
would be via storm water runoff or the wind.
-------
TABLE 3
RELATIVE MOBILITY OF PESTICIDES IN SOILS*
Inmobile S11ghtly Mobfle Mobile
Aldrin Atraz1ne 2.4-0
Chlordane Simazine 2.4.5-T
DOT Prometryne MCPA
Dieldrin AzinophoSlllethy.1 Pic !oram
Endrin Carbophenthion Fenac
Heptachlor Diazlnon
Toxaphene Ethlon
TOE Methyl parathion
L1 ndane -4 Lindane
Heptachlor epox1de . Heptachlor epoxide
Trifluralin Parathion
Phorate
Oluron
Manuren
. L i nuron
CIPC
IPC
EPTC
Pebulate
* Pesticide Disposal and Detoxification - Processes and
Techniques, 1981.
-------
-6-
RECEPIDRS
At the present tine, no receptors have been identified at the site.
Potential receptors at the site include the following:
- Employees of the gravel company who came into contact with the
contaminated soil and pond sediments will be exposed to both
a dermal and an inhalation condition.
- Casual intruders who regularly traverse the site will be exposed
to contaminated surface soils.
Local residents who swUn in the ponds will experience both very
low dermal and (accidental) ingestion exposures to contaminated
sediments and surface water. However, the use of the ponds for
swimming is expected to be highly infrequent.
- Local residents who may regularly consl.JT\e fish fran the ponds would
be at a very low risk; however, present site conditions make this
repeated, long-term exposure unlikely because fish are not known
to be present in any of the ponds.
Local residents who may regularly consl.JT\e fish fran the nearby streams
which receive sediments or runoff fran the site could, throtr;;lh the
food chain, be exposed to contaminants that have migrated fram the
site.
Offsite biota, in the tributaries that receive runoff of pond water
overflow during heavy rainfall, could be adversely affected by site-
related contamination.
- Persons using driveways constructed with sand and gravel fran
the pits, where the sand and gravel has not been covered with asphalt.
Because of the tendency of this material to "set up" after a rain,
exposures will be very limited.
RISK ASSESSMENT
A quantitative risk assessment was performed for various contaminant
exposure pathways. Risks for the exposure pathways were calculated
for the site for the conditions of both mining and no-roining. Based
on the available data and the risk assessment assumptions, the
exposure pathways present no unacceptable risks to human receptors
under both the no-roining and mining conditions. The risks for each
pathway were all less than 1 x 10-6 to hllTlans. Tables 4 and 5 present
summaries of the carcinogenic risks posed by the resumption of mining in
the area of the contaminated ponds. The only unacceptable risk presented
by the Gallaway Ponds Site is the potential risk to offsite biota that
could occur if Ponds 1, 2, and 5 would overflOliol to offsite tributaries.
Table 6 contains ceiling contaminant concentrations (action levels) that
could cause biota risks.
-------
TABLE 4
CARCINOGENIC RISKS FROM DERMAL EXPOSURES OF
MINING COMPANY EMPLOYEES
GALLAWAY PONDS SITE
GALLAWAY, TENNESSEE
Activitv
Soil Disturbance
- Entire Site
Sediment Disturbance
- Pond 1 6.8 x 10-7 ND , ND
- Pond 2 1.1 x 10-8 NO 4.4 x 10-8
- Pond 3 2.2 x 10-8 ND ND
- Pond 4 2.0 x 10-8 ND ND
- Pond 5 NO ND ND
- Pond 6 ND ND ND
- Pond 7 ND ND ND
- Pond 8 ND 5.8 x 10-7 4.2 x 10-9
- Pond 9 4.8 x 10-8 ND ND
Total Risk
Chlordane
Carcinogenic Risk Due to Exposure
Dieldrin
Toxaphene
Total Risk
2.5 x 10-7
ND
ND
2.5 x 10-7
6.8 x 10-7
5.5 x 10-8
2.2 x 1"0-8
2.0 x 10-8
5.8 x 10-7
4.8 x 10-8
1.6 x 10-6
(1 in 600.000)
Notes:
NO - Contaminant was not dotected in me.£1i.um.
-------
TABLE 5
. .
CARCINOGENIC RISKS fROM INHALA TIONAL EXPOSURES Of
MINING COMPANY EMPLOYEES
GALLAWAY PONDS SITE
GALLAWAY. TENNESSEE
Carcinogenic Risk Due to Exposure
Activity Chlordane Dieldrin Toxaphene Arsenic Cadmium Total Risk
Soil Disturbance'
- Entire Site 1.5 x 10-11 ND ND 1.1 x 10-9 ND 1.1 x 10-9
Sediment
Disturbance
- Pond 1 3.8 x 10-11 NO ND 2.6 ~ 10-11 ND 6.4 x 10-11
- Pond 2 6.0 x 10-13 NO 2.4 x 10-12 6.1 x 10-11 ND 6.4 x 10-11
- Pond 3 1.2 x 10-12 ND ND 6.2 x 10-11 ND 6.3 x 10-11
- Pond 4 1.2 x 10-12 ND ND 2.2 x 10-10 ND 2.2 x 10-10
- Pond 5 ND ND ND 5.7 ~ 10-11 ND 5.7 x 10-11
- Pond 6 ND ND ND 7.0 x 10-11 ND 7.0 x 10-11
- Pond 7 ND ND ND 8.4 x 10-11 1.7 x 10-10 2.5 x 10-10
- Pond 8 ND 3.2 x 10-11 2.4 x 10-13 3.2 x 10-10 ND 3.5 x 10-10
- Pond 9 2.7 )( 10-12 NO NO 4.0 x 10-10 NO 4.0x 10-10
Total Risk 2.6 x 10-9
(1 in 3.8)( 1 08)
Notes: NO - Contaminant was not detected in medium.
