United States        Office of
Environmental Protection   Emergency and
Agency           Remedial Response
EPA/ROD/R04-91/099
June 1991
Superfund
Record of Decision
Arlington Blending &
Packaging, TN

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50272-101
I REPORT DOCUMENTATION
        PAGE
1. REPORT NO.
     EPA/ROD/R04-91/099
                                           3. Recipient's Accession No.
 4. TMssndSubMe
   SUPERFUND RECORD OF  DECISION
   Arlington Blending & Packaging,
   First  Remedial Action -'Final
            TN
                                           5. Report Date

                                             06/28/91
 7. Authot(*)
                                                                    8. Performing Organization Rept. No.
 ». Performing Orgalnlnflon Nune «nd Address
                                                                     10. Proiect/Task/Work Urst No.
                                                                     11. Contract(C) or Grsnt(G) No.

                                                                     (C)
 12. Sponsoring Organization Name and Addrsss
   U.S.  Environmental Protection  Agency
   401 M Street, S.W.
   Washington, D.C.   20460
                                           13. Type of Report & Period Covered

                                             800/000
                                                                     14.
 15. Supplementary Note*
 16. Abetraet (Umlt: 200 words)
   The  2.3-acre Arlington Blending & Packaging  site is an  abandoned pesticide and
   herbicide blending and packaging facility  in Arlington,  Shelby County,  Tennessee.
   Land use  in the  area is predominantly residential, agricultural, and light
   commercial.  Site  operations  have contaminated.two units of the underlying aquifer,
   which are not used as drinking water sources   From 1971 to 1978, the Arlington
   Blending  and Packaging Company operated onsite to properly formulate and package
   various, pesticide,  herbicide,  and other chemical formulations.  During site
   operations, spills and leaks  of chemicals  occurred onsite,  which resulted in
   compounds soaking  into soil and process building flooring,  and migrating offsite via
   surface runoff.  Process water containing  hazardous contaminants also was- discharged
   to onsite ditches,  contaminating adjacent  properties including a residential area,
   nearby ditches,  and other surface water bodies.   In addition,  numerous barrels and
   other containers were left onsite.  Site investigations revealed onsite and offsite
   contamination of soil and ground water.  In  1983, EPA initiated a removal action,  and
   excavated and removed 1,920 cubic yards of contaminated soil with chlordane levels in
   excess of 50 mg/kg and 112 drums containing  chemical wastes.  In 1990,  as a result of
    (See  Attached Page)
 17. Oocunsnt Analysis s. Descriptors
   Record of Decision - Arlington Blending  &  Packaging,  TN
   First Remedial  Action - Final
   Contaminated Media:  soil,  debris, gw
   Key Contaminants:  VOCs  (benzene), other  organics  (pesticides), metals  (arsenic)

   b. Mentlfiera/OpMvEndBd Terms
   c. CO8ATI RsM/Oraup
 IB. AvallabUty Statement
                            19. Security Clsss (This Report)
                                   None
                                                      20. Security Class (Thia Page)
                                                     	None	
21. No. of Pages
  110
                                                                                22. Price
(Ses ANSWSS.1B)
                                      See //wtructfona on Rewrse
                                                      OPTIONAL FORM 272 (4-77)
                                                      (Formerly NTtS-15)
                                                      Department of Commerce

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EPA/ROD/R04-91/099
Arlington Blending & Packaging, TN
First Remedial Action - Final

 kbstract (Continued)

the RI data, EPA conducted another removal action and excavated and temporarily stored
onsite 70 cubic yards of contaminated soil from the adjacent residential property.
This Record of Decision (ROD) addresses final remediation of primarily
pesticide-contaminated soil and ground water.  The primary contaminants of concern
affecting the soil, debris, and ground water are VOCs including benzene; other organics
including pesticides; and metals including arsenic.

The selected remedial action for this site includes excavating 24,000 cubic yards of
contaminated soil and decontaminating the soil onsite using ex-situ thermal desorption;
backfilling excavated areas with treated soil; dechlorinating the resulting condensed
organic liquid from the thermal desorption process, followed by offsite disposal of the
residual concentrated organic liquid; treating and disposal of spent carbon or sludge
offsite; temporarily storing residuals onsite, if needed prior to treatment to
treatability levels and offsite disposal; treating soil containing levels of arsenic
and/or other trace metals above action levels onsite using solidification, followed by
offsite disposal; decontaminating and demolishing onsite buildings, followed by offsite
disposal; pumping and onsite treatment of contaminated ground water using activated
carbon, followed by onsite discharge of the treated effluent to surface water or
offsite to a publicly owned treatment works  (POTW); regenerating spent carbon granules
offsite; monitoring ground water; and providing for a contingency remedy that involves
treating soil onsite using thermal destruction instead of thermal desorption.  The
estimated present worth cost for this remedial action is $12,170,167, which includes a
total present worth O&M cost of $1,605,256 for 30 years.

PERFORMANCE STANDARDS OR GOALS:  Soil clean-up levels are based on protection of ground
water and reduction of risk through long-term dermal contact and oral ingestion and
include arsenic 25,000 ug/kg, which also takes into account background levels.
Chemical-specific ground water clean-up goals are based on SDWA MCLs, and include
benzene 5 ug/1.

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                       RECORD OF DECISION

                 Remedial  Alternative Selection

Site Name and Location

Arlington Blending and Packaging Site
Arlington, Shelby County,  Tennessee

•Statement of Basis and Purpose

This decision document presents  the  selected remedial action for
the Arlington Blending and Packaging Site,  in Arlington, Tennessee,
which was chosen in accordance with CERCLA, as amended, and, to the
extent  practicable,  the  National Oil  and  Hazardous  Substances
Pollution Contingency Plan  (NCP).  This  decision is based on the
administrative  record  for  this  site.    The  State  of  Tennessee
concurs with the selected remedy.

Assessment of the Site

Actual  or  threatened releases of hazardous  substances  from this
site, if not  addressed by implementing the response action selected
in  this Record of  Decision  (ROD) ,  may  present  an  imminent and
substantial  endangerment  to  public  health,  welfare,  or  the
environment.

Description of the Selected Remedy

•    Excavation of an estimated 24,000 cubic yards of contaminated
     soil;
•    Decontamination of  contaminated soil using on-site ex-sicu
     thermal desorption process;
•    Dechlorination  of the  condensed  organic liquid and off-sice
     disposal of the concentrated organic liquid;
•    Placement of the treated soil into the excavated areas;
•    Activated carbon treatment of the contaminated groundwater or.-
     site and surface water discharge of  the treated effluent;
•    On-site solidification of soils containing  levels of arsenic
     and/or other trace metals above clean-up levels for off-sice
     disposal:

Description of th« Contingency Remedy

•    Excavation of approximately  24,000 cubic yards of contaroir.aced
     soil;
•.    Decontamination of  contaminated soil using on-site thermal
     destruction treatment;
•    Placement  of the  thermally treated  soil  into  the excavated
     areas;
•    Activated carbon treatment of the contaminated groundwater cr.-
     site and surface water discharge of  the treated effluent;
•    On-site solidification of soils containing  levels of arsenic
     and/or  other trace metals above cleanup levels for off-sice

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        disposal:
   Statutory Determinations

   The  selected  remedy  is  protective  of  human  health  and  the
   environment, complies with Federal  and  State requirements that are
   legally applicable  or relevant  and  appropriate to  the  remedial
   action  (or  'a  waiver can  be  justified for whatever  Federal and
   State applicable or relevant and  appropriate requirement that will
   not  be met'),  and  is  cost-effective.   This  remedy  utilizes
   permanent  solutions  and  alternative  treatment   (or  resource
   recovery)   technology  to  the maximum extent  practicable,  and
   satisfies  the  statutory  preference  for  remedies  that  employ
   treatment that  reduces toxicity, mobility, or volume as a principal
   element.•

   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  the remedial action to
   ensure that the remedy continues  to provide adequate protection of
   human health and the environment.   A  5-year review  (or performance
   evaluation) will be prepared at least once every five years until
   ground-water contaminant concentrations no  longer  exceed health-
   based levels.


                                                    JUN 2 8 1991
J*\Greer C. Tidwell                                 Date
 '  Regional Administrator

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                        TABLE OP CONTENTS

SECTION                                                     PAGE

1.0  SITE NAME, LOCATION, AND DESCRIPTION 	  1

2.0  SITE HISTORY AND ENFORCEMENT ACTIVITIES 	  2

3.0  HIGHLIGHTS COMMUNITY OF PARTICIPATION 	  4

4.0  SCOPE AND ROLE OF RESPONSE ACTION WITHIN SITE
     STRATEGY  	   4
5.0  SUMMARY OF SITE CHARACTERISTICS
6.0  SUMMARY OF SITE RISKS 	  5
     6.1  Exposure Assessment 	  6
     6.2  Toxicity Assessment 	  8
     6.3  Risk Characterization 	  9
     6.4  Risk Uncertainty 	 11
     6.5  Summary 	 12

7.0  DESCRIPTION OF REMEDIAL ALTERNATIVES 	 13
     7.1 Alternative 1 	 13
     7 .2 Alternative 2	 14
     7.3 Alternative 3 and 3A 	 15
     7.4 Alternative 4 and 4A	 17
     7.5 Alternative 5 and 5A 	 19

8.0  SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES 	 21

9.0  THE SELECTED REMEDY 	 31
     9.1 Remediation Goals 	 32
     9.2 Contingency Measures for Ground-water
         Remedial Action 	 35
     9.3 Contingency for Soils Remedial Action 	 36

10.0 STATUTORY DETERMINATIONS 	 38
     10.1 Protection of Human Health and Environment 	 38
     10.2 Compliance with Applicable or Relevant and
          Appropriate Requirements 	 39
     10.3 Cost-Effectiveness 	 41

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10.4 Utilization of Permanent Solutions and
     Alternative Treatment Technologies or
     Resource Recovery Technologies to the
     Maximum Extent Practicable 	 42
10.5 Preference for Treatment as a Principle Element .. 42

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                        LIST OF FIGURES
FIGURE                                                  FOLLOWING
                                                            PAGE
1-1     Site Location                                         1

1-2     Site Map                                              1

1-3     Detailed Site Stratigraphy                            1

5-1     Estimated Contaminant Plume Boundaries                5

6-1     Off-Site Wells Map                                   12

9-1     Equation for Calculating Oral and Dermal Chronic
        Exposure Levels                                      33

9-2     Delineation of Grids Containing Chlordane
        Contamination in Surficial Soils Above
          Site Action Levels                                 33

9-3     Delineation of Subsurface Chlordane Soil
        Contamination Above Site Action Level                34

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                          LIST OF TABLES

TABLE                                                   FOLLOWING
                                                          PAGE

1-1     Details of Monitoring Well Construction              2

6-1     Contaminants of Concern by Media                     6

6-2     Assumptions for Exposure to Soil Contaminants
        of Concern                                           6

6-3     Health-based values for Carcinogens (CPF) and
        Non-Carcinogens (RFD)  and ARARs for Oral
        Exposure to Contaminants of Concern                  9

6-4     Summary of Carcinogenic Risk And Non-Carcinogenic
        Hazard Index for Child Resident from Oral and
        Dermal Exposure to Contaminants in
         Soil/Sediments                                     10
6-5     Summary of Carcinogenic Risks for Adult Workers
        from Oral   and Dermal Exposure to Contaminants
        in Soil/Sediments                                   10

7-1     Treatability Variance Levels for Soils              18

8-1     Summary of Detailed Analysis                        22

9-1     Soil and Sediment Remediation Goals                 33

9-2     Soil Contaminant Levels Yielding Upperbound
        Risk Levels for Worker and Resident Exposure
        Scenarios                                           33

9-3     Soil Cleanup Levels for Ground-water Protection     33

9-4     Ground-water Remediation Goals                      34

9-5     Cost Estimate for the Selected Remedy,
        Alternative 5                                       38

9-6     Cost Estimate for the Contingency Remedy
        Alternative 4                                       38

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                   LIST OF APPENDICES
APPENDIX A
APPENDIX B
APPENDIX C
APPENDIX D
APPENDIX E
Obtaining  a  Soil  and  Debris  Treatability
Variance for Remedial Actions
Arlington    Blending    &
Responsiveness Summary
Packaging    Site
Arlington Blending & Packaging Site
Proposed Plan

Official Transcript of the Arlington Blending
&  Packaging  Site   Public   Meeting  on  the
Proposed Plan for Site Remediation

State Letter of Concurrence

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1.0  SITS NAME,  LOCATION,  AND DESCRIPTION

     The Arlington  Blending  & Packaging  Site  (Site or ABAP)  is
     located approximately 25 miles northeast of Memphis, Tennessee
     at 12121 U.S.  Highway  70 in  the  town of Arlington,  Shelby
     County,  Tennessee (Figure 1.1) .  It is bordered  on the west by
     a Tennessee Department of Transportation  (DOT)  facility,  on
     the east by a residential housing development, on the north by
     a large tract of land currently used  as a sod  farm,  and the
     south by CSX railroad tracks  and  further south by a cotton
     field.   The large tracts of land  located  directly north and
     south of the ABAP property are  currently used for agricultural
     purposes.   The nearby Loosahatchie  River Canal  is  located
     approximately 3000 feet  due  north  of the  Site.

     The Site is the  former location of  the Arlington  Blending &
     Packaging  Company (ABAP). The relatively  flat  2.3 acre site
     is covered primarily with patchy  weeds  and a  gravel,  sandy
     topsoil, and   fill  cover.    All  that remains of  the  now
     abandoned  facility,  where pesticides, herbicides,  and other
     types of chemicals were formulated  and packaged, are three (3)
     Quonset  huts  (and a  warehouse) located at  the rear  of  the
     property.  The concrete floored buildings are abandoned and in
     disrepair.   Located at the front  of  the property  is  a small
     laboratory  that is currently operated by  Helena Chemical,  a
     chemical manufacturing  firm  (Figure 1.2).

     The  population  of   the  town- of  Arlington,   Tennessee  is
     approximately 1800.   Those in  closest proximity to the Site
     are the  residents of the  Mary Alice Drive sub-division  (MADSD)
     and  the   employees   of  the   Tennessee   Department   of
     Transportation  and Helena Chemical Laboratory.   The MADSD is
     comprised  of  forty-four  (44)  homes.   Many of the  homeowners
     have school aged children.

     Topography  in the area  varies  from relatively flat,   in  the
     vicinity of Arlington, to gently rolling to rather steep.  The
     land surface is  topped  mainly by  Pleistocene  loess,  except
     those in flood  plain locations where alluvial deposits  are
     prevalent.

     Site-specific geological and  stratigraphic  information  was
     developed during the  monitoring well construction  and during
     an electric piezocone investigation conducted at the Site.  A
     detailed stratigraphic   column of  the  upper  125-feet  of
     sediments  encountered at the Site has been  constructed from
     data collected  during  both  of  these investigations.   This
     column appears  in Figure  1.3.  Although there is some  lateral
     variation   observed  in  the   stratigraphy   of   the  Site,
     particularly within the 20 to 45 feet interval,  five distinct
     stratigraphic units were  identified.  These are designated as
     Units I  through V.

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&EPA
                                                     ( In feet )
                                                    1 Inch -2000 ft.
              FIGURE 1-1
            LOCATION MAP
ARLINGTON BLENDING AND PACKAGING COMPANY
         ARLINGTON, TENNESSEE

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         0  30   100
         |	,	|
           FEET
                       FIGURE 1-2
                PHASE I  SOIL SAMPLING GRID
         ARLINGTON BLENDING AND PACKAGING COMPANY
                  ARLINGTON,  TENNESSEE
sEPA

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      10
     20 -_._._._..
     30 —
  W
OS
D
CO
Q
z
D
O

O


1
Ed
m

35"
E-
Q.

Q
     40 -
          l^-aotto.°'
     50 --
     60
     70 --
80  — •
     90 —7
     100 -
     110 --
120 -
                  UNIT  T -  SOFT T0 STIFF GRAY & TAN
                            SILTY CLAYS & CLAYEY SILTS,
                            W/ SILTS GENERALLY PREDOMINATING
                            FINE SANDS COMMON NEAR BASE
                            OF UNIT.
                  UNIT  IT-  DENSE. VARIABLY COLORED FINE
                            MEDIUM AND COARSE SANDS. A
                            SILTY SEQUENCE IS PRESENT AT
                            ABOUT 25'- 30' OVER MUCH OF
                            THE SITE  ic PEA GRAVEL IS COMMON
                            NEAR THE BASE OF THE UNIT.
                 UNIT  TTI
                                   STIFF. UGHT GRAY SILTY CLAY
                                   WITH LOCAL TRACES OF SAND  AND
                                   CLAYEY SAND.
                       UNIT  IV
                             VERY DENSE GRAY. SILTY AND
                             CLAYEY SAND.
                 UNIT V~
                                      DENSE LAMINATED UGHT GRAY
                                  & TAN SAND WITH SOME SILT & CLAY.    |
                                  IRON CONCRETIONS & STAINING IN PLACESl
&EPA
                         FIGURE  1-3
                DETAILED SITE STRATIGRAPHY
            ARLINGTON BLENDING  AND PACKAGING
                   ARLINGTON. TENNESSEE

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     Although  shallow groundwater occurs  at  the ABAP  site  from
     about 5  feet  below the surface  downward,  significant yields
     are attainable only in certain zones.  The first significant
     water-bearing zone is stratigraphic Unit II.  Groundwater was
     determined to flow in  a  north to northwesterly direction in
     Unit  II.   The  second  zone  in  which  water  was  found  in
     significant quantities was  Unit V,  located  below  a  70-foot
     thick sequence of confining  clays and'clayey  sands  (Units III
     and IV).

     Table 1.1  lists  the exact screened  intervals  for  all wells
     installed during the RI.   The  shallow surficial intervals are
     screened down to 30 feet  below ground surface, while the deep
     surficial  interval wells are screened,   collectively,  from
     approximately 23 feet to 43  feet.

     The nearest surface water body  is that of  the Loosahatchie
     River Canal (LRC)  which  is  located approximately 3,000  feet
     due north of the site.  The river is recognized by the state
     of Tennessee  as being  suitable  for  recreational  purposes,
     wildlife, irrigation, and livestock watering.


2.0  SITE HISTORY AND ENFORCEMENT ACTIVITIES

     The  Arlington Blending  and  Packaging Company (ABAP)  was
     engaged in the blending  and  packaging of  various pesticide,
     herbicide, and other chemical formulations  at  the  Site from
     1971 to 1978.   The company custom formulated these compounds
     with solvents  and emulsifiers  in  accordance with their client
     companies' specifications.  The  formulated products were then
     packaged   or   bottled  in  a  form  suitable   for   retail
     distribution.

     During the conduct  of formulating activities,  spills and leaks
     of chemicals handled at the Site occurred.  As a result, these
     compounds soaked into site soils and process building flooring
     and migrated off-site via surface runoff.   Similarly, during
     the  site  operational  period,   process  waters  containing
     hazardous contaminants were discharged to ditches draining the
     Site. The ABAP facility, adjacent properties (one of which is
     a residential  community), and nearby ditches  and surface water
     bodies were  contaminated as  a  result  of  these  practices.
     Numerous barrels and other  containers also  were left at the
     Site.

     In October 1983,  the USEPA initiated an immediate removal in
     an effort to eliminate potential or actual  health threats from
     the Site.  People identified as at risk from  the Site included
     residents of the adjacent residential community nearest to the
     ABAP eastern property boundary;  workers employed on the Site
     at the Helena Chemical  Laboratory at the front  of the Site

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                             TABLE .
             MONITORING WELL CONSTRUCTION DETAILS
             ARLINGTON BLENDING AND PACKAGING SITE
                     ARLINGTON, TENNEESSEE
MONITORING
WELL
AB-1S
AB-2S
AB-2D
AB-3S
AB-3D
AB-4S
AB-4D
AB-5S
AB-6DD
AB-7S
AB-7D
AB-8S
AB-8D
AB-9D
AB-IOS
AB-10D
. AB-1IS
AB-11D
TOP OF
CASING ELEVATION
99
280.840
276.12
275.92
274.30
274.42
275.53
275.13
276.12
275.56
279.56
277.65
273.06
273.20
265.95
271.33
271.55
274.31
274.31
GROUND SURFACE
ELEVATION
fflMSLM)
280.0
273.9
273.9
2718
27Z7
273.6
273.6
274.3
273.3
275.81
275.15
270.56
270.70
263.S5
268.83
269.05
271.S1
271.81
SCREENED
INTERVAL
DEPTH
(ftbwKJ)
19.2 - 29.2
12.9-22.9
33.1-43.1
13.5-23.6
33.5-43.5
13.2 - 23.2
26.6-43.6
13.3-28.3
113.5-123.5
16.25 - 26.25
30.0-40.0
20.0-30.0
30.0-40.0
X JO -40.0
20.0 - 30.0
30.0-40.0
20-30*
30-40
BOTTOM OF WELL
DEPTH
tftbtfJO)
30.0'
25.0
44.5'
25JD'
45.0"
25.6*
45.0'
30.0*
125.0'
26.25
42.5'
32.0'
41.0*
40.0'
30.01
41.0'
30.0'
40.0'
(l)MSL-Meu Sea Level
(2) bgt - Below Ground Surface

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property;  and  employees  of  the  Tennessee  Department  of
Transportation facility located adjacent to the Site's western
border.

During  the  Removal  Action,  1920   cubic  yards   (yd3)  of
contaminated soil containing in excess of 50 mg/kg chlordane
were excavated.  Prior to the soil excavations,  the Site and
adjacent properties soil  and drainage ditches were sampled for
their  pesticide  content to  delineate the  areal  extent and
depth of gross surficial contamination.   Similarly, 112 drums
containing stored  chemical  wastes were  sampled and removed
from the site  along with the contaminated material from the
Site buildings and  grounds.

As the result of  data collected during the RI, EPA determined
that unacceptable levels of pesticides,  primarily chlordane,
were located in the soils of  the residential property located
along the eastern  fence  line of the  Site.   In July 1990,  an
emergency  removal   of   these   soils  was   conducted  and
approximately, 70 yd3 of the soil  were excavated and will be
stored on site until final remediation.

