United States
Environmental Protection
Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R04-89/045
March 1989
SEPA
Superfund
Record of Decision
Amnicola Dump, TN
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50272-101
REPORT DOCUMENTATION
PAGE
1. REPORT NO.
EPA/ROD/R04-89/045
X Redptenf* AcceMlon No.
4. TlOemdSublMe
SUPERFUND RECORD OF DECISION
Amnicola Dump, TN
First Remedial Action - Final
5. Report (Me
3/30/89
7. Authors)
i. Performing Organiaton Rept No.
9. Performing Orgilnlation Nun* «nd Addra**
ia ProlectfTuk/Work IMt No.
11. Contnct(C) or Gnnt(G) No.
(C)
(Q)
12. Sponsoring Orginlzstian Nun* «nd Addm*
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
11. Typo ol Report ft Period Covered
800/000
14.
15. SupptomenUry NolM
18. Abstract (Limit 200 word*)
The Amnicola Dump site is an 18-acre inactive construction debris disposal site
located in Chattanooga, Tennessee. The site is located along the east bank of the
Tennessee River, approximately 0.5 mile upstream of the intake for the primary drinking
water source for the city of Chattanooga. The site is bordered on the north by dense
vegetation and vegetation- covered debris, and on the south by an industrial research
facility. The site drains westerly towards the river. During the 1930s the Amnicola
Dump site was reportedly used for clay mining operations, resulting in several
water-filled pits. During the period of 1957-1964 construction debris and other
unidentified wastes were occasionally disposed of in many of the open pits. The site
was then operated as a dump by the city of Chattanooga until 1973, predominantly
receiving construction debris including a substantial amount of waste wood which was
subsequently incinerated onsite. The ashes eventually filled 12 acres of the 18-acre
site. The only industrial waste reportedly disposed of at the site was latex waste.
Unauthorized waste dumping and concerns about leachate discharge in proximity to the
drinking water intake area led to closure of the site in 1973. Closure included
covering, grading slopes, filling depressions, draining standing water, applying
rip-rap along the western perimeter, constructing drainage ditches, and seeding the
entire surface area of the fill. The current owner and operator has been burning,
Attached Sheet)
17. Document Analytic *. Descriptor*
Record of Decision - Amnicola Dump, TN
First Remedial Action - Final
Contaminated Media: soil and debris
Key Contaminants: PAHs
b. Identifiers/Open-Ended Term*
e. COSATI Held/Group
18. Avsilabilty Statement
19. Security CUM (Into Report)
None
20. Security Class (This Pigs)
None
21. No. of Pages
68
22. Price
(See ANSM39.18)
See Inttructlont on R»nr*»
OPTIONAL FORM 272 (4-77)
(Formerly NT1S-35)
Deportment o< Commerce
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EPA/ROD/R04-89/045
Amnicola Dump, TN
First Remendial Action - Final
16. Abstract (continued)
storing, and handling creosoted railroad ties, contributing to elevated PAHs in surface
soil. The primary contaminants of concern affecting the soil, debris, and ground water
are organics including PAHs, and metals including chromium.
The selected remedial action for this site includes excavating and screening 600 yd3 of
contaminated soil/debris with onsite solidification/fixation of 400 yd3 of contaminated
soil and 200 yd3 of debris (debris exceeding cleanup goals or LDR requirements will be
disposed of offsite) , followed by onsite disposal of solidified mass; monitoring of
ground water for 4 years; conducting a public health assessment 5 years after completion
of the remedial action; and implementation of institutional controls including ground
water and land use restrictions. The estimated present worth cost for this remedial
action is $640,000 with O&M of $384,000.
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RECORD OF DECISION
Remedial Alternative Selection
SITE NAME AND LOCATION
Amnicola Dump Site
Chattanooga, Tennessee
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected remedial action for
the Amnicola Dump site, Chattanooga, Tennessee, developed in
accordance with CERCLA, as amended by SARA, and, to the extent
practicable, the National Contingency Plan. The following
documents form the basis for selection of the remedial action:
Remedial Investigation Report, Amnicola Dump Site
Feasibility Study Report, Amnicola Dump Site
Summary of Remedial Alternative Selection
Responsiveness Summary
Staff Recommendations and Reviews
DESCRIPTION OF THE REMEDY
The function of this remedy is to reduce the risks associated
with exposure to contaminated, on-site surface soils.
The major components of the selected remedy include:
Surface Soil
Excavation of contaminated surface soil and debris
Screening of debris from the soil
Treatment of contaminated soil by solidification/
fixation
- Restoration of the ground surface to its original
condition
General
Imposition of ground water use restrictions within a
reasonable distance from the site
Imposition, of land use restrictions on the site
Quarterly ground water monitoring for four years
Public Health Assessment conducted five years following
remedial action
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DECLARATION
The selected remedy is protective of human health and the
environment, attains Federal and State requirements that are
applicable or relevant and appropriate to the remedial action,
and is cost-effective. This remedy satisfies the statutory
preference for remedies that employ treatment that reduces
toxicity, mobility, or volume as a principal element and
utilizes permanent solutions and alternative treatment
technologies to the maximum extent practicable. However,
because treatment of contaminated ground water was not found to
be necessary, hazardous substances will remain in the ground
water above health-based levels. The absence of ground water
users at or downgradient of the Amnicola Dump site, and the fact
that discharge of ground water to the Tennessee River will not
result in a significant increase of contaminants in that surface
water body, precludes the need for ground water remediation.
Therefore, Alternate Concentration Limits (ACLs) have been
established for the site.
Because this remedy will result in hazardous substances
remaining on-site above health-based levels, a review will be
conducted within five years after commencement of remedial
action to ensure that the remedy continues to provide adequate
protection of human health and the environment.
Date tc^ Greer c> Tidwell
Regional Administrator
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RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
AMNICOLA DUMP SITE
CHATTANOOGA, TENNESSEE
PREPARED BY:
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV
ATLANTA, GEORGIA
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
AMNICOLA DUMP SITE
CHATTANOOGA, TENNESSEE
PREPARED BY:
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV
ATLANTA, GEORGIA
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TABLE OF CONTENTS
1.0 INTRODUCTION 1
1.1 Site Location and Description 1
1.2 Site History 1
2.0 ENFORCEMENT ANALYSIS 5
3.0 CURRENT SITE STATUS 7
3.1 Environmental Setting 7
3.1.1 Bedrock 7
3.1.2 Soils 7
3.1.3 Ground Water 7
3.1.4 Surface Water 8
3.2 Surface Soil Contamination 8
3.3 Ground Water Contamination 13
3.4 Subsurface Soil 13
3.5 Surface Water, Sediment and Leachate 15
4.0 CLEANUP CRITERIA '-16
4.1 Surface Soil Cleanup Criteria 16
4.2 Alternate Concentration Limits 17
5.0 ALTERNATIVES EVALUATION 20
Alternative 1 - No Action 22
Alternative 2 - Low Permeability Cover 23
Alternative 3 - Solidification/Fixation 26
Alternative 4 - Off-Site Incineration 29
Alternative 5 - Off-Site Disposal 32
6.0 RECOMMENDED ALTERNATIVE 34
6.1 Description of Recommended Alternative 34
6.2 Operation and Maintenance 40
6.3 Cost of Recommended Alternative 40
6.4 Schedule 40
6.5 Future Actions 40
6.6 Consistency With Other Environmental Laws 41
7.0 COMMUNITY RELATIONS 43
8.0 STATE INVOLVEMENT 43
9.0 SIGNIFICANT CHANGE TO THE PROPOSED PLAN 44
RESPONSIVENESS SUMMARY
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LIST OF FIGURES
Figure Page
1.0 Site Location Map 2
2.0 Site Map 3
3.0 100-Year Floodplain 9
4.0 Area of Surface Soil Remediation 36
LIST OF TABLES
Table Pag<
1.0 Maximum Concentration of Contaminants of
Concern in Surface/Subsurface Soil 11
2.0 Carcinogenic PAH Compound Data 12
3.0 Ground Water Contaminants 14
4.0 Alternate Concentration Limits 19
5.0 State Cost-Sharing Obligations 46
APPENDICES
APPENDIX A - SOIL CLEANUP GOAL CALCULATIONS
APPENDIX B - ALTERNATE CONCENTRATION LIMIT CALCULATIONS
APPENDIX C - LISTED THREATENED AND ENDANGERED SPECIES
APPENDIX D - HISTORICAL/ARCHAELOGICAL DATA
APPENDIX B. ADMINISTRATIVE RECORD INDEX
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RECORD OF DECISION
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
AMNICOLA DUMP SITE
HAMILTON COUNTY, TENNESSEE
1.0 INTRODUCTION
The Amnicola Dump site was included on the National Priorities
List (NPL) in September 1983 and has been the subject of a
Remedial Investigation (RI) and Feasibility Study (FS) performed
by the U.S. Environmental Protection Agency (EPA)/ Region IV.
The RI Report/ which examines the quality of air, soil, surface
water, sediment, and ground water at the site/ was issued to the
public in January 1989. The FS Report/ which develops and
examines alternatives for site remediation/ was also issued in
draft form to the public information repository in January 1989.
This Record of Decision has been prepared to summarize the
remedial alternative selection process and to present the
recommended remedial alternative.
1.1 Site Location and Description
The Amnicola Dump site is an 18-acre inactive construction
debris disposal site located in-Chattanooga, Tennessee (Figure
1). The site is located at latitude 35° 03'04" and longitude
85° 16'35" along the Tennessee River. The site is
approximately 0.5 miles upstream of the intake for the
Tennessee-American Water Company which is the primary water
drinking water source for the City of Chattanooga.
The site is bordered on the south by Syn-Air Research (an
industrial research facility), on the west by the Tennessee
River, on the north by dense vegetation and vegetation-covered
debris (scrap metal, railroad ties, etc.), and on the east by
the Amnicola Highway. A berm/ which extends 15 to 25 feet in
height/ separates the river from the landfill. Two breaks have
been noted in the berm. An on-site pond/ located in the
northwestern corner of the site, occupies approximately four
acres between the landfill and the berm (Figure 2). Located
largely within the 100-year floodplain, the site drains westerly
towards the river with a slope of approximately three to five
percent.
Amnicola Equipment & Materials Sales, a salvage business
operating on the surface of the landfill, is located on an
upland area. This area/ which is relatively flat (less than
one percent slope)/ is approximately 30 to 35 feet above the
main river channel.
1.2 Site History
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Source: Chattanooga USGS TopograjJuc Quadrangle (105 - SE) Map .
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FIGURE 1-2
*MMCni.A DUMP M
CHAHAMOOOA. TENNESSEE
U.S. E.P-A. «QWN IV
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-4-
During the 1930's the Amnicola Dump site was reportedly used for
clay mining operations. These operations resulted in several
water-filled pits along the western boundary of the site in the
present-day pond area. During the period 1957-1964,
construction debris and other unidentified wastes were
occasionally disposed in many of the open pits. This resulted
in a large portion of the pits being filled.
During 1964 to 1970 the area was revegetated (it is not known
whether this revegetation occurred naturally). The Amnicola
site was operated as a dump from mid-1970 to September 1973 by
the City of Chattanooga. Construction debris, with 25 percent
or less household-type waste, was disposed on-site during this
period. A substantial portion of wood waste brought on-site was
incinerated by an air-curtain destructor. The ashes were then
disposed on-site. Approximately 12 acres of the 18-acre site
were eventually filled.
Consolidated Latex, Inc., formerly located on the south border
of the site, allegedly disposed of latex waste in the southwest
corner of Amnicola Dump. In 1971, the Tennessee-American Water
Company noted the dumping of the latex waste at the site as well
as the presence of a strong styrene-like odor during one
leachate sampling event. Concern arose because of the proximity
of the water company's intake, 0.5 miles downstream, to this
leachate stream and latex dumping location. Latex waste is the
only industrial waste reportedly disposed at the site.
On June 2, 1971, the Tennessee Department of Solid Waste
Management (DSWM) recommended closure of the dump. The
recommendation was based on unauthorized wastes from garbage
trucks being dumped in the water-filled pits.
In May 1972, EPA provided the City with recommended actions
required to eliminate the discharge of leachate from the site
into the Tennessee River. Elevated levels of iron, manganese,
total Kjeldahl nitrogen, and total organic carbon were detected
in the leachate stream. EPA recommended closure of the site.
During the summer of 1973, the City finalized closure which
included covering, grading slopes, filling depressions, draining
standing water, applying rip-rap along the western perimeter,
construction of drainage ditches, and seeding the entire
surface area of the fill.