-------
TABLE 6
PRESENT AND F\I1\JRE REMEDIAl ACTION I.£VElS (FOR SUSPECTED CARCINOGENS)
OAU.AWAY PONDS SfTE
FOCUSED FEASIBIUTY STUDY
hposure PathwlY
Ind Rlceptor
Present Ind Future
Remedlll Action
Oblectlves
Action levels - (Units Ire ullll for wlter, ulI/k1l for soli Ind aedlment)
Chlordane
T 0ll8ph8lle
Arsenic
Cldmlum
1. Surf Ice Wlter,
Onslte Panda
10 Ingesllon -- humlns I. Monitor to ensure thlt pond wlter 18,000 ugll ., 100 ugll 1,700 ug" 3,300 ugll
(from swlmlnng' contlmlnlnt level a Ire below
1 II 10-4 risk level for
swimmers, If this ICtlvlty occura.
.
b. Dermll -- hum Ins b. Seme es I. for pond .edlment .50.000 ugll 680,000 ugll NA NA
(from .wlmmlng, dl"uslon Into wlter.
2. Surface Wlter
Ofts"e Trlbutlrles
.. Blotl I. Reduce lurflce water 2.4 ugJI t.8 ugll 140 ugll Pond 1 - 3.8 ugll8 .
contlmlnlnt levels In Pondl I, Pond 2 - 1.1 ugll
2, Ind 5 to Icute AWOC plUI Pond 3 - 1.2 ug/1
monitor 3. 4. 6. Ind 7, Ind Pond 4 - 0.84 ug/1
complre vllu.. to Icute AWOC Pond 5 - 1.1 ugll
to detect potentlll risk to Pond 8 - 2.8 ugll
o"slte blot I. Pond 7 - 0.82 ug/1
Monitor remllnlng pond "dlmenU
Ind complre to level. that can
dmuse to water Ibove Icute AWOC.
Monitor o"s"e trlbutlry wlter 0.00.3 ugll 0.013 ugll 72 ugll 0.3 ugJI
Ind complre to chronic AWOC
vllues to detect ,Isk to biota.
-------
TABLE 6
PRESENT AND F\ITURE ROIEIMl AC1108IUVELS (fOR SUSl'EC1£O CARCINOGENS.
o..uAWAY fIOM)S SIn
FOCUSED FEAS8IJTY STUDY
PAGE tWO
bpolura Pathway
and Rauptor
3. Sedlm.nll
Onllt. Pondl
Pra..nt and Futura
Ram.dlal Action
ObIecth..1
a. 08nnal -- awlmm." a. Monitor pond ledlmanta to enaur.
lav811 ar. balow 1 II t 0-4 rtlt
II thll activity DeC"I.
b. 08rmal -- mlnera
4. Sedlmentl
onalt. Trtbutart.a
a. onalt. biota
b. Dermal -- humana
b. Monitor pond ladimantl to .nlura
laV"1 .... below I II 10-4 rt.t
.. thll activity DeC"I.
a. Monitor trtbute,.. ladlmantl to
.naura laval. wtll not dlflu..
Into .atar to lavall above
chronic AWOC 10 protact biota.
b. Montlor trtbuta,.. aedlmanta to
.nllll. that I.vall ara below
1 . to-4 rtlt 101 tha..
fecaptorl.
Chlordan.
8.2 II 108 uglkg
7.3 II to' uglkg
44.000 ugIkg
5.800 ugIkg
Tooph.na
Action lavall - (Unltl ara I11III101 .at.r. uDlka lor loll and ,8dlmenl)
U II 107 uglkg
e.e II to' uglkg
t 70.000 ugIkg
8.800 ugIkg
Arl.nlc
NA
NA
NS
NS
Cadmium
NA
NA
N8
N8
Ol.,drtn
230.000 l1li'8
300 ugIkg
-------
TABLE 6
PRESENT MD F\ITURt IlEMEow. ACT10N lEVELS (FOR SUSPECTED CARCINOGENSt
OAUAWAY I'ONDS SITE
fOCUSED FEAS8IUTY STUDY
PlIO( TIRE
Pre.ent end Future Action level. - IUnltl Irl uall for wltlr. uallla 'or .011 Ind .edlm,nll
Eapolur, PlthwlY Almed..1 Action
8RcI RecIPtor ObJectlve1 Chlordlnl TOUDhl" Arsenic Cldmlum Dllldrtn
5. SolI. - On.lte
10 08rmll - mln,,. I. Monitor 10111 to en.ure 1_lg, 300,000 uelllg «0.000 ug"" NA NA
.It. .011 contemlnent 18v8I. er.
below 1 II 10-4 d8rm81 rtlk
l.vII to min.,..
b. 08rme1 - c8luII b. Slm... I. for c..u.. Intruder.. 100.000 uuJkg 150.000 UD!'g NA NA
Intruders
8. Air IAirtIom. .0111
.edlment plnlcullt..t
.. Inhelltlon 0' a. Compare Ivareg. sit. .011 Pur. Pure Pure Pure
penlcullt.. -- monitoring dlte Ind aV8f8D8 pond
miner. .adlmant dltl to cllculated .01V
.edlmlnt Vllu.. thlt cen creltl
> 10-4 Inhllllion rt.t.
b. Inhllatlon of b. Complr. Iverlge .It. 8011 Pur. Pur. Pure Pure
plnlcul8te. -- . monitoring dlte to calcul8ted
c..u81 Intrudl" loll vllu.. thlt can crelt. .
> to-4 Inhll.llon rl.t.
-------
TABLE 6
PR(SENT AND FUTUR£ R£MEow. ACTION lfVEl$ If OR SUSP£CT£D CARCINOGENS)
GALlAWAY PONDS Sm:
fOCUSED RASIBIUTY STUDY
PAGE FOUR
Eaposura Pathway
.nd RaceD lor
'res..,t end future
Remedial Action
Olll8ctlve.