On August  15,  1986, USEPA  Region  IV completed a  Hazardous
Ranking System (MRS) package for the Site.  An aggregate MRS
score of 39.03 was  derived for  the  Site.  The score was based
upon a ground-water route score of 67.35 and a surface water
route score of 4.92.  Neither the air route nor the fire and
explosion hazards were evaluated.   In July 1987, the Site was
added to the National Priorities List (NPL).

The United States  Department of Justice, on  behalf  of EPA,
filed suit in 1986  against two  of the owners and operators of
the Arlington Blending and Packaging Site, and against three
companies   who   arranged   for    formulation    of   their
pesticide/herbicide/chemical products by Arlington Blending
and Packaging Company, which resulted in the  disposal of waste
at the Site.   The suit was filed under Section 107 of CERCLA
for recovery of all costs  incurred to  date at  the  Site,
including the costs  for the removal action that was performed,
and for all  studies and  investigations  conducted.   The suit
also seeks declaratory  relief  for a  declaration  that these
defendants are also liable for  any  costs  EPA may incur in the
future, including the costs for the remedy if EPA ultimately
performs the remedy chosen in this  ROD.   This suit also seeks
recovery of the costs that have been  incurred at the Gallaway
Pits Site.  The case is currently pending in federal district
court and is in the discovery phase of the case.

On January 27, 1988 USEPA Region  IV sent  notice letters to
five (5)  Potentially Responsible Parties  (PRPs)  and requested
that they conduct a Remedial Investigation/Feasibility Study
(RI/FS) for the ABAP Site.  Each of the  PRPs declined and as

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     the result EPA initiated a Federally funded RI/FS at the Site.


3.0  HIGHLIGHTS OF COMMUNITY PARTICIPATION

     The  RI/FS and Proposed  Plan for  the  Arlington Blending  &
     Packaging Site were presented at the public  meeting  held on
     January  24,  1991 at  the Arlington  Town Hall.   These  two
     documents  were  made  available  to  the public  in  both  the
     administrative record and an information repository maintained
     at the  EPA Docket Room  in Region  IV  and  at  the  Arlington
     Library.  Notice of availability of  these  two documents  and
     notice of the public meeting was published  in the Commercial
     Appeal on January 13,  1991.   The  Public Comment Period  was
     held  from January  24,  1991 through  April  9,  1991.    An
     extension  to the  original  comment  period  was  granted  in
     response  to  requests  by  site PRPs  for  additional  time  to
     prepare  a thorough review  of site  files.    At  the  public
     meeting,  representatives  from EPA answered  questions  about
     problems  at  the site  and the  remedial  alternatives  under
     consideration.  A  response to the comments  received during
     this period is included in the Responsiveness Summary,  which
     is part of this Record of Decision.  This  decision document
     presents  the selected  remedial  action  for the  Arlington
     Blending & Packaging Site,  chosen in accordance with CERCLA,
     as  amended by  SARA  and,  to  the  extent  practicable,  the
     National  Contingency  Plan.   The decision  for this  site  is
     based on the administrative record.
4.0  SCOPS AND ROLE OP RESPONSE ACTION WITHIN SITE STRATEGY

     The Selected Remedy  will address contaminated media  at  the
     Site by eliminating,  to the extent practicable, the volume of
     contaminants present  and the  continued migration  of  these
     contaminants off site.  This action will remediate all areas
     of contamination at the Site and will include the cleaning and
     subsequent demolition of those  former process buildings under
     which contaminated soils have been identified.

     Surface and subsurface soils containing site contaminants in
     concentrations at which leaching into ground-water may pose a
     continuing threat to contaminate ground water above acceptable
     levels will be excavated and thermally treated.  Surface soils
     which  pose  an   unacceptable  risk  as  a result  of  future
     long-term  dermal contact and  oral  ingestion  will also be
     excavated and thermally treated to acceptable levels.

     Contaminated ground-water identified  on and downgradient of
     the  Site in  the surficial  aquifer will  be  extracted  for
     treatment until  ground-water is restored to  drinking water
     quality.  The ground-water usage will be restricted in these

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     areas until health based levels have been achieved.

     The goals of the remedial action will be to reduce the risks
     associated with  long-term exposure  to  contaminated  on-site
     soils and ground water,  to  reduce  migration of contaminants
     between site soils and  ground  water,  and to reduce off-site
     contaminant migration through the ground-water pathway.


5.0  SUMMARY OF SITE CHARACTERISTICS

     The RI conducted at the  Arlington Blending and Packaging Site
     identified soils, sediment,  and ground-water on and adjacent
     to  the   Site   that   were   contaminated  with  pesticides,
     herbicides,  and/or solvents used in the formulation of these
     compounds and  other  chemicals  handled at  the  facility that
     comprise the principle  threat  posed  by  the Site.   The areal
     extent  of pesticide-contaminated  soils,  identified  above
     action levels,  is  found  primarily around the  exterior  and
     underneath the concrete flooring of the process buildings at
     a  depth  of  up  to  12 feet.   The  volume of these soils  is
     estimated to be  approxiamtely  24,000 yd3.   The contaminated
     soils are the likely source for  the  ground-water contamination
     identified in  the RI.   Chlordane  levels of up  to 400 mg/kg
     were detected,  while pentachlorophenol was identified at up to
     130 mg/kg in a subsurface soil sample  collected underneath the
     concrete flooring in one of the Site process buildings.
     Ground-water contamination was  identified in ten  (10)  of the
     wells at concentrations  that exceeded the current or proposed
     Maximum Contaminant Levels  (MCLs).   Figure 5.1  depicts  the
     estimated extent of contamination plumes identified in the RI.
     Those wells located on  site contained the  largest number of
     contaminants at the greatest concentrations,  although one of
     the monitoring wells, located  3000 feet  downgradient  of  the
     Site,  contained 1,1-dichloroethylene in excess of the MCL.


6.0  SUMMARY OF SITS RISKS

     The ABAP baseline risk assessment concluded that the primary
     health risk posed by the Site is through direct exposure (both
     oral and dermal) to contaminated surface soils and ingest ion
     of contaminated ground-water.  The baseline risk assessment,
     was  based on   contaminated environmental  site  media,  as
     identified by Region IV (ESD)  sampling  studies conducted in
     1988-1990. It was conducted in  order to provide an assessment
     of the resulting impact to human  health and  environment if
     contaminated soils and  ground-water, at the  Site, were not
     remediated.   The baseline  risk assessment is  presented as
     Chapter 6 of the RI Report.

     The contaminants of concern identified in the RI reflect the

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          !       APPROXIMATE SCALE
          :   400          0     200    400
TREATMENT
  PLANT
                                                            1.1 -oiCHLORorm YLENE
                                                                US HWY 70/79
           FIGURE 5-1
 CONTAMINANT PLUME  BOUNDARIES
ARLINGTON  BLENDING & PACKAGING
      ARLINGTON.  TENNESSEE


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nature  of  the operations at the  Site,  namely pesticide and
herbicide formulation. The contaminants of concern identified
in  the  baseline  risk assessment  consist of five pesticides,
two solvents, and three inorganic  chemicals and are presented
in Table 6.1.

Pesticides were the major hazardous contaminants detected in
soils  and  of  these,  chlordane   was   the most  frequently
detected,  generally  in  the  greatest   concentrations.
Chlordane was the primary soil contaminant and was the basis
for the risk assumptions shown in Table 6.2.  Heptachlor was
the next most frequently detected  pesticide and was the major
contaminant of concern in surface  soil  from grid 10 (474 ppm,
the average of duplicates taken from this  grid)  and equalled
the chlordane concentration  (83 ppm) in surface soil beneath
the  concrete floor  of building  G.    Pentachlorophenol  was
detected in  a few soil samples.   The  highest concentration
(130 ppm) was detected in a  surface soil sample found beneath
the concrete  floor of building E  and remained detectable (6
ppm) in the  subsurface sample  taken at 16 feet.   Only these
three compounds  were considered as  organic  contaminants of
concern for the soil medium.  Arsenic appears to be the only
inorganic contaminant  associated  with  site activity  that is
present  at   a   frequency   and   concentration   to  warrant
consideration as a site related contaminant of concern.

All  ground-water  contaminants identified  in concentrations
that either equalled  or exceeded their respective MCL (current
or proposed)  were designated as a  contaminants of concern, if
they were detected  in one or more  samples.   No contaminant
that does not have an MCL or a proposed MCL was detected in
sufficient   concentration   to  warrant   inclusion   on  the
contaminant  of   concern  list.     On-site  monitoring  wells
indicated that several contaminants exceeded MCLs.  The only
off  site  ground-water  sample  having  organic  contamination
exceeding MCL levels was  from a distant downgradient location
(AB-9D)  .   The  deep  well  at  this location  showed  a  1,1-
dichloroethylene level of 26 ug/L compared to the MCL of  7
ug/L.

No significant contamination was indicated in the five surface
water samples and this medium  was not  evaluated in the risk
assessment.  An evaluation of the sediment data indicated that
pesticides are  the  only hazardous  substances detected at
significant concentration and  frequency in this  medium.   Of
the positive  findings, chlordane  was always  detected in the
highest concentration and represents the only contaminant of
concern from the sediment data.

6.1  Exposure Assessment

The objective of the exposure  assessment is to estimate the

                           6

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                 TABLE 6.1
CONTAMINANTS OF CONCERN BY ENVIRONMENTAL MEDIA
    ARLINGTON BLENDING AND PACKAGING SITE
            ARLINGTON, TENNEESSEE
CONSTITUENT
ARSENIC
BENZENE
CHLORDANE
1. 1-DICHLOROETHENE
ENDRIN
HEPTACHLOR
HEFTACHLOR EPOXIDB
FOCTACHLOROPHENOL
son.
•

•


•

•
SEDIMENT


•





GROUND
WATER

•
•
•
•

•
•

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                                      Table 6.2

            Assumptions for Exposure to Soil Contaminants of Concern at the
                         Arlington Blending & Packaging Site
                                Arlington, Tennessee
Oral Exposure                             Adult Worker            Child Resident

Daily soil ingestion level                       50 mg                    200 mg
Portion of time on-site at this location              a                       100 %
Portion of ingested contaminant absorbed        100 %                    100 %
Days per year on-site                          250 days                  245 days
Years on-site                                 20 yrs                    5 yrs.
Body Weight                                 70kg.                    16kg
Lifetime                                     70 yrs.                    70 yrs.

Dermal Exposure
                    u                               27
Skin area contaminated                        2,300 cm                  2,430 cm
Soil adherence per cm  of skin                  2 mg                     2 mg
Portion of adsorbed contaminant absorbed          c                         c
Days per year on-site                          250 days                  245 days
Years on-site                                 20 yrs.                    5 yrs.
Body weight                                 70kg.                    16kg.
Lifetime                                     70 yrs.                    70 yrs.
a Variable - see text for specific scenarios.

  Adult worker scenario - forearms and hands; Child  scenario - arms, legs, and hands

c Pesticides 1.0%; arsenic 0.1%. Includes soil matrix effect

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type and magnitude of exposures to the chemicals of potential
concern that are present at or migrating from the Site.  The
results of the exposure assessment are combined with chemical-
specific toxicity information to characterize potential risks.

The  two   primary  pathways  of  exposure   to  significant
concentrations of hazardous substances associated  with the
Site is through  current and future  direct soil  contact via
ingestion and dermal pathways and through future exposure to
ground-water.   The  inhalation  route  of  exposure was  not
believed  to be   important  in  open space  since   the  soil
contaminants of concern readily adsorb to soil particles and
are relatively nonvolatile under normal conditions.

The Site is located on a major highway in a lightly developed,
somewhat rural setting.  A small residential area (44 homes)
exists immediately adjacent to the  eastern  boundary  of the
Site.  Without strict zoning, it is unclear whether the future
use  of this  Site,  after  it  is remediated,  would be  for
residential  development  or   agricultural/industrial  use.
Therefore, it seems prudent to assume that direct and frequent
contact by children and adults  in a residential setting could
occur in the foreseeable future.  Currently, the major portion
of the Site is  fenced with a locked  gate and  without  any
authorized  human activity  with  the exception  of a  small
commercial  laboratory  in the  front  of  the  property within a
separately  fenced area.

Soil contamination was  detected in a few locations outside the
fenced area at  concentrations and  accessibility  that could
result  in  significant  current  exposure.    For example,  a
composite soil sample from Grid #10 contained high  levels of
heptachlor and chlordane.  About half the area of this grid is
outside the fence on the southeastern property  line.   This
area  along  a   railroad track  has  free  access   from  the
residential area.

Nearby  residential soil  testing during  the  1988  sampling
program   revealed   considerably   lower   total   pesticide
concentrations in surface soil.   Another contaminated area of
concern, outside the property fence, exists in the  northwest
and northeast corners of the Site that extends off  site down
the  roadway ditch to  the  west and  east of  the Site.   The
soil/sediment samples  taken from these  rain-water drainage
areas contained elevated levels of chlordane.

None of these non-residential off-site areas appear to receive
heavy  foot  traffic  or are   obvious  pathways  of routine
exposure.  However, the contaminants are at the soil surface
and direct  soiJL or dust  contact  could  result in exposure to
the residents in this area.

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Contaminants  in  the soil also have  an  exposure pathway via
migration to ground water and subsequent ingestion.  Although
ground water  in aquifer Units I and  II is not currently used
as a drinking water source,  the State of Tennessee classifies
the aquifer at the ABAP Site as a  Class IIB aquifer, which is
to be maintained at drinking water quality.

The RI  report concluded that a contaminant  plume exists in
aquifer Units I and II (Figure 5.1) and that the contaminants
have migrated off-site.   This off-site migration presents a
threat to the ground-water quality, which  is to be maintained
at  drinking  water  standards,  and an  off-site risk  to the
Loosahatchie  River Canal.

Due to the uncertain  nature regarding  the future use of the
site property, both a future child resident and future worker
exposure  scenario were  developed.    The  resident  scenario
considered that a future child would ingest the total amount
of  the  assumed  soil  intake level  (200  mg/day)   from the
specific area of  the Site  under  consideration.   The intake
scenario is based on the assumption that children between the
ages of 1-6 years  spend most of their time  and  ingest all soil
at the resident location.  The future worker scenario assumed
that an  adult worker  would come in contact with  the  Site
during a 250  day work year  for 20 years.

6.2  Toxicity Assessment

The toxicity assessment was conducted to further determine the
potential hazard posed by the chemicals of concern for which
exposure pathways have been identified.  Available evidence is
weighed in regards to the potential of particular contaminants
to  cause  adverse effects  in  exposed individuals  and  to
provide,  where possible,  an estimate  of the relationship
between  the   extent  of  exposure  to a  contaminant  and the
increased likelihood and/or severity of adverse effects.

Cancer potency  factors  (CPFs) have  been  developed  by EPA's
Carcinogenic Assessment Group for estimating excess lifetime
cancer   risks  associated  with  exposure   to  potentially
carcinogenic chemicals.  CPFs, which are expressed in units of
(mg/kg-day) "1,  are multiplied by  the estimated intake  of a
potential carcinogen,  in (mg/kg-day),  to  provide  an upper-
bound estimate of the excess lifetime cancer risk associated
with exposure at  that  intake  level.   The  term "upper bound"
reflects the  conservative estimate  of  the risks calculated
from the CPF.  Use of this approach makes underestimation of
the actual cancer risk highly unlikely.   CPFs are derived from
the results of human epidemiological studies or chronic animal
bioassays   to  which   animal-to-human   extrapolation   and
uncertainty factors have been applied.

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Reference  doses  (RfDs)   have  been  developed  by  EPA  for
indicating  the  potential for  adverse  health   effects  from
exposure  to chemicals  exhibiting noncarcinogenic  effects.
RfDs, which are  expressed in units of mg/kg-day, are estimates
of  lifetime daily  exposure  levels   for humans,  including
sensitive individuals.   Estimated intakes  of chemicals from
environmental media (e.g., the amount of a chemical ingested
from contaminated drinking water)  can be  compared to the RfD.
RfDs are derived from  human epidemiological studies or animal
studies  to  which  uncertainty  factors  have  been  applied
(e.g.,to account for the  use of animal  data to predict effects
on humans).  These  uncertainty factors help  ensure that the
RfDs  will  not  underestimate  the  potential  for  adverse
noncarcinogenic effects  to occur.

The Agency  has  derived the Cancer Potency Factor  (CPF)  and
Reference Dose (RfD) values for the contaminants  of concern at
the Site for use in determining the upperbound level of cancer
risk and non-cancer hazard from exposure to a given level of
contamination (Table 6.3).

6.3 Risk Characterization

Future risk scenarios, based on reasonable maximum exposures
to contaminants found  in  soil,  were developed which estimated
the  probability of resulting carcinogenic  health  effects.
Exposure  scenarios  were developed for  both future  adults
working and future children playing at  the Site, since future
land use is uncertain.

The on-site  risk  to future workers and  child  residents was
evaluated by determining exposure to areas of the Site having
similar levels  of contamination.   A number  of  areas outside
the fenced property boundary  had chlordane  levels  that were
evaluated under a current child resident scenario since they
were freely accessible from the residential area adjacent to
the eastern property boundary.  The availability of composite
sampling data from each gridded area (100 x  100 ft.) allowed
for  exposure assumptions  and  thereby  risk estimates  for
various contaminant concentration and locations within the
Site.

Excess lifetime cancer risks are determined by multiplying the
intake level by the cancer potency factor.   These risks are
probabilities  that  are  generally  expressed in  scientific
notation  (e.g., 1X10'*).   An  excess lifetime cancer risk of
1X10'6  indicates that, as  a  plausible upper bound  risk,  an
individual  has  a one in one million chance  of  developing
cancer as a  result  of site-related exposure to a carcinogen
over a 70-year lifetime under the specific exposure conditions
at a site.

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                                     Table 6 J

                    Health-based Values for Carcinogens (CPF) and
                       Non-carcinogens (RED) and ARARs for
                   Oral Exposure to Contaminants of Concern at the
                        Arlington Blending & Packaging Site
                                Arlington, Tennessee

Contaminant                    CPF                  RFD                 ARARa
                            (mg/kg/day)"1         (mg/kg/day)             (mg/L)
Arsenic                          1.8                   0.001                0.05
Benzene                         0.029                 NA                  0.005
Chlordane                       1.3                   0.00006              0.002
Chromium (VT)                   NA                  0.005                0.1
Dichloroethene(U)               0.6                   0.009                0.007
Endrin                          NA                  0.0003               0.002
Heptachlor                       4.5                   0.0005               0.0004
Heptachlor Epoxide               9.1                   0.000013             0.0002
Pentachlorophenol                0.12                  0.03                 0.00 lb
Selenium                        NA                  NA                  0.05
   a = For drinking water exposure only, EPA promulgated or proposed MCLs

   b = Proposed MCL (1/30/91)

NA = Not applicable or not determined

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EPA  prefers  that remediation of  Superfund sites  achieve  a
residual  cancer  risk  no  greater  that  10"s  (1  chance  in
1,000,000).  However, depending upon site factors,  a risk of
1Q"4  (1   in  10,000)  may  be  considered  protective.    The
calculated upperbound risks from exposure to hot spot areas of
the Site would fall outside the protective range.  The sum of
risk to  the on-site  workers was calculated  to  be 1.1  X  10'4.
The summed upperbound carcinogenic risk to children residing
and playing on site in the future were calculated to be up to
1.1 X 10°.  The carcinogenic upperbound risk for each of the
contaminants of concern identified in site soils is presented
in Tables 6.4 and 6.5.

The non-carcinogenic toxicity risk from soil contaminants was
also evaluated.  This was done  through  the calculation  of a
Hazard Index (HI) .  The HI is  obtained by dividing the assumed
daily exposure dose by the chronic RfD.   HI values  above 1.0
indicate an unacceptable risk that increases in magnitude with
higher numerical scores above 1.0.   The HI provides a useful
reference point  for gauging  the  potential significance  of
multiple  contaminant exposures within  a  single medium  or
across media.   The  HI for future resident children at various
hot  spots on  the  Site ranged  from <1  to 46.    Table  6.4
contains a summary of the HI  values calculated for  the child
scenario.

The human health risk posed by the ingestion of ground-water
was  determined   by  comparing   detected  levels   of   the
contaminants  with   drinking  water  standards  for  these
substances.  The following chemicals were detected in samples
taken from  site ground-water wells  in  concentrations  that
exceed their respective MCLs; benzene,  chlordane,  chromium,
1,1-dichloroethene,    endrin,    heptachlor    epoxide,
pentachlorophenol and  selenium.   Any exceedence of  the MCL
values by water samples taken within the contamination plume
at or downgradient  to the area of attainment (i.e. the entire
ground-water plume except the area directly beneath any waste
that is contained and managed on site) represents a cause for
concern.

The  ground-water aquifer,  investigated  in the  RI,  is  not
currently used  as  a drinking water source, and  the nearest
known private well is about  4000  feet to the  west.  The two
(2) Arlington municipal wells are about 8000-feet and also to
the west of  the Site (Figure 6.1).  However,  the  surficial
aquifer  beneath the  Site contains ground water classified as
either  IIA  (ground  water currently  used  as  a  source  of
drinking  water)  or  IIB (ground water  that is  a  potential
source of drinking  water) by the State of Tennessee.  Also the
Memphis  Sand  aquifer,  which is  located beneath  the Site,
contains ground water which may be classified as IIA and would
depend upon the dissolved solids content  of  the ground water.