From 1971 through 1976, the Tennessee-American Water Company
conducted weekly leachate tests for inorganic analysis on the
storm-water runoff entering the river at River Mile 465.8.
Analyses included heavy metals, manganese, iron and specific
conductance. Little or no pattern in the parameter
concentrations was apparent. Conductivity values were elevated;
some metals were detected but not elevated significantly above
background levels.
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In July 1979, EPA, Tennessee Department of Health and
Environment (TDHE) personnel and local officials conducted a
site visit at the Annicola Dump. According to the trip report,
the overall condition of the site was good. However, there was
some discoloration of water observed in the drainage ditch. EPA
recommended an evaluation of historial water data and further
water sampling.
In May 1982, MCI/Consulting Engineers was tasked by the TDHE to
conduct a study of the leachate originating from the Amnicola
Dump site. The sampling point was the combined leachate stream,
less than 20 feet from the confluence with the Tennessee River
at River Mile 465.8. The results showed trichloroethylene,
vinyl chloride, and 1,2 trans-dichloroethylene.
The Amnicola Dump site was proposed for inclusion on the
National Priorities List (NPL) in December 1982. The site was
finalized on the NPL in September 1983. The primary factor
contributing to this score was the proximity of the site to
Tennessee-American Water Company's water intake, which supplies
water to the majority of Chattanooga.
In December 1986, EPA Region IV noted that site conditions
varied from previous site reports. EPA Region IV reported that
the site was being used as a storage area for heavy equipment,
railroad ties, scrap metal, and several large dumpsters. The
cap had been cleared of vegetation, much of the rip-rap along
the bank had been removed, and discolored water (leachate) was
noted in the southwest corner of the site.
In January 1987, EPA Region IV, Environmental Services Division
(BSD) sampled leachate and surface drainage at the site. The
analytical results indicated that the leachate streams contained
elevated levels of 10 inorganic compounds (barium, strontium,
titanium, zinc, chromium, manganese, calcium, magnesium, iron,
and sodium) . Although several trace organic compounds were
found, the only major organic contaminants were bis
(2-ethylhexyl) phthalate at 82 ug/1 and chloroform at 7.4 ug/1.
ESD concluded that/ based on the results of the finished water
sample collected from the Tennessee-American Water treatment
plant, no impact on the Chattanooga water supply from the
Amnicola Droop site was evident.
EPA Region IV personnel initiated the RI/FS of the Amnicola Dump
site in July 1987; the field investigation portion of the RI was
performed between January and March 1988. Both the RI and FS
Reports were submitted in draft form to the public information
repository in Chattanooga, TN in January 1989.
2.0 ENFORCEMENT ANALYSIS
The Amnicola Dump site was included on the National Priorities
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-6-
List (NPL) in September 1983. Potentially Responsible Parties
(PRPs) wera notified of the commencement of the Amnicola Dump
RI/FS in 1987. The PRPs declined to participate in the RI/FS
and EPA assumed the lead at that time.
The majority of PRPs identified at the Amnicola Dump site were
associated with the alleged disposal of latex wastes at the
site. The Remedial Investigation did not detect latex waste
constituents in any of the media sampled. The RI did, however,
detect polyaromatic hydrocarbons (PAHs) in surface soil. The
Public Health Evaluation concluded that the risks associated
with ingestion of surface soils contaminated with PAHs at the
Amnicola Dump site exceed the Agency's 10~4 to 10 risk
range. Thus, remediation of surface soils is required. The
PAHs in surface soil were not responsible for the site's
placement on the NPL. The primary factor contibuting to the
site's placement on the NPL was the proximity of Amnicola Dump
to the water intake for the Tennessee American Water Company and
the alleged disposal of latex waste at the site. PAHs in
surface soils at the Amnicola Dump site have been attributed to
the burning, storage and handling of creosoted railroad ties
on-site by the current site owner and operator, Southern Foundry
and Amnicola Equipment and Materials Sales, respectively.
The RI also detected the presence of chromium at 89 ppb (39 ppb
above the Maximum Concentration Limit of 50 ppb) and
bis(2-ethylhexyl)phthalate at 370 ppb (70 ppb above the 10~4
risk level of 300 ppb). Both compounds were detected in one
monitoring well during one sampling event and are attributed to
the contents of the landfill. The recommended alternative
provides for the monitoring of ground water for a period of four
years following remedial action completion. This monitoring
will allow for the development of a sufficient ground water data
base upon which a public health assessment will be performed
five years following remedial action completion. Alternate
Concentration Limits (ACLs) have been established at the site
and reflect the low levels of contaminants that enter the
Tennessee River on a sporadic basis. No ground water
remediation is required; however, if ACLs are exceeded during
the four year period of monitoring, a need for remediation may
be identified during the subsequent public health assessment.
In summary, remediation at the Amnicola Dump site is required as
a result of contaminants introduced subsequent to the site's
placement on the NPL. Monitoring of ground water is required
due to low levels of contaminants attributed to the dump. Thus,
Remedial Design/Remedial Action (RD/RA) notice letters will be
sent to the PRPs upon selection of the remedy. Preliminary
discussions with Southern Foundry and the City of Chattanooga on
RI/FS completion and RD/RA activities commenced in March 1989.
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-7-
3.0 CURRENT SITE STATUS
3 .1 Environmental Setting
3.1.1 Bedrock
The bedrock unit beneath the site is the Murfreesboro limestone,
an Ordovician-age limestone of the Stones River Group. Bedrock
was encountered at an average depth of 34 feet below ground
surface. Depth to bedrock decreases from northeast to
southwest/ ranging from 64 feet at the east end of the site to
32 feet adjacent to the Tennessee River.
The uppermost portion of the Murfreesboro limestone is a
weathered rock with numerous clay-filled fractures. This
uppermost unit is approximately 10 feet thick. Rock coring into
the limestone bedrock allowed visual observation of the
Murfreesboro limestone and determination of weathered zone
thickness. The limestone is medium-gray to grayish-brown, hard,
and contains numerous fractures.
Although there are many geologic faults with surface traces
present in Hamilton County, all are considered geologically
inactive, thereby posing no seismic risk. The seismic activity
present in Hamilton County is the result of periodic releases of
stress in rocks at great depth.
3.1.2 Soils
Unconsolidated sediments (soils) overlying limestone bedrock in
the general site vicinity include silts, clays, and sands of
Quarternary Age. These sediments were deposited in a fluvial
environment directly related to the meandering of the Tennessee
River.
These sediments can be categorized into two fairly distinct
units: the uppermost unit (Unit 1 which is 15 - 30 feet thick)
consisting primarily of sandy clayey silts and the unit
immediately overlying the limestone bedrock (Unit 2 which is 2 -
22 feet thick) consisting of sandy, clayey silts and silty sands
with interbedded sand lenses.
3.1.3 Ground Water
Hydrologic characteristics of the subsurface were investigated
by analysis of information obtained during the RI. The
unconfined alluvial formation (shallow aquifer) underlying
Amnicola Dump site comprises the ground water of primary
concern. Ground water of the alluvial aquifer beneath the site
flows primarily through Unit 2, which consists of sandy clayey
silts and silty sands with interbedded sand lenses immediately
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-8-
overlying the limestone bedrock. Depth to ground water averages
34 feet.
Ground water of the alluvial formation flows primarily in
response to the major hydrologic feature near the site, the
Tennessee River. Ground water flows westerly towards the
Tennessee River and under the waste material, intersecting it
only briefly at the on-site pond. Ground water recharges the
pond, maintaining its level within + 2 feet.
Ground water for municipal, industrial and commercial purposes
is available from the alluvium, colluvium and residuum aquifers
in the Hamilton County area; however, the majority of
Chattanooga is serviced by the Tennessee-American Water Works
(TAWW). TAWW supplies drinking water to approximately 60,000
customers and the water supply for this system is located 0.5
miles downstream from the Amnicola Dump on the Tennessee River.
Wells were identified at two of the fifty-one industries and
businesses located within a one-half mile radius of the site
east of the river; both wells are used exclusively for
industrial purposes and do not provide a route of exposure to
the occupants of the building. Furthermore, the two industrial
wells are cased into bedrock and do not draw a substantial
portion of water from the contaminated alluvial aquifer beneath
the Amnicola Dump site. A review of TAWW's records indicated no
known private wells in the area. Personal communications within
TDHE indicate that few, if any, residents within the survey area
have wells en their property.
3.1.4 Surface Water
The Amnicola Dump site is bounded on the west by the Tennessee
River near river mile 466. Historically, Nick-A-Jack Reservoir
(Tennessee River) levels are regulated by the Tennessee Valley
Authority to control flooding. Hurricanes or other significant
rainfall events can, however, disrupt the usual rainfall
patterns and, subsequently, the reservoir levels. The 10-, 50-,
and 100-year flood elevations for the Tennessee River at the
site have been calculated by TVA to be 655.3, 657.1, and 658.1
feet above mean sea level (msl), respectively. The occurrence
of a 100-year flood would cause approximately one-half of the
site (western half) to become submerged. The area of the
100-year floodplain is shown in Figure 3.
3.2 Surface Soil Contamination
Site investigations, conducted prior to the initiation of the RI
field program, indicated that present, and perhaps past,
activities on the landfill cap may have resulted in surface soil
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sio»rw
FIGURE 3
AWMUXLA DUUP M
CHATTANOooA, ra»
U.I LP.A. KOCH N
AHKA UT 100-YEAH
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contamination. To determine what contaminants may have been
present or introduced, twenty five surface soil samples were
collected on and adjacent to the landfill cap.
There were numerous organic contaminants associated with the
surface soil samples collected from the site. The majority of
the compounds were extractable organics that most likely
originated from the creosote railroad ties that were stored and
burned on-site by the present owner; approximately 100
extractable organic compounds were detected in the surface soil
samples. Table 1 lists the maximum concentration of
contaminants of concern in surface/subsurface soil samples. The
majority of compounds detected were polynuclear aromatic
hydrocarbons (PAHs) and are associated with coal tar or creosote
products (i.e. railroad ties). Concentrations ranged from an
estimated 150 ug/kg of acenaphthylene to 46,000 ug/kg of
fluoranthene. The PAHs were detected in all surface soil
samples collected from the site; however, the highest
concentrations were detected in areas where railroad ties were
stored (before and during the RI) and in areas where railroad
ties were once burned. Data on carcinogenic PAH compounds
detected in surface soil samples is given in Table 2. It should
also be noted that the use of front-end loaders and other heavy
equipment has probably resulted in the spreading of PAH
contamination over the entire surface of the site. This is
apparent from the analytical results of the random samples
collected from the grid system. The origin of the
pesticides/PCBs detected in several of the surface soil samples
is unknown. The highest PCB concentration was detected at a
concentration of 17,000 ug/kg. However, the exposure risk level
has been determined to be in the acceptable 10 to 10
range.
The creosote wood products brought on-site by Amnicola Equipment
& Material Sales is the apparent source of PAHs detected in
surficial soil samples. A target population of workers and
visitors to the site could pose a complete pathway of exposure
through ingeation of contaminated soil. Activities using heavy
equipment with considerable traffic across the contaminated site
would create high airborne particulate levels. Additionally, a
future use scenario could include residential development of the
landfill area, allowing exposure of children through the soil
ingestion pathway. Respiratory absorption through inhalation or
dermal absorption by skin exposure are thought to be
insignificant relative to the much more important ingestion
route.
Using the mean PAH soil level, the plausible and maximum
exposure scenarios yielded risk levels of 2.8 x 10"5 and 1.6 x
10" / respectively, under the current-use scenarios. The
future-use residential development scenario yielded an upper
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TABLE 1
MAXIMUM CONCENTRATION OF CONTAMINANTS OP CONCERN
IN SURFACE/SUBSURFACE SOIL SAMPLES
Chemical
Arsenic
Cadmium
Chromium
PAHab
Lead
Mercury
Cyanide
Heptachlor
Sample Concentration
Location No. In Teat Sample
og/lcg
AD-006/007 12.
AO-OS9 2.
AO-020 58.
AD-014 123.
AD-078 460.
AO-024 .62
AD-057 .41
AD-057 .0024
Gamma-DHK(Lindane) AD-057 .013
Dieldrin
DDTC
PCS
Chlordane
a - ND = Not
b - PAH value
AD-006 .059
AD-057 1.49
AD-015 17.
