United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R04-93/129
May 1993
SEPA Superfund
Record of Decision:
Cedartown Industries, GA
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50272-101
REPORT DOCUMENTATION 11. REPORTNO.
PAGE EPA/ROD/R04-93/129
2..
3. Reclplenr8 AeeesPv1 No.
4.
Title and Subtitle
SUPERFUND RECORD OF DECISION
Cedartown Industries, GA
First Remedial Action - Final
AUthor(s)
5.
Report Date
05/07/93
6.
7.
8.
Performing Organization Rept. No.
9.
Performing Organization Name and Address
10 Project T88IcIWork Unit No.
11. Contract(C) or Grant(G) No.
(C)
(G)
12.. Sponsoring Organization Name and Add.....
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report .. Period Covered
Agency
800/800
14.
15. SUpplementary Notes
PB94-964047
16. Abstract (Umlt: 200 words)
The 6.8-acre Cedartown Industries site is an inactive foundry located in Cedartown,
Georgia. The site is bordered by Cedar Creek on the west, and a supply store and
several wooded areas to the south. Land use in the area is predominantly agricultural
and industrial. There are two distinct units within the underlying karst aquifer,
which are hydraulically connected; the bedrock portion is used as a primary source of
drinking water. From 1874, the site was initially operated as an iron foundry under
the name of Cherokee Furnace, which processed approximately 100 tons of iron per day.
The principle ore mineral was limonite along with hydroxides (goethite). In t~e 1930s,
the site changed hands and was operated as the Cedartown foundry until 1976, supplying
water pumps and plow blades; then subsequently was used as a machine shop. From 1978
to 1980, the site was used for lead smelting operations; however after site operations
ceased, waste material remained onsite. Past industrial and waste disposal practices
from onsite smelting operations have impacted the onsite soil and ground water. In
1986, State investigations identified approximately 5,000 yd3 of slag material and
32,000 gallons of contaminated wastewater in the inactive impoundment, and elevated
(See Attached Page)
17. Document Analysis .. Descriptors
Record of Decision - Cedartown Industries, GA
First Remedial Action - Final
Contaminated Media: soil, debris, gw
Key Contaminants: VOCs (benzene), other organics
lead)
(PAHs), metals (arsenic, chromium,
b.
Identifiers/Open-Ended Terms
c.
COSA 11 Field/Group
18. Availability S18tell18nt
19. Security CIaaa (ThIs Report)
None
20. Security Class (ThIs Page)
None
21. No. of Pages
90
22. Price
(See ANSI-Z39.18)
S4N1lnstructions on R-
OPTIONAL FORM 272 (4-77)
(Formerfy NTJS.35)
Department of Commen:e
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- - -
- -
EPA/ROD/R04-93/129
Cedartown Industries, GA
First Remedial Action - Final
Abstract (Continued)
levels of lead and cadmium were detected in both the onsite waste piles and soil. In
1990, EPA conducted an interim removal action to transport 6,700 yd3 of solid hazardous
material, including soil, sediment, debris, and slag, to an offsite. RCRA landfill, and to
remove and reuse the small coke pile as fuel feed for the lead smelting process at an
offsite facility. Additionally, 62,225 gallons of non-hazardous liquid waste was
transported to an offsite lead wastewater treatment and recovery system. This ROD
addresses onsite contamination in soil and the localized ground water as the first and
final remedy for the site. The primary contaminants of concern affecting the soil,
debris, and ground water are VOCs, including benzene; other organics, including PARs; and
metals, including arsenic, chromium, and lead.
The selected remedial action for this site includes removing and demolishing onsite
structures, as necessary; excavating and treating onsite 19,280 yd30f soil and material
exhibiting lead levels exceeding 500 mg/kg using ex-situ solidification/stabilization;
backfilling the excavated areas with the solidified material; adding a cover of clean fill
and restoring the excavations by regrading and repaving the area using asphalt or gravel
and/or a vegetative cover; conducting bench-scale and pilot tests prior to the design of
the treatment system; allowing ground water to naturally attenuate; monitoring soil,
ground water, and air; and implementing institutional controls, including land and ground
water use restrictions. In the event that monitoring data indicates that ground water has
not reached MCLs within 2 years, a contingency remedy for pumping and treatment of ground
water using granular activated carbon, with offsite discharge to the municipal sewer of to
surface water will be implemented. The estimated present worth cost for this remedial
action is $3,372,180, which includes an annual O&M cost of $32,000 for 30 years. The
estimated present worth cost for the contingency remedy is $4,923,700, which includes an
unspecified O&M cost for 30 years.
PERFORMANCE STANDARDS OR GOALS:
50il and ground water cleanup goals are based on Federal MCLs and soil action levels,
which were based on a 10-6 risk level, health-based criteria or background levels.
Chemical-specific soil cleanup goals include antimony 30 mg/kg; arsenic 80 mg/kg;
beryllium 2 mg/kg; cadmium 40 mg/kg; and lead 500 mg/kg. The chemical-specific soil
excavation goal is lead 500 mg/kg. Chemical-specific ground water cleanup goals include
cadmium 0.005 mg/l.
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RECORD OF DECISION
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
CEDARTOWN INDUSTRIES SITE
CEDARTOWN, POLK COUNTY, GEORGIA
PREPARED BY
u. S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV
ATLANTA, GEORGIA.
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DECLARATION
of the
RECORD OF DECISION
SITE NAME AND LOCATION
Cedartown Industries Site
Cedartown, Polk County, Georgia
STATEMENT OF BASIS AND PURPOSE
This decision document (Record of Decision), presents the selected
remedial action for the Cedartown Industries Site, Cedartown, Georgia,
developed in accordance with the. Comprehensive Environmental Response,
Compensation and Liability Act of 1980 (CERCLA), as amended by the
Superfund Amendments and Reauthorization Act of 1986 (SARA), 42 U.S.C.
~ 960~ ~ sea., and to the extent practicable, the National
Contingency Plan .(NCP), 40 CFR Part 300.
This decision is based on the administrative record for the Ced~rtown
Industries Site.
The State of Georgia concurs with the selected remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from the
Cedartown Industries 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
This action is the first and final. action planned for the Site. This
alternative calls for the design and implementation of response
measures which will protect human health and the environment. The
action addresses the principal threat at the Site, the contaminant
sources in the soil, as well as the localized groundwater
contamination at the Site. .
The major components of the selected remedy include:
.
Excavation and EX-situ solidification/stabilization of all soils
exhibiting lead levels exceeding 500 ppm (500 mg/kg);
long-term monitoring of all existing groundwater monitoring wells
to determine if immobilization of the source contaminants provide
natural attenuation of the contaminant levels in the sha~low
groundwater;
.
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.
if natural attenuation of the groundwater contamination is not
effective, a pump and treat system shall be considered with EPA
determining the requirement for system implementation; and
.
institutional controls in the form of deed restrictions and record
notices for land use and groundwater use restrictions shall be.
placed on the Site. .
STATUTORY DETERMINATIONS
The selected remedy is protective .of human health and the environment,
co~lies with Federal and State requir~ents that are legally
applicable or relevant and appropriate, and is cost-effective. This
remedy satisfies the statutory preference for remedies that employ
treatment that reduces toxicity, mobility, or volume as a principal
element. Finally, it is determined that this remedy utilizes a
permanent solution and treatment technology to the maximum extent
practicable.
Because this remedy may result in hazardous substances remaining on-
site, 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.
9~/r)~
PATRICK M. TOBIN, ACTING REGIONAL ADMINISTRATOR
S--7..,93
DATE
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1.0
2.0
3.0
4.0
5.0
6.0
7.0
8.0
'rABLB OP CONTENTS
SITE LOCATION AND DESCRIPTION
.......
.......
SITE HISTORY. . . . . . . . .
........
. . . . . .
HIGHLIGHTS OF COMMUNITY PARTICIPATION
. . . . .
. . . . .
SCOPE AND ROLE OF REMEDY. . . . .
. . . . . .
. . . . . .
SUMMARY OF SITE CHARACTERISTICS. . . . . . . . . .. . . .
5 .1 GEOLOGY / SOILS. . . . . . . . . . . . .
5.2 HYDROGEOLOGY. . . . . . . . . . . . . . . . .
5.2.1 SURFICIAL UNIT . . . . . . . . . . .
5 . 2 . 2 BEDROCK UNIT . . . . . . . . . . . .
5 .3 SUMMARY OF SITE CONTAMINATION. . . . . . . . . . .
5.3.1 SUBSTANCES DETECTED IN SOILS. . . .
5.3 .2 SUBSTANCES DETECTED IN THE GROUNDWATER
5.3 .2 .1 FATE AND TRANSPORT . . . . . .
5.3 .3 SURFACE WATER AND SEDIMENTS
INVESTIGATION. . . . . . . . . . .
AIR PATHWAY INVESTIGATION. . . . . . . .
5.3.4
SUMMARY OF SITE RISKS. . . . . . . . . . . . . . .
6 .1 CONTAMINANTS OF CONCERN (COCs). . . . . . . . .
6 . 2 EXPOSURE ASSESSMENT ..........
6 .3 TOXICITY ASSESSMENT. . . . . . . . . . . . .
6.4 RISK CHARACTERIZATION. . . . . . . . . . . .
6.5 UNCERTAINTY ANALYSIS. . . . . . . . . . . . . . . .
6 . 6 HUMAN HEALTH RISKS CONCLUSION. . . . . . . .
6 . 7 ENVIRONMENTAL ASSESSMENT SUMMARY. . . . . . . . . .
6 . 7 .1 AOUATIC....... . . . .
6 ..7 . 2 TERRESTRIAL........... -. . . .
6 .8 CHEMICALS OF CONCERN AND CLEANUP LEVELS. . . .
DESCRIPTION OF ALTERNATIVES. . . . . . . . . . . .
7.1 ALTERNATIVE No.1 - No Action. . . . . . . .
7 .2 ALTERNATIVE No.2 - Ex-Si tu .
Solidification/Stabilization: Groundwater
Moni torina . . . . . . . .. . . . . .... . . . . . . .
7.3 ALTERNATIVE No.3 - Soil Excavation with Off-Site
DisDosal: Groundwater Monitorina . . . . . . . . . .
7 .4 ALTERNATIVE No.4 - CaDDina: Groundwater
Moni torina . . . . . . . . . . . . . . . . . . . . .
7-.5 ALTERNATIVE No.5 - Ex-Situ Solidification/
Stabilization: Groundwater Treatment. . . . .
7.6 ALTERNATIVE No.6 - Soil Excavation: Groundwater
Treatment. . . . . . . . . . . . . . . . . . . . .
7.7 ALTERNATIVE No.7 - CaDDina: Groundwater Treatment
7.8 .APPLICABLE OR RELEVANT AND APPROPRIATE REGULATIONS.
(ARMs) ...................
SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
8 . 1 THRESHOLD CRITERIA. . . . . . . .
i
1
1
5
6
7
7
9
9
10
11
11
14
19
20
21
21
21
24
27
29
31
31
32
32
33
. 34.
39
39
40
42
43
44
46
46
47
54
55
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9.0
10.0
11.0
8.2
8.1.1
8.1.2
PRIMARY
8.2.1
8.2.2
8.3
OVERALL PROTECTION OF HUMAN HEALTH AND
THE ENVIRONMENT """""'"
COMPLIANCE WITH ARARS ..........
BALANCING CRITERIA . . . . . . . . . .
LONG-TERM EFFECTIVENESS AND PERMANENCE
REDUCTION OF TOXICITY. MOBILITY. OR
VOLUME THROUGH TREATMENT. . . . . . . . .
8' . 2 . 3 SHORT-TERM EFFECTIVENESS. . . . . .
8.2.4 IMPLEMENTABILITY ............
8.2.5 ~........ . . . . . . . .
MODIFYING CRITERIA. . . . . . . . . . . . . . . . .
8.3.1 STATE ACCEPTANCE. . . . . . . . . .
8 . 3 . 2 . COMMUNITY ACCEPTANCE . . . . . . . .
SUMMARY OF SELECTED REMEDY .
. . . . . .
. . . . . .
STATUTORY DETERMINATION
. . . .
. . . .
. . .
10.1 PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT. . .
10.2 ATTAINMENT OF THE APPLICABLE OR RELEVANT AND
APPROPRIATE REOUIREMENTS (ARARs) ..........
10. 3 COST -EFFECTIVENESS. . . . . . . . . . . . . . . . .
10.4 UTILIZATION OF PERMANENT SOLUTIONS TO THE MAXIMUM
EXTENT PRACTICABLE. . . . . . . . . . . . . . . . .
10.5 PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT
DOCUMENTATION OF SIGNIFICANT CHANGES'
. . . .
. . . .
APPENDIX A - RESPONSIVENESS SUMMARY.
APPENDIX B - STATE CONCURRENCE LETTER
. . . . .
. . . . . .
.........
. . . . .
ii
55
56
57
57
59
5~
60
60
61
61
61
62
70
70
71
73
73
74
74
75
76
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LIST OF TABLES
TABLE 5-1 SUMMARY OF ANALYSIS FOR EACH MEDIA
. . . . . . . . . ..
"TABLE 5-2 CEDARTOWN INDUSTRIES SITE: SUMMARY OF POTENTIAL CHEMICALS
OF CONCERN DETECTED IN SOILS DURING THE REMEDIAL 0
INVESTIGATION. . . . . . . . . . . . . . . . . . . . .