                          10

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                                     Table 6.4

          Summary of Carcinogenic Risk and Non-carcinogenic Hazard Index
  for Child Resident from Oral and Dermal Exposure to Contaminants in Soil/Sediments
                        Arlington Blending & Packaging Site
                               Arlington, Tennessee
Site Location
(Grid*)
Soils
8, 10, ll,41a

16. 29, 42a
16a
25, 31,37,43b
Sediments
16b
17, 18, 19b
Contaminant
Level (mg/kg)
145
253
187
15.7
5.2
130
9.3
1.3
18
14
Contaminant
Arsenic
Chlordane
Heptachlor
TOTAL
Chlordane
Heptachlor
TOTAL
Pentachlorophenol
Chlordane
Heptachlor
TOTAL
Chlordane
Chlordane
Upperbound
Risk level
1.6x10"*
2.6 x 10"*
6.5 x 10"*
1.1 x 10'3
1.6xlO'5
1.8 xlO'5
3.4 x 10'5
9.3 x 10"6
9.2 x 10"6
4.6 x 10*
1.4xlO"5
l.SxlO'5
1.4xlO"5
Hazi
Inde
1.2
46
4.1
2.9

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                                    Table 6.5

   Summary of Carcinogenic Risks for Adult Workers from Oral and Dermal Exposure
                         to Contaminants in Soil/Sediments
                        Arlington Blending & Packaging Site
                               Arlington, Tennessee
Site Location
(Grid*)


Soils
10,11
10
8,11,41
8,10,11,41
16,29,42
35, 16a

15, 28, 34b
Fraction of
Time at
a Location

0.14
0.07
0.21
0.29
0.21
0.14

0.25

Contaminant
Level (mg/kg)

265
474
91
253
16
68

21


Contaminant

Arsenic
Heptachlor
Heptachlor
Chlordane
Chlordane
Chlordane
TOTAL
Chlordane

Upperbound
Risk level

l.OxlO'5
4.5 x 10'5
1.8 x 10'5
2.8 x 10'5
1.3 x 10"6
3.5 x 10"6
l.lx 10^
2.0 x 10"6
a = Sediment samples; all other surface soil samples

b = Designates risk to worker at grid on DOT property; other risks for
    worker on ABAP property'

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Data  from on-site wells at two  (2)  depths  in the surficial
aquifer  clearly indicate  that  it has been  contaminated by
pesticides and volatile organics  from operations at the Site.
In addition,  a  recent  sample  from a deep well (about  40-ft.
below  surface)  located about  3,000-feet  downgradient of the
Site   contained  detectable  levels  of  seven   (7)  organic
contaminants.

The contaminants classified by EPA as carcinogens  - chlordane,
heptachlor, and arsenic - were identified as the  primary soil
contaminants.   The  specific  clean-up levels for each of the
contaminants  of concern  detected in  site soils are presented
in Table  9.1.

There  are no  sensitive habitats or ecological systems within
areas  in close proximity  to the  Site,  but  a  ground-water
contaminant  plume  consisting primarily of  1,1-DCE and 1,1-
dichloroethane  has  reached  the  discharge  point  in  the
Loosahatchie River Canal.  These compounds have not been found
to be  discharging at  concentrations above  their respective
ambient water quality criteria levels and do  not bioaccumulate
to any degree. Therefore, these contaminants are  not believed
pose a significant threat to aquatic  life. Remediation of the
ground-water  source  of  contamination  to  drinking  water
standards will be protective of aquatic life in  this surface
water  body.

6.4 Risk Uncertainty

There  is a  generally  recognized uncertainty  in human risk
values developed  from  experimental  data.   This  is primarily
due to the uncertainty of data extrapolation in  the areas of
(1) high  to  low dose exposure and  (2) animal  data to human
experience.   The  site-specific  uncertainty  is mainly in the
degree of accuracy of the exposure assumptions.  Most of the
assumptions used in this  and any risk assessment have not been
verified.  For example, the degree of chemical absorption from
the gut or through the skin or the amount of soil contact is
not known with  certainty.  Generally accepted default values
provided  in  Agency  guidance  were  used  here.    However,  it
should be noted that little data or  guidance is  available on
the dermal absorption of particulate-bound contaminants.  In
the risk assessment conducted for the Site, the dermal pathway
yielded a significant  contribution  to the calculated  direct
exposure risks.

In the presence of such uncertainty, the Agency  and the risk
assessor has  the obligation to make  conservative assumptions
such that the chance is very  small,  approaching zero,  for the
actual health risk to be greater than that determined through
the risk process.   On  the  other hand,  the process is  not to
yield absurdly conservative risks values that have no basis in

                           11

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reality.  That balance was kept  in mind in the development of
exposure assumptions and pathways and in the interpretation of
data and guidance for this baseline risk assessment.

ff.5 Summary

The health risk posed  by this NPL  site is  primarily from
direct exposure to contaminated surface soil and the ingestion
of ground water beneath the Site. The major soil contaminants
are not uniformly distributed over the site surface but exist
in "hot spots" of varying concentrations.

The contaminants of concern reflect the nature  of  the past
operations  at  the  Site,  i.e.,   pesticide  and  herbicide
formulation.  Those contaminants retained as contaminants of
concern  included  five  pesticides,  two solvents, and three
inorganic contaminants - arsenic, chromium, and selenium.  Of
the  three  inorganic contaminants,  only arsenic has  been
retained for remediation because of its detection at elevated
levels in hotspots and its apparent  use during site activities
(Table 6.1).  Both chromium and  selenium were detected in on-
site wells at levels above current or proposed MCLs,  however,
they are unlikely to be site related.

The health risks of soil/sediment contaminants  of concern were
evaluated under two exposure  scenarios,  i.e.,  ingestion and
dermal absorption by future adult workers  and child residents.
The child  residents represented a  realistic  future  scenario
since  the Site  and surrounding area  is  not committed to
industrial use and  is  bordered  to  the  east  by a residential
area.  A number of areas outside the fenced property boundary
had chlordane levels that were evaluated under  a current child
resident scenario since they were freely accessible from the
residential area adjacent to the east property boundary.

The sum of the risk  to the on-site workers was  found to be 1.1
x 10~4.  The ho.t spot areas at the Site were shown to produce
an unacceptable upperbound risk  to a  future child resident at
a calculated  level  of 1.1 x  10°  and a hazard  index  of 46.
Other  areas on-site  and off-site  exceeded  the  upperbound
point-of-departure risk level of 10"*.  In addition,  the non-
cancer toxicity showed hazard index values greater than 1 for
several areas.

Risk from the ingestion of ground water was evaluated relative
to current and proposed MCLs.  Since  the summed risk from all
chemicals  detected  at  the  MCL level  was within  the  NCP
acceptable range, no additional risk evaluation was conducted.
On-site monitoring wells screened to  a depth of about 40 feet
yielded ground water containing  benzene, chlordane, chromium,
1,1-dichloroethene, endrin, heptachlor epoxide, selenium, and
pentachlorophenol in excess of current or proposed MCLs.  An

                           12

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                                          KEY:

                                   • - WELL LOCATION
                                       ( in feet )
                                      1 inch = 2000 ft
  ARLINGTON
MUNICIPAL WLIt
           FIGURE 6-1
POTABLE WELL SUPPLY LOCATIONS
        ARLINGTON AREA
     ARLINGTON,  TENNESSEE

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     off-site  well about  3,000  ft.  downgradient  yielded  1,1-
     dichloroethene at a concentration of 26 ppb, about four times
     the MCL.  Although  other  contaminants were detected in this
     well, no  other findings  in  any  off-site well  exceeded  MCL
     values.

     Actual or  threatened  releases of hazardous  substances from
     this  site,  if not  addressed by  implementing  the  response
     action selected  in this  ROD,  may present an  imminent  and
     substantial endangerment  to  public  health, welfare,  or  the
     environment.
7.0 DESCRIPTION OF REMEDIAL ALTERNATIVES

     The  following  remedial  alternatives   were  selected  for
     evaluation:

     1. No Action;

     2. On-site   Cleaning,   Caps,   Land-Use   Controls,   Fence
        Maintenance,  and Monitoring;

     3.  and   3A.     Excavation,   Off-site   Thermal   Treatment
        (Incineration), Solidification and Landfill of Contaminated.
        Soils,  Activated  Carbon   Treatment   and  Discharge  of
        Ground-water to POTW or Surface Water;

     4.   and   4A.   Excavation,    On-site   Thermal   Treatment
        (Incineration), Solidification,  and On-Site Backfilling of
        Contaminated Soils, Activated Carbon Ground-water Treatment
        and Discharge of Ground-water to Publically Owned Treatment
        Works (POTW)  or Surface Water;

     5. and 5A.  Exception, On-Site Thermal  Treatment  (Ex-Situ
        Thermal   Desorption),    Solidification,    and   On-Site
        Backfilling  of  Contaminated   Soils,   Activated  Carbon
        Ground-water Treatment and  Discharge to  POTW  or Surface
        Water.

     7.1  Alternative 1:  No Action

     CERCLA requires  that the "No Action" alternative be considered
     at  every  site  against  which  the  other alternatives  are
     evaluated.   Under this alternative no provisions  have been
     made  for treatment  or containment  of  contaminated  soils,
     sediments, or ground-water identified at the Site.

     This alternative would not be considered protective of human
     health and  the.environment  because it would not  reduce the
     unacceptable risks posed by the Site when evaluated under a
     future residential  risk  scenario.    The only  reduction of

                               13

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contaminant levels would occur through natural processes such
as  dispersion and  attenuation.    Alternative  1  would  pose
significant   potential   for   adverse   effects   due  to  the
following:

•  Continued  potential  direct  contact  with pesticides  and
   arsenic in contaminated soil, sediment, and buildings,;
•  Increasingly frequent trespassing on the site as the fence
   surrounding it deteriorates;
•  Continued percolation of pesticides from soil  into ground
   water;
•  Ground water would not be  restored to its beneficial uses;
•  Erosion  of   contaminated  soil  and   sediment  causing
   contamination of surrounding areas;
•  Potential future exposure to ground water contaminated with
   pesticides and volatile organics; and
•  Potential exposure to contaminated subsurface soil if it is
   brought to the surface during development of the Site.

Ground-water  monitoring would be  conducted every  five   (5)
years  at nine of  the existing on-site  wells  for  at  least
thirty (30)  years.  The ground-water samples would  be analyzed
for  the  Target  Compound List  organics,  pentachlorophenol,
pesticides,    herbicides,   and  the  Target  Analyte   List
inorganics.   Also two composite bioassays would be performed
annually, one from water collected  from on site and a second
from water collected downgradient of the Site.

Because  the contaminated soils and  ground water would remain
in place, untreated,  at  the  Site,  CERCLA requires that a 5-
year review  of  data  collected  at  the  site be  evaluated at
least  every  five  years to  assure that  a selected  remedy
continues  to be   protective  of  human   health  and  the
environment.  Data obtained from the ground-water monitoring
program and  the bioassays would be compiled and reviewed once,
at least, every  five  years for no  less than 30 years.   The
findings of  the  review  could result  in  the performance of
other studies and/or actions as deemed necessary by EPA.

The estimated capital cost of the  remedy  presented in this
Alternative would be $21,685  and the associated O&M costs and
indirect costs would be $194,857 and $32,481,  respectively.

7.2  Alternative   2:   On-Site   Cleaning,  Caps,   Land-Use
     Restrictions,  and Fence Maintenance and Monitoring:

Annual ground-water sampling would be conducted at  nine  (9) of
the existing  site monitoring  wells, and four (4)  additional
wells,  which  would  be  installed  and  sampled  in  order to
monitor ground-water quality and to further define the extent
of plume migration beyond the  site boundary.    These  wells
would  be analyzed  for  the  Target Compound List organics,

                           14

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pentachlorophenol,  pesticides,  herbicides,  and. the  Target
Analyte List inorganics.  The new wells would be placed both
on  site  and off  site and  screened  throughout  the area  of
attainment (i.e. the entire ground-water plume except the area
directly beneath  any  waste  that  is  contained and managed on
site).  As  part of the ground-water monitoring program two
composite bioassays would be conducted annually.

Contaminated site  soils and sediment,  previously identified
within the 100-square  feet grids employed during  the RI, would
be regridded.  Fifteen-square feet grids would be sampled to
further define  these  areas  in order to  determine  the total
volume of  contaminated soils on Site. Adjacent grids targeted
for remediation activities would  also be  sampled to determine
if any portions of the adjacent  composited  100-square feet
grids were above action levels.

Site process buildings would be decontaminated and demolished,
leaving the floor slabs in place over which a RCRA cap would
be  constructed.    Subsurface  soils  containing  hazardous
substances  above  subsurface  soil  action levels  would  be
excavated,  consolidated with contaminated solid waste from
building-grit  blasting,   and  placed   under  the  RCRA  cap.
Surface soils containing  hazardous  substances  above surface
soil cleanup  levels would be graded and compacted,  covered
with a warning  barrier grid and  a silty-clay cap cover, and
revegetated.   The  volume of  surface  and subsurface soils
requiring remediation is estimated to be 24,000 cubic yards.

Inspection and maintenance of the caps (both RCRA cap and soil
cover)   and  site conditions  would be  conducted  annually.
Land-use restrictions would  be sought by EPA through the local
municipal government  to  impose on the site  property  for an
indefinite period of  time.   EPA  would  also seek to obtain a
ground-water use  restriction  from the  Memphis-Shelby County
Health Department  for that  ground water downgradient  of the
Site until ground water levels no longer exceeded health based
levels.  Because contaminants would be  left on site, a review
of the site  data collected  annually would be reviewed every
five (5)  years for at least thirty  (30) years to assure that
the remedy continued to  be protective of  human health and the
environment.  The findings of the reviews could  result in the
need to perform  additional studies and/or actions at the Site.

The estimated capital cost  of the  remedy presented in this
Alternative would be $403,617 and the associated O&M costs and
indirect costs would  be $278,066 and $80,723, respectively.

Residuals

Once decontaminated, metallic and non-metallic building debris
would  be  disposed  of in  an  appropriate recycling facility

                          . 15

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and/or  RCRA Subtitle  C landfill.   Solid waste  and water,
resulting from grit blasting and steam cleaning the buildings,
would be collected  and  disposed of in a proper facility.

7.3  Alternative  3  and 3A: Excavation  and Off-Site Thermal
     Treatment (Incineration)  of Contaminated  Soils, Off-site
     Solidification and Landfill  of Residual Contaminated
     Soils and Building Debris, Activated Carbon Treatment gpfl
     Discharge of Contaminated Ground-water to POTW:

A minimum of four  (4) additional ground-water monitoring wells
would be installed and  sampled in conjunction with sampling at
nine (9) of  the existing site monitoring wells. The resulting
data would be used to design a ground-water extraction system
and treatment  facility.

Contaminated ground water would be pumped  to  the surface for
treatment  by  filtration  and  carbon  adsorption and  later
discharged  to  the City  of Arlington Publicly  Owned Treatment
Works  (POTW),  after the facility  pretreatment requirements
have  been  met,  or  to  the Loosahatchie  River  Canal  under
National Pollutant Discharge Elimination System (NPDES) permit
requirements.

-Alternative  3  would   utilize   approximately fifteen  (15)
extraction wells for removal of contaminated ground water from
on site  and from the downgradient area- located  between the
Site and  the Loosahatchie  River Canal.   The  daily effluent
flow rate, following treatment,  would  be approximately 43,200
gallons/day.

-Alternative  3A  would  incorporate approximately  eight  (8)
extraction  wells  to remove contaminated  ground  water  on or
very  close   to  the  Site  and would  not  treat ground-water
downgradient  of  the Site.   The  daily  effluent  flow  rate,
following   treatment,    would   be   approximately   23,040
gallons/day.

Temporary ground-water  use restrictions would be imposed on
ground  water  at  and  downgradient  of  the Site during  the
remediation  period by local   authorities.     Performance
evaluations  of  the ground-water  remedial action will  be
conducted as outlined in section 7.5.

Site soils  and sediment located in known contaminated areas
would be regridded (in the manner described for Alternative 2)
and sampled to further delineate the estimated  total volume of
contaminated site soils.  Excavated contaminated site soils,
approximately  24,000 cubic yards,  would  be   shipped  to  an
off-site location  for  thermal  treatment at a  RCRA permitted
hazardous waste incinerator.   Transportation  of contaminated
soils  will   be   in  compliance   with   Federal   and  State

                           16

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regulations.    Areas  excavated  would  be  backfilled  and
revegetated.

Contaminated soils in excess of  the soils action levels would
be excavated to a  depth  of  two  feet,  at one-foot intervals.
The remaining excavation cells would be resampled, and should
soils  in  the  next  layer  exceed soil action  levels,  an
additional 12-inches would  be excavated.   The process would
continue until all contaminated soils have been excavated.

Site process buildings and  the  underlying  concrete flooring
would be decontaminated,  demolished, and removed for off-site
disposal in order to  facilitate  identification and excavation
of contaminated soils located underneath.

The estimated  present worth capital  cost  of  Alternative 3
would  be $21,536,644, while the associated O&M  costs  and
indirect   costs   would   be  $15,504,031  and  $4,307,530,
respectively.  Alternative 3A is estimated to have a present
worth  capital  cost of $21,515,994 and  an  estimated present
worth  O&M  cost   and  indirect  cost  of   $15,267,186  and
$4,3030,199, respectively.

Residuals

Contaminated waste  resulting  from monitoring or  remedial
action  activities  will  be  drummed and if  found  to  be  in
compliance with all LDRs,  they would be sent to an appropriate
RCRA facility.  Otherwise the drummed  wastes would be sent to
a  hazardous waste incinerator.   Soil  and  ash  containing
significant amounts of arsenic or other  trace metals would be
solidified at an off-site treatment facility.

Decontaminated  building  debris  would be   placed  in  an
appropriate RCRA  landfill facility.   Granulated   Activated
Carbon (GAC) filters  from the treatment process  will be either
regenerated and reused or sent off site  for thermal treatment
to meet RCRA requirements.


7.4  Alternative 4 and  4A:  Excavation and  On-Slte Thermal
     Treatment (Incineration) of Contaminated Soils, On-site
     Solidification  and  Backfill of   Contaminated  Soils and
     Off-site Disposal of Building Debris, Activated Carbon
     Treatment, and Discharge of Contaminated Ground-water to
     Surface water or POTW:

As in Alternatives 3 and 3A, sampling data from a minimum of
four (4) new ground-water monitoring wells and nine  (9)  of the
existing  site  monitoring wells would  be  obtained  for the
design of a ground-water extraction and treatment system.
                           17

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Contaminated  ground-water would  be pumped  to  the  on-site
treatment facility to remove pesticides  and volatiles through
filtration  and carbon adsorption prior  to discharge  to the
Loosahatchie River Canal or the local POTW in compliance with
NPDES or facility pretreatment requirements.  The ground-water
extraction   system,   treated   effluent  flow   rates,   and
performance monitoring plan presented for Alternatives 4 and
4A are the same as Alternatives 3 and 3A, respectively.

-Alternative  4  would  utilize approximately  fifteen  (15)
extraction wells for contaminated ground-water removal  from on
site and the downgradient  area located  between the Site and
the Loosahatchie River Canal.

-Alternative   4A  would   utilize   approximately  eight  (8)
extraction wells  to  remove contaminated ground-water on  or
very  close to  the Site  and  would not treat ground-water
downgradient of the Site.

Like Alternatives 2,  3,  and 3A,  site soils and  sediment would
be gridded and sampled  to  further define known contaminated
areas in order to determine the  total  volume  of site soils
containing hazardous substances.

Site process buildings  and the underlying  concrete flooring
would be decontaminated,  demolished, and removed  for off-site
disposal in  order to facilitate  excavation  of contaminated
soils.

An estimated volume of 24,000 yd3 of contaminated site soils
would be excavated and  then  thermally  treated in an on-site
hazardous waste incinerator in compliance with all 40 CFR Part
264 performance standards and  Part 270.19  requirements  to
conduct a  trial burn.   Residual  ash will meet RCRA  LDRs  by
meeting BDAT standards or treatability variance levels where
appropriate.    Any  treated  material  which   does not  meet
treatment  objectives  would  be  incinerated   again  (if  the
problem is  from organics)  or solidified (if  the problem is
from potential  leaching of inorganics).  The excavated areas
would be backfilled with ash  from  the incinerator, compacted,
and then revegetated.

This alternative will comply with LDR through  a Treatability
Variance under 40 CFR 268.44(h) for the contaminated soils and
debris  through  the  use  of  on-site  thermal   destruction
(incineration)   to attain  the  Agency's applicable   interim
•treatment levels/ranges'.  The treatment levels/ranges, which
were established through a Treatability Variance  for  the on-
site incinerator unit, are presented in Table  7.1.

Temporary ground-water use  restrictions would be imposed on
ground-water at and  downgradient  of   the  Site  during the

                           18

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                                             TABLE 7.1

                     TREATABILITY VARIANCE TREATMENT LEVEL RANGE
                                         FOR SITE SOILS
                           ARLINGTON BLENDING AND PACKAGING SITE
                                     ARLINGTON, TENNEESSEE
                                                      THRESHOLD CONCHTTRATION
                                                    RANGE TO BB ACHIEVED
  Ancdc
                               13-370
                                                               10
                                                                                      90-99% (1)
  Chlontane
                              0.043-400
                                                              0.2
                                                                                      90 -99.9% (I)
  Heptachk*
                              0.003-920
                                0.2
                                                                                      90 -99.9% (I)
PeoHchlarophenol
0.360-130
                                                              400
                                                                                      0.5 - 40 ppm
  • Attainment of lifcnufc trc«traenl ttmlto for Und dlipoMl will be oonflimed by loUl wute malyiii for orgulcs and TCLP for loorgtnic*.
 •• See AppeodU A for Si?erfund LOR Guide f6A (2nd Edition)
  1 Reduction In wide ootpaHnbon

-------
remediation  period.    Such  restrictions  would  be  imposed
through  the  Memphis  and  Shelby  County  Health  Department
(MSCHD)  permitting  program.   Performance evaluations of the
ground-water remedial action will be conducted as  outlined in
section  7.5.

The  estimated present  worth  capital cost of Alternative 4
would  be  $16,654,900  while  the associated  O&M  costs  and
indirect   costs  would  be   $1,605,300  and   $3,664,100,
respectively.  Alternative 4A is estimated to have a present
worth  capital  cost  of  $16,632,200  and  an estimated present
worth O&M cost of  $1,409,000 and indirect costs of  $3,659,100.

Residuals

Solid    waste    from   ground-water   treatment,    building
decontamination,  and from related  site  activities would be
incinerated and  solidified (where  necessary)  on  site.   Ash
containing arsenic would be solidified on site and  disposed of
in an  appropriate off-site RCRA landfill.  Soils containing
thermally treated contaminated soils and solid wastes would be
analyzed, and if found  to be below site action levels would be
backfilled into excavation cells.

All decontaminated building debris  would be shipped off site
for  disposal  in  an appropriate  RCRA landfill,  except  the
metallic debris which would be .recycled.   GAC  filters will be
regenerated or  thermally treated to  meet Best Demonstrated
Achievable Technology (BDAT)  or  treatability variance levels.