AD-057 .63
detected
is sum of the detected concentrations of <
Concentration
in Control Sample
nig/kg
NDa
NA
29.00
ND
35.00
.15
NA
ND
ND
ND
ND
ND
NA
Carcinogenic
c -
polynuclear aromatic hydrocarbons
includes DDT and DDE/ODD metabolites
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TABLE 2
CARCINOGENIC PAH COMPOUNDS DETECTED IN SURFACE SOIL SAMPLES
AMNICOLA DUMP SITE
Control
(Background)
Frequency
of
Chemical Detection
Benzo(a) anthracene
Chrysene
Benzo(b and/or k) f luoranthene
Benzo-a-pyrene
Ideno (1,2,3, -cd ) pyrene
Dibenzo(a, h) anthracene
14/15
14/15
14/15
14/15
13/15
8/15
Min. - Max.
(ug/kg)
310J -
360J -
360J -
300J -
290J -
200J -
2600
2400
2400
2500
9300
1900
Mean Concentration
(ug/leg) (ug/kg)
2391
2778
2778
2255
1125
307
ND
ND
ND
ND
ND
ND
NOTES: (1) Frequency of detection ia the number of samples in which the
chemical was detected over the total number of samples.
(2) Geometric means are calculated using one-half the minimum
estimated sample concentration for non-detect sample
concentrations.
J - estimated value
ND - not detected
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bound risk of 2.2 x 10" . The calculated upper bound risks
are outside the Agency's acceptable risk range of 10"** to
10" , thus, remediation of surface soil is required.
3.3 Ground Water Contamination
Organics and inorganics were detected in monitoring well
samples. Table 3 lists those compounds detected in ground water
at the Amnicola Dump site. Four contaminants are regulated by
MCLs under the Safe Drinking Water Act. Compared to the
appropriate ARARs (MCLs), chromium exceeded the level considered
safe for lifetime exposure through drinking water. The 0.09 ppm
detected is approximately two times the MCL standard.
Bis(2-ethylhexyl)phthalate (maximum concentration observed was
370 ppb) exceeded the 10 excess cancer risk level of 300 ppb
in one monitoring well on one occasion. The trihalomethanes
identified in some of the wells can be attributed to monitoring
well installation procedures.
No ground water users are located on or downgradient of the
site. The low concentrations of contaminants discharging into
the River are diluted below human health and aquatic protection
standards. Recreational use of the river adjacent to the
landfill would not be expected to produce exposure to these
contaminants at levels of concern. Based upon the establishment
of Alternate Concentration Limits (See Section 4.2), the current
levels of ground water contaminants will not result in adverse
impacts to human health or the environment; thus, no remediation
of ground water is required.
3.4 Subsurface Soil
Subsurface soil samples were collected to determine if any
contaminants could be detected at the cap-fill interface.
Subsurface soil samples were also collected during the track-hoe
excavation work and at selected monitoring wells to identify
what contaminants may have and may still be migrating from the
site in the surficial ground water.
Lead was detected in several subsurface soil samples at
concentrations from 100 mg/kg to 460 mg/kg. Numerous
extractable organic compounds were detected in the subsurface
soil samples collected from the site. The concentration of
compounds detected in the samples ranged from presumptive
evidence of benzanthracenone detected at an estimated
concentration of 100 ug/kg to di-n-butylphthalate detected at
51,000 ug/kg. The majority of organic compounds detected were
polynuclear aromatic hydrocarbons (PAHs). These compounds were
identified in the shallow subsurface soil samples collected with
hand augers. The majority of compounds detected in five of the
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TABLE 3
GROUND WATER CONTAMINANTS
Contaminant Concentration
(ug/L)
Caprolactum 2.0
Diethyltetrahydrofuran 30.0
Chloroform 8.6
Bromodichloromethane 4 . 6
Ethyl Ether 5.0
Chromium 89.0
Bis(2-ethylhexyl)phthalate 370.0
Bis(dimethylethyl)methylphenol 10.0
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-15-
ten trench samples were also PAHs. No PAH compounds were
detected in the split spoon samples collected from the perimeter
of the site during monitoring well installation.
Shallow subsurface soil samples collected with hand augers from
the cap-fill interface had the greatest number of extractable
organic compounds identified and at the highest concentrations.
The cap-fill interface was not well defined, and the
contamination at these shallow depths may have resulted from the
operation of heavy equipment on the site by Amnicola Equipment &
Materials Sales personnel. The extractable organic
contamination identified in the trench samples probably resulted
from the material disposed at the site.
Remediation of subsurface soils, however, is not necessary due
to the incomplete exposure pathway associated with these soils.
3.5 Surface Water, Sediment and Leachate
The Tennessee River and the pond on the dump site are considered
Class III waters by the State of Tennessee and are to be
protected as a habitat for fish and aquatic life. Surface
water, sediment and leachate samples were collected during the
RI to identify any contaminants that may pose an environmental
and/or human health hazard on-site or by migrating from the site
via surface water and leachate drainage. Samples were collected
from the Tennessee River and on-site from the pond, drainage
ditches and leachate points.
Numerous organic and inorganic contaminants were detected in
several of the leachate samples and soil samples contaminated by
leachate collected during the RI. However, the majority of the
contaminants detected in the sediment samples can probably be
attributed to the railroad ties that were stored on the site.
The analysis of an upstream-downstream pair (relative to the
dump site) of river water samples showed almost identical
contaminant results. The findings were indicative of background
levels and showed no indication of river water degradation by
the dump site.
One surface water sample contained significant levels of
inorganic compounds. A ditch sample taken near the southwestern
corner of the site contained barium, chromium and lead at 820
ppb, 150 ppb, and 660 ppb, respectively. This sample also
contained a PAH compound at 1.4 ppb.
Of the four pond water samples, two contained significant levels
of a carcinogen, bis(2-ethylhexyl)phthalate. A lifetime
exposure for humans (through accidental ingestion) of 4 x 10~5
(within the acceptable risk range) would be associated with
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-16-
these pond concentrations. The concentration of
bis(2-ethylhexyl)phthalate is higher than the fresh water
quality criteria limit for phthalate esters. Phthalates were
not detected in the other two pond water samples and were not
detected in any of the four pond sediment samples. The source
of this compound is not known. A bioassay with daphnids using
undiluted water from the pond drainage ditch did not detect
toxicity. Additional sampling of the pond water will be
performed during remedial design to resolve this unusual pattern
of phthalate findings in two pond samples in the absence of
sediment detection.
Chromium, nickel and lead occurred in most samples at
approximately three times the background level. There is no
reasonably likely scenario that would result in ingestion of the
quantities of sediment required at the site to exceed the
acceptable daily intake.
Complete pathways of human exposure to pond water and sediments
and leachate do not appear to exist since these waters are not
used for drinking, recreation or fishing; therefore remediation
of these media is not required. However, a decision regarding
remediation of surface waters, based on environmental concerns,
will be determined using analytical data collected during
remedial design.
4.0 CLEANUP CRITERIA
The extent of contamination was defined in Section 3.0, CURRENT
SITE STATUS. This section establishes health-based cleanup
goals for surface soil contaminants at Amnicola Dump as well as
defining Alternate Concentration Limits (ACLs) for ground water.
4.1 Surface Soil Cleanup Criteria
Health-based surface soil cleanup goals have been based on
current and potential future site use scenarios.
Current-use scenarios considered include:
Direct contact with on-site soil by part-time outdoor
workers and frequent visitors to the site.
Direct contact with on-site soil by full-time outdoor
workers.
Future-use scenarios include:
Direct contact with on-site soil by future on-site
residents.
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Soil cleanup goals were developed for both practical and
worst-case scenarios. The sum of seven carcinogenic PAHs
present in surface soil was used to calculate a GDI and cleanup
goal for both scenarios.
Soil PAH (total carcinogenic) cleanup levels for adult
practical/ adult worst case, and child resident exposure
scenarios were calculated; the results are presented in Appendix
A. The assumptions for each of the scenarios can be found in
the Public Health Assessment section of the Amnicola Dump RI
Report. The equation used towards calculating risk related soil
cleanup goals is also presented in Appendix A.
Due to the limited and conflicting data available relating to
absorption rates after oral exposure, two "acceptable" soil
cleanup goals were calculated based on 100% and 25% absorption.
In light of the conflicting literature available on absorption
rates, and in keeping with the position of using conservative
assumptions when in doubt, soil cleanup goals which incorporate
a 100% absorption rate were used. Finally, the established soil
cleanup goal was based upon the following considerations:
Amnicola Dump is located in an industrial setting.
Although considered in the Public Health Evaluation, the
likelihood of future development of the site for
residential purposes appears to be remote. Therefore,
child resident values were not considered further.
In light of the conservative positions taken during the
Public Health Evaluation, adult practical values
were selected.
A comparison was made of CERCLA sites within and outside
of Region IV to determine the cleanup levels that were
selected at sites exhibiting similar land use and
types of contaminants (creosote compounds). A cleanup
goal of 100 ppm was the most consistently used.
Thus, a soil cleanup goal of 100 ppm has been established for
the Amnicola Dump site.
4.2 Alternate Concentration Limits
Although ground water is only slightly contaminated at the
Amnicola Dump site, Alternate Concentration Limits (ACLs) were
established to address the potential impact of this
contamination.
Section 121(d) of the Superfund Amendments and Reauthorization
Act (SARA) requires that the selected remedial action establish
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-18-
a level or standard of control which complies with all ARARs.
At the Amnicola Dump site, ground water discharges into the
Tennessee River and, therefore, beyond the boundaries of the
site. Applicable statutory language concerning cleanup
standards under CERCLA is found in Section 121 (d)(2)(B)(ii) of
SARA. SARA does not allow any increase in contaminants in
off-site surface water. Since cleanup goals must be based on
some finite number, the reduction calculation presented in
Appendix B reflects the large dilution factor in the Tennessee
River.
To relate health-based standards for contaminant concentrations
to potential receptors, a current-use scenario was employed.
Under an evaluation of the current-use scenario, there are no
direct receptors of ground water at or downgradient of the
site. Rather, the closest potential receptors are associated
with surface water use at a location where affected ground water
discharges to the Tennessee River.
To calculate probable ACLs for the various contaminants in the
ground water system, a relatively straight-forward mass-balance
approach was used. The analysis involves an initial assumption
that observed levels of contaminants will remain constant as
ground water flows from the source area to a discharge zone at
the Tennessee River.
A second assumption is that ground water enters the surface
water regime in the Tennessee River and undergoes a process of
dilution in a mixing zone. Mixing of the two sources of water
is assumed to occur instantaneously throughout the entire volume
of the mixing zone (one-quarter of the cross-sectional flow of
the Tennessee River), resulting in an output flow and
concentration that can be calculated based on a continuity, or
mass balance approach.
The average reservoir flow rate over 65 years is reported to be
on the order of 30/030 cubic feet per second (cfs). The flow
rate through one quarter of the reservoir was used to estimate
the diluted concentration of contaminants in the Tennessee
River. The point of exposure is the property boundary where the
site meets the Tennessee River.
The recommended ACLs are presented in Table 4 and represent a
one order-of-magnitude increase in i»va »**»"" detected
concentrations of contaminants in ground water. The resulting
diluted concentrations in the Tennessee River due to this one
order-of-magnitude increase would still be nondetectable. The
purpose of the one order-of-magnitude increase is to prevent
unnecessary remedial action in ground water due to seasonal
fluctuations in ground water quality.
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TABLE 4
RECOMMENDED ALTERNATE CONCENTRATION LIMITS (ACLs)
FOR THE AMNICOLA DUMP SITE
Maximum Detected
Concentration in
Ground Water
Projected
Concentration in
Tennessee River
Contaminant
ACL
Caprolactum
Diethyltetrahydrofuran
Chloroform
Bromodichloromethane
Ethyl ether
Chromium
Bis ( 2-ethylhexyl ) phthalate
Bis ( dimethylethyl ) -
methylphenol
2
30
8
4
5
89
370
10
.6
.6
.0
3
5
1
8
9
1
6
1
.7E-07
.6E-06
.6E-06
.5E-07
.3E-07
.6E-05
.8E-05
.9E-06
20
300
86
46
50
890
3700
100
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-20-
The key to obtaining ACLs at the Amnicola Dump site is to
develop an enforceable restriction on ground water use within a
reasonable distance of the site. The exact distance and method
for the restriction will be developed during the Remedial
Design.
A quarterly monitoring program will be conducted for only those
constituents detected in ground water during the RI. This
program will continue for 4 years so that an adequate ground
water data base is available for the public health assessment
that will be conducted 5 years following remedial action
Implementation.
5.0 ALTERNATIVES EVALUATION
The principal remedial action objective at the Amnicola Dump
site is control or treatment of contaminated soil to mitigate
the current and potential future pathways of exposure.