TABLE 5 - 3 CEDARTOWN INDUSTRIES SITE: SUMMARY OF POTENTIAL CHEMICALS
OF CONCERN DETECTED IN GROUNDWATER DURING THE REMEDIAL
INVESTIGATION. . . . . . . . o. . . . . . . . . . . . .
TABLE 6-1 CEDARTOWN INDUSTRIES SITE:
OF CONCERN. . . . . . . .
SUMMARY OF POTENTIAL CHEMICALS
. . . . . . . . . . '. . .. 22
TABLE 6-2 EXPOSURE POINT CONCENTRATIONS, RfDs, AND CPFs FOR COCs
EXCEEDING ACCEPTABLE RISK LEVELS. . . . . . . . . . .
TABLE 6-3 SUMMARY OF CUMULATIVE POTENTIAL CANCER RISKS AND NON-
o 0 0 CARCINOGENIC HAZARD INDICES. . . o. . . . . . . . . . .
TABLE 6-4 HEALTH-BASED CLEANUP GOALS FOR SURFACE AND
SUBSURFACE SOILS. . . . . . . . . . . . . . . . . . .
TABLE 6-5 SUMMARY OF REMEDIAL ACTION OBJECTIVES
TABLE 7 -1 POTENTIAL LOCATION SPECIFIC ARARs . .
. . . .
. . . . .
. . .
. . . . . .
TABLE 7 -2 POTENTIAL ACTION-SPECIFIC ARARs FOR THE SELECTED REMEDY
TABLE 7-3 POTENTIAL ACTION-SPECIFIC ARARs FOR THE GROUNDWATER
CONTINGENCY REMEDY . . . . . . . . . . . . . . . . .0
TABLE 7 -4 POTENTIAL CHEMiCAL-SPECIFIC ARARS .
TABLE 7 -5 TO BE CONSIDERED (TBCs) DOCUMENTS .
. . . .
. . .
. . . . .
.' . . . .
T~LE 8-1 COMPARISON OF COSTS. .
............
. . . .
TABLE 9 -1 CONTAMINATED SOILS ESTIMATED AREAS AND VOLUMES 0
. . . .
iii
13
15
19
28
30
35
36
48
49
. . 51
52
53
61
63
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LIST OF FIGtJRBS
FIGURE 1-1 SITE LOCATION MAP
FIGURE 1-2 SITE PLAN
. . . . .
. . . . . .
..........
........
. . . . .
FIGURE 5-1 SITE MAP: SURFACE SOIL, SURFACE WATER, SEDIMENT SAMPLE,
MONITORING WELL, AND SUBSURFACE BORING LOCATIONS. . .
FIGURE 6-1 APPROXIMATE EXTENT OF SOILS REMEDIATION
FIGURE 6-2 APPROXIMATE EXTENT OF GROUNDWATER CADMIUM REMEDIATION
.......
iv
2
3
12
37
38
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ROD
Cedartown Industries Site
Page 1
Decision Summa%y
Record of Decision .
Cedartown Industries Site
" Cedartown, Georgia
1.0
SITE LOCATION AND DESCRIPTION
<0,'; ""'.\ ..-
The Cedartown Industries Site is located at 404 Furnace Street in
Cedartown, Georgia, about one-half mile from the downtown area.
Figures 1-1 and 1-2 are a Site location map and a general Site
map, respectively. The Site is comprised of 6.8 acres on which a
secondary lead smelting business operated for approximately two
years. Currently, three buildings are located on the property.
One of these buildings currently houses the offices of H&W
"Transfer Company' which leases the Site from the current owners
for the parking and maintenance of vehicles. The Site is
bordered by Cedar Creek on the west and a chain link fence to the
north, south, and east. A levee, constructed in 1980, borders
the Site to the west, north, and south and is designed to protect
the Site from a 100-year flood. Immediately north of the Site is
a narrow strip of land and railroad tracks owned by CSX .
Transportation, and beyond the tracks is a junkyard that has been
in existence since at least the 1940's. Across the street to the
east is a farm supply store that is now out of business, and to
the south is a large, partially wooded area owned by the current
owner of the Cedartown Industries Site. In general, land use in.
the.vicinity of the Site, especially to the south and west, is . .
largely agricultural and industrial.
2.0
SITE HISTORY
The Cedartown Industries Site was initially operated as an iron
foundry under the name Cherokee Furnace. The foundry opened in
about 1874 with a capacity of about 50 tons per day. At the turn
of the centu%y, the furnace was processing about 100 tons per
day. The ore for. the furnace was supplied by the numerous iron.
mines northwest of the Site, among them, the Cherokee Mine run by
the Alabama and Georgia Iron Co. The principle ore mineral was
limonite, along with minor iron hydroxid~s (goethite,
xanthosiderite, limnite). Ore was reportedly shipped to the
furnace along a narrow gauge railway that crossed Cedar Creek
just south of the present CSX.rail line.
In the 1930's, Mr..A.C. Duke bought the furnace and changed the
name to Cedartown Foundry. The foundry reportedly supplied water
pumps to the Ford Motor Company during this period as well as
plow blades to Rome Plow. The Property changed ownership in
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ROD
Cedartown Industries Site
Page 2
FIGURE 1-1
SITE LOCATION HAP
. .
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ROD
Cedartown Industries Site
Page 3
RAJUIW) mACK
1--,
I ,
, J
I I
I I
I t
I I
I I
I I
1 I ~
I I :;:
~Olj
Irnlb
:~:i
I () I ..1
...
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ROD
Cedartown Industries Site
Page 4
September 1939, but still operated under the name Cedartown
Foundry. The Site later operated as a machine shop. From
February 1978 to May 1980, the Site was used as a secondary lead
smelting business. The secondary lead smelting operation
purchased raw lead materials from various suppliers and recycled
these materials through various melting and ski~ng processes.
Although a battery cutting operation including a concrete surface
impoundment was partially constructed on site, the operation ~s
terminated before batteries were broken on site.
Mr. Ray A. Lewis and Ann P. Lewis, the current property owners,
purchased the Site on August 15, 1984. The Site has been leased
to the H&W Transfer Company for the parking and maintenance of
vehicles, mainly tractor-trailers. A Chemical Leeman trucking
facility also leases a portion of the Site.
The property east of the Site at the present Gold Kist location
was reportedly a coke smelter at the time the Cedartown Foundry
was operating. The adjoining property south of Gold Kist was
reportedly the City of Cedartown landfill., which was closed in
the late 1930's to early 1940's.
When the lead smelting operation was terminated in 1980, waste
material remained on site. On January 7, 1986, the Georgia
Environmental Protection Division (EPD) conducted an
investigation and environmental sampling at the Site. A Site
Inspe~tion prepared by the Georgia EPD in 1986 cited the presence
of approximately 5,000. cubic yards of slag material and 32,000
gallons of wastewater in the inactive impoundment. The Site
investigation also reported that lead and cadmium were detected
: .both in 'on site waste piles and in the soil. The only compound
reported in significant quantity during the investigation was
lead.
Under the direction of U.S. EPA Region IV, an Interim Waste
. removal project was completed in May 1990 to remove slag and coke
storage piles, contaminated debris and soil, -wastewater, and
impoundment sediment from the Site, and properly dispose of the
waste material in an off-Site landfill permitted under Resource,
Conservation and Recovery Act (RCRA) Subtitle C. A total of
6,700 cubic yards of solid hazardous materials (approximately
8,380 tons), including slag, soil, sediment, and debris, were
removed and transported to the Chemical Waste Management Landfill
.in EmelIe, Alabama. A total of 62,225 gallons of liquid waste
(non-hazardous rainwater) was transported to the Sanders Lead
Wastewater Treatment and Recovery System in Troy. The industrial
wastewater treatment system is designed and permitted to treat
metal-Containing liquid waste. The small coke pile was also
removed from the Site and was used ~s fuel feed for the lead
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ROD
Cedartown Industries Site
Page 5
smelting process at the Sanders Lead Facility in Troy, Alabama.
At the conclusion of the Interim Waste Removal, no visible waste
material was present ~t the Site. The tasks completed during the
interim waste removal were conducted in accordance with -
applicable federal regulations which require that all interim
removals at NPL Sites must be consistent with the final remedy of
the agency selection in the Record of Decision (ROD).
The Cedartown Industries Site was proposed for listing on the
National priorities List (NPL) in 1988 and finalized in February
i990. In June 1990,-Sanders Lead entered into an Administrative
Order on Consent with EPA to conduct the Remedial
Investigation/Feasibility Study (RI/FS) to determine the nature
and extent of contamination at the Site, to evaluate the .
associated risks, and to evaluate alternatives for eliminating
-.-those-threats..---'Sanders Lead, under EPA's oversight, began field
activities for the first phase of the remedial study in January
1991. The RI/FS was completed in December of 1992.
3.0
HIGHLIGHTS OF COMMUNITY PARTICIPATION
All basic requirements for public participation under CERCLA
sections 113(k) (2) (B) (i-v) and 117, were met in the remedy
selection process. Because the local community has been
interested and involved in the Cedartown Industries Site status
during the removal and the remedial activities at this Site,
community- relations activities remained an important aspect - .'"
throughout the RI/FS process. The community relations program at
the Cedartown Industries Site was designed to maintain
- - communication between the residents in the affected community and
the government agencies conducting remedial activities at the
Cedartown Industries Site. Frequent communication with nearby
residents. and local officials has been maintained as a priority.
Special attention has been directed toward keeping the community
informed of all. study results. Meetings were held with Cedartown
city officials. -Prior to approval of the RI/FS Workplan, EPA
officials attended a local Chamber of Commerce public forum and a
Kiwanis ClUb meeting. In addition, a meeting was held with the
community at an availability session in the Winter of 1991 to
inform residents of EPA's intentions and,to obtain input
concerning sampling locations and health and safety procedures.
On January 14, 1993, after the finalization of the Remedial
Investigation Report and the completion of the Feasibility Study,
EPA presented its preferred remedy for the Cedartown Industries
Site-during a public meeting at -the Cedartown Public Library, 245
East Avenue, Cedartown, Georgia. The 30-day public comment
period was held December 28, 1992, through January 27, 1993. A
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ROD
Cedartown Industries Site
Page 6
copy of the Administrative Record, upon which the remedy was
based, is located at the Cedartown Public Library, 245 East
Avenue, Cedartown, Georgia 31701. EPA's responses to comments
.which were received during the comment period are contained in
Appendix A.
4.0
SCOPE AND ROLE OF REMEDY
This remedy is the first and final remedial action for the Site.
The function of this remedy is to reduce the risks associated
with exposure to contaminated soils and groundwater.
The selected remedial alternative will address three conditions
which pose a threat to human health and the environment:
.
Contaminated qroundwater in the uooermost or surficial
aquifer (may potentially impact drinking water supplies);
contaminated surface soils (presents a continuing direct
contact threat to the public health>"; and
.
. contaminated subsurface soils (present.a continuing source
of contamination to the surficial aquifer).
Pathways of exposure include:
.
.
Ingestion of contaminated. soils and groundwaterr and
dermal contact with contaminated soils and potential
absorption of contaminants.
.
The major components of the remedy are:
.
Excavation of contaminated soiis and materials exhibiting
lead leve~s exceeding 500 ppm (500 mg/kg);
ex-situ solidification/stabilization of excavated
contaminated soil and materials;
.
.
backfilling excavations using solidified material and a
clean compacted fill cover;
restoring excavations to original grade and repaving
(gravel, asphalt, or vegetative);
.
.
institutional controls, such as deed restrictions and record
notices shall be placed on the Site which will be
established to preclude usage of groundwater and mintmize
land use; and
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ROD
Cedartown Industries Site
Page 7
.
monitoring of contaminated groundwater in the surficial
aquifer with possible extraction and treatment of
groundwater if natural attenuation is not effective.
This remedy addresses the first and final cleanup action planned
for the Site. The contaminants present in the soil pose a threat
to human health and the environment because of the risks
associated with possible ingestion (eating or drinking) or dermal
contact (through the skin). Also, the shallow groundwater
present beneath the Site contains elevated levels of a
contaminant similar to that present in soils at the Site.
Although this water bearing zone is affected, the contamination
is contained on site, and is not affecting the public drinking
Water supply (Cedartown Springs) and aquatic biota of Cedar
Creek. The purpose of this proposed action is to prevent current
. -, .. -- 'or--future -exposure ..to- the- contaminated soils, including
associated contaminated groundwater, and to reduce the migration
of contaminants.
5.0
SUMMARY OF SITE CHARACTERISTICS
5.1
GEOLOGY/SOILS
The Cedartown Industries Site geology was determined from
regional geological information and from Site-specific data
. gathered during the-Remedial Investigation (Rr). .
.-
The Cedartown Industries Site is located within the Valley and
.. Ridge Province of northwestern Georgia. The bedrock in the
region is composed of Paleozoic marine and continental sediments
that were folded and faulted during polyphased Appalachian
or",genesis.
The Ordovician Newala Limestone forms the bedrock under the
majority of Cedartown, and the Cambrian to Ordovician
undifferentiated Knox Group comprises the bedrock along the
eastern side of Cedartown. The Newala Limestone consists
predomdnantly of limestone with lesser dolomdte in the Cedartown
area.