Chlordan.
Action levels - (Units are uoll tor water. ua/lto for soli and sediment I
Cadmium
7. Blola -- ons..e
Tributaries
a. Ingesllon -- humans a.
It fish are consumed trom offslta
tributaries, then predicted tlsh
tissue concentraUons shOUld be
esUmated Irom trlbutery watar
and sediment sampling result. In
order to ensure a < to-. risk
to persons eellng fish.
0.018 ugll--water
2.hl08 ug!kg--.edlmenl
Not..:
NA
N8
NS
. Cadmium and ar.enlc not absorbed dermally
. Does not bloconcentreta
. No solubility data available tor ar.enlc
. AWOC tor cadmium. b..ad on water hardne..
. Conllmlnlnl concentrltlon hi' to be nearly pure 'or 10-. rI.k
Pure
To..Dhen.
0.037 ugll watar
.90,000 uglkg--Sedlmant
Ar.anlc
NS--aedlment
120 ugll--water N8 ugII--water
N8--ledlment
Dlaldrin
O.OO8--w..ar
830.000- - ledlment
-------
-7-
HEALTIi ASSESSMENT
As part of the remedial process, the Agency for Toxic Substances and
Disease Registry (ATSDR) was asked to review the site data and provide
carments on the health risk posed by the site as well as the remedial
alternatives under consideration. Their report dated June 16, 1986
concurred with the findings of the focused RI in that the potential hUTlan
health exposure threats from the contaminants onsite appear negligible.
-------
-8-
ENFORCEMENI' ANALYSIS
Q1 Septanber 5, 1985 EPA sent ccri>ined notice and darand letters to
approxirrately t~l ve (12) FOtentially responsible parties (PRPs), including
William Bell the armer/operator of the Arlington Blending and Packaging
Carpany. '!he letters inforned the PRPs of the Agency I s belief that they
were potentially liable for the costs associated with cleanup activities
at the site, incltrled calculations of the cleanup costs and allcwed
fifteen (15) days in Which PRPs could respond to the Agency's denand for
reimburserrent of those oosts. '!he letter also encouraged the PRPs to
organize in order to facilitate discussions withEP,.. concerning payment.
'!he PRPs fomed a steering camri.ttee, ostensibly, for the purfX)5e of
obtaining and revie...ring the goveIT1l'TeI1t's evidentiary rraterials and
the PRPs expressed their desire to cooperate with EPA in determining
their respective liability, if any. fb,.rever, to date the PRPs have not
care fOrNard with a settlerrent offer either individually or collectively.
Based on the PRPs obvious absence of willingness to reach a negotiated
settlenent, the case was referred to the United States I:epartIrent of
Justice (OOJ) on November 8, 1985. SUbsequently, on January 7, 1986,
infornation request letters ~re sent to the PRPs in order to obtain
additional inforrration. .
-------
-9-
INITIAL SCREENING OF REMEDIAL TECHNOr..cx:;IES
Section 300.68 (g) of the NCP requires that alternatives developed in
this section be subjected to an initial screening to narrow the list of
potential remedial actions for further detailed analysis. Criteria used
in the initial screening of alternatives are public health, environmental,
cost, technical and institutional considerations.
POND WATER REMEDIATION
Remedial responses developed for the site include processes which would
be most applicable for hazardous waste site remediation. Rarely will
only one treatment process be sufficient for aqueous waste. Therefore,
this section will include info~ation on unit treatment processes which
are frequently.used in combination and any pre-treatment requirements
which are a prerequisite to effective use of each treatment process.
Processes which were examined but proved not to be applicable to the site
are land treatment, biological treatment, adsorption by oil-absorbing
media, chemical oxidation, chemical dechlorination, chemical reduction,
liquid-liquid extraction, oil-water separation, steam stripping, air
stripping, and ultraviolent/ozonat\on. The unit treatment processes
considered for the site are activated carbon, precipitation and
sedimentation, filtration, equalization, ion exchange, reverse OSlOOSis,
blending onsite pond water, and dilution with public water.
SCREENING EVAWATION
Activated carbon is a well-developed technology which is widely used in
the treatment of hazardous waste streams. It is especially well suited
for rerroval of mixed organics fran aqueous wastes. However, it is not
applicable for the removal of cadimt.rn and iron. Therefore, since equalizing
(mixing) the water fran fran ponds 1, 2, and 5 v.ould provide the same
environmental benefits (Le. reduction of the likelihood of present or
fu~~':' threat fran hazardous substances), this technology was eliminated
trom further consideration.
Precipitation and sedUnentation would be applicable for iron ~val, but
v.ould probably be ineffective for cadmit.rn removal. The efficiency of
carnnl~ removal solely on a solubility basis is dependent upon the pH
level. The theoretical minimt.rn solubility of cadmit.rn hydroxide is higher
than the ATflX. limit for cadmilJTl discharge. Therefore, precipitation
and sedimentation will be eliminated fran further consideration.
Dilution involves pumping pond water to an equalization basin and adding
clean water until all Aw;;!:. levels are met. The diluted pond water
would then be suitable for pl111ping (discharge) to the local surface
water. Any sediment that acct.rnulated in the equalization basin would
be handled, along with the sedUnent in ponds 1, 2, and 5. No other
residuals v.ould be generated by using this technique. This technique
will be retained for further evaluation.
-------
-10-
Unit treatment processes for treating the pond water to Aw;J::. levels would
be filtration, equalization, and either ion exchange or reverse osmosis.
Filtration is applicable at the site if it is neccessary to remove suspended
solids prior fran any aqueous waste stream that may be generated during
the remedial action at the site.