Even though PAH-contaminated soil was introduced subsequent to
the ranking and placement of the Amnicola Dump site on the
National Priorities List (NPL), it has been Agency policy to
identify all hazardous wastes present at NPL sites, determine if
the concentrations pose, or could pose, a human health threat
either now or in the future, and to evaluate potential
ecological effects of site-related contaminants. It is,
therefore, insignificant that PAHs were not initially
responsible for the site's placement on the NPL.
Furthermore, once treatment or control measures are implemented
at the site, assurances are necessary to prevent re-introduction
of additional contaminants. Institutional controls, such as
deed or land use restrictions should be applied to the site to
provide for its long-term integrity.
An additional remedial action objective is to provide for the
monitoring of ground water quality in order to develop a ground
water data base as well as imposition of ground water use
restrictions within a reasonable distance of the site.
The following five remedial action alternatives were considered:
Alternative 1: Monitoring of surface water and ground water
(No Action) quality for 30 years
Fencing of the area of contamination
Imposition of land and ground water use
restrictions
Public Health Assessment every five years
Cost $ 1,100,000
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-21-
Alternative
(Clay Cap)
Alternative 3:
(Solidifica-
tion/Fixation)
Alternative 4:
(Off-Site
Incineration)
Alternative
(Off-Site
Disposal)
2: Placement of clay and topsoil over area of
contamination
Construction of drainage diversion ditches
around the cap
Fencing of the capped area
Imposition of land and ground water use
restrictions
Monitoring of ground water quarterly for four
years and semi-annually thereafter for 26
years
Public Health Assessment conducted five years
following remedial action
Cost $ 900,000
Excavation and screening of contaminated
soil/debris
Treatment of contaminated soil on-site
Debris disposal off-site if contaminated;
allowed to remain on-site if sampling
confirms it is clean
Imposition of land and ground water use
restrictions
Monitoring of ground water quarterly for four
years
Public Health Assessment conducted five years
following remedial action
Cost $ 640,000
Excavation and screening of contaminated
soil/debris
Transportation of soil off-site for
incineration
Debris disposed off-site if contaminated;
allowed to remain on-site if sampling
confirms it is clean
Monitoring of ground water quarterly for four
years
Public Health Assessment conducted five years
following remedial action
Cost $ 1,100,000
5: Excavation of contaminated soil/debris
Transportation of soil/debris to RCRA
landfill
Monitoring of ground water quarterly for four
years
Public Health Assessment conducted five years
following remedial action
Cost $ 610,000
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ALTERNATIVE NO. 1 - NO ACTION
Description
The no action alternative implies leaving the site in its
present condition without disturbing contaminated surface
soils. Associated with the no action alternative would be
continued monitoring of surface water and ground water quality
at the site, allowing identification of any changes in site
conditions which could include the migration of contaminants
off-site. Should changes be discovered which increase the risks
associated with the site, this alternative could be reassessed
and, if necessary, alternative actions taken.
Also included in this alternative is the installation of a fence
around the perimeter of the 7,500 square feet area of surface
soil contamination located at the northeast corner of the
on-site pond. Warning signs would be posted on the fence and
land use restrictions would be imposed on the site owner/
operator to prevent the accumulation of additional areas of
contamination exceeding the surface soil cleanup goals as a
result of the continuous handling, storage or burning of
creosoted railroad ties.
A public health assessment would be performed every five years
to evaluate potential changes in risk associated with no action
at the site. Monitoring will be assumed to continue for 30
years, which is the minimal design life for an EPA remedial
action.
Short-Term Effectiveness
No additional risk to public health or the environment would
result from implementation of this alternative. The
installation of a fence would require approximately two weeks.
Long-Term Effectiveness and Permanence
Little in the way of risk reduction would occur with this
alternative. The potential for trespass in the area of
contamination would remain; thus, the ingestion exposure pathway
would remain. This alternative does not meet SARA'S preference
for permanence and treatment.
Reduction of Toxicity. Mobility or Volume
This alternative provides no treatment or reduction in toxicity,
mobility or volume of contaminated surface soils.
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Implementability
Institutional controls such as land use restrictions could be
implemented within the current Federal/ State and local
regulatory framework.
Fence construction could be implemented in a straightforward
manner requiring no research or engineering and requiring as
little as two weeks for fence construction.
Existing wells at the site would be used for the monitoring of
ground water quality. In 10 to 15 years, well casings and
screens may need to be replaced.
Cost
The total present worth cost for this alternative is estimated
to be $ 1,100,000, the vast majority of which consists of 0 & M.
This alternative is not the least expensive alternative. At
most Superfund sites, the costs of monitoring are significantly
less than the costs for site remediation. However, at the
Amnicola Dump site, the volume of contaminated soil is so small
that several of the more detailed remediation alternatives are
less expensive than the less detailed no action alternative
which includes long-term monitoring of ground and surface
water. In addition to monitoring ground and surface water for
30 years, the no action alternative includes conducting a public
health assessment every 5 years for 30 years.
Compliance with ARARs
This alternative does not comply with CERCLA requirements; ARARs
would not be achieved since the exposure pathway of soil
ingestion would remain.
Overall Protection of Human Health and the Environment
The Public Health Evaluation concludes that ingestion of
contaminated surface soils is the greatest concern at the -
Amnicola Dump site. Ingestion of soils above the established
cleanup goal is not acceptable and the no action alternative
would not provide an effective, long-term barrier to the
ingestion exposure pathway.
State and Community Acceptance
No preference for this alternative was communicated to EPA by
either State personnel or the community.
ALTERNATIVE NO. 2 - LOW PERMEABILITY COVER
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Description
Construction of a low permeability (clay) cover at the Amnicola
Dump site would involve the placement of clay and topsoil over
areas of contaminated surface soil that exceed the established
soil cleanup goals.
Due to the absence of "clean" clay fill on-site, approximately
600 cubic yards of clay would be hauled to the site and placed
over the area of surface soil contamination. Approximately two
feet of this low hydraulic conductivity material would be
placed, compacted, and then covered with a one-foot layer of
vegetative fill. Again, due to the absence of acceptable
topsoil material on-site, approximately 300 cubic yards of this
material would be hauled to the site.
Little in the way of re-contouring of the current ground surface
would be required prior to construction of the cap. The current
surface of the area of concern slopes one to two percent to the
west (towards the on-site pond and Nick-a-Jack Reservoir). The
cap contour would match the current slope, resulting in adequate
drainage of precipitation. Drainage diversion ditches would be
constructed around three sides of the capped area to promote
runon of surface water towards the on-site pond and away from
the capped area. These drainage ditches would be lined with
rip-rap to control erosion.
Once constructed, the capped area would be fenced to help
protect its long-term integrity.
Land use restrictions would be imposed on the site to prevent
the accumulation of additional areas of contamination that
exceed the established surface soil cleanup goals as a result of
the handling, storage or burning of creosoted railroad ties.
Monitoring of ground water quality of the site would be
performed quarterly for a period of four years and semi-annually
for 26 years thereafter. A public health assessment would be
conducted by EPA five years after implementation of the remedial
action to evaluate potential changes in risk associated with the
site.
Ground water use restrictions would be imposed within a
reasonable distance from the site in keeping with the
establishment of ACLs.
Shoirt-Term Effectiveness
A low permeability cover is a reliable, low maintenance
procedure for limiting infiltration and reducing the mobility of
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-25-
contaminanta. The soil exposure pathway would be immediately
broken and risk from the site would be within the acceptable
risk range.
Minimal risk would be associated with the construction of this
remedy; erosion control measures would be implemented during
construction to prevent excessive sediment loading of the
adjacent on-site pond and Nick-a-Jack Reservoir.
Long-Term Effectiveness and Permanence
This alternative would provide a continued, effective reduction
of risk posed by ingestion of contaminated surface soils. A low
permeability cover would minimize infiltration of surface water,
thereby significantly reducing the migration potential of
contaminants. The potential for downward migration of
contaminants would remain; however, the relatively immobile
nature of PAHs, along with the minimization of surface water
infiltration, should prevent the formation of additional
exposure pathways.
Periodic maintenance of the cap would enhance the long-term
reliability of this alternative. Maintenance would consist of
repairing any areas of erosion and maintaining a healthy
vegetative cover.
Approximately one-half of the Amnicola Dump site lies within the
100-year floodplain of the Tennessee River (Nick-a-Jack
Reservoir); all of the contaminated area of concern lies within
this floodplain. Although river elevations are regulated by the
Tennessee Valley Authority, extremely heavy rainfall events over
a short duration could cause flooding of portions of the
Amnicola Dump site, specifically, the capped area, thereby
compromising the long.-term integrity of the cap.
Reduction of Toxicity, Mobility or Volume
This alternative would provide no treatment which would
significantly reduce the toxicity, mobility or volume of the
contaminants.- Preventing surface water infiltration would
reduce the migration potential of contaminants.
Implementability
Implementation of this alternative would involve the use of
standard earth moving and compacting equipment. Site access
would be obtained with little difficulty; no temporary roads or
permits would be required for on-site activities. Only minor
clearing and grading operations would be required prior to cap
construction. Labor and materials for this alternative are
readily available and would be obtained locally.
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Institutional controls such as land use restrictions could be
implemented within the current Federal, State and local
regulatory framework.
Implementation time can be expected to take approximately two
months. Existing wells at the site would be used for the
monitoring of ground water quality. In 10 to 15 years, well
casings and screens may need to be replaced.
Cost
The total present worth cost of this alternative is estimated to
be $ 900,000 which includes $ 684,000 for 0 & M.
Compliance With ARARs
Capping of the entire Amnicola Dump landfill surface was not
considered because 1) Amnicola Dump was used as a construction
debris disposal site and never as a permitted Solid Waste
Disposal facility; and 2) levels of contaminants exceeding soil
cleanup goals were confined to one isolated area of the site.
Thus, closure of the entire dump in accordance with Subtitle D
Solid Waste regulations is neither applicable nor relevant and
appropriate.
Land Disposal Restrictions would not be triggered because
contaminants would be capped in-place; no placement of
contaminants would occur.
This alternative does not comply with SARA'S preference for
treatment.
Overall Protection of Human Health and the Environment
This alternative would effectively break the soil ingestion
exposure pathway.
State and Community Acceptance
No preference for or objections to this alternative were
communicated to EPA by either State personnel or the community.
ALTERNATIVE NO. 3 - SOLIDIFICATION/FIXATION
Solidification/Fixation of contaminated surface soils would
initially involve the excavation of approximately 600 cubic
yards of contaminated soils and debris. Sampling will be
performed during the remedial design to confirm actual lateral
and vertical extent of soil contamination.
Numerous debris in the subsoil of the contaminated area would
require on-site materials handling prior to solidification
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-27-
processes. This debris, such as bricks, broken concrete, scrap
metal/ and wood, may require off-site disposal at a permitted
disposal facility. Land Disposal Restrictions for CERCLA debris
may not be in effect at the time of construction and the debris
could be disposed of at a permitted landfill without prior
treatment. However/ the levels of contaminants on the debris
may not exceed cleanup goals (or Land Disposal Restriction
requirements if they are in effect)/ thereby allowing the debris
to remain on-site.
Once debris has been removed/ approximately 400 cubic yards of
soil would require treatment.
Mixing of the soil with stabilizing agents would be performed
on-site and above-grade. The mixed material would be placed
back in the excavated area and covered with a 12-inch thick
layer of vegetated topsoil. Due to the lack of acceptable
topsoil on-site, approximately 300 cubic yards of material would
be hauled to the site. The finished ground surface would match
the existing ground contour.
Treatability or bench scale studies would be necessary to
determine which solidification agents axe most effective for the
Amnicola Dump waste.
Land use restrictions would be imposed on the site to prevent
the accumulation of contamination that exceed the surface soil
cleanup goals as a result of the handling/ storage or burning of
creosoted railroad ties. Ground water use restrictions would be
imposed within a reasonable distance of the site in keeping with
the establishment of ACLs.
A quarterly monitoring program to analyze for those ground water
constituents of concern would be implemented for a period of
four years. A public health assessment would be conducted by
EPA five years after remedial action implementation. Following
this assessment/ monitoring activities would be terminated,
provided that the public health assessment does not identify a
need for further remedial action or monitoring.
Short-Term Effectiveness
Solidification of contaminants would immediately break the
ingestion exposure pathway. This alternative would involve
minimal risk to workers during construction with the exception
of potential exposure of site workers to contaminated dust
during excavation. Exposure risks would be minimized through
the use of wetting agents or water. Continuous air monitoring
would be performed to ensure site worker safety.