The Knox Group is composed of three formations: the Late Cambrian
Copper Ridge Dolomdte, the Early Ordovician Chepultepec Dolomite,
and the Early Ordovician Longview Limestone. All three of the
formations that represent the Knox Group are lithologically.
similar. These units are generally light to medium gray, cherty,
and, in. the Cedartown area, are dominated b¥ dolomdte.
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Residuum developed over the Knox Group is reportedly as thick as
300 feet, normally ranging from 50 to 150 feet thick, and the
Newala is commonly covered by a residuum 25 to 150 feet thick.
Structurally, the outcrop pattern of the bedrock in western
Cedartown appears to be controlled largely by a south to
southwest-trending syncline that plunges to the south. The axial
trace of the syncline is just to the west of the Cedartown
Industries Site and nearly corresponds to the stream bed of Cedar
Creek at the Site.
The dominant topograp~ic trends in the bedrock surface under the
Site are generally east-west or east-northeast and west-
southwest. Maximum local relief on the bedrock surface is about
35 feet based on borehole data. It appears that the bedrock
'-'surfa'ce -may -be"-characterized by. broad topographic highs
interrupted by narrow, linear, topographically low areas with
relatively steep sides. Some of these vertical features may be
connected to lateral solution voids in the upper portion of the
bedrock.
The upper surface of the bedrock is relatively unweathered.
There is no identifiable transition zone of saprock (weathered
boulders of limestone in a matrix of residuum) above the bedrock
surface. Immediately overlying the limestone bedrock is a
sequence of unconsolidated sediments ranging from seven feet
thick to more than 45 feet thick. The sediments. are dominated by
. .. . silty clays .and clayey... to' sandy silts. . 'Compositional variations.:
consistent with bedding are apparent in some of the sediments,
but many of the sediments are unstratified based on inspection of
. recovered material.
It appears that a considerable portion of the near surface soils
at the Site was fill emplaced both prior to and after its use as
a lead smelter. Many of the soils at the Site contain no primazy
structures.. Any backfill used at the Site likely would have been
removed from local 'borrow pits, thus these materials would be
compositionally consist.ent with locally derived material. Fill.
at some portions of the Site appear to be at least 14 feet thick.
Soils derived from flood plain and channel deposits of Cedar
Creek are widespread at the Site and fo~ the bulk of the native
soils. In general, the alluvial deposits are moderately to
poorly sorted. These alluvial deposits are composed of sands,
silts and clays, and pebble to gravel rich strata.
Where the bedrock surface is topographically low, the alluvial
deposits are dominated by relatively clean silty sands. These
. . sands. extend. to depths greater. .than 45 feet below surface in an
~rea trending east-west across the Site.
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Most of the soils tested are assigned to the CL group of the
United Soil Classification System, based upon the Atterberg
limits. Natural mois~ure ranged from 15.1 percent to 45.0
.percent. Reported saturated hydraulic conductivities ranged from
1.06 x 10-. em/see for a silty sand to sandy silt to 2.65 X 10-8
em/see for sandy silt.
Surface soil samples collected for laboratory analysis appeared"
to be largely represented by fill material. Thus, individual
surface soil samples were not characterized within the context of
the USDA/SCS soil classification system.
5.2
HYDROGEOLOGY
. '...""There .are .'two-distinct "units within . this karst aquifer at the
Cedartown Industries Site. These units are hydraulically
connected, but represent differing lithologies. The uppermost or
surficial portion of the aquifer at the site resides in the
unconsolidated sediments and represents the entire thickness of
the sediments. The underlying hydrogeologic unit is the bedrock
portion of the aquifer. The Newala Limestone in Polk County
carries substantial groundwater in secondary features,
predominantly solution-enlarged fractures. Existing site bedrock
wells are screened in clean, open fractures, in solution modifi.ed
fractures, and in voids, but generally produce low volumes of
water. Information from existing site wells and borings
indicates :that.thebedrock hydraulics are variable, and are
largely dependent upon nature of the water bearing structure
(i.e. solutionally enlarged fracture development) and its
position relative to the bedrock surface.
,
The bedrock or underlying portion of the aquifer is the primary
source for drinking water wells and the source for Cedar Spring
located upgradient from the Site. Groundwater at the Site is
present under unconfined conditions. Surveying demonstrated that
the maximum potentiometric surface.observed at the Site is
generally lower than the elevation of Cedar Spring. This means
that groundwater flows from Cedar Spring to the Site, rather that
from the Site to Cedar Spring.
5.2.1
SURFICIAL UNIT
Wells screened in the unconsolidated sediments are generally 15
to 20 feet deep. The potentiometric data from the Site suggested
...that . the surficial. aquifer is discharging to. Cedar Creek. The
creek bed at this location appears to be developed on the bedrock
surface. The surficial unit is likely recharged ~ precipitation
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Cedartown Industries Site
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at unpaved areas of the Site and by lateral groundwater flow from
the east. northeast. and southeast.
Hydraulic conductivity v~lues ranged from' a high of 3.335 x 10-3
em/see to a low of 9.797 x 10-5 em/sec. These values are typical
for silty to clayey sands.
5.2.2.
BEDROCK UNIT
Full characterization of the hydrogeology of fractured rocks is
difficult because different fractures may exhibit varied'
hydraulic characteristics depending on such factors as their
geometry, location, and extent. Wells were screened in the
bedrock at the Site. Although the bedrock at the Site is herein
. " -- treateduas "one-system,"-it.. can --be-viewed as containing two
geologic components.
The upper portion of the bedrock aquifer or upper bedrock unit
contains more extensive solution cavities.and extends as bedrock
pinnacles into the overlying unconsolidated sediments. Because
most of the solution voids in this portion of the bedrock are
filled with sediments and the pinnacles are apparently
intersected by fractures, this portion of the bedrock is probably
hydraulically interconnected with materials in the uppermost
unit. Groundwater in the upper bedrock unit freely communicates
with the surficial zone and groundwater quality is similar in ..
poth zones,.therefore,.the.unconsolidated sediments and the_upper
bedrock Unit are hydraulically interconnected.
Field investigations indicated that the bedrock below a depth of
about 70 feet represents a different. component of the bedrock
geologic system. Deep bedrock monitoring wells were installed
with an outer casing extending to approximately 70 feet and were
screened at a depth of approximately 100 feet. These wells were
...designed.to monitor portions of the. bedrock that may not be
directly hydraulically interconnected with the overlying
unconsolidated sediments due to the reduced number of fractures,
reduced groundwater flow, and reduced interconnectedness.
Results of water level measurements indicate that groundwater
elevations were inconsistent in relation to the extrapolated
elevation of the potentiometric surface of the surficial unit.
This is not uncommon in karst. hydrogeologic settings. The
chemistry. of -groundwater samples from these wells was found to be
substantially different that the chemistry of groundwater from
the wells in ..theupperbedrock . unit . This is attributed to the
reduced fracture development and connectivity of pore space.
Data also indicates there is a measurable upward gradient from
the bedrock unit to the unconsolidated portion of the aquifer.
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5.3
SUMMARY OF SITE CONTAMINATION
An Interim Waste removal project was completed in May 1990 and
removed slag and coke 'storage piles, contaminated debris and
soil, wastewater, and impoundment sediment from the Site. A
total of 6,700 cubic yards of solid hazardous materials
(approximately 8,380 tons), including slag, soil, sediment, and
debris in addition to 62,225 gallons of liquid waste were
removed.
The Remedial Investigation was initiated in 1991. RI sampling,
conducted in three ph~ses from June 1991 to July 1992, focused on
areas related to for.mer smeltering operations and areas impacted
from the Interim Waste Removal. The soils and groundwater at the
Site have been impacted by past industrial and waste practices at
, - ,. ,-'the"'Site~"-"-rhe'vertical'and horizontal. extent of contaminants
have been defined. Table 5-1 and Figure 1 defines the sampling
matrix and locations for the RI.
5.3.1
SUBSTANCES DETECTED IN SOILS
Of greatest concern are surface and subsurface soils over most of
the Site exhibiting elevated levels of heavy metals, most notably
lead. In general, subsurface soils have not been impacted at
depths greater than four (4) feet. However, in one location,
lead is present in elevated concentrations to a maximum depth of '
eight (8) feet.
Although all visible waste.was removed during the interim waste
, -, 'removal proj ect, '.additional sampling was conducted during the RI
to deter.mine if residual contamination remained in the soil. '
Additional surface and subsurface soil samples were collected
during the three phases of RI field work to more thoroughly
,assess, the nature and extent of Site contamination. A total of .
50 surface soil samples were collected from 46 locations on site
and from four background locations situated to the west of the,
Site. A total of 80 subsurface soil samples were collected from
20 soil boring locations. The soil borings ranged from 6.5 to
12.4 feet deep. Figure 5-1 indicates lo~ations of surface and
subsurface soil sampling locations.
Based on past Site activities, it is not surprising that lead is
a widespread soil contaminant. In surface soil samples, lead
concentrations ranged from below the detection limit of 6 mg/kg
:, in several samples to 260,000 mg/kg in sample SG-43. In general,
lead concentrations decreased with depth. With one exception,
sample BH-7, no lead concentrations in excess of 500 mg/kg'were
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FIG'O'RB 5-1
SITE MAP: SURFACE SOIL, SURFACE WATER, SEDIMENT SAMPLE,
MONITORING WELL, AND SUBSURFACE BORING LOCATIONS
~
II
II
I'
II
II
,I
II
.,
....
-
. .
.....
_II
. .....
. .....
V\I
-......
"",
,
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I TABLE 5-1 I
SUMMARY OF ANALYSIS FOR EACH MEDIA
Metals Analysis TCL/TAL Total Metals Ta.P SPLT Other .
Surface Soils 13 40 20 28 -
Subsurface Soils 11 15 51 - 5
Sediment 4 9 4 - -
Surface Water 4 5 - - -
Groundwater 6 22 - - -
Air Samples 14 28 - - -
. Includes solbed metals, PEOC, and CEC £or soDs
present below a depth of 4 feet. Samples collected on all four
sides of sample BH-7 contained less than 100 mg/kg lead at depths
greater than 2 feet, suggesting that elevated lead concentrations
. at depths greater than 2 feet were restricted to the area.
inunediately adjacent to BH-7. Two other lead subsurface .hot
spots. were located at BH-4 and BH-5. At BH-4, lead was present
. at concentrations of up to 26,500 mg/kg (2-4 feet), and at BH-8,
the maximum concentration was 4,290 mg/kg. Not only was
contaminated soil found within fenced portions of the Site, but
an area south and east of the fenced perimeter also showed
slightly elevated (but less than 800 mg/kg) lead concentrations
in the surface soil. Background lead concentrations (determined
from samples BG-1, BG-2, BG-3, and BG-4) ranged from 19.1 to 78.6
mg/kg.
Surface soils at the Site exhibited slightly elevated cadmium
concentrations (greater than 40 mg/kg) a~ only one location,
SG-15. Three cadmium hot spots (i.e., concentrations exceeding
AO mg/kg) were identified in subsurface soils, and a~l three were
within the boundaries of the former waste piles. Sample BH-14
contained cadmium at concentrations up to.45.1 mg/kg. Samples
BH-4 and BH-8 contained cadmium concentrations of 170 and 362
mg/kg, respectively. . Background cadmium ranged from 0.46 to 0.64
mg/~. .
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Four areas of elevated antimony concentration were identified in
Site surface soils. Three of the four areas were within the
boundaries of the former waste piles. No subsurface soil samples
contained antimony at concentrations greater than 30 mg/kg.
Concentrations of antimony ranged from below the detection limit
of 2.3 mg/kg to 330 mg/kg in sample SG-21. Background antimony
concentrations ranged from the detection limit to 5.2 mg/kg.
In surface soil, arsenic was detected above 80 mg/kg in only one
location,SG-15, where a concentration of 285 mg/kg was recorded.
!!'his location was also a hot spot for cadmium. Elevated levels
of arsenic were present in only one subsurface soil sample, BH-4,
at a depth of 0-2 feet. Since BH-4 is located only 20 feet west
. of SG-15, it appears that the two samples represent the same hot
spot. Arsenic concentrations in background samples ranged from
.3.2 to 6.4 mg/kg.
Beryllium was detected in surface soil in every sample collected.
Concentrations ranged from 0.4 mg/kg in background sample BG-01
to 9.1 mg/kg in SG-09. Likewise, beryllium was present in
elevated concentrations in most of the subsurface soil samples,
ranging from 0.15 mg/kg in several sample locations to 11.3 mg/kg
in BH-10. The wide spread presence of elevated beryllium
concentrations below 2 mg/kg does not seem to be related to past
or present waste disposal activities at the Site. Sediment data
collected in Polk County as part of the National Uranium Resource
Evaluation (NURE) program, in addition to site background
sampling data, indicates that elevated beryllium concentrations .-
are present throughout the Cedartown area.
The. primary soil contaminants identified as associated with the
Cedartown Industries Site were the presence of high levels of
metals (antimony, arsenic, beryllium, cadmium, chromium, and
ie~d) in surface and subsurface soils. Table 5-2 show the
concentration levels of substances detected and utilized for the
Baseline Risk Assessment (BRA) potential contaminants of concern
in surface and sub-surface soils.