Once   incineration   activities   have  been  completed,   the
remaining  treated decontamination  fluids  may be stored in
3,000  gallon   tanks,  tested, and  disposed  of through  the
ground-water   treatment  system   and  discharged   to   the
Loosahatchie River Canal or the local POTW,  after verification
that it meets applicable criteria for discharge.

Residues which  contain or which are  containing listed RCRA
hazardous waste would  be handled in  the manner outlined in
Section 7.5.

7.5  Alternative  5  and  5A:  Excavation  and  On-Site Thermal
     Treatment  (Ex-Situ Thermal Desorption), Solidification
     and  Backfill of  Contaminated Soils/ Activated Carbon
     Treatment *«<* Discharge of Contaminated Ground-water to
     Surface Water or Local POTW:

The preliminary implementation of Alternatives 5 and 5A (as in
Alternatives 3, 3A,  4,  and 4A) would involve  the conduct of a
detailed soil  and hydrogeological  sampling  plan  to further
refine the  volumetric  estimates  of  contaminated soils  and
ground-water.      Once   treated,    extracted  contaminated

                           19

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ground-water  would  be  pumped  to  the  Arlington  POTW  or
discharged to the Loosahatchie River Canal in compliance with
appropriate requirements cited in Alternatives 3,  3A,  4,  and
4A.   The  estimated effluent  discharge  rates  specified  in
Alternatives 3 and  3A  would  apply to  Alternatives  5 and 5A,
respectively.

-Alternative  5  would  utilize  approximately   fifteen  (15)
extraction wells  for contaminated ground-water removal from on
site and from the area downgradient  located between the Site
and the Loosahatchie River Canal.

-Alternative  5A  would   utilize approximately  eight  (8)
extraction wells  to remove contaminated ground-water  at  or
very  close to the Site  and  would  not treat  ground-water
downgradient of the Site.

Temporary ground-water use restrictions would be required at
and downgradient  of the  Site during  the remediation period.
Enforcement of these restrictions would be implemented through
the existing MSCHD permitting program.

Performance evaluations would be conducted no less than every
five years during the  ground-water remedial  action or until
contaminant concentrations in ground-water no longer exceed
health-based levels. The evaluations  would continue  until the
completion of the ground-water remedial action and would serve
to  indicate  whether  cleanup  levels  have  been or will  be
attained.

Contaminated site soils,  estimated  at  24,000  yd3,  would  be
excavated  and  then thermally treated  in an  on-site ex-situ
desorption unit to remove organics contamination. Those soils
found to be contaminated with  listed wastes coded F021 or F027
will be segregated prior to treatment.  The excavation cells
would be backfilled and compacted with the treated soils, once
treatability  variance   levels   have   been   met,   and  then
revegetated.

This  alternative  will   comply with  the   LDR  through  a
Treatability Variance, pursuant to 40 CFR 268.44(h), for the
wastes  that  cannot be treated to  meet the  applicable LDR,
because existing  and  available data  do not  demonstrate that
the  full-scale operation of  this  treatment  technology can
attain the LDR treatment standards consistently for all soil
and  debris wastes  to be addressed  by this  action.    The
treatment  level   ranges,  which  were  established  through  a
Treatability Variance that  the ex-situ thermal  desorption
unit, are shown in Table 7.1.

Once   soils   containing  listed RCRA  wastes  have  been
decontaminated by reducing contaminant concentrations to below

                           20

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health based  levels  they  will  be delisted under CERCLA and,
therefore, will meet RCRA's substantive requirements

As in the other thermal treatment alternatives, site process
buildings   and  underlying   concrete  flooring   would  be
decontaminated and demolished in order to  sample and excavate
contaminated  soils located underneath the concrete slabs.

The  estimated present worth  capital  cost of  Alternative  5
would  be  $8,253,800,  while  the associated  O&M  costs and
indirect   costs   would   be    $1,605,300  and   2,311,100,
respectively.  Alternative 5A is estimated to have a present
worth capital cost of $8,231,000, an estimated present worth
O&M  cost  of  $1,381,800,  and  a   total  indirect  cost  of
$2,304,700.

Residuals

Waste resulting from the implementation of Alternatives  5 and
5A  would  be  disposed   of   in  the   manner  outlined  for
Alternatives  4 and 4A,  except  for those  disposal requirements
that  are the  direct  result of  incineration.    Those  soils
containing arsenic or other trace metals in significant levels
(above  background)  will  be  solidified  on  site  and  later
disposed of at an off-site facility.

The  thermal  desorption  treatment  may  generate  condensed
organic  liquids which will  be  disposed of in an appropriate
off-site  RCRA facility.    Other residuals,  such  as  organic
phase liquids,  sludges, and  spent  carbon, will also require
further treatment by incineration or off-site disposal.

Residues from the thermal  treatment  of  soils and treatment of
ground-water,  which  contain or  which  are  listed hazardous
wastes,  would be subject  to  the delisting process  (40 CFR
260.20 and .22) as appropriate or disposed of at an off-site
RCRA  facility.   Because existing data  show  that  site soils
containing PCP  contain dioxin/furan congeners  in low levels
that would not be considered hazardous  (i.e., are present in
concentrations below health based levels) ,  EPA will attempt to
delist  these  residual  materials   during remedial  design.
Therefore, if RCRA Subtitle C requirements are found not  to be
ARARs, the residual materials would be managed as solid wastes
under RCRA  Subtitle  D  [and  State  of  Tennessee  solid waste
disposal requirements].

If testing of the waste  during  the remedial action  shows that
the necessary levels are  not  being  attained  for delisting
these wastes,  they will  be managed as  Subtitle C hazardous
wastes  and   the  applicable  or  relevant  and  appropriate
requirements under Subtitle C will be  met. Temporary storage
of residual materials may  be necessary prior to  disposal  at an

                           21

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     appropriate RCRA  facility.    Residuals will  be treated  to
     treatability variance levels prior to disposal in an off-site
     RCRA facility.


8.0  SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES

     EPA's  selected alternative  is  Alternative  5,  along  with
     Alternative 4  as a contingency alternative, for remediation of
     soil and ground-water at the Arlington Blending and Packaging
     Site.   Both  of  these alternatives  involve  extraction  and
     treatment of the contaminated ground-water via approximately
     fifteen (15) extraction wells (exact number will be determined
     during  the remedial  design).   The  final   decision  as  to
     discharge of  water  to either  the  local  POTW or  the  nearby
     Loosahatchie River Canal  will be made during Remedial  Design
     (RD) .  Both of these alternatives utilize thermal treatment of
     contaminated soils and debris  (including treatment residuals)
     as a means  of soils remediation, but differ  in  the process
     option  (technology   type)  used  to  implement  the  remedial
     technology. Alternative 5 involves the use of ex-situ thermal
     desorption, an innovative technology, to remove contaminants
     from site soils, while 4 involves  treatment  of  soils  via an
     on-site hazardous waste incinerator.  Table 8.1 presents the
     summary of  the detailed  analysis  for  each of  the  remedial
     alternatives.

     Overall  Protection   of  Human Health  and  the  Environment
     addresses whether or not a remedy provides adequate protection
     and describes  how risks are eliminated,  reduced, or controlled
     through  treatment,  engineering  controls,  or  institutional
     controls.  Criteria  used to evaluate the protectiveness of an
     alternative included  the following:  (1)  cancer  risks  from
     exposure to soil of  less than IxlO"5, on-site, and IxlO"6,  off-
     site; (2)  no significant risks  of threshold toxic effects (HI
     less than  1)  under  reasonable maximum exposure;  and  (3)  no
     significant risk of  adverse  effects on the environment.

     All alternatives,  except  for  "No Action", would be protective
     of  human  health  and  the  environment.    The  "No Action*
     alternative is'not  protective because it would  not prevent
     unacceptable  risk from soil  exposure in certain  land  use
     scenarios,  and   it  would   allow   off-site   migration  of
     contaminants leading to possible ingestion of water from wells
     drilled into the surficial aquifer, resulting in unacceptable
     risk levels.   Also, Alternative 1 does not involve containment
     or  treatment   of  site  soils,  which  comprise one of  the
     principle threats through dermal exposure and  ingestion of
     these soils.

     The other  Alternatives are  protective because  they prevent
     direct exposure to contaminated soils through either capping

                               22

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                                                                                                TAIIE  8.1   (com..~*d>

                                                                                             SUMMIT Of  DETAILED ANALYSIS
                                                                                         Arlington glending t Packaging  Site
                                                                                                 Arlington,  Tennessee
                                     MO Action
                                     On Sit. Cleaning. Soil Caps,
                                     •CTA Cap, land-Use Control*.
                                     Fence Maintenance i Monitoring
                                                                                                                         J  and SA
                                                                                                               Off  Site  Therms! Treatment,
                                                                                                               Solidification and landfill.
                                                                                                               Activated Carbon Treat t POTU
                                                                                 * and 4«
                                                                        On  Site  Thenxel Treatment,
                                                                        Solidification t lackflll.
                                                                        Activated Carbon Treatment
                                                                                  5 and *A
                                                                         On Site Thenaal Separation.
                                                                         Off lite »e«idue Disposal,
                                                                         leckfllt.  t Activated Carbon
                                                                         Treatment
Ione-Term Effectiveness
and Performance

Magnitude of
residual risks
Adequacy of control
••liability of
Controls
•.eduction of
Toxicitv. Mobility
or Volume. (THV)
  plementability
Technical
feasibility
Existing carcinogenic risk
of 2x10   mm*, and hciard
Index of 3 wilt continue.
Risk could Increase If land
Is f•properly developed (max
cancer rtsk of U10 5 and
max haiard index of 46
There is no control of land-
use or groundwater lite.
Significant existing haiard
fro» Incidental ingest ion of
soil and significant
potential risk froai
groundwater.

Sole reliance on existing
condition* to contro(
exposure
Does not reduce IMV, except
for slow, natural reduction
In pesticides
All components easily
implementable
Reduced likelihood of direct
exposure due to caps, fence
and land-use and water-use
control.  Expect a»x. cancer
risk <1xTO"* and haiard
Index <1 from on-site
residential exposure to
•oft.

Ohect contact, site access,
land-use and groundwater use
are controlled.  Quick
response if grounduater
quality deteriorates.
Monitoring reliable. Caps.
fence, tand use control can
be reliable, but require
ax>re intense (and longer)
Ot* than Alt 344.

Does not reduce toiicfty or
volum*. but caps reduce and
land-use control reduce
•wbility
All components easily
I lap lenient able
Sit* specific goal of
reducing MX. cancer risk
<1x10° and haiard Index <1
for worst-case exposure to
soil achieved Mxiaua off-
site risks to residents
<1x10"6.
Thenaal treatment and
solidification of solids and
carbon treatment of water
demonstrated to be effective
for arsenic 4 pesticides.
POTU effective for votatlles
in water.

Sand I steam cleaning,soil
removal, incineration, C
solidification, carbon
treatment and POTU Permanent
4 reliable.

Incineration, carbon
treatment and P01U will
permanently reduce the
volune and toxicity of
hydrocarbona. Solid, will
reduce mobility.  Alt.5
reduces more than Alt.SA.

All components easily
implementable after arrange-
ments made with POTU, rail-
road, and sod farm.
Sit* specific goal of
reducing max. cancer risk
<1xiO   *nd haiard Index <1
for on site residential
*xpo*ur* to soil achieved.
Haxlaua off-site risk to
residents <1x10  .
Thermal treatment and
solidification of solids and
carbon treatment of water
demonstrated to be effective
for arsenic I hydrocarbons.
Sandblasting, steam
cleaning, incineration, 4
solid, of solids and carbon
treatment of water permanent
4 reliable.

Incineration and carbon
treatment will permanently
reduce the volume and
loxtclty of hydrocarbona.
Solid. -Ml reduce mobility
of arsenic. Alt.4 reduces
•ore than Alt.4A.

All components easily
Implamentable one* HPDCS
permit granted.
Site specific goal of
reduclpg max. cancer rlak
<1x10~* and haiard Index <
for on-site residential
exposure to toll achieved.
Naxlmua off-site risk to
residents <1x1Q*°.
Thermal separation and off-
site Incineration of residue
and carbon treatment of
water demonstrated to be
effective for arsenic 4
hydrocarbons.
Sandblasting, steam
Cleaning, thermal separation
4 incineration of solids and
carbon treatment of water
permanent t reliable.

Thermal and carbon treatavnt
will permanently reduce the
volume and toxicity of
hydrocarbons.
All components easily
faplementable once MPOCS
permit granted.
O'o
c£  c£
00
o

-------
                                                                                                TAIU 8.1  (continued)

                                                                                             SVMWT Of OEKIUO ANAUSIS
                                                                                         Arlington Blending 1 Packaging Site
                                                                                                 Arlington,  Tennessee
 UlEKMIIVt:
                                      Do Action
                                     On-fit* Cloning, Soil t«p«.
                                     1C** Cap, land-Use Control.,
                                     r«i> t Maintenance I Monitoring
                                                                                                                        3 end V»
                                                                                                               Ofl-tltt Thermal IreotBent,
                                                                                                               Solidified Ion and landfill.
                                                                                                               Activated Carbon Irnt t POTW
                                                                                 t end *A
                                                                        On-11 It thermal treatment,
                                                                        Solidification t seckflll.
                                                                        Activated Carbon Treatment
 Availability of urvlcet
 and •d'
 Service* md materials
 readily available
Cett (Present Worth)


Compliance with AtAM
Overall Protection of Human
Health and Environment
                                     t 2<9,02J
Don not aret KM clour*
requirement•
Hot protect I.e
Adalnlstratlve service* it
local md State lew I will
take effort to obtain.
Technlcil services md
mterlils are readily
•vail able.
                                     * 762. *06
Meets ICtA clotur* require-
ments for waste In place If
Tennessee agrees with alter-
native grounduater limits
based on groundyater-use
controls.

Permanently decontaailnates
buildings,  deduces exposure
fro» trespassing,  (educes
run-off and direct contact.
limits future land-use and
grounduater use. preventing
major Increase in risks.
At  least one off-site
commercial  Incinerator Is
•vailable.  Two "ore are
•ipected to be available In
1991.  Groundwater remedial
services end soil e*c*v*tlon
and transport services and
equipment available.
Obtaining State and POTW
support will require tarn
effort.

t 41.34g.20> (Alt. II
* 41.nSA.3rv (Alt. 3A>

Alt. 3 «eeti ICIA clean
closure requirements. Alt.
3A meets clesn closure
requlreavnts after down-
gradient water compiles with
llailta.

Pereunently decontaailn»tes
•oil, buildings, and
groundMater. pensanently
elidlnstlng slgnlflcsnt
risks.  Alt. 1 Is sore
protective than Alt. 5A
because It treats all
confnainetrd grounduater.
Several entilte Incinerators
readily evallaWe along with
other required services and
equipment.  May need to add
flux fore* condenser to
enUtlne systesi.  Obtalnlna)
pemlsslon to Install
discharge pipe and WOCS
persilt would require scan
effort.
» 21.679.1S8 (Alt. U>

Alt. * «eets tCM clem
closure reqjlreaamts.  Alt
44 a**ts clean closure
requl resents after down-
gradient niter complies with
llBtts.
                                                                                                                                                   •oil. building*,  and
                                                                                                                                                   •llrHratlng slsnlflcant
                                                                                                                                                   risk*.  Alt. 4  la Bore
                                                                                                                                                   protective then Alt. 4A
                                                                                                                                                   because It treets all
                                                                                                                                                   contBslneted groundwater.
                                                                                   i  and SA
                                                                          On-Slte therol  Seperetlon,
                                                                          Off-Site tesldue Dispose).
                                                                          Isctflll. 1 Activated Carbon
                                                                          Ireatecnt
Administrative
feasibility
long-term monitoring
requires coordination
between EPA and Slat*.
Coordination between EPA,
State, and local authorities
will be necessary for
monitoring. Negotiations or
legal action needed for
land-use control. Effort
needed for permission to
wort In railroad right-of-
way.
DOT manifesting necessary.
No permits required for on-
ilte wort. Coordination
between EPA, State, and POTW
authorities needed. Dust
obtain right-of-way thru sod
firm. Effort needed for
permission to wort In
railroad right-of-way.
NPKI permit and right-of-
way to Install discharge
pip* required. Coordination
between EPA, State, md
local authorities needed.
Effort needed for permission
to work In railroad right-
of-wiy.
DOT manifesting mey be
required. Also. NPDES
permit md right-of-way to
Install discharge pfps
required. Coordination
between EPA, Stete, md
local authorities needed.
Effort needed for permission
to wort In rstlroad right-
of-way.
A Halted rucber of flreo
hive developed the tech-
nology.  Laboratory scale
testing would be beneficial
In refining cost and resid-
ual voluse.  Activity around
or under the railroad right-
of-way Bay require tlBe end
effort to secur* pereileslon.
* 12,170,167 (Alt ft
t 11,92],r74 (Alt M)

Alt. I Beets ROM clesn
closure requlreBents.  Alt
5A Beets clem closure
requirements after down-
gradient wster cosplles with
llBlts.

PeiBBiintly dacontaBlnetes
•oil. building*, end
groundweter, perBanently
ellwlnetlng significant
risks.  Alt. S Is sore
protective than Alt. SA
because It treats all
contBslnated groundwater.

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                                                                                                                                                                    SUHHART OF DETAILED ANALYSIS
                                                                                                                                                                Arlington  llending  t  Packaging  Site
                                                                                                                                                                       Arlington, Tennessee
ALTERNATIVE : i
No Act ion
Major Components Annual Monitoring of ground-
water in deep aquifer 1
Monitoring of grounduater in
shallow aquifer, soil, land-
use and grounduater use
every five years.
Evaluate site and options to
extend, shorten or terminate
ground water Monitoring
every five years.
Continue for at least 30
years.
2
On Site Cleaning, Soil Caps,
RCRA Cap, Land Use Controls,

Groundwater Monitoring 1
Modeling and toil Monitor.
Decontaminate buildings,
demolish building over
highly contaminated soil and
nstall RCRA cap. Install
oi 1 cap over other
on lamina ted toil .
and-use and groundwater- use
ontrols. Maintain caps and
ence.
Groundwater monitoring with
annual review and full eval-
uation if problem. Routine
evaluation of site, monitor-
ing data and ground water
use every five years. Con-
tinue for at least 30 years
3 and 3*
Off Site Thermal Treatment,
Solidification and Landfill,

Grounduater monitoring t
modeling and soil Monitor.
Pump, filter, and activated
ca bon treat all liquid
wa tc and groundwater
(A t-3) or on Site ground-
wa er (Att.SA) and send to
PO U. Excavate, screen and
sh p contaminated soi &
so id waste to off-si e
incineration and/or s lidif-
Icatfon t RCKA landfi t.
Decontaminate buildings,
boulders end large re use
on-site. Demolish fau (ding
over highly con lamina *d
Five years follow-up
moni tor Ing
4 and 4A
On-Sit* Thermal Treatment,
Sol idif ication t lackf ill.

Grounduater monitoring I
Modeling and soil monitor.
Pump, filter, and activated
carbon treat all liquid
waste and grounduater
(Alt. 4) or on-site
groundwater (Alt.U) and
send to canal . Excavate,
Screen and treat contam-
inated soil t solid waste
with on-site incineration
and/ or solidification i
backfill. Decontaminate
bui 1 dings, boulders and
large refuse on sue.
Demolish building over
highly contaminated soil.
F ive years fol low-up
monitoring
5 and 5*
On Site Thermal Separation,
Off Site Residue Disposal,
lackfill, 1 Activated Carbon
Treatment
Groundwater Monitoring t
Modeling and •oil monitor.
Pump, filter, and activated
carbon treat all liquid
waste and groundwater and
send to canal. Excavate,
screen and treat con tarn
tion of f -site etldue
incineration, backf i 1 1 .
Decontaminate buildings,
boulders and ( rga refuse
on-site. Demo ish building
over highly contaminated
soil .
F ive years fol low-up
monitoring
O
                                                                         ection  of  community  arid
                                                                         ers during remedial
                                                                                                          Not  applicable
Potential exposure during
decon., excavat ion, conset -
fdation, capping, monitoring
and Maintenance Mitigated by
personnel protection and
dust Control.
                                                                                                                                                Qust  control  methods  will
                                                                                                                                                minimize risk froa excava
                                                                                                                                                tion  and material  handling.
                                                                                                                                                Impacts would be modeled and
                                                                                                                                                appropriate measures  taken
                                                                                                                                                {o prevent  significant
                                                                                                                                                impacts.
                                                                                                              if e pot ent i al  risk
                                                                                                              i ins Ir c*» pest ic ictes  arid
                                                                                                              •me, with  11 ow  r edut t i un
                                                                                                              les t ic i be torcerit rat i on-.
Potential exposure during
decon., soil excavation,
screening t transport, and
groundwater remediation
aitigated by personnel
protection and dust cont.
                                     Dust control methods will
                                     Minimize risk  from
                                     excavation and Material
                                     handling. Impacts would be
                                     modeled and appropriate
                                     Measures taten to prevent
                                     significant impacts
                                     45 months for soiI,
                                     More than 30 years for
                                     groundwater under Alt.
                                     and Alt. 3A
Potential exposure during
decon., excavation,
screening, incineration,
solid, and groundwater
remediation mitigated by
pers.protect., dust cont. I
system design t control.
                                                                                                                                                                                                                          Dust and
                                                                                                                                                                                                                                                 ol
                                      nil i
                                     emissions  from excavatior,
                                     incineration, solid t GU.
                                     treat.   Impacts would be
                                     Modeled  and appropriate
                                     Measures taken to preveni
                                     Sigm ficant impacts.

                                     34 months  for soil
                                     more than  30 yean for
                                     grouidwater under Alt. t
Potential exposure during
dec on., excavation,
screening, thermal separa
tion, and groundwater
remediation mitigated by
pers. protect., dust cont   t
system design t control

Dust and emission control
will minimize risk from
emissions from excavation.
thermal separation, solid!
CU. treat.  Impacts would be
modeled and appropriate
measures taken to prevent
significant iapacts.