Erosion control measures would be implemented during excavation
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-28-
activities to prevent sediment and contaminant loading of the
on-site pond and Nick-a-Jack Reservoir.
Lona-Term Effectiveness and Permanence
All contaminated soil exceeding the established cleanup goals
would be immobilized and the soil ingestion exposure pathway
broken. Solidification would produce a monolithic block of
waste with high structural integrity. Stabilizing agents should
mechanically lock up the PAH compounds within a solidified
matrix resulting in reduced surface area and negligible
contaminant loss over a long period of time. Leaching tests
have shown that solidification is an effective means to
prevention of contaminant migration.
The organic compounds at Amnicola Dump (sum of six carcinogenic
compounds was less than 125 ppm in the area of concern) should
not interfere with the setting, curing, and performance of the
solidified material.
Long-term management and monitoring would not be required with
this alternative.
Reduction of Toxicity, Mobility or Volume
Solidification would significantly reduce the mobility of
contaminants and comply with SARA'S preference for treatment.
Implementability
Implementation of this alternative would involve the use of
standard earth moving and cement mixing equipment. Special
equipment would be required, however, to separate debris from
the waste prior to solidification processes. Site access would
be obtained with little difficulty; no temporary roads or
permits would be required for these on-site activities. Minor
clearing operations would be required prior to excavation
activities. Labor and materials (assuming Portland cement or
lime-based pozzolan is used) are readily available and could be
obtained locally.
Institutional controls such as land use restrictions could be
implemented within the current Federal, State and local
regulatory framework.
An implementation time of approximately two months can be
expected following remedial design which would include a
treatability or bench-scale study requiring up to three months
to complete.
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The total present worth cost for this alternative is estimated
to be $ 640,000 which includes $ 384,000 for 0 & M.
Compliance With ARARs
This alternative achieves SARA'S preference for treatment and,
as demonstrated by the ACL calculations, is protective of human
health and the environment.
Overall Protection of Human Health and the Environment
This alternative is protective of human health and the
environment since all contaminants exceeding the established
soil cleanup goal will be immobilized and the soil ingestion
exposure pathway broken.
State and Community Acceptance
The State accepts this alternative for achieving the remedial''
action objectives; however, the State has withheld concurrence
pending a further review of Tennessee's Alternate Concentration
Limit policy and its applicability to ground water contaminants
at the Amnicola Dump site. Only one comment from the community
was received during the public comment period. This resident
felt too much money was being spent on site remediation.
ALTERNATIVE NO. 4 - OFF-SITE INCINERATION
Description
This alternative involves the off-site incineration of
contaminated soils and off-site disposal of incineration
residuals.
Approximately 600 cubic yards of contaminated soil would be
excavated to a depth of two feet below ground surface. Sampling
will be performed during remedial design to confirm the actual
lateral and vertical extent of contamination.
Numerous debris in the subsoil of the contaminated area would
require on-aite materials handling prior to shipment of the
waste off-site. For estimation purposes, it was assumed that
50% of the excavated material consists of debris. This debris
(approximately 325 cubic yards), such as wood, scrap metal,
concrete blocks, etc., may require off-site disposal at a
permitted landfill or allowed to remain on-site. Off-site
disposal would be necessary if sampling indicates the debris
contains concentrations of contaminants exceeding the cleanup
goals. However, if Land Disposal Restrictions are in effect at
the time of remedial action implementation, disposal at an
off-site location will be necessary if contaminants exceed LDR
treatment standards.
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Subsoil debris would undergo on-site materials handling
processes such as screening to remove debris and reduce particle
size to two inches or less, depending upon the incineration
facility used. Once debris has been removed, and assuming a 20%
volume expansion of soil during excavation, approximately 350 -
400 cubic yards of soil would remain to be treated.
All feed material would be containerized in 30-gallon fiber or
polyethylene drums or 55-gallon steel drums prior to
transportation. All transportation loads would be manifested
and carried by licensed hazardous waste haulers. Permits for
the incineration facility would be verified prior to initiating
the process.
Once excavation activities have been completed, the excavated
area would be backfilled with clean fill hauled in from an
off-site location and the ground restored to its original
contour.
Land use restrictions would be imposed on the site to prevent
the accumulation of additional areas of contamination that
exceed the surface soil cleanup goals as a result of the
handling, storage or burning of creosoted railroad ties. Ground
water use restrictions would be imposed witihin a reasonable
distance from the site in keeping with the establishment of
ACLs.
A quarterly monitoring program to analyze for those ground water
constituents of concern would be Implemented for a period of
four years. A public health assessment would be conducted by
EPA five years after remedial action implementation. Following
this assessment, monitoring activities would be terminated,
provided that the public health assessment does not identify a
need for further remedial action or monitoring.
Short-Term Effectiveness
Incineration of contaminated soils would immediately break the
soil ingestion exposure pathway.
This alternative would involve minimal risk with the exception
of short term exposure to site workers. These potential impacts
can be reduced by implementation of a site-specific health and
safety plan including the use of wetting agents during
excavation activities. Continuous air monitoring would be
performed to ensure site worker safety. In addition, there is
some risk to the general population associated with
transportation of the materials.
Erosion control measures would be implemented during excavation
activities to prevent sediment and contaminant loading of the
adjacent on-site pond and Nick-a-Jack Reservoir.
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Long-Term Effectiveness and Permanence
All contaminated soil exceeding the established cleanup goals
would be detoxified and delisted. The soil ingestion exposure
pathway would be broken. Removal of contaminated soil will
eliminate the need for installation of any long-term treatment
or containment technologies.
Reduction of Toxicity. Mobility or Volume
Implementation of this alternative will result in total
reduction of toxicity, mobility and volume of site contaminants.
Implementability
Implementation of this alternative would involve the use of
standard earth moving and hauling equipment. Special equipment
would be required, however, to separate debris from the waste
prior to transportation.
Site access would be obtained with little difficulty; no
temporary roads would be required for on-site activities. Labor
and resources are readily available and could be obtained
locally. Transportation loads would require manifests and
transportation by licensed hazardous waste haulers. Permits for
the incineration facility would require verification;
verification of the unit's ability to accept waste within the
required timeframe would be necessary.
The greatest difficulty with this alternative would be locating
a facility to accept the screened-out debris. For costing
purposes, it is assumed that the debris would be transported to
the Chemical Waste Management Inc. RCRA facility in Emelle,
Alabama and that Land Disposal Restrictions for CERCLA debris
are not in effect at the time of remedy implementation.
However, these restrictions for CERCLA debris may not be in
effect at the time of construction and the debris could be
disposed at a permitted landfill without prior treatment.. If
sampling indicates that the levels of contaminants on the debris
do not exceed cleanup goals (or Land Disposal Restriction
requirements if they are in effect), the debris may remain
on-site.
Total implementation time is estimated to take no longer than
s ix weeks.
Institutional controls such as land use restrictions could be
implemented within the current Federal, State and local
regulatory framework.
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The total present worth cost of this alternative is estimated to
be $ 1,100,000 which includes $ 384,000 for 0 & M.
Compliance With ARARs
This alternative would comply with SARA'S preference for
treatment and, as demonstrated by the ACL calculations, is
protective of human health and the environment.
Transportation of all contaminated soil would be in accordance
with appropriate Federal and State regulations. The treatment
and disposal facility receiving the contaminated soil would be
in compliance with all ARARs.
Overall Protection of Human Health and the Environment
This alternative is protective of human health and the
environment since all contaminants exceeding the established
soil cleanup goal would be removed from the site, detoxified,
and delisted. The soil ingestion exposure pathway would be
broken.
State and Community Acceptance
No preference for or objection to this alternative was
communicated to EPA by either State personnel or the community.
ALTERNATIVE NO. 5 - OFF-SITE DISPOSAL
Description
Off-site disposal would involve the excavation of approximately
600 cubic yards of contaminated soils down to two feet below
ground surface. This material contains numerous debris such as
wood, scrap metal, broken concrete, etc. that were identified
during the RI field sampling program. Actual extent and depth
of contaminated material to be excavated will be determined
during remedial design.
Excavated wastes would be stockpiled in a staging area that
would serve as a place for loading and decontamination. Wastes
should not require stockpiling for more than two or three days;
thus, no special pads or drainage devices would be required.
The wastes would be manifested by a licensed hazardous waste
hauler and transported to an approved RCRA Subtitle C hazardous
waste landfill.
Once excavation activities have been completed, the excavated
area would be backfilled with clean material hauled in from an
off-site location and the ground surface restored to its
original contour.
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Land use restrictions would be imposed on the site to prevent
the accumulation of additional areas of contamination that
exceed the surface soil cleanup goals as a result of the
handling, storage or burning of creosoted railroad ties. Ground
water use restrictions would be imposed within a reasonable
distance from the site in keeping with the establishment of
ACLs .
A quarterly monitoring program to analyze for those ground water
constituents of concern would be implemented for four years. A
public health assessment would be conducted by EPA five years
after remedial action implementation. Following this
assessment/ monitoring activities would be terminated/ provided
that the public health assessment does not identify a need for
further remedial action or monitoring.
Short-Term Effectiveness
Off-site disposal of contaminants exceeding the established soil
cleanup goals would immediately break the ingestion exposure
pathway.
This alternative would involve minimal risk with the exception
of short-term exposure to site workers. These potential impacts
can be reduced by implementation of a site-specific health and
safety plan and the use of wetting agents during excavation
activities. Continuous air monitoring would be performed to
ensure site worker safety. In addition/ there is some risk to
the general population associated with transportation of the
materials.
Erosion control measures would be implemented during excavation
activities to prevent sediment and contaminant loading of the
adjacent on-site pond and Nick-a-Jack Reservoir.
Long-Term Effectiveness and Permanence
All contaminated soils exceeding the established soil cleanup
goals would be removed form the site; however/ risk from these
soils would be transferred from the Amnicola Dump site to
another location. No long-term monitoring or 0 & M requirements
are anticipated.
Reduction of Toxicity, Mobility or Volume
This alternative provides no reduction of toxicity/ mobility or
volume of contaminated soils.
Implementability
Implementation of this alternative would involve the use of
standard earth moving and hauling equipment.
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Site access would be obtained with little difficulty; no
temporary roads would be required for on-site activities. Labor
and resources are readily available and could be obtained
locally. Transportation loads would require manifests and
transportation by licensed hazardous waste haulers.
The greatest difficulty with this alternative would be locating
a facility to accept the waste. For costing purposes, it is
assumed that the waste would be transported to the Chemical
Waste Management Inc. RCRA facility in Emelle, Alabama.
Land Disposal Restrictions, however, may take effect before this
alternative could be implemented in which case the soil/debris
may require treatment prior to disposal. For cost estimation
purposes, it is assumed that Land Disposal Restrictions are not
in effect at the time of remedy implementation. If sampling
indicates that the levels of contaminants on the debris do not
exceed cleanup goals (or Land Disposal Restriction requirements
if they are in effect), the debris may remain on-site.
Implementation time, including excavation, hauling, and site
restoration is estimated to take no longer than three weeks.
Cost
The total present worth cost for this alternative is estimated
to be $ 610,000 which includes $ 384,000 for 0 & M.
Compliance With ARARs
This alternative would not comply with SARA'S preference for
treatment.
Transportation of all contaminated soil would be in accordance
with appropriate Federal and State regulations. The disposal
facility would be in compliance with all ARARs.
Overall Protection of Human Health and the Environment
This alternative is only partially protective of human health
and the environment since all risk would be removed from the
Amnicola Dump site but transferred to another location.
State and Community Acceptance
No preference for or objection to this alternative was
communicated to EPA by the community. The State commented that
this Off-Site Disposal would also be an acceptable alternative.
6.0 RECOMMENDED ALTERNATIVE
6.1 Description of Recommended Alternative
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The recommended alternative, Alternative # 3, for remediation of
contamination at the Amnicola Dump site, includes the following
components:
Excavation and screening of contaminated soil/debris
Treatment of contaminated soil on-site
Debris disposed off-site if contaminated; allowed to
remain on-site if sampling confirms it is clean
Placement of solidified mass on-site, above the ground
water table, and outside the 100-year floodplain
Monitoring of ground water quality for four years
Public health assessment conducted five years after
remedial action
Contaminated soil/debris would be excavated from a location in
the northwest corner of the Amnicola Dump site (Figure 4). PAHs
at this location were detected at a concentration of 123 ppm, 23
ppm above the 100 ppm cleanup goal that has been established for
PAHs at the Amnicola Dump site. While the levels of PAHs above
this cleanup goal of 100 ppm are believed to be confined to this
one location, biased sampling in the area of concern, as well as
random site-wide sampling, will be conducted during remedial
design to determine if heavy equipment traffic on-site has
distributed contaminants elsewhere on-site.