5.3.2
SUBSTANCES DETECTED IN THE GROUNDWATER
To investigate the quality of groundwater beneath the Site,
shallow and deep groundwater monitoring wells were installed in.
the surficial and bedrock aquifer units to monitor the water
bearing zones. Shallow wells were installed to monitor water
quality in the unconsolidated portion of the aquifer. In
addition to the shallow wells, one deep bedrock well was
installed during each of the first two RI phases, and two bedrock
monitoring wells were installed during phase III. The
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TABLE 5-2
CEDARTOWN INDUSTRIES SITE: SUMMARY OF POTENTIAL CHEMICALS OF CONCERN
DETECTED IN SOILS DURING THE REMEDIAL INVESTIGATION
RESUL1S FROM OIEMICAL NUMBER OF RESULTS FROM CHEMICAL NUMBER OF sons BACKGROUND
ANAL~ OFSURPACE DETa:'lICN:; ANALYSIS OF SUB-SURFACE DEI'ECIIONS RESULTS
sons sons
OIEMICALS RANGE OF RANGE OF RANGE OF
CD'lCENTRA1"IQ\6 cx::NCEN1'RA1"IQ\6 ~CENTRA11ONS
DE1'EC1'ED(mg/kg DE'I'EC'ImXmsJkg DE1'EC1'ED(mg/kg
VOLA11LE ORGANICS
Acetaae .125- - .730 4/9 .«S- - 1.0 4/11 .13- - .18
. . 2-ButaDoDe " '. '.-JJ82 4/9 ND ND .CI5P - .CB2
Beazene .008 - ZJ!> 2/9 ND ND .028. - .~
I,3-DicbJorobenzene ND ND .002 1/1 ND
TrichJOJoBuaromelhaue ND ND .00r - 1.5 6/6 ND
SEMIVOLAm.E ORGANICS
Benzo(a)anthracelle ND ND ,w - .21 1111 ND
Benzo(b)fJuorantheae ND ND .15 -.36 2/11 ND
BeIIzoOOfIuoranthene ND ND .16 - .36 2/11 ND
BeIIzo(a)pyrene ND ND .14 -.36 2/11 ND
8eazo(g,h,f)per ND ND .14 - .36 2/11 ND
QzyIeae ND ND 'w-33 111 ND
Fh101'1Q1tMfte ND ND . .aT4 - A2 2/11 ND
.1DdeD~ ND ND :g. - .36 1111 ND
Pyrene ND ND .11 - AO 2111 ND
INORGANICS
Alumfnum smo - 21900 'Zl/'Z1 4900 - la1000 80/80 4960 - 96?0
Antimony ~ - 361 13/'Z1 2.r - 129 30/80 23.-5.2
AzseuIc 2-285 'Zl/'Z1 1.70 - 142 80/80 3.2 - 5.5
Barium 32 - 5S4 'Zl/'Z1 11.6 - 4080 fA>/80 47 - 72.6
BeryIUum .38 - 9.1 'Zl/'Z1 .(1;9 - 11.3 80/80 .4 - .56
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TABLE 5-2
CEDARTOWN INDUSTRIES SITE: SUMMARY OF POTENT1AL CHEMICALS OF CONCERN
DETECTED IN SOILS DURING THE REMEDIAL INVESTIGATION
RESUL1S FROM CHEMICAL NUMBER OF RESUL1S FROM amdICAL NUMBER OF sons BACKGROUND
ANALYSIS OF SURFACE DETEC'I1ONS ANALYSIS OF SUB-SURFACE DETECI10NS RESUL1S
sons . SOIlS
CHEMICAlS RANGE OF RANGE OF RANGE OF
CONCENTRATICNS CONCENTRA~ CONCENI'RATICNS
D~ DETECI'EDCJDg/kg DETECI'EDCJDg/kg
Cadmium oW - 46.2 11/'Z1 A3- - 3Q 58/80 oW
0\r0m1um U - 69.4 'Z7/'Z1 3.2 - SU 80/80 12.2-13.9
Cobalt U - 293 'Z7/'Z1 .95 - 31.8 80/80 4.8-7.4
CQpp« 8.6 -1510 'Z7/'Z1 3.2- - 1150 71/80 6.5-20
Cyudde 2.58-6.2 1/9 2.58-1.5 9/18 :z.s.
Lead 18.8 - 260000 49/49 S.1 - 21100 80/80 19.1 - 31.9
Manganese 1510 -1630 'Z7/'Z1 14,9 - 2840 80/80 446 - 492
Mercury .m8 - .16 16/11 .az- - :za 41/~ JB - .0&
Nlcbl 6.1 - 83.9 21!1/'Z1 3.7'" . 808 71/80 3.3 - 8.3
SeJenfwn .61- - 1 3/11 .6&8..81 1/4'7 r-s-
Silver .558 - 3.1 18/'Z1 .548 - 105 25/80 ND
1baDium .22S. 1.3 8/11 A3- . 2.5 24/~ oW
Vaadium 12A - 62.1 'Z7/'Z1 11.2 . 65.2 80/80 13.1-19.2
Zinc 40..4 - 2170 'Z7/'Z1 11.6 . 6710 79/80- 18.1 - 39.1
. Below die IIadt of ~... far the I8IDpIe
purpose of these deep wells was to assess the character of the
deeper bedrock groundwater and to assess whether the Site has
impacted this groundwater. Deep wells were a150 installed to
determine any interconnection between the surficial and bedrock
units, since an objective of the RI was to assess the potential
impact of the Site on the drinking water supply (Cedar Spring)
for the City of Cedartown.
Results indicated that with the exception of one shallow well,
groundwater- quality has not been affected by the Site. The
effective absence of measurable COCs above their respective
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Cedartown Industries Site
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maximum concentration level in all but one well in the surficial
unit and upper bedrock unit indicates that a slight quantity of
metals have leached into these units and should not significantly
impact Cedar Springs, Cedartown's source of drinking water.
Furthermore, the upward gradient from the bedrock unit to the
. unconsolidated sediments indicates that if' groundwater does move.
from one zone to the other it would be upward from the bedrock to
the overburden, naturally protecting the water quality in the.
bedrock. A shallow well located between the Site and Cedar
Spring, displayed no concentrations of metals. In addition, the
surveyed elevation of Cedar Spring is higher than the groundwater
elevation at the Site. The results of the RI therefore indicate
that the Site does not currently threaten the water quality of
Cedar Spring. While groundwater from the Site discharges to
Cedar Creek through the surficial unit, based on the sampling
.L. -. "'... analysis ,-"'Cedar""Creek' appears' not. to.. have been impacted by the
Site.
Although sampling of the upper bedrock unit of the aquifer did
reveal detectable concentrations of various contaminants, the
concentrations were well below Maximum Concentration Levels
(MCLs) and Applicable and Relevant and Appropriate Regulations
(ARARs). Sampling data from the lower bedrock unit indicate that
contaminated soils and waste have not impacted this portion of
the aquifer.
The data collected during phase I and phase II sampling suggested
.-..,. .that the.surficial.unit..hasbeen.impactedby various...heavy.., -. -".-.
metals. However, phase III sampling, which included a resampling
of all phase I and II wells, detected elevated concentrations of
metals in only one well MW-4. The lack of elevated
c09centrations of constituents reported during phase III sampling
may be attributed to sampling methods from phases I and II to
phase III. Sampling from the top of the water column and the use
of a peristaltic pump and low flow purging and sampling
techniques during phase III appears to have eliminated suspended
particulates in the groundwater and provided a more
representative indication of groundwater concentrations of metals
and other constituents. Thus, results of phase III sampling
indicate that past waste management practices at the Site have
only adversely impacted the surficial aquifer unit as evidenced
by elevated metal concentrations with well MW-4 exceeding the MCL
for cadmium. See Figure 5-1 for locations of monitoring wells.
Phase I sampling indicated that lead was present in all
monitoring wells at concentrations greater than the Safe Drinking
Water ~ct Action Level of 0.015 milligrams per liter (mg/l).
During ~hase II sampling lead concentrations ranged from a low of
0.002 mg/l in well MW-IC to a high of 0.127 mg/l in MW-7. .
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.- '. -'. ". '.
. However, MW-7 was a background well installed on adjacent
property (Goldkist). MW-7 was resampled prior to initiating
phase III work using a peristaltic pump and low flow techniques,
and the results (lead at a concentration of 0.0057 mg/l)
indicated that the elevated lead concentration' reported in phase
II was the result of naturally occurring lead containing
particulates suspended in the groundwater sample. With one
exception, lead concentrations decreased from phase I to phase II
sampling. During phase III, lead concentrations were reported
below the detection limit 'of 0.001 mg/l in all wells sampled,
with three exceptions: MW-1, MW-4, and MW-9.
During phase I sampling, cadmium was present above the detection
limit of 0.004 mg/l in four out of six wells and was greater than
or equal to the MCL of 0.005 mg/l. Phase II sampling indicated
. that "'only one' well, MW-4, contained cadmium. above the analytical
detection limit. Phase III sampling lead concentrations and
analysis showed only well MW-4 above the detection limit. The
cadmium concentration in this well, 0.0206 mg/l, is approximately
four times greater than the MCL of 0.005 ~g/l.
.
Phase I sampling revealed that all six wells contained chromium
at concentrations above the detection limit but below the MCL of
0.10 mg/l. Phase II sampling showed only one well (MW-2) with
slightly elevated chromium levels. Concentrations for the 10
phase II wells sampled ranged from below the limit of detection
to 0.153 mg/l in MW-2. Phase III sampling indicated that three
. .surficial wel~s ..contained .chromium.above .the . detection -limit.. but.
below the drinking water standard for chromium.
Elevated beryllium'concentrations (i.e. greater than the
beryllium MCL of 0.004 mg/l) were reported in three of six wells
tested during phase I sampling. Beryllium concentrations were
0.012 mg/l in MW-6, 0.006 mg/l in MW-3, and 0.005 mg/l in MW-2.
Although the concentration levels were below the MCL, the same
'. three -wells. contained beryllium above the detection . limit during
phase II sampling. Concentrations during this phase of sampling
ranged from below' the detection limit in six wells to a maximum .
of 0.003 in wells MW-2 and MW-3. During phase III sampling and
analysis, no concentrations of beryllium greater than the
detection limit were recorded in any monitoring wells.
Table 5-3 show the concentration levels of substances detected
and utilized for the Baseline Risk Assessment as potential
contaminants of concern in groundwater.
The total estimated volume of contaminated groundwater beneath
the Site in the surficial unit is 0.5 million gallons.
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TABLE 5-3
CEDAR TOWN INDUSTRIBS SID: SUMHAllY 01' POTBNT:IAL CHBHICALS 01' CONCERN
DBTECTED IN GROUNDWATER DORING THB RBMBD:IAL INVESTIGATION
RESULTS FROM CHEMICAL ANAL~ OF NUMBER OF RESULTS FROM OiEMICAL ANALYSIS OF
GROUNDWATER . DETECI10NS BACKGROUND SAMPLES
amdICAlS RANGE OF a:>NCEN'I'RA1tCIIS RANGE OF CDNCEN'mAnONS
DB'I'ECIED(mg/D DETEC'IED(mg/J)
Aluminum .an - 108 1113 :ns
Anemc .001 - JI06 5/13 .001- - .cxrz-
Barium .001 - .211 12/13 .0193
Ouf..mDn .00& - .an 1/13 ' .001-
Caprolaclam .011- .200 4/4 ND
CIromium .00& - J1lS 1113 .00&- - .CM38
Cobalt .00& - JI06 1/13 .em-
Coppc .ooz - .D18 4/13 .JX116
Lead .001 -.oos 1/13 .001- -.127
MmpD88 .001 - 3.48 12/13 .119
NIckel .CJ11- .141 9/13 .246
Silver .00& - .D13 2/13 .0083
Vanadium .005 - .D1S 2/13 .em-
23Dc: .015 - .161 4/13 JM.1
- Below the JImit of ...........11- - the sample
5.3.2.1
FATE AND TRANSPORT
Although elevated levels of heavy metals are present in the soil,
data indicate with the exception of cadmium in one well, there
has been no adverse impact on groundwater. No potable wells are
currently located on site. Exposure to contaminated groundwater
may result if a drinking water or domestic use water well is
installed in a water bearing zone which is known to be
contaminated. . The cadmium contamination in this one well appears
to be confined to the Site and only in the upper aquifer.
Because the groundwater is flowing towards Cedar. Creek, there is
a mechanism for contaminant migration to surface water (Cedar
Creek) and sediments. However, data and modeling indicate that
the contamination level attenuates to below Georgia Water Quality
Standard prior to reaching the creek. Modeling shows attenuation
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~o this standard occurs 130 feet from this well which is located
342 feet from Cedar Creek.
5.3.3
SURFACE WATER AND SEDIMENTS INVESTIGATION
Analytical data collected from the RI- indicates that surface
water and sediments have not been adversely impacted ~
contaminants on the Site.
Water and sediment samples were collected from Cedar Creek at
three locations during phase I of the RI. Water samples were
collected at five locations, and sediments were collected at nine
locations during phase III of the RI better de~er.mine contaminant
concentrations in sediments as indicated in Figure 5-1.