The prilnary objective of equalization is to dampen flow and concentration
fluctuations. Most treatment processes operate more effectively if
wastewater composition and flow rate are fairly constant. Equalization
basins and tanks can dramatically increase the stability of treatment
processes that are sensitive to fluctuating contaminant concentrations.
In this case, sediment that accumulated in the equalization basin would
be removed and handled wi th the sed iment fran Ponds 1, 2, and 5. There
are no other environmental impacts associated with equalization. The
only disadvantage is that an equalization basin, when used to dampen fluc-
tuations in the flow rate, may require a considerable amount of land area.
Ion exchange is an aqueous phase process. The dilute, purified stream
YoQuld be suitable for discharge. However, the concentrated regenerant
stream would require proper disposal. This regenerant stream could
potentially have high concentration$ of the substances removed fran the
pond water. The regenerant waste could be recycled, but ultimately it
YoQuld be disposed as a hazardous waste. The regenerant waste stream
could be as much as 2.5 percent to 5 percent of the wastewater volune,
depending on the volume that could be recycled.
Reverse osmosis, as with ion exchange, results in a dilute, clean
stream and a concentrated stream. The concentrate, which contains the
substances removed fran the wastewater, would require proper disposal.
A portion of the concentrate could be rec}'C1ed, but ultimately it
YoQuld be disposed as a hazardous waste. The concentrate waste stream
could be as much as 15 percent to 30 percent of the wastewater volume,
depending on the volune that could be recycled.
Since dilution of the pond water to meet Aw;J::. would provide the same
level of environmental protection as treating the water using ion exchange
or reverse osmosis, both ion exchange and reverse osmosis will be eliminated
on the basis of cost.
The only feasible offsite treatment measure is treatment at a Publicly
o..med Treatment r«:>rks (FCYIW). The transport of contaminated pond water
for treatment should have no adverse impacts on the environment, public
health or welfare, providing there is no spill during transport. Any
residuals generated fran treatment of pond water at the FCYIW would be the
responsibility of the FCYIW. The FCYIW will not accept wastes that 'NOuld
interfere with plant operations, including use and disposal of sludge, or
cause the NPDES limits for the FCYIW to be exceeded.
-------
-11-
rom SEDIMENT TRFA'IMENI'
Treatment technologies identified for sediments fram Ponds 1, 2, and 5 are
sOlidification/fixation, biological degradation, and dewatering. Successful
treatment methods ~uld result in remediation of the same contaminant
pathways addressed by excavation. Treatment technologies are described
below:
- Solidification/Fixation (S/F)
For an S/F process to be effective, it must stabilize the wastes into
a configuration which prevents physical migration and leaching of the
waste constituents of concern in the sediment (in this case, metals and
pesticides). The S/F process reagents or energy requirements must also
be of relatively law cost, since material handling costs for excavation,
mixing with reagents, and redeposition are relatively high. In addition,
if the S/F process does not meet the leaching criterion, the treated
wastes must still be placed in a approved RCRA disposal unit. Thus,
additional costs associated with reagents, solids handling, solids
mixing, and waste volune increase, in this case, ~uld be unnecessary
and substantial. CNerall, none of the waste S/F processes appears to
meet the sOlidification, nonleachability, and long-term effectiveness
requirements for proper application as a process. The solidification/
fixation technologies will not be considered for use in any remedial
alternatives at the Gallaway Ponds site. .
- Biological Degradation
This technology involves the biological seeding of wastes with acclimated
or mutant bacteria that will hasten natural biodegradation. There is
very limited data on the use of this technology to degrade pesticides.
Also, the process will not remove metals: therefore, it is eliminated
fram further consideration at the Gallaway Ponds site.
- D=watering
Municipal Treatment Plant sludge is cammonly dewatered using mechanical
equipment, such as a vacuum filter, plate and frame filter press, belt
filter press, or centrifljJe. The pond sediment at the Gallaway Ponds
site may contain debris such as refuse, rusted drum pieces, sticks,
logs, plant material, etc. The sediment would be difficult to pll'np
under these conditions. Also, the debris ~uld have to be removed
prior to application to the dewatering equipnent. Because of these
constraints, mechanical sediment dewatering is eliminated fram further
consideration.
Air drying beds can be used to dewater sediment by both natural drainage
and by evaporation fram the surface exposed to air. This dewatering
method will not require the removal of debris in the sediment prior to
dewatering. However, due to the technical lD1certainties in the effec-
tiveness of air drying methods, dewatering is not considered for further
evaluation at this time.
-------
-12-
RECCMMENDED PRCX::EOORES FOR THE DISPOSAL OF SELECrED PESTICIDES
Land burial or ground surface disposal are the only other options suitable
for the disposal of small quantities of these pesticides.
SEDIMENT DISPOSAL
Options considered for the pond sediments include disposal in an offsite
RCRA landfill, an onsite RCRA landfill and the designated Pond #1 area.
These options are described in the following section:
- Offsite Landfill
The offsite disposal of sediments is assumed to be at a hazardous waste
management facility (HWMF) permitted in accordance with applicable EPA
or state regulations based on the Resource Conservation and Recovery
Act (RCRA).
The offsite disposal technology meets all of the criteria for screening:
implementability, technical development, and applicability for site
conditions. This technology is considered appropriate for removal
action and will be included in the development of alternatives.
- Onsite Landfill
Onsite disposal of contaminated sediments for Ponds 1, 2, and 5 would be
performed after the pond water has been removed. All of these materials
are considered hazardous in accordance with Tennessee Department of
Health & Environment (TDHE) Hazardous Waste Management Rules, Sec.
1200-1-11.
Landfill design will be in accordance with TDHE rules for hazardous
waste landfills, Sec. 1200-1-11-.06.
Onsite landfilling of sediments is considered an appropriate technology
for remediation of the contaminated sediments, and it will be retained
for further evaluation.