Additionally, surface water samples would be collected from the
on-site pond during the remedial design. Additional samples are
necessary in light of the conflicting data obtained during the
RI concerning the presence of bis(2-ethylhexyl)phthalate in two
pond water samples. Should bis(2-ethylhexyl)phthalate be
detected at significant concentrations during the remedial
design sampling, the Record of Decision would be re-evaluated
and appropriate actions taken to mitigate the threat or
potential threat to aquatic life, if necessary.
Following remedial design, an estimated 600 cubic yards of
soil/debris would be excavated and the debris (wood, metal,
concrete, etc.) screened. Approximately 400 cubic yards of
contaminated soil would remain to be treated. Sampling of the
debris will be performed during remedial action to determine if
the debris contains concentrations of contaminants exceeding
either the cleanup goal or Land Disposal Restriction
requirements (if LORs are in effect at the time of remedy
implementation), whichever is more stringent. If sampling
indicates that the debris does not contain concentrations of
contaminants above the applicable standard, the debris will be
re-deposited on-site.
Mixing of the contaminated soil with stabilizing agents such as
cement, kiln dust, etc. would be performed on-site and
above-grade.
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Solidification/fixation of contaminated soil should facilitate a
chemical or physical reduction of the mobility of contaminants.
A bench-scale treatability test would be conducted to select the
proper additives and their ratios and to determine the curing
time required to set the waste adequately. Leaching tests and
compressive strength tests would also be conducted to determine
the integrity of the solid end product.
Actual attainment of cleanup goals/ like any other remedial
alternative, using the solidification/fixation technology will
not be known until remedial action has been completed. However,
creosote type wastes have been successfully treated by
solidification/fixation and it is very reasonable to assume that
at least a 19% reduction in the concentration of PAHs from the
leachate that may migrate from the solidified mass can be
achieved. A 19% reduction would reduce the concentration of
contaminants to the cleanup goal of 100 ppm.
The solidified mass would be placed in an area of the site above
the ground water table and outside the 100-year floodplain. A'
12-inch thick layer of topsoil would then be placed over the
solidified mass and the ground surface restored to its original
condition.
Land use restrictions would be imposed on the site to prevent
the accumulation of contamination that exceed the surface soil
cleanup goals as a result of the handling, storage, or burning
of creosoted railroad ties.
SARA Section 121(d){2)(b)(ii) provides for the establishment of
Alternate Concentration Limits (ACLs) under certain
circumstances. One of the criteria for establishment of ACLs is
the existence of institutional controls that preclude human
exposure to the contaminated ground water at any point between
the site boundary and all known and projected points of entry of
such ground water into surface water. The point of entry for
the Amnicola Dump site is the property boundary where the site
meets the Tennessee River. Therefore, the key to obtaining ACLs.
at the Amnicola Dump site is to develop enforceable restrictions
on ground water use within a reasonable distance of the site.
The exact distance and method for the restriction would be
developed during the remedial design phase.
A quarterly monitoring program to analyze for those ground water
constituents of concern would be implemented for a period of
four years. A public health assessment would be conducted by
EPA five years after remedial action implementation. Following
this assessment monitoring activities would be terminated,
provided that the public health assessment does not identify a
need for further remedial action or monitoring.
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All of the alternatives, with the exception of the No Action
alternative, would immediately break the soil ingestion exposure
pathway. Minimal risk is associated with remedy construction
for each alternative; however, solidification, off-site
incineration, and off-site disposal would require additional
precautionary measures to ensure the safety of workers.
Off-site Disposal and Off-Site Incineration add a slight risk to
the general public due to hauling activities. Given the
relative immobility of site contaminants and media they are
contained in (soil), this risk would be minimal in the event of
an accident.
All alternatives, with the exception of the No Action
alternative, would require temporary erosion control measures to
prevent impact to the adjacent on-site pond and Nick-a-Jack
Reservoir during remedial action.
Alternatives 2 through 5 provide an equal degree of short-term
effectiveness .
Solidification and Off-Site Incineration provide the greatest
degree of long-term elimination of risk posed by contaminants at
the Amnicola Dump site.
The Low Permeability Cover Alternative would also provide
long-term protection to public health and the environment but
the potential exists for rare, but nonetheless possible, flood
events which could compromise the integrity of the cap.
Off-Site Disposal merely transfers the risk to another location
but would offer some protection by proper disposal in a
permitted hazardous waste facility. Fencing (No Action)
provides little in the way of prevention of long-term exposure
to site contaminants.
By detoxifying contaminants, the Off-Site Incineration
alternative offers maTimnm reduction of toxicity, mobility, and
volume and is thereby the most effective in achieving this
criteria. Solidification would provide a significant reduction
of contaminant mobility.
Alternatives 1 and 2 offer no or minimal reduction in toxicity,
mobility or volume of contaminants at the Amnicola Dump site.
The fence construction, monitoring and land use restriction
components of Alternative 1 would make this alternative the
least difficult to implement.
The Low Permeability Cover would present fewer difficulties than
Alternatives 3 through 5 because no permits would be required
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and all activities could be performed with standard, readily
available equipment and resources.
Off-Site Disposal would require licensed hazardous waste haulers
and location of an approved RCRA facility to accept the waste.
Standard, readily available equipment could also be used.
Both Solidification/Fixation and Off-Site Incineration
alternatives require licensed hazardous waste haulers (debris
only for the Solidification/Fixation alternative) and the use of
special equipment for screening of debris from the waste.
However, Off-Site Incineration involves the location of a
licensed incineration unit that would accept the waste within
the required timeframe. Solidification/Fixation would require a
treatability or bench-scale study but this could be performed
during the remedial design with minimal impact to project
schedule.
Off-Site Incineration is estimated to be the most expensive
treatment alternative. The Solidification/Fixation and Off-S'i'te
Disposal alternative are similar in cost and are the least
expensive alternatives. The alternatives which included the
most limited remediation alternatives, No Action and Capping,
are not the least expensive alternatives. This is due to the
extensive long-term monitoring requirements not included in the
other alternatives.
Cost estimates for Solidification/Fixation are perhaps the least
accurate. This is due to the large variability in unit costs
attributable to difficulty in estimating operating parameters
before completion of treatability studies, and the very small
volume of soils to be remediated.
All alternatives, with the exception of the No Action
alternative, are protective of human health and the environment;
however, only Solidification/Fixation and Off-Site Incineration
comply with SARA'S preference for treatment.
Off-Site Icineration and Off-Site Disposal involve compliance
with additional ARARs associated with the transportation of
hazardous materials. Alternatives 4 and 5 involve incineration
and disposal, respectively, at approved facilities only.
Off-Site Incineration and Solidifcation/Fixation alternatives
both offer the greatest degree of overall protection of human
health and the environment. Off-Site Incineration involves
slightly greater risk due to the transportation requirements.
No Action provides the least protection while Capping and
Off-Site Disposal fall somewhere in the middle.
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Thus, EPA believes that Alternative 3 presents the best balance
among the effectiveness, implementability, and cost factors for
this site. Further, this remedy meets all applicable federal
and state standards.
6.2 Operation and Maintenance
Overall implementation of this remedy is estimated to take 1
month following remedial design. Ground water monitoring will
be performed for four years following remedial action. A public
health assessment will be conducted within 5 years of remedial
action. Monitoring activities would be terminated after the
4-year monitoring period, provided that the public health
assessment does not identify a need for further monitoring or
remedial action.
6.3 Cost of Recommended Alternative
The present worth cost of this remedy is estimated to be
$ 640,000. The capital cost would be approximately $ 256,000.
The total present worth of the 0 & M costs is estimated to be
$ 384,000.
6.4 Schedule
The planned schedule for remedial activities at the Amnicola
Dump site is as follows:
April 1989 Initiation of Remedial Design
September 1989 Initiation of Remedial Action
October 1989 Remedial Action Completed/
0 & M Initiated
Note: This schedule assumes that EPA will conduct the Remedial
Design/Remedial Action. Should the Potentially Responsible
:arties accept EPA's offer to conduct the RD/RA, this schedule
will not apply and a new schedule would be negotiated through a
Consent Decree.
6.5 Future Action
Following completion of remedial action, 0 & M activities will
be initiated. 0 & M activities are estimated to take 4 years
followed by a public health assessment within 5 years of
remedial action implementation. Currently, there are no known
state or federal regulations or guidelines that restrict the use
of a site containing solidified waste. As long as the ground
water and land use restrictions are adhered to, site use will be
dictated by the site owner.
During Remedial Design, soil samples will be collected at the
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Amnicola Dump site. Sampling will include random, site-wide
surface soil as well as biased sampling in the area of concern.
Biased sampling will be conducted to gain a more accurate
vertical and lateral extent of contamination for use in design
considerations. Random, site-wide sampling will be conducted to
determine if site conditions have changed since the 1988 site
sampling.
Should sampling indicate that soil contamination is no longer
present (e.g. traffic over the site by the on-site salvage
business has dispersed contaminants), surface soil remediation
may not be required. Site-wide sampling may indicate that
additional hot spots are present on-site. If additional areas
containing concentrations of contaminants above 100 ppm are
discovered during remedial design, the scope of soil remediation
will be expanded to include these areas. If soil contamination
above 100 ppm in the area of concern is no longer present, or if
additional areas are discovered, the remedy will be
re-evaluated. This re-evaluation may result in a change in the
selected alternative or the decision to take no action at the
site. Such actions would be public-noticed and a comment period
held prior to implementation of these actions.
6.6 Consistency With Other Environmental Laws
SARA Section 121 Cleanup Standards - Section 121 governs
ground water cleanup standards and allows the establishment
of ACLs provided that there is no significant increase in
contaminants in off-site surface water. Section 121 also
specifies that the point of human exposure may not be
beyond the boundaries of the site when establishing ACLs
unless:
- There are known and projected points of entry of
contaminated ground water into surface water;
- There will be no measured or projected increase of
contaminants from the ground water in the surface water
at the point of entry/ and;
- There are institutional controls that preclude human
exposure to ground water.
Institutional controls will be put in place within a
reasonable distance of the Amnicola Dump site to preclude
human consumption of ground water. There are currently
no ground water users on or downgradient of the site.
Should the concentration of contaminants in ground water
meet or slightly exceed the established ACLs, the
resulting concentration of these contaminants in the
Tennessee River will still be non-detectable. Thus,
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there will be no significant increase of contaminants in
surface water.
Fish and Wildlife Coordination Act - Requires adequate
protection of fish and wildlife if any stream or other
body of water is modified. Additionally, actions in
floodplains are required to avoid adverse effects,
minimize potential harm, and restore and preserve natural
and beneficial values.
Actions such as silt fencing will be undertaken during
remedial action to avoid sediment and/or contaminant
loading of the Tennessee River or on-site pond.
Endangered Species Act - Requires action to conserve
endangered or threatened species for activities in
critical habitats upon which these species depend.
Those species identified by the U.S. Department of
Interior - Fish and Wildlife Service (See Appendix C) as"
federally listed endangered (E) and/or threatened (T) which
may occur in the area of influence of remedial action at
Amnicola Dump include:
Snail Dairter (T), Orange-footed pearly mussel (E), and
Pink mucket pearly mussel (E) . Remedial action at
Amnicola Dump will be implemented in a manner resulting
in no impact to threatened and endangered species or
surface water quality of the Nick-a-Jack
reservoir.
National Historical Preservation Act - Requires that
action be taken to preserve or recover historical or
archaeological data which might be destroyed as a result
of site activities.
There is no information to indicate that the Amnicola Dump
site contains any sites which may be considered to be of
historic or archaeological significance (Appendix D).
40 CFR Section 264.99 Compliance Monitoring Program -
Establishes criteria for monitoring ground water quality
when contaminants have been detected. This involves
development of a ground water quality data base sufficient
enough to characterize seasonal fluctuations in ground
water quality at the site.
Land Disposal Restrictions (LDRs^ - The LDRa are
applicable to the waste on-site if the soils are excavated
and removed or excavated and treated. In alternatives
where the LDRs are applicable, the soil must be treated to
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the interim treatment levels prior to land disposal.
LDRs for CERCLA soil and debris will be adhered to if they
are in effect at the time of remedial action. Should LDRs
be in effect at the time of remedial action, and if the
concentration of contaminants on the excavated debris
exceeds LDR standards, the debris will be treated prior to
disposal.