12 months for soil acre than
JO yeait for groundwatir

-------
       TABLE 6.1   (continued)

    SUTMART OF DETAILED ANALYSIS
Arlington Blending I Packaging Site
       Arlington,  Teonettev
ALTERNATIVE:
Administrative
Feasibility
Availability of services
and materials
Cost (Present Worth)
CocDtiance with ARARs
Overall Protection of xunan

1 2
On- Site Cleaning, Soil Caps.
RCRA Cap, Land-Use Controls,
No Action Fence Haintenanee 1 Monitoring
Long-term monitoring Coordination between EPA,
requires coordination State, and local authorities
between EPA and State. will be necessary for
monitoring. Negotiations or
legal action needed for
land-use control. Effort
needed for permission to
work in railroad right-of-
way.
Services and materials Administrative services at
readily available local and State level will
take effort to obtain.
Technical services and
» 249,023 * 762,406
Does not meet RCRA closure Meets RCBA closure require-
requirements ments for waste in place if
Tennessee agrees with alter-
native groundwater limits
based on groundwater -use
controls.
No( protective Permanently decontaminates
from trespassing. Reduces
run-oft and direct contact.
Limits future land-use and
groundwater use, preventing
major increase in risks.
3 and 3A
Off-Site Thermal treatment.
Solidification and Landfill.
Activated Carbon Treat 1 POTU
DOT manifesting necessary.
No permits required for on-
site work. Coordination
between EPA, State, and POTU
authorities needed. Must
obtain right-of-way thru sod
farm. Effort needed for
permission to work in
railroad right-of-way.
t least one off-site
ommerclal incinerator is
vail able. Two more arc
upected to be available in
991. Groundwater remedial
and transport services and
equipment available.
Obtaining State and POIU
support will require some
effort.
I 43.348,203 (Alt. 3>
1 41.086.379 (Alt. 3A>
Alt. 3 meets RCRA clean
closure requirements. Alt.
3A meets clean closure
requirements after down-
gradient water compiles with
limits.
Permanently decontaminates
soil, building*, and
groundwater, permanently
eliminating significant
risks. Alt. 3 is sore
protective than Alt. 3A
because it treats all
contaminated groundwater.
4 end 4A
Solidification « Backfill.
Activated Carbon Treatment
KPOfS permit and right-of-
way to Install discharge
pipe required. Coordination
between EPA, State, and
local authorities needed.
Effort needed for permission
to work in railroad right-
of-way.
Several mobile incinerators
readily available along with
other required services and
equipment. Kay need to add
flux force condenser to
permission to install
discharge pipe and NPOCS
permit would require some
effort.
* 21,924,186 (Alt. 4)
S 2t.679,1Sa (Alt. 4A>
Alt. 4 meets RCRA clean
requirements after down-
gradient water complies with
limits.
Permanently decontaminates
soil, buildings, and
groundwater, permanently
eliminating significant
risks. Alt. 4 is more
protective than Alt. 4A
because it treats all
contaminated groundwater.
5 and 5A
On- Site Thermal 'Separation,
Off-Site lest due, Disposal,
Backfill, I Activated Carbon
treatment
DOT manifesting may be
required. Alto. HPOES
permit and right-of-way to
install discharge pipe
required. Coordination
between EPA. State, and
local authorities needed.
Effort needed for permission
to work in railroad right-
of-way.
A limited number of firms
have developed the tech-
nology. Laboratory scale
testing would be beneficial
in refining cost and resid-
ual volume. Activity around
or under the railroad right-
of-way may require time and
effort to secure permission.
% 12,170,167 (Alt S>
S 11,923.774 (Alt SA)
Alt. 5 meets RCRA clean
closure requirements. Alt
SA meets clean closure
requirements after down-
gradient water complies with
limits.
Permanently decontaminates
toil, buildings, and
groundwtter. permanently
eliminating significant
risks. Alt. 5 It more
protective than Alt. SA
contaminated groundwater.

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                                                                                                                       TABLE 8.t  (continued)




                                                                                                                    SUMMARY OF DEIAIlfcD ANALYSIS

                                                                                                                  Ai I irtglon Blending t Packaging Si

                                                                                                                       Art irtgtori,  Tennessee
 ^8
00
2x0

QO
zc

ALTERNATIVE :
long term £ f feet iveness
and Performance
Maontiude of
residual r itks

Adequacy of control

Ret 1*6 1 lily of
Controls
I 0« 1 ( Mj. HOC" i ill

t**iU,i Ml,
1
Ho Action


Exist ing carcinogenic risk
of 2*10 max. and hazard
index of 3 -HI continue.
it i properly developed (max
ma* haiird index of 46
There ic no control of land
use or grounduater use.
from incidental irtgestion of
potent ial i isk from
groundwater .
Sole reliance on enisling
conditions to control
expoeure
Does rtot reduce IHU, encepl
for si Ow, natural r educ ( i on
in pelt icide*
All t uwpw*"' •• c*s ' ' »

?
On Site Cleaning, Soil Caps,
RCRA Cap, Land Use Controls,
Fence Maintenance i Monitoring


Reduced likelihood ot direct
exposure due to cops, fence
and land-use and wa er use
risk <1>10 and ha ard
residential exposur to
soil .
Direct contact, site access,
lard use and groundMater use
response if grourxfeater
Monitoring reliable Caps,
fence, land use cortiol can
be reliable, but retire
•lore intense ( and longer)
O1M than Alt il*
Does riot reduce to» city or
vol ijne, bul t api r eOuce a()d
land use control reOuce
r*jfci 1 i t.

n* em,
5 and JA
Off-Site Thermal Ireatawnt,
Solidification and Landfill,
Activated Carbon treat t POtu


Si te spec if ic goal of
reducipg na*. cancer risk
<1x10 and hazard indei <1
toil achieved MIIIMUM off
erdt ion of solids and
carbon 1 r eat men t of water
permanent i reliable,
Thermal and carbon treatment
will peimaoently reduce the
volume and toxicity of
hydr ocai boris .
Al 1 component s eas i 1 y
pei »i t a< anted.

-------
and fencing (Alternative 2) or thermal treatment  (the others).
Alternative 2 would significantly reduce further exposure to
ground-water contamination  through  monitoring,  ground-water
use controls, and the  installation  of a  RCRA cap and ground
cover  (which would  prevent leachate  formation).   The other
Alternatives would employ both ground-water use restrictions
and pump-arid-treat methods.

Overall, Alternatives 3, 3A, 4, 4A, 5,'and 5A provide a higher
level of long-term protection than Alternative 2 because the
most contaminated material is significantly decontaminated in
these alternatives,  while maintenance is required to assure
the effectiveness of  the  RCRA cap  and  land-use controls in
Alternative 2.   Ground-water contamination would spread more
under  Alternative  2   than  under  Alternatives  3A and  4A,
rendering Alternative 2 less protective than Alternatives 3A
and 4A.   Alternatives 3A,  4A,  and 5A provide  less  overall
protection than Alternatives 3,  4,  and 5 because they allow
downgradient  ground-water  pollution  to spread more  than
Alternatives 3,  4, and 5.

Compliance with ARARs addresses whether or not a remedy will
meet  all  of  the  applicable  or  relevant   and  appropriate
requirements of other  environmental statutes and/or provide
grounds for invoking a waiver.  The  identified ARARs for this
site are listed in section 10.2.

Soils containing listed RCRA hazardous wastes, in Alternatives
3,  4,   and  5,   would   be   decontaminated   by  reducing
concentrations  of  contaminants  below that   of  health based
levels, and would thereby  be delisted under CERCLA by meeting
the substantive requirements of RCRA [40  CFR  260.20 and .22].

Alternatives  3,  4,  and  5  would  reduce  the  levels  of
contaminants in the ground-water  and comply with  the Safe
Drinking  Water  Act   (SDWA)  by  meeting  applicable  MCLs.
Alternatives 3A, 4A, and 5A would meet ground-water ARARs once
contaminant  concentrations in  the  portions  of  the  plume
located downgradient  of  the Site have  been reduced through
natural attenuation.

Treated water,  from the on-site extraction system described
for Alternatives  3,  3A,  4, 4A,  5 and  5A  would  be either
discharged to the POTW or  to the  Loosahatchie River Canal and
would meet the respective pretreatment or National Pollution
Discharge Elimination System (NPDES) permitting  limits.

Alternative 2 could meet  RCRA landfill closure  requirements
for closure with waste in place, however, ground-water ARARs
would   not  be   addressed.   The   'No-action*   alternative
(Alternative  1)  would   not   meet  RCRA  landfill  closure
requirements.

                           23

-------
The  LDRs are ARARs  for six  (6)  of the  eight  (8)  remedial
alternatives being considered (all except for 1 and 2).  Each
of the six  (6) alternatives would comply with LDRs through a
treatability  variance  or  by  meeting  BOAT  standards  or
treatability variance  levels  for both  on-site  and off-site
CERCLA response actions.

Reduction of Toxicity,  Mobility,  or  Volume is the anticipated
performance of the treatment technologies a remedy may employ.
Each  of  the Alternatives  except  1  and  2  employs  treatment
technologies  that   permanently   and  significantly  reduce
toxicity, volume, and mobility of ground-water contamination
by treating the plume and by eliminating contaminated s-oils
that act as a source for contaminant leaching.

Alternatives 3,  3A,  4,  4A, 5, and  5A  reduce the  volume and
toxicity of soil  and ground water contaminated with organic
contaminants and the mobility  of  contaminants in soil through
the  use  of  effective and  permanent treatment technologies.
Alternatives 3(and 3A), 4(and 4A),  and 5(and 5A)  each employ
thermal treatment to either permanently destroy pesticide and
other organic contaminants found  in the soils (3,  3A, 4, and
4A)  or  induce  physical separation  of pesticide  and other
organic  contaminants  from soils  (5  &  5A)   for  subsequent
treatment.  In Alternatives 5 and 5A, once physical separation
of organic  contaminants from site  soils  has been  achieved,
process water would be  further treated  in  the site wastewater
treatment facility.  The offgas would be further scrubbed by
passing it through beds of  activated carbon before release to
the atmosphere.

In Alternatives 3  (and  3A), 4  (and  4A),  and  5 (and 5A)  pump
and treat techniques would  be  employed  to remove contaminants
contained  in  the area  of attainment  to  levels  that  are
consistent  with  site  ARARS.    Less ground  water would  be
treated for Alternatives 3A,  4Ay  and 5A compared to 3, 4, and
5, rendering Alternatives  3A,  4A,  and  5A less  effective in
reducing the  toxicity,  mobility  and volume  of  contaminated
ground  water   (located downgradient   of  the  Site)  than
Alternatives 3, 4, and  5.  Alternatives 3A,  4A,  and 5A are,
however,  more  effective than  Alternative  2  at  reducing the
toxicity, mobility, and volume of contaminated ground water.

Under Alternative  2, access within  site boundaries would be
restricted  and  the RCRA cap  and soil  cover  would  serve to
prevent exposure to site soils and also  to reduce the mobility
of leachate through  the contaminated soils.   It  would also
restrict the use  of  contaminated ground  water.   But, these
remediation measures would  do  nothing to reduce the volume or
toxicity of the contaminated soil or ground water.

Alternative 1  would  provide  no reduction  in the  current

                           24

-------
contaminant  toxicity,  mobility or volume.   Risks  to  human
health would remain unacceptable.

Long-term Effectiveness and Permanence refers to the ability
to  maintain reliable  protection of  human  health and  the
environment  over time  once  cleanup  goals  have been  met.
Long-term effectiveness and permanence would be attained by
each of the  alternatives, except Alternatives 1 and 2, through
extraction  and treatment  of  contaminated  ground-water  and
thermal treatment of site soils.  Alternatives 3 (and 3A), 4
(and 4A) or 5 (and 5A) would each achieve the cleanup levels,
thereby  reducing   the   risk  associated   with  soils  and
ground-water at  the Site,  and would  thus  provide long-term
effectiveness  and  permanence.    These  Alternatives  employ
remediation  techniques  in  which  contaminated  media  are
significantly  decontaminated  through  thermal  treatment  of
contaminated soils and pump and treat of contaminated ground
water.   Long-term  maintenance  is  required  to insure  the
effectiveness of the RCRA cap and land-use controls that would
be  employed in Alternative 2.   The  "No Action" alternative
offers no long-term effectiveness or permanence.

Alternatives 3(and  3A),  4(and  4A),   and  5(and  5A)  provide
greater   long-term   effectiveness    and   permanence   than
Alternative 2  because these Alternatives would  restore site
ground  water  through treatment,  while  Alternative  2  would'
leave contaminated site ground water to naturally attenuate.
The  larger  the  volume of contaminated ground water  left
untreated the  greater the  probability that  people  could be
exposed to  contaminated  ground water.  Alternative 2  would
significantly  reduce  further  leaching of  contaminants from
soils to ground water through solidification of source soils
and placement in a RCRA cap.

Alternatives 3A,  4A,  and  5A would  be  less  effective than
Alternatives 3, 4,  and 5 because these Alternatives would not
actively remediate site ground water located downgradient of
the  site   and  thus   contaminated   ground  water  (located
downgradient of  the site)  would  be  left  to  migrate  to the
probable  discharge point, the  Loosahatchie  River  Canal,
untreated.

These Alternatives -3 (and 3A), 4 (and 4A), and 5 (and 5A) - would
each include provisions that would inhibit public exposure to
site ground water, that exceeds drinking water standards.  The
possibility of exposure  to contaminated ground water would
remain  (despite  the existence of ground-water-use controls)
should  ground-water-use  restrictions not  be complied with
and/or enforced.

Ground-water use controls would be required for up to 30 years
for  Alternatives 3,  4  and  5,   after which  drinking  water

                           25

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standards would be met as a result of the treatment program.
Alternatives 3A, 4A, and 5A would not achieve compliance with
drinking water standards until years  after Alternatives 3, 4,
and 5 achieve compliance,  and Alternative 2 would take longer
still.

Alternatives 2, 3(and 3A) , 4(and  4A) ,  and Stand 5A) would each
reduce  the   reasonable   maximum  potential   cancer  risks,
resulting  from site soils,   to  the same degree.   For these
Alternatives,  the  reasonable maximum risk  to future on-site
residents  from exposure  to contaminated soil  would be less
than IxlO"5; and the maximum  risk to off-site residents would
be less than IxlO'6.  Alternative 2 would reduce  the  risk from
incidental soil ingestion through solidification and capping
of contaminated soils.  In addition,  these alternatives would
reduce the maximum hazard index  from site-related pollutants
to less than one,  eliminating significant risks of  threshold
toxic effects.

Alternative  1  would do  nothing  to  eliminate risks  from
exposure to pesticides and arsenic contaminated surface soil
associated with the site, nor would it eliminate significant
risks  from  exposure  to pesticides   and  volatile organic
contaminants  in ground  water, if  it  is used.   These risks
include, for average exposure:

•  A future IxlO"4  upperbound individual risk of cancer from
   exposure to contaminated soil  to on-site workers;
   A current 2xlO"6 upperbound individual risk of cancer from
   exposure to chlordane in  off-site  soil and sediment  to
   Tennessee DOT workers;
•  A current hazard index  of  3 and a cancer risk  of 2xlO"5 from
   exposure  of children  to  contaminated  soil  in  off-site
   residential areas;
•  The  maximum upperbound  individual  cancer risk  would be
   IxlO"3 and the associated  non-cancer risk would be 46 to on-
   site children under the residential scenario.

Alternatives 3, 4,  and 5  would require no  long term on-site
maintenance  and  are  both  permanent,  assuming   that  the
solidification  of  arsenic  contaminated soil  is  permanent.
Alternatives  3A  and  4A  would not  significantly  reduce
contaminant concentrations to acceptable levels until dilution
and  natural  removal  mechanisms  have  reduced  downgradient
ground-water contaminant concentrations to acceptable levels,
after which they would be as permanent as Alternatives 3 and
Alternative 4.

Maintenance is required to insure the long-term  effectiveness
of the caps in Alternative 2.  Land-use controls must also be
enforced  for  Alternative 2  to  be  effective.   With proper
maintenance, caps  can be considered to  be permanent, and with

                           26

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proper monitoring and  enforcement,  land-use  controls  can be
considered to be permanent.   Because waste would be left in
place above health based levels, a review would be conducted
every 5 years under both Alternatives 1 and 2 for at least 30
years.  The other alternatives would require that evaluation
reports be prepared,  no less than every  five years, through at
least  the fifth year  following completion  of  ground-water
response action.

Short-term Effectiveness addresses the period of time needed
to achieve protection and any adverse impacts on human health
and the environment that may be  posed during the construction
and implementation period until cleanup goals are achieved.

Alternative 1 would  have little impact upon the surrounding
community,  workers  during  implementation  of  the  on-site
activities, and the environment and would require the shortest
period  of  time  to  implement.     Since  the  'No-Action'
alternative involves no on-site  activities other than limited
annual monitoring,  no risks to human health or the environment
is probable from performing site remedial action construction
activities.

Short-term risks  from Alternative  2  are higher  than those
associated with the  'No-action' alternative because  of the
risk associated with  consolidation of contaminated soil, risks
from  emissions  during  building decontamination, and risks
during installation,  inspection, and maintenance of the caps.

Alternative  2  would  require  approximately  24  months  to
excavate and solidify contaminated soil for construction of a
RCRA  cap  and  for decontamination,  demolition,  and  off-site
transportation  of  building  debris.     During  this  period
contaminated soil and  ground water would be  mapped.  Annual
ground-water monitoring would be carried out over  a thirty
year period.

Short-term risks during implementation  of Alternatives 3  (and
3A) are higher  than for Alternative 2 due  to  the increased
handling of contaminated material  during screening, packing
and long range,  transportation, along with off-site risks due
to emissions from the chosen treatment facility.

Alternative  5(and  5A)  would  present   greater  risks  than
Alternatives  1, 2,  and 3 (and  3A)  but  lower  than  that of
Alternative  4(and 4A)   because  contaminants would  not  be
brought  into  direct  contact  with  a  flame or with   fuel
combustion products  and  low off-gas flow.  The likelihood of
adverse impacts to the  community from the on-site  treatment is
considered very low.

The risks to the Mary Alice Drive  community, the DOT facility

                           27

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workers,  and the on-site workers  during implementation are
highest  for  Alternative 4  (and  4A),  due  to  the  on-site
treatment of contaminated soil and solid waste,  along with on-
site activities similar  to those associated with Alternative
3.    However,  the   likelihood  of  adverse  impacts  to  the
community  from these  activities is  considered to be low.
Excessive  air  pollution emissions  are  unlikely with  the
representative  air  pollution  control  measures  described.
Also,  such  emissions  can  be  detected  very   quickly with
standard  industrial  hygiene monitoring,  visible  emission
monitoring  for  fugitive  emissions,  and stack  monitoring
instruments   normally   associated   with  hazardous   waste
incinerators.     Based  on   past  experience  with  similar
incineration applications, maximum individual risks of  cancer
from  emissions associated with Alternatives  4 and  4A are
expected to be less  than 10"5.

For all treatment  technologies, workers are not  expected to be
adversely impacted.   This is because of personal protective
equipment,  implementation of  proper personnel  protection
procedures in accordance with OSHA regulations,  the design of
the process equipment, and proper operating procedures.

For Alternatives  4(and 4A) and  5(and 5A)  buildings would be
decontaminated  and  demolished   and  all  contaminated soil
treated  within  34   months  after  a  ROD  is  signed.    For
Alternative 3(and 3A), buildings would be decontaminated and
demolished  and all  contaminated  soil  would  be remediated
within 45 months of  signing a ROD.

Ground-water  remediation for Alternatives 3,  4,  and  5 will
require more than 30  years.    Ground-water  remediation for
Alternatives  3A,  4A,  and 5A  will take longer because of the
additional time required for dilution and removal mechanisms
to reduce contaminant concentrations  in downgradient ground
water to acceptable  levels.   In addition, follow-up ground-
water monitoring would occur for an additional five years to
verify the'effectiveness of the remedial action program.

Alternatives 3(and 3A), 4(and 4A), and 5(and 5A) incorporate
ground-water treatment and would require more than 30 years to
achieve the  remedial action  goals.   Alternative 3  (and 3A)
would require the most  time to  implement  soil remediation
activities (21-months), while Alternative 5 would require at
least  12  months.    During  the  implementation  of  these
alternatives the community would be protected from short-term
risk by dust control measures and  the  use of  institutional
controls on ground-water.

Implementability   is   the   technical   and   administrative
feasibility  of  a  remedy,   including  the   availability  of
materials  and  services  needed  to  implement  the   chosen

                           28

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solution.  Each of the alternatives are technically feasible
using technologies that have demonstrated prior performance,
except Alternative  5(and  5A),  which involves the  use  of an
innovative technology.

Alternatives 3(and 3A), 4(and 4A) and 5(and 5A), which involve
discharge via POTW or surface  water, may not be feasible if
the local POTW will not accept  discharge  from the Site and\or
NPDES  permitting  requirements  cannot   be  achieved.    All
components  of  each  of  the  alternatives use  commercially
available equipment and services.

Alternative 1 is technically the easiest to implement, but may
not be administratively feasible because  of the high risks to
public health associated with the contaminated soil, buildings
and ground water,  EPA's  legal  requirement and institutional
commitments to remediate such risks, and the concerns of the
public, State, and local officials.

Alternative  2  is  easier  technically  to  implement  than
Alternatives  3, 4,  and  5, because  it  involves  no treatment
technology.   However  it  may or  may not  be administratively
easier  to  implement  compared  to  alternatives  involving
treatment, because of  the  congressionally mandated preference
for alternatives involving treatment.

COSt

The total  Present  Worth  Costs for  each  of the alternatives
evaluated are as follows  (Indirect Costs Included) :
Alternative 1:  $249,023
Alternative 2:  $762,406
Alternative 3:  $41,348,205
Alternative 3A: $41,086,379
Alternative 4:  $21,924,186
Alternative 4A: $21,679,158
Alternative 5:  $ 12,170,167
Alternative 5A: $ 11,923,774


State Acceptance


EPA and  the  Tennessee Department of Health  and Environment
(State or TDHE)  have cooperated throughout the RI/FS process.
The State  has participated in the  development  of the RI/FS
through comment on  each of the planning  and decision documents
developed by  EPA, namely  the  RI Report,  FS Report, Proposed
Plan,  and the Draft ROD and through frequent contact between
                           29

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 the EPA and TDHE site project managers.  After review of the
 Draft ROD dated March 13, 1991 and the Final Draft ROD dated
 June 10, 1991, the State gave its concurrence on the selected
 remedy and  its contingency remedy in a  letter  to EPA dated
 June 26, 1991  (see Appendix E).   The  State has indicated that
 formal  concurrence  with  the  ABAP   ROD will  be  provided
 following its  review of the Final Draft ROD.