- Centralization of waste with Onsite Disposal in Pond 1
For this disposal option, sediments fram Ponds 2 and 5 will be backfilled
into Pond 1. '!he sediment rerooval and disposal operations will occur
after the pond waters have been pumped out.
-------
-13-
BACKFILL & RffiRADE
Backfilling and regrading of Ponds 1,2, and 5 has been identified as a
potential technology for ~iation of the future risk associated with
overflow of pond water into the unnamed-tributary of Cane Creek.
Backfilling and regrading is applicable only where pond sed~nts can
be left in place without threat of future disturbance by mining.
Conventional earth-moving equipment, such as bulldozers
pans are expected to accanplish the site' gradi.ng work.
backfilling are considered appropriate technologies and
for development of remedial alternatives.
and scraper
Regrading and
will be included
.
-------
-14-
ALTERNATIVES EVAIlJATION
The Feasibility Study developed a range of alternatives that would mitigate
any unacceptable risks to receptors posed by seven of the onsite ponds
(Ponds 1-7) and the areas of known surficial soil contamination based on
data presented in the Remedial Investigation. Ponds 8 and 9 were not
addressed for remediation because (1) due to site topography, they would
not overflow and (2) sediments would not be disturbed since institutional
controls would be implemented to control mining. The only transport
pathway would be addressed in the groundwa\:ermonitoring program.
As discussed above, the only unacceptable risk presented by the Gallaway
Ponds Site is the potential risk to offsite biota that would occur if
ponds 1, 2, or 5 were to overflow to offsite tributaries, since these ponds
exceed the acute Ambient Water Quality Criteria (AWQC). This assumes a
worst-case situation, since the tributaries are intermittent, and probably
contain few biota receptors. The -remedial objectives and cleanup criteria
for this pathway are based on the acute AWQC levels for pond water
contaminants. The general objectives are to eliminate the contaminated
pond waters which exceed the acute AWQC, and to ensure that the remaining
pond sedilnents do not contaminate future surface waters by contaminant
diffusion.
The following seven remedial action responses were developed for a
detailed analysis of public health, environmental, and institutional
considerations and cost effectiveness:
1.
No Action - Since there is no evidence that contaminants are
present at the site at levels representing a significant threat
to public health or the environment, the "No Action" Alternative
will be considered as a feasible response.
2.
Backfill/Regrade Ponds 1, 2, 5 - This action would eliminate ponds
1, 2 and 5 by reIroving the water and backfi 11 ing the ponds. This
action would result in a fina~ graded site area without depressions
or catchments that could pond rainwater.
3.
Excavation of sediments fram Ponds 2, 5 with onsite disposal in
Pond 1 - Sediment renova1 fram Ponds 2 and 5 would prevent the
future potential of contaminant diffusion into ponded water,
which could occur following mining if these sediments were left
on site. Once drained, Pond 1 would then be backfilled with
clean fill and regraded to prevent reponding of water, which
could bee<::m3 contaminated throUJh sediment diffusion.
4.
Offsite Disposal of Pond 1, 2, 5 sedilnents in a RCRA Landfill-
Sediment removal would prevent the distribution of sediments
over a larger area that could result in contamination of runoff
and surface waters by transport and diffusion of contaminants in
sediments if mining resumed.
-------
-15-
5.
Disposal of Pond 1, 2, 5 sedlinents in an Onsite RCRA Landfill-
An onsite hazardous waste landfill for pond sediments will effectively
reduce to an acceptable level the future potential environmental
risks to biota. Excavation of the contaminated sediments from Ponds
1, 2, and 5 \otoUuld be required, at a minirnUtl, and sediments \otoUuld be
disposed of in an onsite landfill. Removal of the contaminated
sediments fraTI Ponds 1, 2, and 5 \otoUuld prevent any leaching or transport
of the sediments and ¥.Quld prevent the onsite pond water contamination
that causes a potential risk to biota if discharge to onsite tributaries
occurs. .
6.
tlOnitoring - Monitoring \otoUuld be used at various stages of the site
remediation process to ensure the effectiveness of the remedial
technologies and alternatives.
7.
Pond water .Treatment - For each alternative that includes pond water
treatment, three different treatment options have been identified.
These are pUtlping and disposal at a PO'lW, dilution with city water or
onsite treatment to meet all AWQCs, and blending of onsite ponds to
meet organic A~.
The alternatives were assessed relative to the following considerations:
o Appropriate treatment and disposal technologies.
o Special engineering considerations.
o Environmental impacts and proposed methods for mitigating any
adverse effects.
o Operation, maintenance, and rronitoring requirements.
o Offsite disposal needs and transportation plans.
: i.emporacy storage requirements.
o Safety requirements for remedial implementation.
The following alternatives which are presented in Table 7 will be
evaluated to determine the effectiveness of each alternative to meet
these critical components:
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-16-
N:> Action
No Action will not require the implementation of any remedial cleanup,
investigation, or monitoring actions. Technical and cost evaluations
will not be performed.
An unacceptable risk to offsite biota would exist under the Nb-Action
alternative if surface water run-off exceeding the AWQC intercepted the
tributaries. The calculated risks to humans for all exposures pathways
evaluated \Nere less than 10-6 and are the"refore .acceptable.
No Action with Monitoring
No remedial action will be performed; hO"tved (see Figure 4).
Another closure method would be to cap Ponds 1, 2, and 5 in-place
in accordance with RCRA requirements.
~M activities would inclooe groundwater sampling and inspection and
maintenance of the sedLmentation basin, vegetative cover or cap.
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TABLE 8
PROPOSED GROUNDWATER MONITORING WELL PROGRAMS
FDR THE VARIOUS REMEDIAL ALTERNATIVES
GALLAWAY PONDS SITE - FOCUSED FEASIBILITY STUDY
Remedial Alternative
No Action
No Action with Monitoring
Backfill/Regrade Ponds 1, 2, 5
Excavate Ponds 2, 5 Sediment with Onsite
Disposal in Pond 1 and Backfill/Regrade
Pond 1
Excavate Ponds 2, 5 Sediment with Onsite
Disposal in Pond 1 and Cover Pond 1 with
Multimedia Cap.