7.0 COMMUNITY RELATIONS
Community relations activities have remained an important aspect
throughout the RI/FS. On December 15, 1987, a public
information meeting was held at the Chattanooga Hamilton County
Bicentennial Library in Chattanooga, TN to inform the community
of EPA's activities during the RI/FS process. Prior to the
December 15 meeting, public notices, fact sheets, and press
releases were issued.
On January 30, 1989, the final draft RI and FS reports were
submitted to the public information repository in Chattanooga.
A public meeting was held at the Chattanooga Hamilton County
Bicentennial Library in Chattanooga on February 13, 1989 to
present the findings of the RI and EPA's preferred remedial
alternative. Prior to the February 13 meeting, EPA issued press
releases, public notices, fact sheets, and a proposed plan.
Following the February 13 meeting, a public comment period was
held for 21 days, ending on March 5, 1989.
Comments and EPA responses are included in the Responsiveness
Summary portion of this Record of Decision. The Record of
Decision will be placed in the public information repository and
a public notice will be issued stating the basis and purpose of
the selected alternative. When EPA approves the design for the
selected alternative, a fact sheet will be issued explaining the
final engineering design. A fact sheet will be issued again
before construction of the design begins.
8.0 STATE INVOLVEMENT
As required by CERCLA, Section 104(C), the State must assure
payment of ten percent of all costs of remedial action.
Remedial action has been defined in SARA as including all
construction and implementation activities until site
remediation is completed. Activities required to maintain the
effectiveness of the remedy following completion of the remedial
action is considered operation and maintenance (0 & M) . If
surface water or ground water treatment is part of the remedy,
only the first ten years of such treatment will be considered as
remedial action; the remaining period of treatment will be a
part of 0 & M activities. The State is required to pay 100
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percent of all 0 & M following completion of the remedial
action. EPA and the State may enter into an agreement whereby
EPA would fund 90 percent of 0 & M costs, for a period not to
exceed one year, until the remedy is determined to be
operational and functional.
A summary of State cost-sharing obligations for the recommended
alternative at the Amnicola Dump site is shown in Table 5. The
State of Tennessee's cost-sharing responsibility is estimated to
be $ 25,300 for remedial action and $ 297,600 for 0 & M.
9.0 SIGNIFICANT CHANGE TO THE PROPOSED PLAN
CERCLA section 117(b) requires that the final remedial action
plan (i.e., ROD) be accompanied by a discussion of any
significant changes (and the reasons for such changes) in the
proposed plan and a response to each of the significant
comments, criticisms, and new data submitted [on the RI/FS
report and the Proposed Plan].
If significant changes are made to the Proposed Plan, EPA must
document the significant changes, and the reasons for the
significant changes, in the ROD. EPA also must make the
determination if the significant changes could have been
reasonably anticipated based on the RI/FS Reports and the
Proposed Plan. Where such changes could not reasonably have
been anticipated by the public, EPA must provide an additional
opportunity for public comment.
A significant change was incorporated to the recommended
alternative (Solidifcation/Fixation) subsequent to the public
meeting and release of the Proposed Plan. The cost for the
recommended alternative was presented at the Public Meeting and
in the Proposed Plan as $ 415,500, which included $ 127,500 for
Operations and Maintenance (0 & M). Revised cost estimates were
received on all alternatives evaluated in the Feasibility Study
subsequent to the issuance of the Proposed Plan. As presented
in this ROD, the estimated cost for Solidification/Fixation is
now $ 637,000, which includes $ 384,000 for 0 & M.
Ground water monitoring was added to the treatment alternatives
subsequent to EPA'a peer review of the draft Feasibility Study
Report. The additional costs associated with this new component
was underestimated. The contractor preparing the revised cost
estimates could not provide final costs prior to the public
meeting and issuance of the Proposed Plan. The public meeting
date was already established when the need for revised cost
estimates was identified. Thus, a significant change in the
cost of the recommended alternative resulted.
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The estimated cost of the recommended alternative increased by
$ 221,500 and could have been reasonably anticipated by the
public. On page 5-12 of the Feasibilty Study report that was
sent to the public information repository, the following
statement was made: "Revised cost estimates will be prepared
and included in the Final FS Report following the public comment
period." It was also noted on page 5-12 that the addition of
ground water monitoring to the treatment alternatives was the
reason for cost uncertainty.
Therefore, the estimated cost for the recommended alternative
increased significantly (53%) as a result of the addition of
ground water monitoring to the treatment alternatives just prior
to the public meeting. This increase could have been reasonably
anticipated by the public based on the information in the FS
Report. Subsequently, there is no need for an additional public
comment period.
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TABLE 5
STATE COST-SHARING OBLIGATIONS
AMNICOLA DUMP SITE
ACTIVITY
CONSTRUCTION
CAPITAL COSTS
FIRST YEAR 0 & M
REMAINING 0 & M
TOTAL
EPA STATE
$ 227,700 $ 25,300
86,400 9,600
0 288,000
314,000 322,900
TOTAL
$ 253,000
96,000
288,000
637,000
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RESPONSIVENESS SUMMARY
AMNICOLA DUMP SITE, CHATTANOOGA, TENNESSEE
This community relations responsiveness summary is divided into the
following sections:
SECTION I. Overviewt This section discusses EPA's recommended
alternative for remedial action and public reaction to this
alternative.
SECTION II. Background on Community involvement and Concerns; This
section provides a brief history of community interest and concerns
raised during remedial planning activities at the Amnicola Dump site.
SECTION III. Summary of Maior Comments Received During the Public
Comment Period and EPA Responses to Those Comments; Both the comment
and EPA's response are provided.
SECTION IV. Remaining Concerns; This section describes remaining
community concerns that EPA should be aware of in conducting the
remedial design and remedial action at the Amnicola Dump site.
I. OVERVIEW
With the issuance of the Proposed Plan to the public in February
1989, EPA presented its preferred alternative. This alternative
addresses surface soil and ground water contamination at the site.
The recommended alternative specified in the Record of Decision (ROD)
includes; solidification/fixation of contaminated surface soils,
imposition of land and ground water use restrictions, and the
monitoring of ground water.
Only three sets of comments were received during the public comment
period; two from residents, and the third from one of the Potentially
Responsible Parties. Therefore, it is difficult to assess the
community's preference for remediation of the site. One of the
residents did, however, feel that the alternative cost too much and
that no action was more appropriate.
II. BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS
The Amnicola Dump site is located in an industrial area of the city
of Chattanooga. The nearest resident is located approximately one
mile to the northeast of the site. Community interest at the
Amnicola Dump site is low as was indicated by participation at the
December 1987 and February 1989 public meetings, the low number of
inquiries received throughout the RI/FS, and the low number of
comments received during the public comment period.
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-2-
There are no active environmental or citizen groups following the
progress of the site. This can probably be attributed to the
location of the site in an industrial surrounding and the fact that
the Remedial Investigation, as well as numerous sampling events prior
to the RI, concluded that the site was having no negative impact on
the surface water quality of the Tennessee River.
III. SUMMARY OF PUBLIC COMMENTS RECEIVED DURING THE PUBLIC COMMENT
PERIOD AND SPA'S RESPONSES TO THOSE COMMENTS
1. A comment was made that remediation costs for the recommended
alternative were too high, that EPA must stop putting millions into
"non-dangers". An article in the Chattanooga News-Free Press, dated
February 15, 1989, on the Amnicola Dump site was referenced in the
comment. This article stated that "...the [Superfund] emphasis
[should] be put on major problems while simply fencing and posting
warning signs might be sufficient to avoid any danger from those
[Amnicola Dump] of less magnitude."
EPA Response
The Public Health Evaluation, using Agency guidelines and policy for
determining site risks, identified an unacceptable level of risk to
site workers, site visitors, and potential future on-site residents
if soil was ingested in the area of concern over a number of years.
Fencing and warnings signs around the area of concern might deter
ingestion of soil in that area; however, it is Agency policy to
monitor a site for 30 years if contaminants are left in place above
health-based levels. Therefore, fencing the area (No Action) would
cost more than treatment of waste and not meet Superfund'a preference
for treatment. Solidification/Fixation represents the most
cost-effective alternative for site deletion from the National
Priorities List.
2. A comment was made that EPA should reconsider bioremediation as a
treatment alternative. The following questions were also raised:
(1) Was the sampling technique accurate and clean enough that PAHs
were not introduced to greater depths of soil;
(2) Is it not likely that contamination is actually in the first 6' *
horizon;
(3) Was EPA's concern over clay soil from the standpoint of cap
integrity breach;
(4) Did your bioremediation option consider tilling in composted
organic material and turning a couple of times; and,
(5) Your risk assessment assumed that the PAH levels assumed that the
PAH levels remained constant over 30 years. Will they not likely
degrade before 30 years is up.
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-3-
EPA Response
(1) Surface soil sampling at the Amnicola Dump site was conducted in
accordance with U.S. EPA Region IV Standard Operating Procedures.
Sample ADO14, collected in the area requiring remediation, was
collected from the top six inches of soil. PAHs were not introduced
to greater depths during this sampling.
(2) Yes. It is likely that the PAHs of concern are in the top six to
twelve inches. However/ for the purposes of estimating volume of
soil requiring cleanup, it was assumed that soil contamination above
the cleanup goal existed at depths of up to two feet below ground
surface. Traffic from the salvage business on-site may have forced
the PAHs to greater depths than would have occurred naturally. Thus,
a two foot depth was assumed. Sampling in the area of concern will
be conducted during remedial design to get a more accurate vertical
and lateral extent of contamination.
(3) This question is not understood. The concern over clay arose
because of clay's impact on the feasibility and implementability of
bioremediation. Bioremediation is most effective on sandy soils.
Bioremediation was eliminated from further consideration during the
screening of alternatives because of implementability and
effectiveness concerns in light of the other more effective treatment
technologies.
(4) Yes. Bioremediation was also screened out because it was felt
that the large number of debris (scrap metal, concrete, bricks, etc.)
in the surface and subsurface soil would inhibit the implementability
of this technology. Tilling of the soil would require screening of
the soil/debris mixture first.
(5) It is possible that the PAH compounds will degrade over 30
years. But there are no assurances that, if degradation is
occurring, it will reduce the concentration of PAHs below the soil
cleanup goal. Natural degradation is not a treatment technology.
3. A request to re-rank the site was made. It was felt that, given
the results of the Remedial Investigation, the site would not receive
a high enough score to be on the National Priorities List (NPL). An
, additional statement was made that the original factors used in the
model to rank the site were flawed and the model should be refigured
using the correct data.
EPA Response
To simply re-rank the site every time additional information is
gathered on a site is neither the most efficient use of Agency
resources nor is it the appropriate method for site deletion from the
NPL. It is irrelevant that the PAHs that are driving site cleanup
were not initially responsible for the site's placement on the NPL.
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-4-
An unacceptable level of risk is associated with the potential
ingestion of contaminated surface soil at the Amnicola Dump site;
remediation of the defined area of concern is therefore justified and
required.
RanJcing of the site used information available at that time, along
with assumptions as to the landfill's potential contents. Some
assumptions, in the absence of extensive technical information
gathered during a remedial investigation, are necessary to assess a
site's potential risk to human health or the environment. To have
assumed, during the ranking process, that the landfill did not
contain hazardous wastes (in light of reports of hazardous waste
disposal at the site and sample analyses of leachate streams), would
have been irresponsible. The absence of latex wastes at the site can
be explained as follows: (1) Either the reports concerning the
disposal of latex waste at the site were false and the leachate
sample analyses that indicated latex constituents present were not
representative of site conditions, or (2) the latex wastes were
flushed from the site and diluted in the Tennessee River below
detectable quantities.
4. A comment was made that the site poses no hazard to the
population. The following statements were used in an attempt to
justify this claim:
(1) Only one soil sample from the site showed contamination in exce-
of EPA guidance on acceptable levels. Even that sample was
marginally above acceptable limits. It was only by the assumption o^
an unrealistic level of contact with PAHs at the site that action wa<-.
indicated under the "reasonable worst case".
(2) The study assumed that the PAHs were composed of 100% of the most
dangerous of the PAHs, even though this substance comprised 20% or
less of the total PAHs found on the site.
EPA Response
The site does pose an unacceptable level of risk to site workers,
site visitors, and potential future site residents due to potential
ingestion of contaminated surface soils.
(1) True, only one sample, AD014, contained a total carcinogenic PAH
concentration above the soil cleanup goal. However, every surface
soil sample collected, with the exception of the control sample,
contained PAHs; thereby indicating that sample ADO 14 is
representative of site conditions. It is irrelevant that the
concentration of PAHs was only marginally above the cleanup goal.