 The State commented that it would not accept the  'No Action'
 alternative nor Alternative 2.  The State agrees with EPA that
 neither alternative would  be protective of human health and
 the  environment.     TDHE   further   commented   that  these
 alternatives were  not  acceptable for the following reasons:
 (1) not consistent with the federal and state preference for
 a permanent remedy; (2) not consistent with State of Tennessee
 aquifer classification  for the  site  area;  (3)  inconsistent
 with non-point source initiatives; and (4) impractical due to
 long term maintenance  required  as result of hazardous waste
 being left at  site.

 The State  requested  in comments  submitted  on  the Draft ROD
 that it and EPA mutually concur  prior to- EPA granting an ARAR
 waiver on  the basis  of  technical impracticability.   State
 ARARs identified by TDHE are listed in section 10.2.

 Community Acceptance

 EPA received no formal comments  from  the residents comprising
 the  community  of  Arlington,  Tennessee  during   the  Public
 Comment Period.  However,  during the public^ meetiag. held on
January W^^S-f^fioate^town residents  in~arEeftdance expressed
 support for the selected remedy  presented by EPA.  During the
 conduct of th« RI/FS,  town  residents  frequently stated to EPA
personnel,  during visits  to  the Site,  that they would like the
 Site cleaneH up.

 EPA did receive comments at the close of the extended Public
Comment Period from identified site PRP's who have chosen to
 refer to themselves collectively as the  "Interested Parties'.
The  'Interested Parties'  notified  EPA that  it wanted  to
discuss the  development  of  a work plan to conduct another
                           30

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     RI/FS at the Site.  The. "Interested  Parties'  commented that
     they  felt  that  the EPA  Federally  funded  RI/FS  contained
     •numerous  errors   in  data   collection,  methodology,   and
     analysis' and further, that 'any remedy'  selected based on the
     EPA RI/FS would be 'arbitrary  and capricious and inconsistent
     with the National  Contingency  Plan.'  EPA has responded to the
     comments  raised  and  questions  posed  in  the. "Interested
     Parties''  Technical Comments on  the Final  RI/FSS  for  the
     Arlington  Blending  and  Packaging  Site  in  the  attached
     responsiveness  summary.
9.0 THE SELECTED REMEDY

     The Selected Remedy, Alternative 5,  involves  the  use of the
     innovative technology,  thermal desorption.  EPA has selected
     this remedy based upon consideration of  the requirements of
     CERCLA and the detailed analysis of  the  alternatives.   This
     thermal treatment method will  separate  organic contaminants
     from   site   soils  and   debris  through   vaporization  at
     temperatures of up  to  800°F.   Though the contaminants would
     not be destroyed,  the  off-gases would be  condensed  and the
     resulting  liquids  would   be   treated by  activated  carbon
     columns.   The collected condensates and precipitates will be
     treated before off-site disposal.

     An   estimated  24,000  yd3   of  chlorinated  hydrocarbons
     contaminated soils, namely pesticides, will be excavated at
     the Site.  These soils are mainly located  around the perimeter
     of the former process buildings, G and E, and adjacent areas
     that  received surface water  run-off from hot spots  where
     spills  occurred. ~   The   vertical   extent   of   pesticide
     contamination is  approximately 12  feet.   Once treated, the
     soils will be backfilled,  on  site,  in the excavation cells,
     regraded,   and revegetated.    Those  soils  containing  trace
     metals in excess  of soils  action  levels  will be solidified,
     on-site,  and disposed of in an off-site facility.

     Ground water will  be extracted via approximately 15 extraction
     wells.  These wells will  be  spaced  approximately  200  feet
     apart on a line running perpendicular to  the southern boundary

                                31

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of  the  site,  with  the  first well  located  near  the  CSX
Railroad.   The  extraction system  would have a combined flow
rate of  30  gallons per minute  (gpm).

Ground water would be pumped from the extraction wells through
buried polyethylene  piping to  a  run tank  in  the treatment
facility.  The run tank serves as  both a  regulator  for varied
influent  flow and a  repository for backwash effluent.  From
the first  run  tank,  water is  pumped  through a dual section
sandfilter.   The sandfilter  removes suspended  solids  via
mechanical  filtering.     The  purpose  of  the dual  section
sandfilter  is to  prevent  temporary system shutdown during a
backwash cycle.  The sandfilter is backwashed periodically to
remove accumulated sediment.

After the carbon adsorption units  have reached  their capacity
for adsorbing organic impurities,   the carbon granules can be
regenerated  through  off-site  reactivation.    Alternately,
disposable  carbon canisters can  be used and  then properly
discarded.  Effluent  from  the carbon adsorption units would be
discharged  to the Loosahatchie River  Canal  or local POTW in
compliance with NPDES or  facility pretreatment requirements.

9.1  Remediation  Goals

The goals of the Remedial  Action are:  (1)  to  reduce the risks
associated with long-term  exposure to contaminated on-site and
off-site soils;  (2) to prevent future ingestion of potentially
contaminated  ground  water;   (3)   to  reduce  migration  of
contaminants between site  soils   and ground-water;  (4)  to
restore ground water in the Unit II aquifer to  drinking water
quality;   and (5)   to reduce off-site contaminant migration
through the ground-water pathway.   Remediation of  the Site is
based on  risk-based  cleanup  levels that would significantly
reduce) endangennent to public health  and  the environment and
achieve  levels  mandated  by  Applicable  or  Relevant  and
Appropriate Requirements  (ARARs) for  the  Site.

Cleanup  levels  for  soil  and  sediment  were  based  on  two
criteria:   (1)  to reduce the  ingestion  and dermal contact
risks to  10'5 to  10"';  and  (2)  to protect  ground water and
                           32

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surface water from contaminants migrating from the soil.

Surface soil  and sediment cleanup levels were  derived from
risk calculations based on both oral ingestion of and dermal
exposure to contaminants  of  concern  found  in site soils.   A
more thorough  description of the derivation of  the surface
cleanup levels is presented in Chapter 6  of  the RI Report.  A
leachate model,  as described in  Chapter  5  of the RI report,
was developed to estimate the subsurface soil cleanup levels
necessary  to  protect  the  ground water from  contaminated
leachate containing the ground-water  contaminants of concern.
The more  conservative of the two  cleanup  levels  for each
contaminant was selected as the remedial goal.

The remediation  goals  for soil  and  sediment contaminants of
concern are listed in  Table  9.1.  This table summarizes the
soil action levels selected for the Site  on  the basis of both
direct risk exposure (Table 9.2) and ground-water protection
(Table 9.3).  The more conservative of the two concentration
levels for a given soil contaminant was selected for both on-
site and off-site  soils,  except  arsenic.  Arsenic typically
may be found in background soils at double-digit mg/kg levels.
In addition, evidence for its essential-element status at low
dosages and its likely  threshold toxic response  in humans
suggest that the concentrations  may  be overly conservative.
The surface  soil cleanup level for  arsenic was  chosen with
these factors in mind.  The approximate volume of soil above
the levels requiring remediation is 24,000 cubic yards.

Soil Cleanup Levels for Direct Exposure to Site Soils

Table 9.2 presents the surficial soil cleanup levels for the
contaminants of  concern  for  three levels in the risk range,
i.e.,  10~4, 10~5, and 10"'.'  These levels were  derived using the
oral and dermal exposure assumptions  (Table 6.4 and Table 6.5)
utilitsjd in the equation shown in Figure 9.1, to calculate the
resident upperbound risks for contaminants at the Site.

Figure 9.2 shows the grid areas that  exceed a chlordane action
level of 1 mg/kg for off  site areas and  10 mg/kg for on-site
areas.  These  levels represent a 10"' risk  level in current
                           33

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                                 ORAL


             Intake    =     CS  x  IR  *  CF x  Fl  *  EF x  ED

                                      Bw x  AT
                                DERMAL


   Absorbed dose    =   CS  x CF  x  SA  x  AF  x  Fl  x  ABS  x EF  x  ED
   (mg/kg-day)                          BW x  AT
   CS  =  Chemical Concentration In  Soil  (ng/kg)
   IR  =  Ingestion Rate   
-------
                                             MOTE;
        -.    -*—, , rv-A-rmu                      ON-STTC - *a«P rACUTY WOUNDS INSOC
        •  - SM0LE LOCATION                           OF TOCO) PROPERTY
           - SOILS IN GRID DETECTED ABOVE OFF SITE ACTION LEVEL FOR RESIDENTIAL USE (1 no/kg)
       ['...-. ,| - SOILS IN GRID DETECTED ABOVE ON-SITE ACTION LEVEL FOR POTENTIAL RESIDENTIAL USE (10 MG/KG)

                               FIGURE  9-E
   DELINEATION OF GRIDS CONTAINING  CHLDRDANE  CONTAMINATION
           IN SURFICIAL SOILS ABOVE  SITE  ACTION LEVELS
             ARLINGTON  BLENDING  AND PACKAGING  COMPANY
A f«->*              ARLINGTON, TENNESSEE

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                                       Table 9.1

                         Soil and Sediment Remediation Levels
                         Arlington Blending and Packaging Site
                                  Arlington, Tennessee
Surface Soil
Contaminant
(SI Foot BGS)
Arsenic
Chlordane
Endrin
Heptachlor
Heptachlor Epoxide
Pentachlorophenol

Concentration
Range (ug/kg)
2,600 - 370,000
82 - 390,000
26 - 70,000
2.8 - 920,000
15 - 20,000
360-130,000

Clean-Up Level
On-Site
25,000d
10,000*
2,700C
3,000*
2,000*
635°

(Ug/kg)
Off-Site
25,000d
l,000b
2,700C
300b
200b
635°
Sub-surface Soil
Contaminant
(>1 Foot BGS)
Chlordane
Endrin
Heptachlor
Heptachlor Epoxide
Pentachlorophenol
Sediment
Contaminant
Chlordane
Heptachlor

Concentration
Range (ug/kg)
43 - 120,000
37 - 20,000
3.4 - 34,000
4.5 - 170
810-8,500
Concentration
Range (Mg/kg)
70 - 4^,000
38 - 2,800

Clean-Up Level (^g/kg)
On-Site Off-Site
3300C 3300C
608C 608C
3,000* 300b
2,000* 200b
635° 635°
Qean-Up Level (ng/kg)
On-Site Off-Site
3300C 3300C
3,000C 300b
Notes: a
       b
       c

    10"J Health-based calculated standard for a resident exposure scenario
    10  Health-based calculated standard for a resident exposure scenario
    Value calculated by Region IV EPA using available empirical data and
    model analysis.
d » See RI Text for discussion of arsenic cleanup levels.

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                                      Table 9J

                  Soil Contaminant Levels (mg/kg) yielding 10"* to W4
          Upperbound Risk Levels for Worker and Resident Exposure Scenarios
                         Arlington Blending & Packaging Site
                                 Arlington, Tennesse

Contaminant
Arsenic
Chlordane
Heptachlor
Heptalchlor Epoxidc

ID"4
400
300
100
40
Adult

Worker
i
-------
                                     Table 9 J

                               Soil Cleanup Levels for
                             Ground-water Protection
                        Arlington Blending & Packaging Site
                                Arlington, Tennessee
                                      Surface Soil                     Deep Soil
Compound	Cleanup Level	Cleanup Level
Chlordane                             17 ppm                         3.3 ppm
Endrin                                2.7 ppm                        0.61 ppm
Pentachlorophenol                      0.64 ppm                        0.64 ppm

-------
residential  areas  and a. 10*s risk  level  for  surface soils
within the fenced area for potential  future resident children.
The remediation of surface soil to these levels of chlordane
will reduce  the  total  risk  from direct  exposure to all site
contaminants to acceptable levels.

Soil Cleanup Levels for Ground-water Protection

Calculations of  the  soil  cleanup levels necessary to assure
ground-water protection are  presented in Table  9.3.   These
soil cleanup levels  are  based on a  composite approach that
relies on both  empirical data and model analysis.   It accounts
for  the  fact  that  pesticide  contaminants  in  soilwater
percolating  out  of  the  upper  one  foot of  soil  (the most
contaminated zone)  are partially attenuated on soil material
between  the one  foot  depth  and  the  water  table.    The
assumption was made  that  contaminants in  the saturated zone
will initially have percolated out of the upper 1  foot of the
Site surface soils  into the  lower saturated zone.  Figure 9.3
depicts  the approximate  areal  extent  of subsurface soils
requiring remediation.

Ground-water Cleanup Levels

The goal of this  part of the remedial action is to  restore the
ground water to  its  beneficial  use,  which  is, at this site,
Class IIB,  a potential source of drinking water.   Based on
information obtained during the  RI,  and the  analysis of all
remedial alternatives, EPA and the State of Tennessee believe
that the seleqted remedy will  achieve this goal.  The ground-
water  contaminants of  concern  or  indicator  parameters  as
listed in Table 6.1 are those  compounds  which  have an MCL and
were detected in one or more samples at concentrations at or
above the MCL.  Ground-w*ater remedial levels and the range of
concentrations detected   for  each  indicator  parameter  are
listed in Table 9.4.

Ground-water contamination may be especially persistent in the
immediate  vicinity   of   the   contaminants'   source,  where
concentrations are relatively  high.   The  ability to  achieve
cleanup  levels  at   all  points  throughout  the  area  of
                           34

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$) - LOVWST DEPTH OCTECIID AKKC ACTION LML (FT) " m^/t^ - CHU*OANE
~] - APPROXIMATE AflCAL EXTENT Of CKUMMNC
SUBSURFACE SOL CONTAMINATION
FIGURE 9-3
LINEATION OF SUBSURFACE CHLORDANE SOIL CONTAMINATION
ABOVE SITE ACTION LEVEL
ARLINGTON BLENDING AND PACKAGING COMPANY
_m ARLINGTON, TENNESSEE
PA


-------
                                     Table 9.4
                          Ground-water Remediation Levels
                         Arlington Blending & Packaging Site
                                Arlington, Tennessee


Contaminant
Benzene
Chlordane
1,1-Dichloroethene
Endrin
Heptachlor Epoxide
Pentachlorophenol
Toluene
Xylenes
Ground-water*
Concentration
Range (ug/l)
0.67 - 7.95
0.20 - 28.6
1.2 - 26
0.084 - 0.63
0.05 - 0.20
2.2 - 1200
0.76 - 10
9.5 - 81

Clean.Up
Level (ng/l)
5.0d
2.0d
7.0d
0.2"
0.2d/0.04e
1.0C
2,000C
10,000C
Notes:  a = Detected values only
       b= Chlordane is considered a combination of the following: Chlordene,
          Alpha-Chlordane, Gamma-Chlordane, 1-Hydroxychlordane, Gamma-Chlordane,
          Trans-nonachlor, Alpha-Chlordene, Beta-Chlordene, Gamma-Chlordene,
           Heptachlor, cis-Nonachlor, and trans-Nonachlor
       c = Proposed MCL
       d= Current MCL
       c= Health-based clean-up levels

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attainment,  or   plume,   cannot   be  determined  until  the
extraction system has been implemented, modified as necessary,
and  plume response monitored  over time.   If  the selected
remedy cannot meet remediation levels,  which are a combination
of MCLs  and  proposed  MCLs,  at any  or all  of  the monitoring
points during  implementation,  the  contingency measures and
levels,  described  in  this  section,  may replace the selected
remedy and levels.   Such contingency  measures will,  at  a
minimum,  prevent further migration of  the plume and include a
combination   of   containment   technologies    (ground-water
extraction and treatment) and institutional controls.  These
measures are considered to be protective of human health and
the  environment,  and  are technically practicable  under the
corresponding circumstances.

The  selected remedy will include ground water extraction for
an  estimated period  of  30  years,   during which time  the
system's performance will be  carefully monitored on a regular
basis  and adjusted  as  warranted by the  performance  data
collected during operation.   Modifications  may  include any or
all  of the following:

a) at  individual  wells  where  cleanup  levels  have  been
   attained,  pumping may be discontinued;

b) alternating pumping  at wells  to eliminate  stagnation
   points;

c) pulse pumping to allow aquifer  equilibration and encourage
   adsorbed contaminants to partition into ground water; and

d) installation of additional extraction wells  to  facilitate
   or accelerate cleanun of the contaminant plume.

To ensure that cleanup levels continue to be maintained, the
aquif«r  will be  monitored at those wells  where pumping has
ceased on an occurrence  of at  least every 5 years following
discontinuation of ground water extraction.

9.2  Contingency Measures for Ground-water Remedial Action
                           35

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If it  is determined, on  the  basis  of  the preceding criteria
and the system performance data, that certain portions of the
aquifer cannot be restored to their beneficial use, any or all
of the following measures involving long-term management may
be  implemented  for an   indefinite  period of  time,  as  a
modification of the existing system:

a) low  level  pumping  would  be implemented  as a  long-term
   gradient control, or containment measure;

b) chemical-specific ARARs would be waived for the cleanup of
   those portions  of  the aquifer based  on  the  technical
   impracticability   of   achieving   further   contaminant
   reduction;

c) institutional  controls would be provided/maintained  to
   restrict access  to  those portions  of  the  aquifer  which
   remain above health-based levels,  should this  aquifer be
   proposed for use as a drinking water source;

d) continued monitoring of specified wells; and

e) periodic reevaluation of remedial technologies for ground
   water restoration.

The decision  to  invoke any or all  of  these measures may be
made during a  periodic  performance  evaluation (5 year review)
of the remedial action which will  occur  at least  once every
five years  or  at  the conclusion  of  remedial action under this
ROD,   which would  occur  after 30 years  of  ground-water
remediation.   Should  EPA decide   that  an ARAR  waiver  is
appropriate, due  to non-compliance with  an ARAR or ARARs as
the result of technical impracticability from an engineering
perspective, it will notify and  seek to gain concurrence from
the State prior to granting such a waiver pursuant to CERCLA
Sections 121(d)(4)   and   (f)(2).    Also,  an  Explanation  of
Significant Differences would be issued to inform the public
of the details of these actions, should they occur.

9.3  Contingency Measures for Soils Remedial Action
                           36

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 Should   implementation  of  the  thermal  desorption  method
 (Alternative 5) prove ineffective as a soils remedial action
 by not meeting soil cleanup levels, Alternative 4 would be the
 Agency's Preferred Alternative.  All  aspects of  Alternative 4
 are identical to those of  Alternative 5,  including the method
 used to remediate Site ground  water,  except that contaminated
 soils,  solid waste from ground-water treatment and building
 decontamination (and demolition) , and other residuals would be
 remediated using on-site  incineration.

 An on-site  incinerator  with a dry  scrubber,  baghouse,  flux
 force  condenser,   a  high energy  collision  scrubber  (using
 sodium hydroxide for acid neutralization) and an entrainment
 separator for  demisting is  the thermal treatment system for
 Alternative 4.   The  treated  soil and solid waste will  be
 tested  for  residual contamination and if  found to  be below
 action levels,  will be used  as clean  backfill on-site.  Those
 soils containing organics  in levels that  exceed  action levels
 would be incinerated again.  This process  would continue until
 organics  contamination in  soils  is  below  action  levels.
 Appropriate moisture would  then  be  added to  treated soils
 prior to on-site backfilling.   Also,  like Alternative 5,  this
 alternative involves  on-site  solidification of soils which
 contain  significant levels of trace  metals,   in excess  of
 background.  Solidified soils  would be disposed  of in an off-
 site  facility.   The  incinerator  and  pollution control  and
 material  handling  equipment   would  be  set  up within  the
 boundaries of the site.

 Flue gas from the furnace would pass through an afterburner,
where combustion of organic vapors would take place, through
a dry  scrubber where  blowdown from the scrubber  would  be
 evaporated,  a  baghouse, and  finally through  a conventional
 quencher/saturator followed by a forced  flux condenser.

Wastewater from the  scrubber  would  pass  through a clarifier
 and a chemical  addition  tank where additional  caustic would be
added  for  HCL removal.   Blowdown  water from  the  scrubber
clarifier system would be treated using chemical precipitation
 to  remove  arsenic  (if  it  is  cationic)  and  other  toxic
materials in a chemical treatment system  and  settling tank
                           37

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     equipped  with  a chain  drag  for  sediment  removal.    The
     precipitated solids would also be  fed  into the  cement  mill,
     with fly ash and ground bottom ash to  make concrete blocks.
     The treated water would be returned to the scrubber and to the
     ash quench  system and used  for solidification.   Some excess
     blowdown water would be treated by distillation in  the flue
     gas spray dryer.

     Decontamination  fluids would be collected separately at the
     site.   These  liquid wastes  would be tested,  treated in the
     clarifier  used  for the  scrubber  water  and   used in  the
     scrubbing   process.   Once   incineration   activities   were
     completed,  remaining waste water would be disposed of through
     the ground water  treatment system and discharged to  the
     Loosahatchie River Canal or the local POTW, after verification
     that it meets applicable criteria for discharge.  Pilot-scale
     testing would be necessary  prior  to implementation  of full-
     scale  treatment  on-site  to   determine   primary  design
     requirements.