Take Ponds 1, 2, 5, Sediments to Offsite
RCRA Landfill
Excavate Ponds 1, 2, 5 Sediment with
Disposal in Onsite RCRA Landfill
Existing
wells
New Wells
4 Offset
Garments
4 Offset
4 Offset
4 Offset
2 Offset
3 RCRA landfill
wells 2 offset
No Monitoring
Install an offset well cluster
downgradient of Pond 1 and
another downgradient of Ponds
8 and 9 (each cluster consists
of two wells - shallow (35') and
deep (60')
Install offset well clusters
downgradient of Pond 1 and
Ponds 8 and 9.
Install two offset downgradient
of Ponds 8 and 9 and two
offset downgradient of Pond 1.
Install two offset downgradient
of Ponds 8 and 9 and two
offset downgradient of Pond 1.
Install offset well cluster
downgradient of Ponds 8 and
9.
Utilize existing MW-2 for
upgradient monitoring
of onsite landfill.
Install three new wells
downgradient of landfill
Install offset well cluster
downgradient of Ponds 8
and 9.
WELL ^AMPIIMH IS INCLUDED IN AUWPTERNATIVES EXCEPT
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FIGURE" 4
BACKFILL AND REGRADING OF PONDS 1,2, a 5
GALLAWAY PONDS SITE, GALLAWAY, TN
o 100
..........-~
SCAU IN F[U
200 "
.
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TABLE 7
REMEDIAL AcrIOO ALTERNATIVES
CAPITAL AND PRESENT-W)Rrn Q)STS SUMMARY
GALIAWAY POOOO SITE
REMEDIAL ALTERNATIVE
No Action
No Action with Monitoring
Backfill/Regrade Ponds 1,2,5 following:
a. 1,2,5 water to PCYlW
b. Dilute 1,2,5 H;2<) with city H;2<) and
discharge to tributary to meet AWQC
c. Blend 1,2,5 H;2<) and discharge to tributary
to meet pesticide AWQC .
Backfill/Regrade and cover Ponds 1, 2, 5
with Multi~dia cap (RCM cap)
a. 1,2,5 water to PO'IW
b. Dil ute 1,2, 5 H;2<) with c i t Y wa te rand
discharge to tributary to meet
pesticide A~.
c. Blend 1,2,5 water and discharge to
tributary to meet pesticide AWQC.
Excavate sediments fran Ponds 2,5 with onsite
disposal in Pond 1; backfill/regrade Pond 1
a. 1,2,5 water to POTW
b. Dilute 1,2,5 H20 with city H20 and
discharge to tributary to meet AWQC
c. Blend 1,2,5 H;2<) and discharge to tributary
to meet pesticide AWQC
Excavate sediments fran Ponds 2,5 with onsite
disposal in Pond 1 and cover Pond 1 with multi-
media cap (ReM cap)
a. 1,2,5 water to POTW
b. Dilute 1,2,5 H;2<) with city H;2<) and
discharge to tributary to meet AWQC
c. Blend 1,2,5 H;2<) and discharge to tributary
to meet pesticide AWQC
CAPITAL
$0
25,000
364,464
317,889
284,398
453,243
406,668
373,177
300,371
243,767
220,304
401,339
344,735
321,272
Q)STS
PRESENT-w)Rrn *
(30 }ear O&M)
$0
141,000
537,000
491,000
457,000
629,000
580,000
546,000
464,000
407,000
384,000
565,000
508,000
485,000
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TABLE 7
Take Ponds 1,2,5 sedirrents to offsite ReM
landfill
a. 1,2,5 water to rorw
b. Dilute 1,2, 5 H~ with city H20 and
discharge to tribJtary to neet NH:;1::.
c. Blend 1,2,5 H20 and discharge to tribJt.ary
to meet pesticide AWQC
Excavate Pond 1, 2, 5 sedi1rents with disposal
in onsite RCRA landfill
a. 1,2,5 v.ater to rorw
b. Dilute 1,2,5 H20 with city H20 and
discharge to tribJtary to neet AWQC
c. Blend 1, 2, 5 H LfJ and discharge to tribJt.ary
to meet pesticide AWQC
955,296
908,720
1,072,000
1,025,000
875,229
992,000
1,084,673
1,220,000
1,038,097
1,173,000
1,004,606
1,149,000
* THESE COSTS REFLECT QlNUERLY SAMPLING FOR 0-2 YEARS AND ANNUAL SAMPLING 3-30 YEARS
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-17-
CENTRALIZATIOO OF WASTE WI'IH OOSITE DISPOSAL IN PCND 1
For this disposal option, sediments fran Ponds 2 and 5 will be backfilled
into FOnd 1. The sediment rem:>val and disposal operations will occur
after the pond waters have been rem:>ved. An .estimated 1,600 cubic yards
of raw, undried sediment will be backfilled into Pond 1. Figure 5 shows
the FOnd 1 sediment disposal plan.
FOnd 1 has an available disposal capacity of approximately 3,500 cubic
yards, based on an estimated bottan elevation of 380 feet above mean sea
level (AMSL) and berm elevation of 388 feet AMSL. The disposal capacity
of Pond 1 can be easily increased by construction of a perimeter berm;
however, this is not expected to be necessary.
The extra storage capacity of 1,900 cubic yards (3,500 minus 1,600) will
be used for backfill soils to stabilize the "wet" sediments and allow
final covering. Backfill of 1,900 cubic yards of "dry" onsite soils into
1,600 cubic yards of "wet" sediments will result in approximately 3,500
cubic yards of mixed soil/sediment.