During phase I sampling of surface water, lead was reported above
the detection limit of 0.001 mg/l at 0.0012 and 0.0016 mg/l in
only two samples. During phase III water sampling, .lead was
reported above the detection limit in fou~ of five surface water
samples ranging from 0.0015 mg/l to 0.0021 mg/l. one
semi-volatile compound, bis(2-ethylhexyl)phthalate was detected
in surface water samples, including the background sample.
Concentrations ranged from 0.037 mg/l to 0.19 mg/l (background).
All reported concentrations of all contaminants were below their
respective Georgia Water Quality Standard.
:Phase I and phase .III..sediment samples revealed lead . .
concentrations ranged from 17.3 mg/kg to 51.2 mg/kg. Sediment
background samples for lead ranged from 19.5 to 35.9 mg/kg.
. Phase III sediment samples were above the National Oceanic and
Atmospheric Administration Effects ~nge-Low (NOAA ER-L)
concentration of 35 mg/kg. NOAA defines ER-L values as the.
concentrations equivalent to the lower 10 percentile of screened
available data at which effects were observed or predicted among
sensitive aquatic biota. Beryllium was detected in phase III
sediment samples; 'however, these concentrations were all within
the documented background based on soil site'specific data and
from the NURE (National Uranium Resource Evaluation) survey of
Polk County. Arsenic was detected in samples ranging from 2.10 -
21.7 mg/kg; with a 95% UCL of 17.0 mg/kg. however, the Site
specific background was 12.1 mg/kg.
In order to assess the benthic fauna characteristics 'of Cedar
Creek, a 'benthic macroinvertebrate sampling' and survey was.
conducted. The survey was conducted as a Rapid Bioassessment
Protocol III. Because macroinvertebrate are found in all aquatic
habitats, are less mobile than most groups of aquatic organisms, .
and have a relatively long periods of deve~opment in aquatic
.-.
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environments, macro invertebrates are indicative of the health of
a stream. The results of a conducted benthic macroinvertebrate
study concluded that fair conditions predominate the aquatic
environment.
5.3.4
AIR PATHWAY INVESTIGATION
Air is a potential route for migration of contaminants through
airborne contaminated dust and soil. Since the waste and most
contaminated soils were removed, and a majority of the Site has
been paved or covered. with clean soil and/or crushed stone, the
potential for air transport is low.
6..0
. 'SUMMARY OF SITE RISKS
CERCLA directs EPA to conduct a Baseline Risk Assessment (BRA) to
determine whether a Superfund Site poses a current or potential
threat to human health and the environment in the absence of any
remedial action. The baseline risk assessment provides the basis
for determining whether or not remedial action is necessary and
the justification for performing remedial action.
6.1
CONTAMINANTS OF CONCERN (COCs)
,-
. _. The. chemicals' measured in. .the.various- .environmental : media during'.,.
the RI were evaluated for inclusion as chemicals of potential
concern in the risk assessment b¥ application of screening
criteria~ The .criteria'which resulted in elimination of
chemicals included:
.
Site contaminant concentrations below background
concentrations;
.
measurements below quantification limits; quantative
data on risks including combination of low toxicity and
low concentration and low concentration and low
frequency of detection; and
the degree in which one chemical may substitute for a
class of related chemicals based on toxicological
similarity.
.
As a result of applying the above listed criteria, Table 6-1
lists the potential contaminants of concern associated with the
Cedartown Industries Site and selected as a 'basis for performing
the BRA. The chemicals listed in Table 6-1 are of greatest
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concern because of their toxicity, their relation to background
~oncentrations, their prevalence on site, and the likelihood of
human exposure.
TABLE 6-1
CEDARTOWN INDUSTRIES SITE: SUMMARY OF POTEN11AL CHEMICALS OF CONCERN
CHEMICALS POn'.NTIAL aiEMICALS POTENTIAL amMICALS P01'EN'I1AL amMICAlS POTEN'I1AL amMICALS
OF CONCERN IN SURFACE OF c:cNCERN IN OF CONCERN IN OF CDlCERNIN
sons SUBSURFACE SOlIS SEDIMENTS GR.OUNDWA1ER
VOLA1U.E ORGANICS
Acetone . .
. 2-Butanone .
Benzene .
l~DidaJorobeazene .
~umometbme .
SEMlVOLA1U.E ORGANICS
BeDzo(a)anthracene .
BeIIzo(b)fJuonnthelle .
. BeIIzo(k)fIuoraDIhene .
Benzo(a)pyrene .
Benzo(g.h.i)per .
Chrysene .
FJuaranthene .
Jndeno(1~ .
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TABLE 6-1
CEDARTOWN INDUSTRIES SITE: SUMMARY OF POTENT1AL CHEMICALS OF CONCERN
CALS POTENTIAL OiEMICALS POTENrIAL CHEMICALS POTENTIAL CHEMICALS P01FNl1AL CHEMICALS
OF CONCERN IN SURFACE OF CONCERN IN OF CONCERN IN OF CONCERN IN
sons SUBSURFACE sons SEDIMENTS GROUNDWATER
Pyrene .
INORGANICS
Aluminum . . .
ADllmclDy . .
Ameak: . . .
Barium . . .
BeryDium . .
r~~1ID . . . .
CIromium . . .
Cobalt . .
Copper . . .
Cy.mide . .
Lead. . . .
Mangmese . . . .
Mercury . .
NUb! . . .
~h.... . .
SilYK . . .
TbaDium . .
Vanadium . . .
ZJnc . . .
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6.2
EXPOSURE ASSESSMENT
Whether a chemical is actually a concern to human health and the
environment depends upon the likelihood of exposure~ i.e. whether
the exposure pathway is currently complete or could be complete
in the future. A complete exposure pathway (a sequence of events
leading to contact with a chemical) is defined by the following
four elements:
.
A source and mechanism of release from the source;
.
a transport medium (e.g., surface water, air) and
mechanisms of migration through the medium;
the presence or potential presence of a receptor at the
. exposure point; and
.
a route of exposure (ingestion, inhalation, dermal
absorption) .
If all four elements are present, the pathway is considered
complete.
.
The four major constituent release and transport mechanisms
potentially associated with the Site are as follows:
.
The infiltration of precipitation through the affected
soils. and the percolation of the resultingleachate-"
into the shallow groundwater, followed by groundwater
transport;
.
release of affected surface soil through wind erosion
and fugitive dust generation. Surface soils could be
suspended in air and transported from their source by
the wind;
.
contaminated soil from the source areas des orbing into
other soils; and .
release of affected surface soil thiough surface water
run-off and groundwater seepag~..
.
Because the ground cover (gravel and pavement) present at the
Site will impede wind erosion, exposure to constituents in air,
as dust, is not considered significant at the Site under current
land use conditions.
An evaluation was undertaken of all potential exposure pathways
which could connect chemical sources at the Site with potential
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receptors. All possible pathways were first hypothesized and
evaluated for completeness using the above criteria. Seven
current potentially complete exposure pathways and eight future
exposure pathways remained. after screening. The current pathways
represent exposure pathways which could exist under current Site
conditions while the future pathways represent exposure pathways
which could exist, in the future, if the current exposure
conditions change. While the Cedartown Industries Site is
currently being utilized as a truck parking area, it is located
nearby to residentially zones properties. Therefore, residential
exposures were evaluated to be protective of possible residential
development. Exposure by each of these pathways was
~thematically modeled using generally conservative assumptions.
The current pathways are:
.
Potential ingestion and dermal exposure of soils and
sediments by a trespasser;
.
potential inhalation of particulate chemicals in air by
a trespasser;
.
potential inhalation of vapor phase chemicals from soil
by a trespasser;
potential inhalation of particulate chemicals in air by
workers;
.
.
potential inhalation of vapor phase chemicals from soil
by workers;
potential ingestion and dermal exposure of soils and
sediments by workers; and .
.
.
. potential ingestion of sediments and surface water by
terrestrial and aquatic biota. .
The future pathways
are:
.
Potential ingestion and dermal exposure of soils and
sediments by residents;
.
potential inhalation of particulate chemicals in air by
residents;
.
potential inhalation of vapor phase chemicals from soil
by residents;
potential ingestion inhalation exposure to groundwater
.
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by residents;
.
potential inhalation of particulate chemicals in air by
workers;
.
potential inhalation of vapor phase chemicals from soil
by workers;
.
potential ingestion and dermal exposure of soils and
sediments by workers; and
potential ingestion exposure to groundwater by workers.
.
The exposure point concentrations for each of the chemicals of
-, concern 'and" the -exposure ""assumptions for each pathway were used
to estimate the chronic daily intakes for the potentially
complete pathways, with the exception of the groundwater pathway.
The chronic daily intakes were then used in conjunction with
cancer potency factors and non-carcinogenic reference doses to
evaluate risk.
The reasonable maximum exposure (RME) was used to develop
exposures at this Site. In this assessment, the 95% upper
confidence chemical concentrations were used for exposure. For
soil exposures by inhalation and oral routes, it was assumed that
chemicals by these routes were completely absorbed.
The major assumptions about exposure frequency and duration that
were included in the exposure assessment were:
.
The most likely trespasser is a child;
the trespasser will spend equal time on all areas of
the Site;
.
.
the trespasser will visit the Site 80 days/year for
nine years (age 6-14);
the average body weight of the trespasser is 35 kg;
.
.
the ~esident will spend 350 days per year on site;
the resident child lives on the Site for a seven year
period and resident adult lives on the Site for 30
years;
.
.
the average weight of the child and adult is 16 kg and
70 kg, respectively;
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.
the individual expected to have the highest exposure
under a commercial-use scenario is a worker;
.
the worker's weight is assumed to be 70 kg;
.
the worker's exposure period is estimated to be 25
years; and
the worker's exposure frequency is anticipated to be
250 days per year.
The baseline risk assessment considered three land use scenarios
without the added protection of any .remedial action: current
land use, future commercial land use, and future residential land
use.
.
6.3
TOXICITY ASSESSMENT
Toxicity values are used in conjunction with the results of the
exposure assessment to characterize Site risk. EPA has developed
critical toxicity values for carcinogens and non-carcinogens.
~ancer potency factors (CPFs) have been developed 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 conservative approach makes underestimation of the
actual cancer risk highly unlikely. Cancer potency factors are
derived from the results of human epidemiological studies or
ch~onic animal bioassays to which animal-to-human extrapolation
and uncertainty factors have been applied.
Reference doses (RfDs) have been developed ~ EPA for indicating
the potential for adverse health effects from exposure to
chemicals exhibiting non-carcinogenic 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 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 non-
carcinogenic effects to occur. Exposure point concentrations,
CPFs and RfDs for the COCs exceeding, acceptable risk levels are
shown in Table 6-2.
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TABLB 6-2
EXPOSORB POINT CONCENTRATIONS, RfDa, AND CPPa POR COCa EXCEEDING
ACCEPTABLB RISK LEVELS
/Arsenic ktimony Beryllium kadmium Lead
RME 1 Point Concentration
Subsurface Soils 11.2 5.51 1.56 6.39 404
Surface Soils 36.5 210 3.05 11.1 20,273
Groundwater 0.002 N/A N/A 0.005 0.004
Surface Water N/A N/A N/A N/A 0.002
. Sediments 17.0 N/A 1.24 0.720 39.5
RfDs Values 2
Dermal 2. 7X10-' 4. OX10-6 2. 5X10-s 2 .5X10-s N/D '
Inhalation N/D N/D N/D N/D N/D
Oral 3. OX10-' 4. OX10-' 5X10-3 5X10-' N/D .
CPF Values 5
Dermal 1.9 N/A 8. 6X10.2 N/A N/A
Inhalation 6 .5.0X10.1. N/A 8.4 .6.1 N/D ' ..
Oral 1.75 N/A 4.3 N/D N/D .
N/A Not Applicable
~/D USEPA slope factors or references doses were not available.
1 Reasonable Maxim\DD Exposure defined as the 95% upper confidence chemical
concentration.
~ Reference doses (RfDs) have been developed by EPA for indicating the
potential for adverse health effects from exposure to chemicals exhibiting
non-carcinogenic effects. Adapted from USEPA IRIS, 9/1992 unless
otherwise noted.
3 Dermal Reference doses calculated by multiplying the oral reference dose
by the GI factor as referenced in BRA Table 6.4.3 in the RI.
f4 Toxicity was determined by applying IU/BK model.
5 Cancer potency factors (CPFs) have been developed for estimating excess
lifetime cancer risks associated with exposure to potentially carcinogenic
chemicals. Adapted from USEPA IRIS, 9/1992 unless otherwise noted.
6 CPF for Arsenic determine from USEPA Health Effects SUmmary Table (1992)
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6.4
RISK CHARACTERIZATION
Human health risks are characterized for potential carcinogenic
and non-carcinogenic effects by combining exposure and toxicity
information. Excessive lifetime cancer risks are determined by
multiplying the estimated daily intake level with the cancer
potency factor. These risks are probabilities that are generally
expressed in scientific notation (e.g., lx10-6). An excess
lifetime cancer risk of 1x10-6 indicates that, as a plausible
upper bounda~, an individual has a one in one million additional
(above their normal risk) chance of developing cancer as a result
of Site-related exposure to a carcinogen over a 70-year lifetime
under the assumed specific exposure conditions at a Site.