     Alternative  4,  like  Alternative  5,   utilizes  a   thermal
     treatment   to   remediate   contaminated   Site    soils,   but
     Alternative 4 would involve  the use  of an on-site incinerator
     which would destroy the  organics  present in site soils and
     identified  solid  wastes   rather   than  cause   a   physical
     separation of organics from the  soils.  The use of thermal
     treatment of soils  will  ensure that contaminant levels are
     permanently reduced,  thus  eliminating a  current source of
     ground-water contamination.   Both Alternatives  would utilize
     restrictions  on  land  and  ground-water  use   during  site
     remediation periods.  Tables 9.5  and 9.6 provide a breakdown
     of the cost estimates for Alternative  5 and  Alternative 5A,
     respectively.
10.0  STATUTORY DBTKRMIMATIONS

     10.1  Protection of Human Health and Environment

     Alternatives 4 and 5 provide  approximately the same overall
     protection to the health of individuals and to the environment

                                38

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                                        TABLE 9.5

                           COST ESTIMATE  ALTERNATIVE  5
   SOIL EXCAVATION,  ON-SITE  LOW TEMPERATURE  THERMAL TREATMENT  OF
     CONTAMINATED SOIL AND  OFF-SITE INCINERATION  OF  CONCENTRATED
   RESIDUE,  AS WELL AS ACTIVATED CARBON TREATMENT OF  GROUNDWATER
             AND  SURFACE WATER  DISCHARGE OF  TREATED EFFLUENT
TEAR  1 COSTS

   1. New Welt Installation (4)
      A.  Installation I completion                                               t    9,154
      B.  ChMHcal anelysle of cutting*                                            S    3,560
      C.  Stap draw down tests                                                   •    8,926

   II. GroundMater Modalfng                                                       S    4,860

  III. Soil/Sediment Monitoring                                                   f  188,567

   IV. H I S Monitoring of RA Activitits/Environmntal Impact Testing (Tr 1)             S  277,268

   V. Environmental Study and Report of Using Incinerated Ash as Backfill               S   34,200

   VI. Building Decontamination and Demolition
      A.  Sand blast/Steam clean buildings in contaminated areas                       $   15,575
      B.  Demolish buildings in contaminated areas                                  S   27,762
      C.  Remove concrete slabs                                                   *   19,500
      0.  Off-site disposal of solid wastes                                        S   18,780
      E.  Off-site disposal of liquid waste                                        S   20,650

  VII. Obtain ROW, Install Pipe System to Canal                                      S   45,556

 VIII. Excavate, Screen, and Stockpile Contaminated Soil                               S  384,880

   IX. On-Site Thermal Separation
      A.  Mob, de-mob, hook-up, and pilot test                                      S  475,000
      B.  Thermal Separator                                                      S6,000,000

   X. Off-Site Residue Incinerator                                                S   20,000

   XI. Test, Backfill, and Revegetate Treated Soil                                    S  384,797

  XII. Pump and Treat Grounduater (Yr 1)                                            S  190,353

 XIII. Establishment of Land Use Controls                                           S   50,000

  XIV. Five-Year Report (Yr 1)                                                    <   12,000

   XV. Continuous GroundMter Level Recording ytr 1)                                  S    5,849

  XVI. Annual R«vie*/Hydrologic Summary Report (Yr  1)                                 S   12,000

 XVII. Annual Stapling of 13 Wells (Yr 1)                                           S   17,600

XVIII. BiomonitoHng (Yr 1)                                                       S   27.000



                                                 TOTAL COST FOR YEAR 1 »         18,253,837

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                          TABLE  9.5  (continued)

                      COST  ESTIMATE ALTERNATIVE  5
SOIL  EXCAVATION,  ON-SITE LOW TEMPERATURE THERMAL TREATMENT  OF
 CONTAMINATED SOIL  AND OFF-SITE  INCINERATION OF CONCENTRATED
RESIDUE,  AS WELL AS ACTIVATED  CARBON TREATMENT OF  GROUNDWATER
         AND SURFACE  WATER DISCHARGE OF TREATED  EFFLUENT
   ADDITIONAL OPERATIONS AND MAINTENANCE COSTS (YR 1*)             Present Worth (P/A,i,n)


    IV.    HIS Heritor ing of RA Activities/
          Environments! Inpact Testing (Tr 2)                        *  112,566

     V.    Quarterly Bioaonitoring (Yr» 2-30)                        S  181,693

    XII.    Piup and Treat Ground*ater  (Yr 2)                         *  134,921

   XIII.    Pimp and Treat Groundwater  (Yr« 3-30)                      S 1,042,860

    XIV.    Five-Year Rtport (Yrs 5, 10, IS, 20, 25, 30)                 S   32,133

    XV.    Continuous Crovnduattr Ltvtl Recording (Yrs 2-5)              S   11,055

    XVI.    Annual Rwitw/Hydrologfc Sunary Rtport (Yrt 2-5)             S   4,536

   XVIt.    Annual Sampling of 13 U«U« (Yr« 2-5)                      »   45.492


                                    TOTAL PRESENT WORTH COST >     $ 1,605,256


                                    TOTAL ALTERNATIVE COST   •     S 9,859.093
                                    (without  indirect cost)
                                    Indirect Cost* (28X)    •     S 2,311,074


                                    TOTAL ALTERNATIVE COST   >     $12,170,167

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                                        TABLE 9.6
                           COST ESTIMATE  ALTERNATIVE  4
        EXCAVATION,  ON-SITE THERMAL  TREATMENT,  SOLIDIFICATION,
            ON-SITE  BACKFILLING,  LAND-USE  CONTROLS,  ACTIVATED
     CARBON GROUNDWATER TREATMENT AND DISCHARGE TO  SURFACE  WATER
                    ARLINGTON BLENDING  AND PACKAGING  SITE
                                ARLINGTON,   TENNESSEE
TEAR 1 COSTS
    t. New W«U Instillation (4)
      A.  Installation I carpittion                                             S     9,154
      B.  Chemical analysis of cuttings                                          S     3,560
      C.  Step draw down tests                                                  $     8,926
   II. Groundwater Modal ing                                                     S     4,860
  III. Soil/Sediment Monitoring                                                  S   188,567
   IV. HIS Monitoring of RA Activities/Environwntal Impact Testing (Yr 1)           S   277,268
    V. Environmental Study and Report of Using Incinerated Ash as Backfill             S    34,200
   VI. Building Decontamination and Demolition
      A.  Sand blast/Steam clean buildings in cootmi rated areas                     S    15,575
      B.  Demolish buildings in contaminated areas                                 I    27,762
      C.  Remove concrete slabs                                                 S    19,500
      D.  Off-site disposal of solid wastes                                      S    18,780
      E.  Off-site disposal of liquid waste                                      S    20,650
  VII. Obtain ROU, Install Pipe System to Canal                                    S    45,556
 VIII. Excavate, Screen, and Stockpile Contaminated Soil                             S   384,880
   IX. On-Site Thermal Treatment
      A.  Mob, de-mob, hook-up, and pilot test                                    S 1,500,000
      B.  Incinerator                                                         $12,606,000
      C.  Scrubber operation*                                                  S   138,600
    X. On-Site Solidification of Ash                                             S   651,424
   XI. Test, Backfill, and Revegetate Treated Soil                                  S   384,797
  XII. Pump and Treat Groundwater (Yr 1)                                          S   190,353
 XIII. Establishment of Land Use Controls                                         «    50,000
  XIV. Five-Teer Report (Yr 1)                                                  S    12,000
   XV. Continuous Oroundwater Lev*I Recording (Yr 1)                                S     5,849
  XVI. Annual MvteWtydrologic Summery Report (Yr 1)                               S    12,000
 XVII. Annual tammlfnf of 13 Walls (Yr 1)                                         S    17,600
XVIII. Blomonitoring (Yr 1)                                                     «    27.000

                                                 TOTAL COST FOR YEAR 1 •       (16,654,861

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                             TABLE  9,6  (continued)
                         COST ESTIMATE  ALTERNATIVES
       EXCAVATION,  ON-SITE THERMAL TREATMENT,  SOLIDIFICATION,
           ON-SITE BACKFILLING,  LAND-USE CONTROLS,  ACTIVATED
    CARBON GROUNDWATER  TREATMENT AND  DISCHARGE TO  SURFACE WATER
                  ARLINGTON BLENDING  AND PACKAGING  SITE
                             ARLINGTON,  TENNESSEE
ADDITIONAL OPERATIONS AND MAINTENANCE COSTS 
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 (cancer risks from exposure  to soil of less than IxlO'5 for on-
 site soils and 1x10"* for off-site soils, no significant risks
 of threshold toxic effects under maximum plausible exposure,
 and no significant risk (HI  less than 1)  of adverse effects on
 the environment).  The baseline risk assessment concluded that
 the primary health risks  posed  by the Site were due to long
 term exposure  to  both  contaminated surface soils and to the
 ingestion of ground  water,  both beneath and downgradient of
 the Site.

 Both Alternatives 4 and 5 involve on-site thermal  treatment of
 soils contaminated with organics and long-term pump and treat
 measures  to  reduce  contaminants  in  site  ground  water.
 Excavation and subsequent  thermal treatment of the surface and
 subsurface soils will prevent human contact and also eliminate
 the probable  source for  ground-water contamination  due to
 leaching.   Ground water  use restrictions will be  imposed
 during the ground-water remediation until  health based levels
 have been restored.

 Implementation  of Alternatives  4  and  5  would impact  the
 residential community and workers adjacent to the Site due to
 the on-site  activities resulting  from  operation  of  thermal
 treatment and solidification facilities,  the increased traffic
 in support  of  remediation  activities and possible fugitive
 emissions.     Adverse  impacts  to public health and  to the
 environment as the result of these alternatives are  felt to be
 insignificant.

 10.2 Compliance with Applicable  or Relevant  and Appropriate
     Requirement*

 Both Alternatives  4  and  5  attain all ARARs that  have been
 identified as applicable  to actions that  would  occur as the
 result of  implementation  of the  selected remedial  action.
 The following are major applicable or relevant and appropriate
 requirements  (ARARs),  risk-based  levels,  and  other  "to be
 considered"  (TBCs)  being  met/utilized  for  the  specific
 components of the remedial alternative:

Contaminant-Specific ARARS

                           39

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The  Safe  Drinking Water  Act  (SDWA)  promulgated  National
Primary  Drinking  Water Standard Maximum  Contaminant Levels
(MCLs) (40 CFR Part 141) for the following contaminants:  (1)
benzene; (2)  chlordane;  (3) chromium; (4) 1,1-DCE;  (5) endrin;
(6) heptachlor epoxide; and (7) selenium.

The  Clean Air  Act  (CAA)  consists  .of  three programs   for
requirements that may be ARARs: National  Ambient Air Quality
Standards  (NAAQS)  (40  CFR   Part   50),   National  Emissions
Standards for Hazardous Air Pollutants  (NESHAPs)  (40 CFR Part
61), and New Source Performance Standards  (NSPS)  (40 CFR Part
60) .

Location-Specific ARARs

RCRA Subtitle C regulates the treatment, storage, and disposal
of hazardous waste from generation through ultimate disposal.

Land Disposal Restriction (40 CFR Part 268)  The Hazardous  and
Solid Waste  Amendments  (HSWA), signed on November  8,  1984,
include specific provisions restricting the land disposal of
RCRA hazardous wastes.

Delistina RCRA Wastes  (40  CFR 260.20 and .22)  outlines  the
procedures for delisting RCRA  wastes for  an off-site CERCLA
response action.

Standards Applicable to  Transporters of  Hazardous Waste  (40
CFR Part  263)  are applicable  to off-site transportation of
hazardous waste from the Arlington Blending Site.

Standards  for  Owners  and  Operators  of  Hazardous  Waste
Treatment. Storaoe and Disposal Facilities  (TSDFs)  (40  CFR
Part 264) are applicable to remedial actions taken at  the Site
and to off-site facilities  receiving hazardous waste  from  the
site  for treatment and/or disposal  and  have a  RCRA Part  B
permit if the site is not a Federally ordered  CERCLA cleanup.

DOT Rules for Hazardous Materials Transport (49 CFR Parts  107
and 171-179)  regulate  the  transport of hazardous materials,
including packaging, transport equipment,  and placarding.
                           40

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The  Clean  Water Act (CWA),  as amended, governs point-source
discharges   through   the   National    Pollutant   Discharge
Elimination  System  (NPDES),  discharge or  dredge  or  fill
material, and oil and hazardous waste  spills to U.S. waters.

Tennessee Water Quality Criteria Control Act, Tennessee Code
Sections 69-3-104, '(1) Chapter 1200-4-3; used to determine the
permissible conditions of waters with respect to pollution and
preventive  or   corrective   measures   rec^uired  to  control
pollution in various waters  and  (2)  Chapter  1200-4-6-.05; use
to classify ground water and  water quality  standards:

•To Be Considered"  (TBCs)

Primary Drinking Water Standard Proposed Maximum Contaminant
Levels  (Proposed MCLsl found in the  May  22,  1989 Federal
Register  for  the  following:    (1)  pentachlorophenol;  (2)
toluene; and  (3) xylenes:

Reference  Dose  (RFD),   is   an  estimate   (with  uncertainty
spanning perhaps an order of magnitude) of a daily exposure to
the human population (including sensitive subgroups) that is
likely  to be  without  an  appreciable risk  of deleterious
effects  during  a lifetime.   Interim  Final Risk  Assessment
Guidance for Superfund  (Human  Health Evaluation Manual Part A.

EPA Health Advisories guidelines developed  by the EPA Office
of Drinking  Water for chemicals that  may be intermittently
encountered in public water supply systems.

EPA Ambient Water Quality  Criteria  (AWQC)  are guidelines that
were developed  for  pollutants in  surface waters pursuant to
Section 304 (a) (1) of the, Clean Water Act.

Carcinoxrenic Potency Factors  (CPFs)  are used for estimating
the lifetime probability (assumed 70-year lifespan)  of human
receptors contracting cancer as  a  result of  exposure to known
or  suspected carcinogens.    Interim   Final  Risk  Assessment
Guidance for Superfund  (Human  Health Evaluation Manual Part A.

EPA's Ground-water Protection Strategy (EPA, 1984) policy is

                          41

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to restore ground water to its beneficial uses within a time
frame that is reasonable.  Ground water beneath and adjacent
to the Arlington Blending Site is classified as a Class II A
aquifer.

RCRA Guidance Manual for Suboart G. Closure and Post Closure
Standards (Volumes I-V of the  EPA Hazardous Waste Incinerator
Guidance Series) EPA-530-SW78-010.

10.3 Cost-Effectiveness

Both the Selected Remedy, Alternative 5, and the Contingency
Remedy,  Alternative 4, were chosen because they provided the
best  balance  among  the  criteria  used  to  evaluate  the
alternatives  considered in  the Detailed  Analysis.   These
alternatives were found to achieve both adequate protection of
human health  and the environment and  to meet  the statutory
requirements  of  Section  121  of  CERCLA.    The  costs  of
Alternatives 5 and 4,  including indirect costs at 28% and 22%
of their  present worth  capital costs, are  $12,170,200  and
$21,924,100, respectively.

10.4 Utilization  of  Permanent  Solutions  and  Alternative
     Treatment Technologies or Resource Recovery Technologies
     to the Maximum Extent Practicable

Alternative  4  and Alternative  5  both utilize a  thermal
treatment to remediate contaminated Site soils.  The Selected
Remedy,  Alternative 5, would remove organic contamination from
site soils by volatilization to achieve physical separation,
while Alternative 4  would involve-  the use  of  an on-site
incinerator which would destroy the organics present in site
soils and  identified solid  wastes.    The  use of  thermal
treatment of  soils will' ensure that  contaminant levels are
permanently  reduced,  thus eliminating a current  source  of
ground-water contamination.  Both Alternatives would utilize
carbon  treatment  of   extracted   ground  water  to  remove
contaminants that are present.

Use  of   thermal  treatment   and  carbon   treatment  would
permanently  reduce the  volume,  toxicity,  and  mobility  of
                           42

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contaminants  in both  ground  water and  soils  at  the  Site.
Similarly, Alternatives 4  and  5  would provide  for long-term
protection against exposure to site contaminants.

10.5 Preference for Treatment as a Principle Element

Both   alternatives   incorporate   the   use  of   treatment
technologies to remediate contaminated media at the Site as a
means  of  reducing to  the  extent practicable  the principle
threats to future  long  term contact through dermal  exposure to
and ingestion of contaminated site media.
                           43

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        APPENDIX B
State Letter of Concurrence

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                    TENNESSEE DEPARTMENT OF CONSERVATION

                               Doctors Building
                               706 Church Street
                           Nashville, TN  37247-3801
June 26, 1991
Mr. Derek Matory
Remedial Project Manager
North Site Management Section
United States Environmental Protection Agency
345 Courtland St., N.E.
Atlanta, GA  30365

Re:  Review  of  the Draft  Record of  Decision  for  the  Arlington  Blending and
     Packaging Site, TDSF #7^-503

Dear Mr. Matory:

Division of  Superfund personnel  have  reviewed  the  Draft Record of Decision for
the Arlington Blending  Packaging Superfund Site in  Arlington,  Shelby, County,
Tennessee dated 6/10/91.  The major components of the remedy include:

     *   Excavation of an estimated 24,000 cubic yards of contaminated soil;

     *   Decontamination  of  contaminated  soil using  on-site  ex-situ thermal
         desorption process;

     *   Dechlorination of  the  condensed organic liquid  and  off-site disposal
         of  the concentrated organic liquid;

     *   Placement of the treated soil into the excavated areas;

     *   Activated carbon  treatment of  the  contaminated ground  water on-site
         and within the plume defined off-site;

     *   On-site solidification  of  soils  containing levels of  arsenic  and/or
         other trace metals above background for off-site disposal.

A contingency remedy substitutes  on-site thermal destruction  treatment for the
on-site thermal dtaorption  if treatability studies  indicate thermal desorption
if not effective.

The  Division  faala  that  the  selected  remedy  adequately  addresses   State
concerns  and  is  appropriate  for   this  site  based   on   the  existing   known
conditions.

Sincerely,
Ralph M. Sinclair, Ph.D.
Director
Tennessee Division of Superfund

RMS/F6021175

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      ATTACHMENT A
Comment Response Number 2

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   , 7 |    UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
   - V
                               REGION IV
                        ENVIRONMENTAL SERVICES DIVISION
                           ATHENS. GEORGIA 3O6 1 3

MEMORANDUM

DATE:     June 10, 1991

SUBJECT:  EPA Method Specifying Chlordane Congeners
                                     ^*  *• —     -»        *•
FROM:     E. William Loy, Chemist    C . ^/'~t£b-
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                                 METHOD 8080

                     ORGANOCHLORINE PESTICIDES AND PCBs


1.0  SCOPE AN0 APPLICATION

     1.1  Method 8080  1s  used  to  determine  the  concentration   of  various
organochlorlne pesticides and  polychlorinated  biphenyls  (PCBs).      Table  1
indicates compounds that may be determined by this method and lists  the method
detection limit for  each  compound  1n  reagent  water.     Table 2 lists  the
practical quantltatlon limit (PQL) for other matrices.


2.0  SUMMARY OF METHOD

     2.1  Method  8080  provides   gas   chromatograpMc  conditions  for  the
detection of ppb levels of certain  organochlorlne pesticides and PCBs.  Prior
to the use of this  method,  appropriate  sample extraction techniques  must be
used.  Both neat and diluted organic liquids (Method 3580, Waste Dilution)  may
be analyzed by direct Injection.  A  2-  to 5-uL sample 1s Injected  into a  gas
chromatograph (GC) using the solvent flush  technique,  and compounds in the GC
effluent are detected by  an  electron  capture  detector  (ECD) or  a halogen-
specific detector  (HSD).

     2.2  The sensitivity of  Method  8080  usually  depends  on  the level of
Interferences rather  than  on  Instrumental  limitations.    If Interferences
prevent detection of  the  analytes,  Method  8080  may  also  be performed on
samples that have undergone cleanup.  Method 3620, Florlsil Column Cleanup, by
Itself or followed by Method  3660,  Sulfur  Cleanup, may be used to eliminate
Interferences 1n the analysis.


3.0  INTERFERENCES

     3.1  Refer to Methods  3500 (Section  3.5,  1n  particular), 3600,  and 8000.

     3.2  Interferences by   phthalate   esters   can  pose  a  major   problem  in
pesticide determinations when   using   the  electron  capture  detector.  These
compounds generally  appear  in   the chromatogram   as large  late-eluting peaks,
especially  In the  15X  and  50%   fractions  from  the Florlsil cleanup.  Common
flexible plastics  contain varying amounts of  phthalates.  These phthalates are
easily  extracted or  leached from  such  materials  during  laboratory  operations.
Cross contamination  of  clean   glassware   routinely  occurs  when plastics are
handled during  extraction steps,   especially   when solvent-wetted surfaces are
handled.   Interferences  from   phthalates  can best   be minimized  by  avoiding
contact with any  plastic   materials.     Exhaustive   cleanup   of reagents and
glassware may be   required   to   eliminate  background  phthalate contamination.
The  contamination  from phthalate  esters   can  be completely eliminated with a
microcoulometric or  electrolytic conductivity detector.
                                   8080 - 1
                                                          Revision
                                                          Date  September 1986

-------
D, a chlordane analog; G, coelutlon  of ds-nonachlor and "Compound  K,"  a
chlordane Isomer.  The right "shoulder"  of  peak  F 1s   caused  by trans-
nonachlor.

          7.6.4.1  The GC  pattern  of  a  chlordane  residue may differ
     considerably from that of the  technical  standard.   Depending on  the
     sample substrate and Its history,  residues of chlordane can consist
     of almost  any  combination  of:    constituents  from the  technical
     chlordane;  plant  and/or  animal   metabol1t1es;  and  products   of
     degradation caused  by  exposure  to  environmental  factors such as
     water and sunlight.  Only  limited Information 1s available on  which
     residue GC patterns are likely to  occur 1n which samples types,  and
     even this Information may not be applicable to a situation  where  the
     route of exposure 1s unusual.  For example, fish exposed to a recent
     spill of  technical  chlordane  will  contain  a residue drastically
     different from a  fish  whose  chlordane  residue was accumulated by
     ingestlon of  smaller  fish  or  of  vegetation,  which  in turn  had
     accumulated  residues  because  chlordane  was   1n  the  water  from
     agricultural runoff.

          7.6.4.2  Because  of  this   inability  to   predict  a chlordane
     residue GC  pattern, it is not  possible to prescribe a  single method
     for  the quantltatlon of chlordane  residues.  The  analyst must Judge
     whether or  not the  residue's  GC  pattern 1s  sufficiently similar to
     that of a technical chlordane   reference  material  to use the latter
     as a reference standard for quantltatlon.

          7.6.4.3  When  the chlordane  residue does not  resemble  technical
     chlordane,   but   instead    consists   primarily   of   individual,
     Identifiable peaks,  quantltate   each  peak   separately against the
     appropriate reference materials  and   report the  Individual  residues.
      (Reference  materials  are   available  for  at   least   11   chlordane
     constituents, metabolites or  degradation products  which may occur  in
     the  residue.)