Whether the soil cleanup goal was exceeded by only 23 ppm (as in the
case at Amnicola Dump) or by 2300 ppm, remediation is still
required. The soil cleanup goals at the site ranged from 1.2 ppm to
122 ppm. It is felt that the cleanup goal selected, 100 ppm, is
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-5-
appropriate for the waste type and industrial setting of Amnicola
Dump. An "unrealistic" level of contact was not used. The public
health evaluation followed standard Agency guidance, as outlined in
the Superfund Public Health Evaluation manual, in calculating site
risk.
(2) For PAHs, the approach adopted by EPA and used as the basis of
the risk assessment is to divide the PAHs into two subclasses,
carcinogenic and non-carcinogenic PAHs, and to apply a cancer potency
factor derived from oral bioassays on benzo(a)pyrene to the subclass
of carcinogenic PAHs. ADO14 was comprised of 20% benzo(a)pyrene.
Six other PAHs comprised the remaining 80%. Their carcinogenic
potency is considered to be less than benzo(a)pyrene but this
relationship cannot be adequately quantitated with the limited data
available. Considering this uncertainty, it has been Agency policy
to apply benzo(a)pyrene cancer potency values to PAH risk assessment
procedures.
5. A comment was made that there is inadequate evidence that the
railroad ties are a source of the PAHs. The following statements
were used in an attempt to justify this claim:
(1) There was no consideration of the concept that burning at the
landfill or the disposing of industrial material containing PAHs was
the source.
(2) Burning of the type formerly conducted at the site, as well as
industrial and construction wastes such as tar paper, are sources of
PAH contamination.
(3) The fact that PAHs were found throughout the site and no
creosote was found anywhere on the property should have caused
further inquiry into their source. The EPA did not fully investigate
to determine the source of these PAHs but erroneously made
assumptions regarding their source.
EPA Response
(1) This statement is not true. All waste disposal practices at the
Amnicola Dump site were evaluated during the Remedial Investigation.
EPA is aware of the types of debris disposed at the dump as well as
the practice of burning and disposing of wood wastes during the
dump's period of operation, 1970 to 1973. EPA is also aware of the
types of operations conducted by Amnicola Equipment and Materials
Sales, the salvage operation currently located on the surface of the
dump. Photographs and site visits indicated that creosoted railroad
ties were burned, stored and handled on-site. Burn spots were
observed, photographed and sampled. This type of activity most
likely resulted in PAH contamination of the surface soils. Wood
waste burning and disposal between 1970 and 1973 did result in the
deposit of ashes throughout the site but in the interior of the dump.
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-6-
The surface soil samples that contained the PAHs were collected in
the top six to twelve inches, either on the bottom of the clay cap
that once covered the site or on the surface of the dump. PAHs were
also detected in subsurface soil samples within the dump area. These
PAHs could possibly be attributed to past wood burning practices or
other types of disposal, but subsurface PAHs are not driving
remediation of the site. PAHs are often associated with creosote or
coal tar products. Thus, the source of surface soil contamination by
PAHs was attributed to the burning of creosoted railroad ties.
(2) See the above response.
(3) The fact that PAHs were found throughout the site does not
preclude the railroad ties as a source. The observed traffic at the
site by the on-site operation has spread the PAHs from their burning
and storage location to other areas of the site.
6 . A comment was made that there is inadequate explanation of how
the Agency came up with the cost figures as many of the costs appear
to be overestimated and undocumented.
EPA Response
The commenter is encouraged to review Section 5 of the Feasibility
Study report, Cost Analysis, and Appendix B of the Feasibility Studv
Report, Present Worth Costing of Remedial Alternatives. All of thej
assumptions, general and specific, that went in to the calculation or
costs for site remediation and 0 & M are provided in Appendix B.
IV. REMAINING CONCERNS
The community's concerns surrounding the Amnicola Dump site should be
addressed through community relations support during the Remedial
Design/Remedial Action (RD/RA).
Community relations support during the RD/RA should consist of
available final documents (i.e., Remedial Design Work Plan, Remedial'
Design Report., etc.) in a timely manner to the public information
repository and issuance of fact sheets upon selection of a remedy ana
prior to remedial action. The community should be aware that at any"
time during the remedial design or remedial action, if new
information is obtained on site conditions, the remedy will be
re-evaluated to determine its effectiveness in protecting public
health and the environment. If changes are necessary to the Record
of Decision, these changes will be public noticed prior to
implementation of the changes.
Community relations activities should remain an active aspect of the
RD/RA phase of this project.
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APPENDIX A
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EQUATION FOR. CALCULATING
RISK RELATED SOIL CLEANUP LEVELS .
(Ad
C ., = soil clean-up level (mg contaminant/kg soil)
SO X j.
D = acceptable daily dose (mg/kg/day)
A. = absorption factor from oral exposre, (unitless)
I. = intake by incidental oral ingestion of soil (kg/day)
A = absorption factor from dermal exposure (unitless)
I = soil deposition on exposed skin (kg/day)
A, = absorption factor from respiratory exposure (unitless)
! = soil dust inhalation exposure (kg/day)
ri
BW = body weigth (kg)
F = Frequency of exposure (days exposed/days lived (70 .yes.)
-------
Soil clean up levels for total carcinogenic PAHs considering
soil ingestion exposures described in the PHE
Soil levels (mg/kg)
Upper bound
risk level
io-6
io-5
io-4
Adult practical
*
100%
1.2
12.0
122.0
25%
4.9
49.0
490.0
Adult Worst Case
absorption level
100% 25%
0.2 0.84
2.0 8.40
20.0 84.00
Child Res
100%
0.02
2.00
20.00
ident
25%
0.87
8.70
87.00
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APPENDIX B
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ATTACHMENT
GROUND-WATER DILUTION ESTIMATE AND ACLs
Reference: Super fund Exposure Assessment Manual, EPA/540/1-88/001.
Flow Characteristics of Tennessee Streams. USGS & TN Dept.
of Conservation, 1965.
1. Estimate ground-water discharge rate across front of landfill into
Nickajack Reservoir.
Q=KiA where Q = ground-water discharge in cfd;
K = average hydraulic conductivity of unconfined aquifer
in ft/d;
i = hydraulic gradient across site (dimensionless) .
K = 13 gpd/sq. ft. = 1.738 ft/d. [see RI].
i = (24.0 ft - 22.2 ft)/700 ft = 0.00257 [MW-3 to MW-5, 3-9-88].
A = 35 ft x 950 ft = 33,250.sq. ft.
Q = (1.738 ft/d)(0.00257)(33,250 sq. ft.) = 148.5 cfd = 0.00172 cfs.
2. Estimate flow in affected portion of Nickajack Reservoir.
Reservoir flow rate = 1200 cfs [lowest mean discharge, in cfs, of record].
Consider flow rate through one-quarter of reservoir [see ACL guidance
document, p. 6-3, July, 1987].
Q(reservoir) = 1200 cfs / 4 = 300 cfs.
3. Estimate diluted concentration in one-quarter of cross-sectional flow
of Nickajack Reservoir.
C = I(Ce)(Qe) ]/Qt where C = reservoir concentration (ppb);
Ce = contaminant concentration in ground water
(ppb);
Qe = ground-water discharge (cfs);
Qt = total flow (ground-water discharge plus
reservoir flow) in cfs.
Equation reference: p. 53, Superfund Exposure Assessment Manual.
Dilution factor = Qe/Qt = 0.00172/300.00172 = 5.7E-06.
The dilution factor multiplied by the contaminant concentration in ground
water will result in the diluted concentration in one-quarter of the
reservoir flow. .
Contaminant
Caprolactam
Diethyltetrahydrofuran
Chloroform
Br omod ichl or ome thane
Ethyl ether
Chromium
Bis ( 2-ethylhexyl ) phthalate
Bis(dimethylethyl )methylphenol
Ce (DDb)
2
30
8.6
4.6
5.0
89
370
10
C (DDb)
1.1E-05
1.7E-04
4.9E-05
2.6E-05
2.9E-05
5.1E-04
2.-1E-03
5.7E-05
ACL (DDb)
20
300
86
46
50
890
3700
100
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APPENDIX C
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United States Department of the Interior
FISH AND WILDLIFE SERVICE
ENDANGERED SPECIES FIELD OFFICE
100 OTIS STREET, ROOM 224
ASHEVILLE, NORTH CAROLINA 28801
Break:
Other:
June 17, 1987
IN REPLY REFER TO
LOG NO. 4-2-87-406
Mr. Thomas M. Roth
Remedial Project Manager
Emergency and Remedial Response Branch
U.S. Environmental Protection Agency
345 Courtland Street
Atlanta, Georgia 30365
Dear Mr. Roth:
ERRB/RAS
J21Z
JUN19 1987
TTE
EPA-RECIOM IV
ATLANTA, CA
Your May 19, 1987, letter regarding the proposed remedial investigation of
the Amnicola Dump hazardous waste site in Hamilton County, Tennessee, was
received May 28, 1987. We have reviewed the project as requested with regard
to endangered and threatened species.
The attached page lists the federally listed endangered (E) and/or
threatened (T) and/or species proposed for listing as endangered (PE) or
threatened (PT) which may occur in the area of influence of this action.
The legal responsibilities of a Federal agency under Section 7 of the
Endangered Species Act of 1973 (as amended) were detailed in material sent to
you previously. If you would like another copy of this material, or if you
have questions, please contact us at 704/259-0321 (FTS 672-0321).
Your concern for endangered species is appreciated, and we look forward to
working with you on endangered species matters in the future.
Sincerely yours,
£k«^u
V. Gary Henry '
Acting Field Supervisor
CC:
Mr. Bob Hatcher, Tennessee Wildlife Resources Agency, Nashville, TN
Mr.. Dan Eager, Program Administrator, Ecological Services Division, Tennessee
Department of Conservation, 701 Broadway, Nashville, TN 3/219
Field Supervisor, ES, FWS, Cookeville, TN
-------
United States Department of the Interior
FISH AND WILDLIFE SERVICE
ENDANGERED SPECIES FIELD OFFICE
100 OTIS STREET, ROOM 224
ASHEVILLE, NORTH CAROLINA 28801
IN REPLY REFER TO
LOG NO. 4-2-87-406
ff
Sue:
Break:
'Other:
v
16. 1
ERRB/RAS
JUN 1 9 1987
trA-RECION IV
ATlJUfTA, £4
LISTED SPECIES
FISHES
Snail darter - Percina tanasi (T)
CLAMS
Orange-footed pearly mussel - Plethobasus cooperianus (E)
Pink mucket pearly mussel - Lampsi1 is orbiculata (E)
STATUS REVIEW SPECIES
"Status Review" (SR) species are not legally protected under the Endangered
Species Act, and are not subject to any of its provisions, including
Section 7, until they are formally proposed or listed as
endangered/threatened. We are including these species in our response for
the purpose of giving you advance notification. These species may be listed
in the future, at which time tney will be protected under the Endangered
Species Act. In the meantime, we would appreciate anything you might do
to avoid impacting them.
PLANTS
False foxglove - Aureolaria patula
Carey's saxifrage - Saxifraqa careyana
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APPENDIX D
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TENNESSEE HISTORICAL COMMISSION -.-.
DEPARTMENT OF CONSERVATION ^^ R£s?
701 BROADWAY
NASHVILLE. TENNESSEE 37203
frTiP^n=nnjTcJ
|y< JAN 021986 |
. 615/742-6716
December 16, 1985
Jack E. Raven
Environmental Protection Agency, Region IV An^.r.., -;A.
345 Courtland Street
Atlanta, Georgia 30365
Re: Intergovernmental Review, Amnicola Dump Site, Chattanooga,
Hamilton County, CH# 86-04-77
Dear Mr. Raven:
The above proposed undertaking has been reviewed with regard to National
Historic Preservation Act compliance by the participating federal agency
or its designated representative. Procedures for implementing Section 106
of the Act are codified at 36 CFR 800 (44 FR 6068-6081, Jan. 30, 1979).
Based on the information available, it is our-opinion that due to the location,
scope, and nature of the undertaking the project will have no effect on National
Register or eligible properties. Therefore, unless project plans are changed
or National Register eligible properties are discovered during project .;
implementation, no additional action is necessary to comply with the Act.
The applicant or federal agency should keep this letter as evidence of compliance
with Section 106. Any questions or comments should be directed to Joe Garrison.
Your cooperation is appreciated.
Sincerely,
Herbert L. Harper,
Executive Director and
Deputy State Historic
Preservation Officer
HLH:jk
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