EPA considers individual excess cancer risks in the range of
, 1x10-t to" 1x1'O-' -as . protective; however, the lx10-6 risk level is
generally used as the point of departure for setting cleanup
levels at Superfund Sites. The point of departure risk level of
1x10-6 expresses EPA's preference for remedial actions that
result in risks at the more protective end of the risk range.
The health-based risk levels for this Site are shown in Table 6-
3.
Potential concern for non-carcinogenic effects of a single
contaminant in a single medium is expressed as the hazard
quotient (HQ) (or the ratio of the estimated intake derived from
the contaminant concentration in a given medium to the
contaminants's reference dose). A HQwhich exceeds one (1)-
indicates that the daily intake from a scenario exceeds the
chemical's reference dose. By adding the HQs for all
. contaminants within a medium or across all media to which a given
population may reasonably be exposed, the Hazard Index' (HI) can
be generated. The HI provides a useful reference point for
gauging the potential significance of multiple contaminant
exposures within a single medium or across media. An HI which
exceeds unity indicates that there may be a concern for potential
health effects resulting from the cumulative exposure to multiple
contaminants within a single medium or across media. The HIs are
shown in Table 6-3.
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TABLE 6-3
StJMHARy OF CtJHt7LAT:IVB PO'1'EN'1'ZAL CANCER R:tSltS
AND NON-CARCINOGENIC HAZARD INDICES
POPULATION EXPOSURE MEDIUM . CARCINOGENIC NONCARCINOGENIC
RISK HAZARD INDEX
Surface Soil 2xlO-5 2
TRESPASSER
Sediments * 3xlO-1
. WORKER '-" . ..Surface Soil 4xl 0 -5 2
SUbsurface Soils 2xlO-5 4xlO-l
Sediment * 2xl0-.
Groundwater 3xl0-5 4
FUTURE Surface Soil lxl0'" 17
"RESIDENTIAL Subsurface Soil 6xl 0 -5 2
(CHILD)
Sediment * 4
Groundwater 2xlO-5 12
FUTURE Surface Soil lx1 0-. 6
RESIDENTIAL Subsurface Soil 7xl0-5 5xl0-1
(ADULT)
Sediment * 9xl0-1
Groundwater 5x10-5 5
* The Chemicals of Concern in sediments, manganese and
cadmium, are not considered to be carcinogenic ~ the oral
route. Thus, cancer risks fo~ this pathway were not
calculated.
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6.5
UNCERTAINTY ANALYSIS
The following areas of uncertainty were associated with the
estimation of chemical uptake from exposure to Soils and
groundwater: .
1. Use of concentrations at or near method detection lindt
and estimated concentrations below the detection lindt to
deterndne exposure point concentrations.
2. Selected frequencies of human contact with soil and
groundwater.
3. Exposure variables used to estimate oral, dermal, and
inhalation intakes.
The following are uncertainties associated with estimation of
risks:
1. Risks calculated from slope factors derived using the
linearized multistage procedure, are likely conservative
upper bound estimates. The actual risks are likely much
lower.
2. Uncertainty on whether regarding at what level lead
should be considered at which adverse toxicological effects
do not occur based on applying the IU/BK model
6.6
HUMAN HEALTH RISKS CONCLUSION.
TRESPASSER
The hazard index associated with exposure to chemicals in surface
soils was 2. The hazard index value for sediment exposure was
3E-01. The total pon-cancer hazard for the trespasser, 2, suggests
that an inadequate margin of safety may exist as a result of the
combined exposure. to the Site chemicals in surface soils.
WORKER
Cancer risks were calculated to range from a low of 2E-oS to a
high of 4E-oS for exposure to subsurface and surface soil,
respectively. The largest calculated non-cancer hazard index for
workers,. 4, was associated with groundwater exposure. As in the
case for the Site trespasser, risks and hazards were attributed
primarily to exposure to the metals arsenic. .and . beryllium. The
non-cancer hazard for this population was primarily due to
manganese.
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FUTURE ADULT AND CHILD RESIDENT
Risks ranged from 2E-05 to 1E-04 for exposure to Site groundwater
and surface soil, respectively. Hazard indices for this
population ranged from 2 (subsurface soil exposure) to 17
(surface soil exposure). For adult residents, cancer risks
ranged from 5E-05 (groundwater exposure) to 1E-0. (surface soil
exposure). The highest hazard index for this group, 6, was
associated with exposure to surface soil.
,Concerns for cancer risks and non-cancer hazards which exceed
.values considered acceptable by the USEPA can be lessened by the
~ollowing considerations:
.
Surface soil lead contamination was widespread on the
. 'Site --and "clean-up of the lead concentrations to an
acceptable level will probably reduce any other soil
contaminants at the Site to acceptable concentrations.
It is likely and must be confirmed with sampling during
the remedial design that cleanup of lead contamination
will lower risks and hazards of other contaminants
(e.g., antimony, arsenic, and beryllium--the
constituents contributing greatest to soil risks and
hazards) to acceptable levels, an examination of sample
locations which contain high (> 500 ppm) soil lead
levels indicates that high concentrations of other
chemicals are found in these locations. Thus, the
,- "-removal.of'.lead,'contamination from these .areas will: -,-._'.
affect cleanup of other contaminants which coexist with
lead, and thus lower the risks and hazards associated
with these contaminants to protective levels.
The cancer risks and non-cancer hazard values presented
. in the BRA represent RME exposure conditions which may
. not be applicable to persons potentially contacting
Site chemicals. In some instances, total risks for
trespasser, worker, and resident populations were
determined by summing the RME risks from a number of
exposure pathways.
.
6.7
ENVIRONMENTAL ASSESSMENT SUMMARY
6.7.1
AOUATIC
Although contaminants may migrate-to the creek through several'
pathways including both surface runoff and groundwater discharge,
sampling indicates the water quality of Cedar Creek has not been
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impacted. Although creek sediments displayed some elevated metal
concentrations adjacent to the Site, NOAA ER-L levels were not
exceeded except for l~ad. For lead, the 95% UCL sediment
concentration found was 38 mg/kg. The NOAA ER-L for lead is 35
mg/kg. Since the UCL concentration is not. appreciably greater
than the NOAA ER-L concentration and the results of a conducted
benthic macro invertebrate study concluded that fair conditions
predominate the aquatic environment, the Site has not adversely
affected and has a limited potential for adverse effects on
aquatic populations.
6.7.2
TERRESTRIAL
The Georgia Fish and Wildlife Service provided the following list
.' . . of . federal'ly' "endangered species: .
Red-Cockaded Woodpecker
Bald Eagle
Eastern Cougar
Gray Bat
The Georgia Department of Natural Resources indicated the red-
cockaded woodpecker would not locate near the Site because pine
trees are relatively young, and this bird inhabits old growth
pines. The bald eagle and eastern cougar would not be found in
this area due to urbanization/industrialization. The nearest.
u . ':cave. which hosts: the, gray bat...is.over 30..miles . from the Site.':".u_-~;<:
Since the typical range of the gray bat 'is a few miles, it is .
unlikely that the Site would impact this species.
The U.S. Fish and Wildlife indicted ~he following plants are
protected:
Yellow Lady's Slipper
False Hellebore
While both species are native to Northwest Georgia, they are only
found in undisturbed, old growth forests. This habitat does not
exist on or near the Site.
The Cedartown Industries Site is located in an industrial/urban
setting. This Site has been developed for over 100 years,
consequently there are no sensitive terrestrial ecosystems at or
near the Site that would be affected by the Site.
.- -- -. _..
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TABLE 6-4
HEALTH-BASED CLEANUP GOALS FOR SURFACE AND SUBSURFACE SOilS.
Goal Based on Carcinogenic Goal Based on Hazard
Chemicals Risk of lXl~ Index of 1
(mgJkg) (mgJkg)
INORGANICS
Antimony NlA 29.6
Arsenic 0.42 22.2
Beryllium 0.17 371
Cadmium NlA 37.1
lead N/A 500.
1* Values in table are for the most sensitive Site reCeptor (children) using RME
exposure parameters
~ Clean up level for lead was determined by applying IUIBK model
will reduce other soil contaminants at the Site to acceptable
levels.
Remedial Action goals or cleanup levels consist of specific goals
for the protection of Human Health and the Environment. The
remediation goals were based on'COCs and their allowable exposure
levels anQ chemical specific ARARs. Chemical specific ARARs
include maximum contaminant levels (MCLs) established for
drinking'water and federal action levels proposed for corrective
actions at RCRA solid waste management units. MCLs and federal
soil action levels are set by EPA and are based on a level that
at which no known or anticipated adverse effect on the health of
persons occur and which allows an adequate margin of safety.
The clean up goals established in Table 6-5, graphically
represented in Figures 6-1 for soils and.6-2 for groundwater are
based on MCLs and federal soil action levels. These goals were
developed based on health-based criteria and are considered
conservative for the protection of human health. 'Field sampling
during the remedial stage will be used to guide the actual area
to be remediated. '
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6.8
CHEMICALS OF CONCERN AND CLEANUP LEVELS
The establishment of health-based cleanup goals serves as an
important means of guiding remedial activities. A health-based
approach is warranted when cleanup standards promulgated by state
or federal agencies are not available for contaminants in soil,
as well as for certain groundwater contaminants. The approach to
developing health-based goals is derived from the risk assessment
process. The risk assessment is essentially a process by which
the magnitude of potential cancer risks and other health effects
at a Site can be evaluated quantitatively. A cleanup goal is
established by back-calculating a health protective contaminant
concentration, given a target cancer risk which is deemed
acceptable and realistic. The concept of the cleanup goal.
inherently incorporates the concept of exposure reduction which
". ""allows"remedial.;alternatives to be flexible. The BRA indicate
that the media of concern are groundwater and, surface and
subsurface soils. The resulting COCs used for establishing
remedial action goals or clean up levels, established from
health-based risks exceeding carcinogenic. at lX10-6 or HI of 1
and calculated health-based clean up levels, are summarized in
Table 6-4.
. d. .'
The shallow groundwater beneath the Site exhibits elevated levels
of one metal constituent (cadmium) in only one well (MW-4).
Because elevated levels of cadmium appear to exist only in the
area immediately adjacent to MW-4, there appear to be no
potential receptors .to' .the contaminated groundwater.' The. BRA
included ingestion exposure to groundwater as unlikely for the
worker and resident populations in the exposure pathway analysis.
In addition, groundwater in' the bedrock unit is not considered to
be a risk to human receptors either at the Site or through
upgradient migration to Cedar Spring. Analytical data indicate
th~t the surface water and sediment have not been impacted by the
Site. Therefore, the groundwater should be monitored to ensure
that the localized groundwater contamination is naturally
attenuating and is not migrating.
Because present levels of constituents in the soil have not
significantly impacted the groundwater, both surface and
subsurface soil cleanup levels should foqus. on removing any risk
to potential receptors. Site specific data indicate that a
cleanup level protective of human health would also be protective
of groundwater. Because lead concentrations in isolated areas in
. the soil as high as 260,000 mg/kg have not impacted the
groundwater, a health-based clean up level of 500 mg/kg for lead
. .would be protective of the groundwater as well as human health.
With one exception (naturally occurring beryllium), removal or
treatment of the soil with lead concentrations above 500 mg/kg
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. ."- .. ...
TABLE 6-5
SUMMARY OF REMEDIAL ACTION OBJECTIVES
Compound Medium
Surface Soil Subsurface Soil Groundwater
(mgJkg) (mgJkg) (mgll)
Cadmium 40b 40b 0.005 .
Lead 500 c 500 c -
Arsenic 80 b 80 b -
Beryllium 2.0d 2.0 d -
Antimony 30 b 30 b -
a. Cadmium clean up goal Is cadmium MOL estabfished for drinking water in 40 OFR
Parts>141. 142. 143-Effective July 30.1992.
b. SoD contaminant cleallJp levels were obtained flOm Federal AdJon Levels
developed for soDs In 40 CFR Part 264 and prevents direct contact with soli having
a 1~ excess cancer risk.
c. SoU contaminant cleallJp level for lead was obtained from EPA memorandum
-Interim Guidance on Establishing SoU CleanJp Levels at Superfund Sites. and
Integrated UptakeJBiokenetic (lUlBK) model which prever:ats direct contact with
soils having an unacceptable noncarcinogenic hazard.
d. Soil contaminant clean up level is based on background or naturally oc:cuning
berylrlum concentrations documented In Site specific samples and for Polk County
as presented in Section 4.2.5 of the RI versus the Federal Action Level of .2 mgIkg
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FIGURE
APPROXIMATE EXTENT OF
6-1
SOILS REMEDIATION
. \
\. \
~_.~
L...-I
~'
."",t
- I.
'A "',
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~ .. \
--~ ;~
"
\
\
\
\
,
,
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.--
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FIGURE 6-2
APPROXIMATB EXTENT OF GROUNDWATER CADMIUH REMEDIATION
cQ.orM 7'"
-,,'
1
..
,
'''-.--
a
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o
ea.
r.~-";
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.
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\
~
-..... ! ..
,
~.. (''''
~-: ~7.~rp..~--= :-~.4.:-::- .
:'~ .".
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ROD
Cedartown Industries Site
Page 39
Actual or threatened releases of hazardous substances from the
Cedartown Industries 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.
7.0
DESCRIPTION OF ALTERNATIVES
The Feasibility Study Report evaluated possible alternatives for
remediation of conditions at the Cedartown Industries Site. A
total of six (6) alternatives have been established for detailed
analysis consideration. These alternatives were selected to
provide a range of remedial actions for the Cedartown Industries
Site.