          7.6.4.4  When  the GC pattern  of  the  residue resembles that  of
     technical chlordane, quantltate chlordane   residues by  comparing the
     total  area  of  the  chlordane  chromatogram  from   peaks A  through F
      (Figure 9a) 1n   the  sample   versus   the   same   part  of the standard
     chromatogram.  Peak G may be  obscured  in a  sample  by  the presence  of
     other  pesticides.     If  G   1s  not  obscured,   Include  it   in the
     measurement for  both  standard and sample.   If the  heptachlor epoxlde
     peak Is  relatively  small,  Include 1t  as part of the  total  chlordane
     aret  for  calculation   of   the   residue.     If  heptachlor   and/or
     heptachlor  epoxlde  are   much   out  of proportion   as  in  Figure 6j,
     calculate these  separately  and  subtract  their areas  from  total  area
     to-give a corrected chlordane  area.   (Note  that  octachlor epoxlde,
     metabolite  of  chlordane,   can   easily  be  mistaken   for  heptachlor
     epoxide on  a nonpolar  GC column.)
                              8080 - 19
                                                     Revision      0
                                                     Date  September 1986

-------
      g' -deral Register / Vol. 51. No. 247  /  Wednesday. December 24.  1986 / Rulea  and Regulations -46665
          ACTION LEVELS TO REMAIN
        IN EFFECT—Contmo«j
                             Existing
                          •"•'"  and
                           >, Recom-
Commodities .'.' ,'

Egg* 	
Fai. meat, and meal byproducts of
cattle, goats, horses. she«p.
swino. poultry, and rabbits (fat
Fats and oils (animal and vegeta-
ble) (animal feed) 	
Figs 	 _ 	 	
Hay . 	
Milk, raw (fat basis) 	 , 	
Small fruits and berries • 	 	

Action
'Levels
(ppm)
Aldhn/
DwWnn
005
• 0.03
' -
0.3
. 0.3
0.05
0.03
0.3
0.05
0.1

  » Refer to 40 CFR 180.34(0 for the list of
commodities  covered by  the  crop group
"small fruits and berries."

  The commodity definition "Fat of
calves, cattle, chickens, ducks, geese.
goats, horses, rabbits, sheep, swine, and
turkeys," which was listed in the
proposed rule, has been modified as
shown in Table 3 above to agree with
the commodity definition used by FS1S.
  The proposal to revoke the tolerances
for aldrih and dieldrin discussed action  •
levels for the.crops blackberries.' •• •' •-••'••
blueberries, boysenberriea. currantsr -
dewberries, elderberries, gooseberries,-
huckleberries, loganberries, and    •
raspberries; FDA now indicates that the
current FDA Compliance Policy Guide,
which lists pesticide action levels, uses
the crop group  name "small fruits" in
lieu of the individual crop names;
therefore. FDA has requested that EPA
revise its recommendations for action •
levels for aldrin and dieldrin to  reflect
the crop group rather than the individual
crops which comprise the group. The
crop group name, as it appears in the
current 40 CFR 180.34(0.  is "small fruits
and berries."
  The proposal to revoke the tolerances
for aldrin and dieldrin «lso discussed
the action levels of 0.3 ppa for residues
in butter and manufactured dairy   •  ••.
products, as well as raw Ailk. FDA now
indicates that  the action level in raw
milk*will automatically apply to any
processed milk product and. therefore,
separate action levels for the processed
products such  as butter are not
necessary. EPA is recommending that
FDA retain the current action level of 0.3
ppm for residues of aldrin and dieldrin
in raw milk.
   As discussed earlier In this document.
EPA is not making a recommendation to
FDA at this time regarding the current
0.3 ppm action level for the sum of aldrin
 and dieldrin residues in  fish (edible
 portion).
   Any person adversely affected by this
 regulation revoking the tolerances may.
 within 30 days after the date of
 publication of this regulation in the
 Federal Register, file written objections
 with the Hearing Clerk, at the address
 given above. Such objections submitted
 must specify the provisioha of the ..  .
 regulation deemed objectionable and the
 grounds for the objection!. If a hearing  . •
 is requested, the objections must state
 the issues for the hearing. A hearing will
 be granted if the objections are
 supported by grounds legally sufficient
 to justify the relief sought.
   This document has been reviewed by
 the Office of Management and Budget as
 required by section 3 of Executive Order
 12291.
   In order to satisfy requirements for
 analysis as specified by Executive Order
 12291 and the Regulatory Flexibility Act.
 the Agency has analyzed the costs and
 benefits of the revocation of tolerances
 for this chemical. This analysis is
 available for public inspection in Room
 236. CM *2.1921 Jefferson Davis
 Highway. Arlington. VA.
 Executive Order 12291
   As explained in the proposal
 published on March 13.1985. the Agency
 has determined, pursuant to the
 requirements of Executive Order 12291.
 that the revocation of these tolerances
 will not cause adverse  economic
 impacts on significant portions of U.S.
 .enterprises.                  i '•    '
'• Regulatory Flexibility Act     '"'.'....'
' . This rulemaking has been reviewed
 under the Regulatory Flexibility Act of .
 1980 (Pub. L 96-354: 94 Slat. 1164. 5
 U.S.C. 601 et seq.) and it has been
 determined that it will  not have a
 significant economic impact on a
 substantial number of small businesses,
 small governments, or small
 organizations. The reasons for this
 conclusion are discussed in the March
 13.1983 proposal.

 list of Subjects In 40 CFR Part 180
   Administrative practice and
 procedure. Agricultural commodities.
 Pesticides and pests. Reporting and
 recordkeeping requirements.
   Dated: December IS. 1986.
 J.A.MOOC*.
 Assistant Administrator for Pesticides and
 Toxic Substances.      '.
 PART 180—(AMENDED)

   Therefore. 40 CFR Part 180 is
 amended as follows:
   1. The authority citation for Part 180
 continues to read as follows:
   Authority: 21 U.S.C. 346«.
 S 1M.13S (Removed)     ' j
   2. Section 180.135 is'remdved.
 } 180.137 (Removed)
   3. Section 180.137 Is  removed.

 |FR Doc. 88-28745 Filed 12-23-68; 8:45 «m|
 eUXJHO COM 4MO-40-M
 40 CFR Part 180

 (OPP-300123A; FRL-J1J1-71
 Revocation of CMordan* Totorancas
"AOINCV: Environmental Protection
 Agency (EPA).
 ACTION: Final rule. ••  - •'•

 SUMMARY: This document (1) revokes all .
 interim tolerances and permanent
•. tolerances for residues of the insecticide
 chlordane: (2) lists the action levels EPA
 is recommending to the Food and Drug
 Administration (FDA) to replace the
 revoked tolerances; and (3) lists EPA's
 recommendations to FDA and the Food
 Safety and Inspection Service (FS1S) of
 the U.S. Department of Agriculture
 (USDA) regarding existing action levels
 for commodities bearing residues for
 which tolerances had not been
 established. This rule was initialed by
 the Environmental Protection Agency  to
 remove pesticide tolerances for which
 related registered uses have been
 cancelled.
 iFFtcrtvi OATB Effective on December
 24.1986.           ...   . :
 ADDRESS: Written objections, identified
 by the document control number [OPP-
 300123A], may be submitted to the:
 Hearing Clerk. Environmental Protection
 Agency. Rm. 3708 (A-110). 401 M St..
 SW.. Washington. DC 20460.
" FOR FURTHtR  INFORMATION CONTACT: By
 mail: Patricia  Critchlow, Registration  .
 Division (TS-767). Environmental
 Protection Agency. 401M St.. SW	
 Washington, DC 20460.
   Office location and telephone number
 Rm. 716. CM W2.1921 Jefferson Davis   ..
 Highway. Arlington. VA. (703-557-1806).
 3UFFUMENTARY INFORMATION: EPA -
 issued a notice, published in the Federal
 Register of June 5.1985 (50 FR 23717).
 which proposed the revocation of all
 tolerances in 40 CFR 180.122 and the
 interim tolerances in 40 CFR 180.319 for
 residues of the Insecticide chlordane.
   The June 5 Federal Register notice
 also listed the action levels which EPA
 intended to recommend to FDA to
 replace the tolerances once the rule
 revoking the tolerances is final. The
 action levels would cover unavoidable
 pesticide residues, which can continue to
 occur in the tolerance related food and
 feed commodities because of the
 persistence of the pesticide in the
 environment The notice also listed
 EPA's intended recommendations to
 FDA and FSIS regarding retention of
 existing action levels for food and feed.
 commodities  for which tolerances had
 not been established and which may
. contain unavoidable  residues of the
 pesticide because of environmental
 contamination.   •.  ..
   No requests for referral to an advisory
 committee were received. However.
 several interested persons submitted
 comments regarding  the proposed
 revocation action.

-------
46668  Federal Register / Vol. 51. No. 247  / Wednesday, December 24. 1986  /  Rules and
  The National Food Processors
Association (NFPA) and the Pineapple
Growers Association of Hawaii (PGAH)
indicated their opposition to EPA's.  .
revocation of the existing  tolermncai for
residues of persistent pesticides such ••
chlordane before such residues have
fully dissipated from the environment.
These organizations also expressed  .
concern that the setting of replacement
action levels may not be legal under the
recent decision of the United States
Court of Appeals for the District of
Columbia in Community Nutrition
Institute (CNI) v. Young. 757 F. 2d 354
(D.C. Cir. 1985V
  In order to eliminate any implied
sanctioning of the use of pesticides
whose registrations have been cancelled
fur food safety reasons and of the
presence of residues in food and feed
commodities from such use. EPA
considers it appropriate to revoke
Uilcrunccs for residues of  such
pesticides. There are major differences
between tolerances and action levels. A
tolerance is set before the fact to cover
residues which will result from legal and
purposeful use of the pesticide. An
action level is a more appropriate
mechanism for situations  involving
residues which persist in the
environment after the once-legal use o!
that pesticide has been halted. With
regard to the concern of NFPA and
PCAH that the setting of replacement
action levels may not be legal in light to
the Court of Appeals decision in the CNI
case, the Agency notes that the Supreme
Court has recently  reversed the Court of
Appeals decision. The Court gave
deference to FDA's interpretation that
the Federal Food. Drug, and Cosmetic
Act provides flexibility to set action
levels under section 402(a) rather than
promulgate tolerances by formal
rulemaking pursuant to section 406. The
Agency also notes  that it does not
interpret section 406 as applying to
residues of pesticide rheeVicasi in food:
rather, sections 402UKajH». 4Ctt(*H2KQ.
4UO. and 409 govern tncSMue of whether
food bearing such residues is
adulterated.
  The NFPA also stated that action
levels do not provide sufficient legal
protection to food producers (but did not
specify  m what manner) and further
indicated that NFPA also opposed the
1982 policy statement 147  FR 42956.
September Z9.1962) which describes
EPA's policy on the revocation of
tolerances for cancelled pesticides and
the replacement of these tolerances with
action levels for unavoidable residues of
these pesticides. The basis for their
opposition was that the setting and
revising of action levels does not afford
the public the same hearing rights and
pruteUujV. protections provided for
tolerance rulemaking actions under
section 408 of the FFDCA.
  EPA believes that its procedures
regarding the recommendation of
replacement action levels afford
adequate legal protection to food
producers. As a matter of policy, the
Agency will provide notice and the
opportunity to comment on
recommended action levels at the
proposal stage of a tolerance revocation
action. When a determination is reached
to further decrease action levels, the
Agency will publish a notice in the
Federal Register of that determination
and provide an opportunity to comment
before making its final
recommendations on action levels to
FDA or USDA.
  The Regional Administrator for EPA's
Region VII (which includes the states of
Iowa. Kansas, Missouri, and Nebraska)
expressed concern about the proposal   •
that FDA continue to enforce the current
action level of 0.3 part per million for
residues of chlordane in fish, indicating .
that this  action level might not be
sufficiently low to provide adequate
protection of human health and that
possibly it was inconsistent with
Agency policy on replacement action
levels as well as with human health
protection processes in other EPA
programs. The Regional Administrator
also recommended that the Agency
conduct a thorough review of fish
residue data, collected on a nationwide
basis, to better determine the extent of
chlordane contamination in the U.S..
and further suggested that the action
level  risk assessment process.
particularly regarding  fish, be critically
examined.
  EPA has been  advised of the
availability of additional regional fish
residue data and fish consumption
statistics which needlo be submitted for
analysis and consideration before the
Agency makes its final recommendation
on the fish action level.
  Until this additional Information is
received and can be evaluated, the
Agency has decided to make no
recommendation at this time regarding
the current chlordane  action level in
fish. When EPA  has accumulated more
data  and studied the situation throughly,
the Agency will  reassess the fish action
level and determine what
recommendation to make to FDA for the
action level.
   As part of this reassessment EPA
intends also to study further the
concerns about pesticides in fish in
various regional areas where members
of specific population subgroups may
consume fish at  rales  above the
"national average." Because action
levels unforced by FDA apply to fish in
interstate commerce, it would be very
 difficult, if not impossible, for FDA to
 enforce  und defend IP. court differing
"regional" limits. However. EPA
recognizes that some population groups"'
may be at higher risk because of the
frequency and amount of fish consumed
locally. It is usually not possible,
however, to set an enforcement limit for
this situation while also satisfying the
criteria for setting an appropriate
national limit.
  If a potential local health problem
exists, a state or locality may issue
guidance on the quantity of
contaminated fish which may be
consumed without appreciable risk to
the health of local consumers, based on
an assessment of the level of the
contaminant and on fish consumption
patterns.
  EPA believes that the factors listed in
the 1982 policy statement for setting
appropriate  action levels are basically
sound and need not be changed.
Therefore, these factors will continue to
be used as guidance by the Agency  in
assessing the appropriate action level
for fish.
  This final rule revoking the tolerances
for chlordane Is being issued In
accordance  with EPA's 1982 policy
statement and the action levels being
recommended are based on the factors
cited in that statement i.e_ the action
levels are set at the level necessary to
protect the public health while taking
into account the extent to which the
residues cannot be avoided. As
environmental residues continue  to
dissipate, risk will gradually decrease
and action levels may be lowered. EPA
plans to reassess all its recommended
action levels in the  future on a regular
basis so that the action levels may be
lowered as residues decline.
   It ia EPA's opinion that during the
period of time that residues of chlordane
and its degradation products continue  to
occur in food, the potential nsk from
dietary exposure to such residues will
be low. Based on the monitoring data
which were used to formulate its action
level recommendations. EPA has
 determined that most foods and feeds
 contain no detectable residues of
 chlordane and its degradation products,
 or contain residues which are generally
 below the recommended action levels. It
 is important to recognize that only  a few
 foods and feeds on the action level list
 contain residues at or near the
 maximum limits being recommended. In
 fact, most of the foods and (etds contain
 residues well below the recommended
 action level. Thus,  the occurrence of
 unavoidable residues is not a
 widespread or commonplace situation.
 In addition, the level of exposure will.
 continue to decrease u environmental
 residues decrease.
   Based on the information considered
 by the Agency and discussed in  detail I
 the June 5,1985, proposal tnd in this
                                                                          POOR Q'JAUTv
                                                                            x  ORIGINAL

-------
                 Register /  Vof.  51. No. 247  /  Wednesday. December 24. 1986 / Rules and Regulations  46667
   - rule, the Agency is hereby: (1)
 .'evoking all tolerances for residues of
chlordane listed in 40 CFR 180.122, and
(2) revoking the interim tolerances listed
in 40 CFR 180.319 specifically for
residues of chlordane.
  h'l'A is recommending lo FDA tha
action levels listed below, expressed to
parts per million (ppm). to replac* the
following tolerances which are being
revoked for residues of chlordane. For '"'
consistency with existing FDA action'
levels, all recommended action levels •-"
are for "the sum of residues of cis- and
/rons-chlordane, cis- and trans-
nonachlor. oxychlontane (octachtor
epoxide), alpha, beta, and gamma:
chiordene. and chiordene."

  TABLE i.—RECOMMENDED ACTION LEVELS
                                        of chlordane. Ifsted in 40 CFR 180.319.
                                        which are being revoked.

                                          TABU 2.—RECOMMENDED ACTION LEVELS
                                                (FOR INTERIM TOLERANCES)
                         (ppm.)
8o»MflMmn.—__	
B'occnt		
B'utua iprouit...	
Cjixwot	
CwrOU		
Cft6rn««	
&uu**ua
D.
Evgp«M ...
PUXWM.
PlUft...
PUnt(lr*M«
AilOMmM..
Ruutue** (wot or •Am MM..
Rt.uo*gu. ion..
Sui
ToniuaM	_
Twnpi (wm or i
                             .
                         CMor-
03
03
0.3
0.3
03
03
0.3
0.3
0.3
0.3
03
03
0.3
0.3
0.3
0.3
OJ
0.3
0.9
0.3
0.3
0.3
0.3
0.9
0.3
0.3
0.3
0.3
0.3
03
O.S
03
0.3
03
0.3
0.3
OJ
0*
OX
OS

OS
04
OS
OS
9.3
0.3
as
0.3
0.3
                                (BPW.
                                   0.1
                                   O.I
                                   0.1
                                   ai
                                   ai
                                   0.1
                                   9.1
                                   ai
                                   0.1
                                   o.i
                                   O.I
                                   0.1
                                   ai
                                   ai
                                   at
                                   at
                                   ai
                                   at
                                   ai
                                   o.i
                                   ai
                                   at
                                   at
                                   ai
                                   o.i
                                   ai
                                   ai
                                   o.i
                                   01
                                   o.i
                                   at
                                   at
                                   at
                                   at
                                   at
                                   at
                                   at
                                   at
                                   at
                                   at
                                   at
                                   at
                                   at
                                   at
                                   ai
                                   ai
                                   at
                                   at
                                   at
                                   at
                                   at
                                   at
                                    at
  EPA is recommending to FDA the •
action levels listed below to replace1 the
following interim tolerances for residues
                                        pimnM	lr L.	
                                        Punpnot
                                        SMUCturd ---
                                                                 (ppm)
                                                                 CMor-
                                                                   0.1
                                                                  003
                                                                   at
                                                                   o.a
                                                                   ot
                                                                   ai
                                                                   0.1
                                                                        (ppm).
                                                                       Ctuoramt
                                                0.1
                                                O.I
                                                01
                                                O.I
                                                0.1
                                                ai
                                                O.I
                                          The proposed rule (50 FR 23717. June
                                        5.1985) stated thai EPA planned to
                                        recommend that FDA retain its existing
                                        action level of 0.8 ppm in rendered
                                        animal fat. FDA has since indicated that
                                        a lower action level of 0.3 ppm would be
                                        adequate, based on residue monitoring
                                        data from 1982 through 1985. and would
                                        also be consistent with FSIS' action
                                        level in fat of livestock.
                                          Therefore. EPA is recommending to
                                        FDA the following action level to
                                        replace the current action level for
                                        residues of chlordane in the processed
                                        feed commodity, rendered animal fat.

                                          TABLE 3.—RECOMMENDED REPLACEMENT
                                                    ACTION LEVEL
                                        Annul (0 (irand)..
                                                                  Exa-
SE
                                                                   oa
                                                                        (pom).
                                                                       OonUM
                                          EPA Is recommending that FDA and
                                        FSIS retain the following action levels
                                        for residues of chlordane.
                                           TAILI 4.—ACTION LEVELS TO REMAIN IM
                                                        EFFECT
                                        A/MM iMd (pronvM
                                        FM. «ML ana ••
                                              (t«bu«.
                                                                        inpmi.
                                                                       CMoraan*
                                                                            ai
                                          The commodity definition "Fat of
                                        meat from cattle, goats, hogs, horses.
                                        sheep, poultry, and rabbits." which was
                                        listed in the proposed rule, has been
                                        modified aa shown in Table 4 above to
                                        agree with the commodity definition
                                        used by FSIS.
  Commodities affected by the action
level recommendations listed above in
Tables 3 and 4 include processed animal
feed and the processed feed commodity
rendered animal fat. which is used as an
animal feed ingredient. There are no
established feed additive tolerances in
21 CFR Part Sfll for residues of
chlordane which would be subject to
revocation under section 409(h) of the
Federal Food. Drug, and Cosmetic Act;
therefore, a separate Federal Register
notice addressing feed additive
tolerances or replacement action levels
will not be published.
  As discussed earlier in this document.
EPA is not making a recommendation to
FDA at this time regarding the current
0.3 ppm action level for chlordane
residues on fish (edible portion).
  Any person adversely affected by this
regulation revoking the tolerances may.
within 30 days after the date of
publication of this regulation in the
Federal Register, file written objections
with the Hearing Clerk, at the address
given above. Such objections submitted
must specify the provisions of the
regulation deemed objectionable and the
grounds for the objections. If a hearing
is requested, the objections must state
the issues for the hearing. A hearing will
be granted if the objections are
supported by grounds legally sufficient
lo justify the relief sought.
   This document has been reviewed by
the Office of Management and Budget as
required by section 3 of Executive Order
12291.
   In order to satisfy requirements for
analysis as specified by Executive Order
12291 and the Regulatory Flexibility Act.
the Agency has analyzed the coats and
benefits of the revocation of toleraoces
for this pesticide. This analysis is
available for public inspection in Rm.
236. CM #2.1921 Jefferson Davis
Highway. Arlington. VA.
Executive Order 12291

   As explained in the proposal
published on June S. 1905. the Agency
has determined, pursuant to the
requirements of Executive Order 12291.
that the revocation of these tolerances
will not cause adverse economic
impacts on significant portions of U.S.
enterprises.
Regulatory Flexibility Act
   This rulemaking has been reviewed
 under the Regulatory Flexibility Act of
 1980 (Pub. L. 96-354: 94 StaL 1164. S
 U.S.C. 601 etseq.) and it has been
 determined that it wilt not have *
 significant economic impact on a
 substantial number of small bus-ncstes.
 smalt governments, or smalt

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           ATTACHMENT B
Comment Response Numbers 26 and 57

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             ATTACHMENT

  SELECTED HYDROCONE CHROMATOGRAPHS,
ARLINGTON BLENDING AND PACKAGING SITE

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