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.
-------
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.
-------
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'
-------
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
-------
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
-------
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 fproperly 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
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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.
-------
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.
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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.
-------
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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KEL MOTH-
- 0»TA LOCATON SJ8SUHFACE ACTON UVO. S
$) - 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
-------
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
-------
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
-------
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
-------
(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
-------
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
-------
, 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-
-------
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 EFFECTContmo«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
-------
ATTACHMENT B
Comment Response Numbers 26 and 57
-------
ATTACHMENT
SELECTED HYDROCONE CHROMATOGRAPHS,
ARLINGTON BLENDING AND PACKAGING SITE
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