3.
-Situ Solidification/Stabilization;
roundwater Monitoring
Soil Excavation and Off-Site Disposal;
roundwater Monitoring .
apping; Groundwater Monitoring
4.
5.
-Situ Solidification/Stabilization;
roundwater Treatment
Soil Excavation and Off-Site Disposal;
roundwater Treatment
6.
apping; Groundwater Treatment
7.1
ALTERNATIVE No.1 - No Action
The no action alternative is carried through the screening
process as required by the National Oil and Hazardous Substances
Pollution Contingenqy Plan (NCP). This alternative is used as a
baseline for comparison with other developed alternatives. EPA
would not take further action to minimize the impact of
contamination.. The no-action alternative would result in no
disturbance of existing contaminated soils and no remediation of
contaminated groundwater. Contaminants in the soil would
continue to pose a threat to human health and the environment and
leach into the groundwater. The overall remedial action levels
would not be achieved by utilizing this alternative and all
current and potential future risks would remain under this
alternative. This alternative does not provide for a reduction
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Cedartown Industries Site
Page 40
in toxicity, mobility, or volume of the contaminated soil. The
no-action alternative would involve groundwater monitoring.
However, installation of additional monitoring wells to monitor
the movement of the contaminant plume would not be necessary.
Alternative 1 provides minimal control of exposure to the
contaminated soil and no reduction in risk to human health posed
through the groundwater-.
The 30-year present worth cost of this alternative is estimated
to be $324,860, with a capital cost of $0.00 and an annual O~
cost of $23,600. The associated costs are the annual O&M costs
are for the groundwater monitoring program. .
, . 7;2 .
. 'ALTERNATIVE No.2 -. Ex-Situ
Solidification/Stabilization: Groundwater Monitorina
This alternative includes ex-situ (excavating or digging to
treat) soil fixation of lead-contaminated soil which exceeds 500
ma/ka or oarts oer million (oom), coupled with cleanup of ---
cadmium-contaminated groundwater to the drinking water standard
of 5 ua/l (0.005 mg/l) through natural attenuation. Cadmium is
the only groundwater contaminant detected above standards and
appears to be confined to one area in the surficial unit of the
aquifer. Monitoring of cadmium at four existing downgradient (in
the direction of groundwater flow) wells and one existing
.. :. upgradie;nt welL would be' :accomplished on a quarterly basis ~ ."'IL
Once the source is immobilized through ex-situ solidification/
stabilization, the cadmium-contaminated groundwater is expected
to naturally attenuate in approximately two years. Groundwater
monitoring of soil COCs, .including lead, shall be conducted.
during the post-cleanup period to verify that the solidified
material does not release COCs to the groundwater. If the
groundwater monitoring indicates that cadmium levels increase
during two consecutive quarters. of sampling, that after three
years, natural attenuation has failed to achieve the cleanup
standard of 5 ug/l (0.005 mg/l), or that other soil released COCs
exceed their respective MCLs, EPA shall consider and determine
the requirement to initiate a pump and treat system as described
in Alternative No.5.
The area to be solidified/stabilized was identified by comparing
data for soil with criteria for COCs for each medium (soil and
groundwater). Lead was chosen as the indicator chemical because
the areas of lead contamination, both vertical and horizontal,
encompassed those areas in which other contaminants were
identified. Thus, treatment of the lead-contaminated soil' would
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Cedartown Industries Site
Page 41
result in treatment of the other contaminants, as well. The soil
remedial action target concentrations shall be used to determine
the vertical and horizontal excavation boundaries for
contaminated soil. A sampling program would be conducted to
determine the actual volumes of surface soil and subsurface soil
~equiring remedial action. Based. on the excavation performance
standard of 500 mg/kg, the volume of contaminated soil to be
solidified is approximately 19,280 cu yds. Prior to excavation
of contaminated subsurface soils, any clean backfill would be
excavated and stockpiled on site for reuse after the
solidification/stabilization process has been completed.
Prior to designing the final ex-situ solidification/stabilization
system, additional bench and pilot-scale treatability studies or
testing would be required to veri~ the effectiveness of the
..'."'process-optimization parameters and attainment of the performance
standards. Process optimization parameters include, but are not
limited to, selection of stabilizing agents and other additives,
the waste-to-additive ratio, mixing and curing conditions, and
availability of reagents and vendors. Performance standards
include, but are not limited to, TCLP, unconfined compressive
strength, permeability, and leachability. Testing of the
solidified soils would be necessary to ensure that performance
requirements are being met.
With the exception of underground utilities, there would be no
internal Site restrictions or logistic problems that would impact
'. ~se .of this'. technology. .,.'Excavation.maybe ..accomplished with. or...,:.
without the removal of buildings or structures in areas requiring
excavation. Currently, there is no evidence that contamination
. . exists under the buildings. However, if contamination is found
during the remedial design, appropriate action involving .
demolition of impacted structures may be undertaken.
Upon contaminated and treated soils meeting treatment performance
'standards and having been rendered nonhazardous, i.e. the soils
meet the toxicity characteristics regulatory levels, it would be
disposed on site.' The excavated areas would be backfilled with'
the solidified material and clean compacted cover. The excavated
areas would be regraded and regraveled or revegetated to existing
conditions. .
Institutional controls for land use and groundwater use
restrictions will be implemented.
The 30-year present worth cost of this alternative is estimated
to be $3,372,180. The primary cost item is the soil fixation.
The capital cost is estimated to be $2,931,700 with an annual O&M
cost of $32,000.
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Cedartown Industries Site
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If the contingency groundwater remedy is implemented, the 30-year
'present worth cost is estimated to be $4,923,700 with a projected
$3,188,075 for capital expenditures, a $1,551,520 increase in
capitol and O&M costs. For cost estimation, it was assumed pre-
treatment would not be necessary. The annual O&M cost is
estimated to be $192,000 for the groundwater extraction and
treatment system, Site maintenance, and groundwater monitoring
for 5 years. Groundwater monitoring and Site maintenance annual
O&M costs are estimated at $32,000 for the remaining 25 years.
7.3
ALTERNATIVE No.3 - Soil Excavation with Off-Site
DisDosal: Groundwater Monitorina
In this alternative, all lead-contaminated soils exceeding 500
ppm"wouldbe-excavated and taken to an off-Site regulated
landfill for disposal. The excavated areas would be filled in
with clean soil, then regraded and regraveled or revegetated. ,
Concurrently, cleanup of the cadmium-contaminated groundwater
would take place by natural attenuation as described in
Alternative No.2.
The area and volumes to be excavated would be the same as ex-situ
solidification/stabilization described in Alternative No.2.
Excavation of contaminated soils would be done in a way to
minimize contact by the trucks with contamination, thus
preventing spreading onto local roadways. Earth moving equipment
, would be used - to;,excavate ~the ,soils. and. the primary-.transport' ',....:i
vehicle would be 20-yard dump trailers with tarpaulin covers,
liners, and adsorbents, as necessary. Equipment for waste
removal would be decontaminated on site. Wash water would be
captured and transported to an approved off-Site water treatment
system. The soils would then be transported directly to the
disposal facility. The excavated areas would be backfilled with
clean fill, then regraded and regraveled or revegetated.
Disposal of contaminated materials would take place at an
approved RCRA-permitted hazardous waste facility.
-
Excavation may be accomplished with or without the removal of
buildings or structures in areas requiring excavation. currently,
there is no evidence that contamination exists under the
buildings. However, if contamination is found during the
remedial design appropriate action involving demolition of
impacted structures may be undertaken.
Assuming each vehicle would transport 20 .tons of unconsolidated
..material, approximately 1250 loads would be shipped off-site.
The 30-year present worth cost of this alternative is estimated
to be $9,594,060 with a capital cost of $9,153,580 and an annual
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Cedartown Industries Site
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O&M cost of $32,000. The capital cost is for excavation and
disposal of the contaminated soil. The annual O&M costs are for
the groundwater monitoring program.
7.4
ALTERNATIVE No.4 - Caooina: Groundwater Monitorinq
The primary components of No.4 are capping of the lead-
contaminated soils which exceed 500 ppm and cleanup of the
cadmium-contaminated groundwater through natural attenuation.
Monitoring for both soil and groundwater COCs is described in
Alternative No.2. . .
Capping would consist of two primary activities: (1) excavation
and relocation of contaminated surface soils from outside the
-.-, fence line .-to within the fenced area of the property; and (2)
construction of a multimedia cap to inhibit rain or storm water
from entering the underlying soils. A 12-inch thick vegetated
layer would subsequently be constructed to the original ground
elevations across all off-Site disturbed areas. Initial
activities would consist of digging up about 2,420 cu yd of off-
Site material from three locations totaling approximately 1.5
acres in surface area extent.
Three separate cap systems would be used under this alternative
based upon existing Site activities -- clay and asphalt pavement
over 2.6 acres; clay and concrete pavement over 0.5 acres; and
.- . clay. and. a flexible SYnthetic "membrane over the rest:. (0 . 5 ;acres).~'
. .
Clay and Asphalt Cap
In areas of the Site currently utilized for truck-parking,
the proposed cap would consist of a 24-inch thick clay layer
re-compacted to a maxtmum saturated hydraulic conductivity
of 1 x 10-7 em/s. Overlaying the clay barrier would be a
minimum 8-inch thick layer. of asphalt pavement with a 6-inch
stone base. It is estimated that the asphalt/clay cap would
be utilized over approximately 2.6 acres of the Site.
Clay and Concrete Cap
In areas currently utilized for trailer parking, the 24-inch
thick clay barrier would be overlain by a minimum 6-inch
thick layer of concrete pavement with a 4-inch stone base.
It is estimated that the concrete pavement/clay cap would be
utilized over approximately 0.5 acres of the Site.
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Cedartown Industries Site
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Synthetic Layer
The remaining portion of the
exceeding the clean up level
with a 24-inch thick barrier
flexible membrane liner.
Site, .at which contamination
of 500 ppm lead would be capped
clay layer overlain by a 20-mil
Surface water would be transported away from the cap via
construction of a 12-inch thick sand drainage layer over the
liner. The drainage layer would be overlain by a 24-inch thick
vegetated layer. It is estimated that the vegetated cap would be
utilized over approximately 0.5 acres of the Site. Additional
geologic analyses may be required during the remedial design to
determine subsurface soil conditions relative to cap design.
'..' '...'Additional'''cap'protection may not be required at the location of
the existing structures. However, in order to maintain access to
existing structures, excavation of the upper 3-5 feet of existing
materials and replacement with proposed cap materials would be
required adjacent to the structures. Excavation of the existing
soils and regrading of the area, prior to cap construction, would
be required to divert storm water runoff around the structures.
Excavated materials would be spread and compacted in the areas of
the proposed cap construction to prevent ponding and promote
drainage across the Site. The cap could be enlarged if more
contamination were discovered during remedial design activities.
The reliability of the cap will require regular maintenance.
. Maintenance..would include,. .but not .be limited to, regular
asphalt, concrete crack, and erosion repair.
. ..'.....
This alternative would provide no reduction. in the toxicity or
volume of contaminated soil or groundwater through treatment.
The 19,280 cu yds of contaminated soil would remain on site
within the fenced perimeter.
The 30-year present worth cost of this alternative is estimated
to be $1,136,540, with a capital cost of $438,655. The capital
cost is primarily for the installation of the cap. The annual
O&M costs of $50,700 are primarily for the groundwater monitoring
program and for maintaining the cap.
7.5
ALTERNATIVE No.5 - EX-Situ Solidification/
Stabilization: Groundwater Treatment
Alternative No.5 would combine ex-situ solidification/
.stabilization of the lead-contaminated soils as described in
Alternative No.2 to prevent contaminants from moving into
groundwater with treatment of the caqmium-contaminated
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Cedartown Industries Site
Page 45
groundwater found in the uppermost unit of the aquifer. The
'groundwater contamination, consisting of cadmium levels greater
than the cleanup level of 5.0 ~g/l (0.005 mg/l), has an
approximate area of 22,500. square feet (ft2). The thickness of
the surficial unit of the aquifer at the affected area is about 9
feet. Assuming an estimated average effective porosity of 0.35.
~e estimated volume of water to be treated is approximately 0.5
million gallons.
The groundwater extraction system would consist of a group of
wells located within 'the estimated area of the plume designed to
intercept the contaminated groundwater and treat the groundwater
to remove the contaminants to below the cleanup level or MCL.
The pumping system would be designed to provide a capture zone
sufficient to intercept the delineated plume would be targeted
for removal.
The effectiveness of the groundwater extraction system is
dependent upon the aquifer characteristics, transmissivity, and
storativity. TYPically, these design criteria are developed by
aquifer testing based on constant discharge pumping and/or
recove:ty tests. Since extensive aquifer testing h~s not been
completed, additional pump tests and groundwater modeling will be
required during the remedial design. Based on conservative
design criteria to be confirmed during the remedial design,
transmissivity of 330 g/day/ft and storativity of 0.01, a minimum
of 3 wells to a depth of approximately 15 feet would be needed.