It is anticipated that after Pond 1 is backfilled with raw, wet sediments,
settling will occur and a liquid supernatant lajer will ~ formed. This
liquid will be removed as required, and will be treated with the same
method used for the pond water. This will result in an increase in
sediment solids content wIth a corresponding increase in extra storage.
capacity above the estimated 1,900 cubic yards. This benefit fran
additional settling should be realized if Pond 1 is permitted to be
undisturbed for at least one full, dry-weather day. The exact amoLD1t of
increase in storage capacity is not determinable; however, the increased
volure might be needed to allow for more backfill material if the actual
sediment moisture contents and disposal quantities are significantly
greater than estimated in the FS.
For one closure method, the backfilled FOnd 1 will be covered with a
local s,~.i 1 cover sloping away fran the pond center. A 6-inch topsoil
lajer will be placed on the sloped soil cover and will be vegetated to
minimize future erosion and rainfall percolation.
A second ~losure method for Pond 1 will be a multi-media cap consisting
of 2-feet of clay, a synthetic membrane, and an internal drainage lajer.
A 2-foot vegetated soil cover will be placed above the drainage lajer and
will be sloped away fran the pond center.
A 6-foot chain-link fence with a locking gate will be constructed around
the Pond 1 disposal site to restrict site access and future mining
activity.
o & M activities would inclLrle groLD1dwater IIDnitoring and inspection
and maintenance of the cap or cover.
-------
PROPERTY LINES ARE
FIGURE 5
SEDIMENT DISPOSAL INTO POND No. ,
GALLAWAY PONDS SITE, GALLAWAY, TN
o IC":'
~~
S~( ... f[(f
l'f
? - The depth of the contaminated sed:i1rent is unknown.
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-18-
OOSITE RCRA LANDFILL
Q1site disposal of contaminated sediments fran FOnds 1, 2, and 5 would be
performed after the pond water has been rerroved. '!he disposal cell would
cover an approximated loS-acre area. '!he onsite landfill would consist
of a RCRA cap and double liner. '!be liner and cap both incorporate
contairment layers of 2 feet of canpacted clay. '!he secondary liner is a
30-roil membrane. The liner system incllrles leachate collection and
detection zones, both of which will be drained to separate storage tanks
for leachate holding. . . .
The cap consists of a clay/synthetic combination using a 20-roil membrane.
The cap incorporates a gravel/sand drainage layer beneath the final 2-
foot soil cover to promote drainage of percolating rainfall (see
Figure 6).
The landfill will also include a miniml.lt\ of four groundwater IIDnitoring
wells.
OFFSITE RCRA LANDFILL
After the water is reroc>ved fran ~nds h 2, and 5, the sediments would be
excavated fran the pond bot tans . It is estimated that an average 2 feet of
sediment would be reroc>ved fran the bottan of each pond. This converts to
a total volLrne of 2,215 cubic yards. '!he sediment is expected to be.
interspersed with vegetative matter and bulk solid wastes, such as danestic
refuse and possibly metal drlJ1lS. Clamshell or dragline-type excavating
equipment would be appropriate for the pond sedUTIent removal.
After the sediment layer as been reroc>ved fran each pond, the pond bot tan .
will be sampled at the surface (0-3 inches) and analyzed for HSL pesticides
and metals. Analyses would be quick-turnaroLmd (24 hours) to provide
vertification of cleanup action levels. Additional sediments would be
excavated if contaminant concentrations exceed the designated action
levels (see Table 4). Under this alternative, the ponds would not be
backfilled, since remJval of the sediments and water would effectively
eliminate the future potential environmental risks, based on the present
site data.
All excavated sediment and bulky wastes would be hauled offsite to a
RCRA permitted hazardous waste management facility (HWMF). For costing
purposes, the Chemical Waste Management Facility in Emelle, Alabama, has
been identified. Q1e-way haul distance is approximately 270 miles.
Actual landfill selection would be determined by EPA following a Request
for Qootation (RFQ) for hauling and disPOSal services.
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. .
FlGUP~ 6
ONSITE RCRA LANDFILL
GALLAWAY PONDS SITE. GALLAWAY
.,..
~
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-19-
CCM1UNITY REIATIONS
A public neeting was held on July 21, 1986, to present a slJltlT'aI'y of the
RI/FS process and to explain the prop::>sed remedies for the cleanup of the
site. 'lb aid in this presentation, fact sheets \tIIere prepared for the
neeting. '!he public ccmnent period officially begun on July 21 and closed
on August 12, 1986. Canrrents received \tIIere respcnded to and are in
Sl.mTlBry fonn in the attached Respensi veness SUrmery. .
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-20-
CONSIsrEOCY WITH ornER ENVIro~AL lAWS
The recamended remedial action is applicable, relevant, and awrcpriate
to ReRA clean closure requiranents. The site will be closed in accordance
with Subtitle C of RCRA. The recatmended action includes excavatim of
contaminated sedirrent frc:rn Ponds 2 and 5 with onsite disposal in Pond l.
This action will be in corrpliance with RCRA I s clean closure requirements.
In addition, a groundwater rronitoring program which includes quarterly
rronitoring to establish background concentration levels and thereafter,
serni-annually rronitoring for the rerraining of the post~losure care
period nay be appropriate.
Discharge of pond water to surface water may require a NPDES permit.
The discharge limits will bE specified in the pennit. Effluent limits
are not knawn until the pennit awlication is reviewed and th~ state
issues the limits.
.
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-21-
RECG1MENDED ALTERNATIVE
The appropriate remedial action selected should be protective of human
health and the environment, cost effective and utilize permanent solutions
and alternative treatment technologies or resource recovery technologies
to the maximum extent practicable. "Additionally, the selected alternative
should be consistent with the CERCI.A canpliance policy which requires
consideration of RCRA applicable, relevant and appropriate requirements
(ARM's) when remedying and closing sites..
At a minimum, each alternative developed, with the exception of Alter-
native 1 ( No-Action) will provide a comprehensive response that meets
the CERCI.A goal of protection of the public health and the environment.
Additionally, each alternative will include monitoring to evaluate the
effectiveness of the remedial action.
The most cost-effective remedy that is applicable, relevant, and appropriate
to RCRA requirements involves excavation of contaminated sed~nts fram
ponds 2 and 5 with onsite disposal in ~nd 1. ~nd 1 would be covered
with a multi-it'ledia (RCRA) cap. The pond water would be diluted with city
water to meet Aw::t::. and discharged to a tributary.
.
The estimated cost to implement this remedy would be $508,000 which includes
o & M costs for 30 years.
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-22-
OPERATIOO AND MAINTENANCE (0 & M)
Operation and maintenance activities will include groundwater monitoring
and inspection and maintenance of the cap. Projected 0 & M costs for
for quarterly sampling during the first year are $40,600 (see Table 9).
o & M costs are calculated using a present worth analysis calculation.
This analysis was based on the Office of Management and Budget - prescribed
10 percent discount rate.
Cost sharing for the project Umplementation,will be 90 percent Federal
and 10 percent State. After one-year, all 0 & M costs will be borne
by the State.
SCHEOOLE
The Record of ~cision will be finalized in September 1986. The Remedial
D:!sign should be canpleted in April 1987. The Remedial Action should be
completed in February 1988.
FlJIURE AcrIOOS
Future actions will include the Office of Regional Counsel obtaining a
Consent Order with the site owner to refrain fran mining the remediated
pond 1 area. This order will also include other institutional cont:rols
needed to ensure future land uses canpatible with the remedy selected.
After the remedy is Umplemented, monitoring will be needed to ensure the
effectiveness of the action.
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TABLE 9
o & M COST SUMMARY - Pump Ponds 1, 2, 5: Dilute Ons i te and Discharge Ons i te :
ReITOve Sediments From 2 and 5 and Dispose Onsite in Pond 1 with Multimedia
(RCRA) Cap, Gallaway Ponds Site-
ITEM
. ITEM ($)
QUARTERLY SAMPLING
1.
Sanpling
8,000.00
f 7., .'
2. Analysis
3. Maintenance
4.
Reporting
'.
'IDTAL ANNUAL COST
"iJ: 1 >
30,000.00
1,000.00
1,600.00
40,600.00
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GALLAWAY POOOO
GALIAWAY, TENNESSEE
DRAFT RESPONSIVENESS SUMMARY
INI'ROOOCTION
This responsiveness slJ'!lT1ary doct.ments cithens' reactions and concerns
raised in reference to the Remed~a~ Investigation/Feasibility Study
(RI/FS) for the Gallaway Ponds site in Gallaway, Tennessee. It also
doct.ments for the public record the United States Environmental
Protection Agency's response to the questions and camments presented
during the public meeting and public carment period. .
OVERVIEW
'The public meeting was held on July 21, 1986 to discuss the RI/FS and the
proposed recomnended alternative for the Gallaway Ponds site. 'The proPOsed
remedial alternative included monitoring for two years after which the
. contaminated sediments v.ould be centralized in one pond or taken to an
offsite RCRA facility. Rather than monitor for 2-years, the Agency
has decided to ilnplement the sediment centralization remedy upfront
and confirm with 30 years of monitoring. l'btification of the neeting was
accanplished thro~h news releases and mailings to all interested parties
listed in the Catrnunity Relations Plan (CRP). 'The meeting was attended by
approxilnately 13 people including EPA, State officials and the press.
The Agency received no carments fran the public during the 3-week public
caments period.
BACKGRCXJND ON CCX>1MUNITY INVOLVEMENT AND OONCERNS
'The Gallaway Ponds Site was first bro~ht to the attention of the state
by several local residents. It appears that while hunting in the vicinity
they found sample bottles dtmped into one of the ponds on the site. 'The
men also noticed a disagreeable odor and according to a state official,
could see where liquid wastes had been allowed to run into the POnd. '!he
concerned citizens alerted the Fayette County Environmental Officer who
in turn contacted the State the first week of January 1982. AroLD1d the
end of January, the State assigned one of its representatives to neat
with the nen at the site in an effort to determine the extent of the
problem .
Residential wells were tested because of the concern over contamination
of the shallow aquifer. l'b contamination was fotmd.
When the site was first discovered in 1982, media interest was high.
However, little media interest is shown at the present time. Local
residents have shown minUmaI interest since the site's discovery.
-------
. 'SU'MMARY QF'J.q1,MENI'S RECEIvED 00Ri~ TIiE. PUBLIC MEETING AND
, 'IH£E;PA:.~pQ4sES ' .
1.0 HOw often._.~Uld 'the:grolJi'Xjwa~e,r Qe- m:>nitored?
EPAResponse: "QUatterl)':':for'a"'period of one;war. After the
first, ye~r" rroni"toting ,wi.l~be' performed ~~i1ar:lpually for
30~ars. . . , . , .
2.0 , . What were. : the ,'levels ofdGntqminants found during the Emergency
, Response. '. .
"EPAj~e~ponse: Table~3i df'the F6C\i?~(LR~ical ,Investigation
Report!~,wasreferenced. -
3. 0 ~o owns the land? --
, EPA:Response :,~:' Mr. Billy. Ra:~"is the current owner.
,'.' 4.0 ,'Ateth~re,afly'existing ,wel:rs onsi.te?
. " ',:-- ' Wells?
Did }-OU look for any old
EPA Response :' Q11yo~~xisting well was identifed during, the
.R!. The ,site owner drilled a drinki J water well which
. penetrated the Jac~son Clay.
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