These wells .would. be, .spaced approximately 60 feet ,apart and '
located downgradient from MW-4 to intercept the delineated plume
~nd provide a hydraulic barrier against plume migration. Each
'well would be pumped at an approximate rate of 1 gallon per
minute with the total discharge of the extraction system totaling
approximately 3 gpm. At this rate, approximately 4,300 gallons
would be discharged for treatment per day.
Extracted groundwater concentration of cadmium is anticipated to
be lower than the limits (0.3 mg/l) set for discharges to the
public sewer system (Cedartown Code 22-64). Therefore, the
groundwater may be discharged directly'from the extraction system
to the city sewer.
If groundwater cannot be discharge to the POTW, a contingency of
discharging the contaminated groundwater to surface water after
treatment would be required. Groundwater treatment is to be
..- accomplished by ion exchange or reverse osmosis. ,.' Both treatment
processes are proven technologies and are'widely used in
,industrial treatment. Treatability studies would be needed
during remedial design to determine design parameters and
procedures. The treated effluent would be discharged to the
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Cedartown Industries Site
Page 46
surface' water or
designed to meet
discharge to the
Standards.
shallow groundwater and the system would be
Federal and State NPDES limitations for
surface water and/or State Water Quality
Routine maintenance on the pumps and treatment unit would be
required. Operation and maintenance of the extraction and .
treatment system would require trained personnel. Major
components of the groundwater withdrawal and treatment system may
need major servicing at 5-year intervals.
The 30-year present worth cost is estimated to be $4,923,700 with
a projected $3,809,330 for capital expenditures. For CO$t
estimation, it was assumed pre-treatment would not be necessary.
The annual O~ cost is estimated to be $192,000 for the
. ., '-groundwater ~extraction . and, treatment system, Site maintenance,
and groundwater monitoring for 5 years. Groundwater monitoring
and Site maintenance annual O&M costs are estimated at $32,000
for the remaining 25 years.
ALTERNATIVE No.6 - Soil Excavation: Groundwater
Treatment
7.6
Alternative No.6 contains the excavation component of
Alternative No.3 combined with the groundwater extraction and
treatment systems described in Alternative No.5.
The 30-year present worth cost is estimated to be $11,145,570
with a projected $10,031,200 for capital expenditures. For cost
estimation, it was assumed pre-treatment would not be necessary.
The annual O~ cost is estimated to be $192,000 for the
groundwater extraction and treatment 'system, Site maintenance,
and groundwater monitoring for 5 years. Groundwater monitoring
and Site maintenance annual O~ costs are estimated at $32,000
for the remaining 25 years.
7.7
ALTERNATIVE No.7 - CaDDina: Groundwater Treatment
Alternative No.7 contains the capping component of Alternative
No.4 combined with the groundwater extraction and treatment
systems described in Alternative No.5.
The 30-year present worth cost is estimated to be $2,688,040 with
a projected $1,136,280 for capital expenditures. For cost
. estimation, it was assumed pre~treatment would not be necessary.
The annual O~ cost is estimated to be $210,700 for the
groundwater extraction and treatment system, Site maintenance, .
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and groundwater monitoring for 5 years. Groundwater monitoring
and Site maintenance annual O&M costs are estimated at $50,700
for the remaining 25 years.
7.8
APPLICABLE OR RELEVANT 'AND APPROPRIATE REGULATIONS
(ARARs)
The remedial action for the Cedartown Industries Site, under
CERCLA Section 121(d), must comply with federal and state
environmental laws that are either applicable or relevant and
appropriate (ARARs). Applicable requirements are those
standards, criteria or limitations promulgated under federal or
state law that specifically address a hazardous substance,
pollutant, contaminant, remedial action, location, or other
. 'circumstance at 'aCERCLA Site. Relevant and appropriate'
requirements are those that, while not applicable, still address
problems or situations sufficiently similar to those encountered
at the Site and that their use is well suited to the particular
Site. To-Se-Considered Criteria (TBCs) are non-promulgated
advisories and guidance that are not legally binding, but should
be considered in determining the necessa~ level of cleanup for
protection of health or the environment. The affected
groundwater in the aquifer beneath the Cedartown Industries Site
has been classified by EPA as Class IIA. Class IIA groundwater
is a source of drinking water. It is EPA's poliqy that
groundwater resources be protected and restored to their
beneficial uses..- A .:complete ,definition for. groundwater "
classification is' provided in the Guidelines for Groundwater
Classification under the EPA Groundwater Protection Strateav,
Final Draft, December 1986.
While TBCs do not have the status of ARARS, EPA' s approach to
d~ter.mining if a remedial action is protective of human health
and the environment involves consideration of TBCs along with
ARARs .
Location-specific ARARs are restrictions placed on the
concentration of hazardous substances or the conduct of
activities solely on the basis of location. Examples of
location-specific ARARs include state and .federal requirements to
protect floodplains, critical habitats, and wetlands, and solid
and hazardous waste facility siting criteria. Table 7-1
summarizes the potential location-specific ARARs for the
Cedartown Industries Site.
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Cedartown Industries Site
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. .
TABLE 7-1
POTENTIAL LOCATION SPECIFIC ARARs
Location Citation
A Within 1~year General RCRA'Facility Location Standard (40 CFR. Part
floodplain 264. 18[b])
Protection of Floodplain (40 CFR Part 6. Appendix A)
Fish and Wildlife Coordination Act
. 40 CFR Part 6.302
A Within floodplain Protection of Floodplain (40 CFR Part 6. Appendix A)
Fish and Wildlife Coordination ACt
40 CFR Part 6.302
R&A Critical habitat Endangered Species Act of 1973
upon which SO CFR Parts 200 and 402
endangered or Fish and Wildlife Coordination Act
threatened 33 CFR Parts 320-330 .
species depends
R&A Area affecting Wild and Scenic River Ad.
stream or river 40 CFR Part 6.302(e)
R&A Within area Wild and Scenic River Ad.
affecting wild. 40 CFR Part 6.302(e)
scenic or
recreational river
STATE OF GEORGIA REGULATIONS.
A Within lOG-year Georgia Facirlty Location Standards (391-3-4)
floodplain
R&A Critical habitat Georgia EPD 391-4-10
upon which
endangered or
threatened
species depends
R&A Within area Georgia EPD 391-3+.03
affecting wild.
scenic or
recreational river
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TABLE 7.1
POTENTIAL LOCATION SPECIFIC ARARs
A
APPLICABLE REQUIREMENTS WHICH WERE PROMULGATED UNDER FEDERAL LAW
TO SPECIFICALLY ADDRESS A HAZARDOUS SUBSTANCE, POLLUTANT,
CONTAMINANT, REMEDIAL ACTION LOCATION OR OTHER CIRCUMSTANCE AT THE
CEDARTOWN INDUSTRIES SITE. .
R&A-
RELEVANT AND APPROPRIATE REQUIREMENTS WHICH WHILE THEY ARE NOT
"APPLICABLE" TO A HAZARDOUS SUBSTANCE, POLLUTANT, CONTAMINANT,
REMEDIAL ACTION, LOCATION, OR OTHER CIRCUMSTANCE AT THE CEDARTOWN
INDUSTRIES SITE, ADDRESS PROBLEMS OR SITUATIONS SUFFICIENTLY SIMILAR TO
THOSE ENCOUNTERED AT THIS SITE THAT THEIR USE IS WELL SUITED.
,-., ,. -Action"'="specific.ARARs. are technology- or, activity-based
requirements or limitations on actions taken with respect to
hazardous wastes. These requirements are triggered by the
particular remedial activities that are selected to accomplish a
remedy. Since there are usually several alternative actions for
any remedial Site, various requirements c'an be ARARs. Table 7-2
lists potential ,action-specific ARARs and TBCs for the selected
remedy for the Cedartown Industries Site, and Table 7-3 lists
potential action-specific ARARs for the contingency remedy for
groundwater.
TABLE 7-2
POTENTIAL AC110N-SPECIFIC ARARs FOR THE SELECTED REMEDY
CLEAN WATER ACT. 33 U. S. C. IS 1251.1376
R&A 40 CFR Part 131 - Ambient Water Suggested ambient water standards for the
Quality Criteria protection of human health and aquatic life
A 40 CFR Part 403 - National sets standards to control pollutants which
Pretreatment Standards pass through or interfere with tre~ment
processes in public treatment works or
which may. contaminate sewage sludge.
RESOURCE CONSERV A110N AND RECOVERY ACT. 42 U.S.C. IS 6901-6987
R&A 40 CFR Part 241 - GuideDnes for Establishes minimum levels 01 performance
he Land Disposal 01 Solid Wastes required 01 any solid waste land disposal
Site operation and includes operation and
maintenance.
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Cedartown Industries Site
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TABLE 7-2
POTENTIAL ACTION-SPECIRC ARARs FOR THE SELECTED REMEDY
A 0 CFR Part 264 - Standards for Establishes minimum national standards
wners and Operators of hich define the acceptable management
Hazardous Waste Treatment, f hazardous wastes for owners and
torage and Disposal (TSC) perators of facilities which treat, store or
Facilities ispose of hazardous wastes.
LEAN AIR ACT. 42 U.S.C. II 7401-7642
A CFR Part 61 - National ddresses hazardous air pollutants at their
Emission Standards for Hazardous int of emission from specific sources
'r Pollutants
A
eorgia Hazardous Site Response Establishes minimum state standards
ct ~ 12-8-90 et sea. ich define the acceptable management
f hazardous wastes for owners and
perators of facilities which treat, store or
Ispose of hazardous wastes.
eorgia Comprehensive Solid EstabDshes minimum levels of
aste Management Act 112-8-20 performance required of any solid waste
t se . land disposal Site operation and includes
peration and maintenance.
eorgia Hazardous Waste EstabDshes minimum state standards
anagement Ad ~ 12-8--60 at sea ich define the acceptable management
f hazardous wastes for owners and
perators of facilities which treat, store or
ispose of hazardous wastes.
APPUCABLE REQUIREMENTS WHICH WERE PROMULGATED UNDER FEDERAL LAW
TO SPECIFICALLY ADDRESS A HAZARDOUS SUBSTANCE, POLLUTANT,
CONTAMINANT, REMEDIAL ACTION LOCATION OR OTHER CIRCUMSTANCE AT THE
CEDARTOWN INDUSTRIES SITE.
R&A -
RELEVANT AND APPROPRIATE REQUIREMENTS WHICH WHILE THEY ARE NOT
-APPLICABLE- TO A HAZARDOUS SUBSTANCE, POllUTANT, CONTAMINANT,
REMEDIAl ACTION, LOCATION, OR OTHER CIRCUMSTANCE AT THE CEDARTOWN
INDUSTRIES SITE, ADDRESS PROBLEMS OR SITUATIONS SUFFICIENTLY SIMIlAR
TO THOSE ENCOUNTERED AT THE CEDARTOWN INDUSTRIES SITE THAT THEIR
USE IS WELL SUITED TO THE SITE.
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,,". ".." '-',
TABLE 7-3
POTENTIAL ACTlON-5PECIFIC ARARs FOR THE GROUNDWATER
CONTINGENCY REMEDY
CLEAN WATER ACT - 33 U.S.C.IS 1251-1376
R&A ~O CFR Part 122, 125 - National Requires permits for the discharge of
Pollutant Discharge Elimination pollutants for any point source into waters
System of the United States.
~ CFR Part 125
~O CFR Part 131
~ CFR Part 136.1
R&A ~ CFR Part 131 - Ambient Water Suggested ambient water standards for the
Quality Criteria protection of human health and aquatic life
--!A. . 40 CFR Part 403- National Sets standards to control pollutants which
Pretreatment Standards pass through or interfere with treatment
processes in public treatment works or
which may contaminate sewage sludge.
A APPLICABLE REQUIREMENTS WHICH WERE PROMULGATED UNDER FEDERAL LAW
TO SPECIFICALLY ADDRESS A HAZARDOUS SUBSTANCE. POLLUTANT.
CONTAMINANT. REMEDIAl ACTION LOCATION OR OTHER CIRCUMSTANCE AT THE
CEDARTOWN INDUSTRIES SITE.
R&A - RELEVANT AND APPROPRIATE REQUIREMENTS WHICH WHILE THEY ARE NOT
-APPLICABle" TO A HAZARDOUS SUBSTANCE. POLLUTANT. CONTAMINANT.
.. -- REMEDIAL ACTION.. LOCATION~ OR OTHER CIRCUMSTANCE AT THE CEDARTOWN .\,
INDUSTRIES SITE, ADDRESS PROBLEMS OR SITUATIONS SUFRCIENTL Y SIMILAR
TO THOSE ENCOUNTERED AT THE CEDARTOWN -INDUSTRIES SITE THAT THEtA
USE IS WELL SUITED TO THE SITE. I
Chemical-specific ARARs are specific numerical quantity
restrictions on individually-listed chemicals in specific media.
Examples of chemical-specific ARARs include the MCLs specified
under the Safe Drinking Water Act as well as the ambient water
quality criteria that are enumerated under the Clean Water A~t.
Since there are usually numerous chemicals of concern for any
remedial Site, various numerical quantity requirements can be
ARARs. Table 7-4 lists potential chemical-specific ARARs for the
Cedartown Industries Site.
To-Be-Considered Criteria. (TBCs) are non-promulgated advisories
and guidance that "are not legally binding, but should be
considered in determining the necessary level of cleanup for
protection of health or the environment. TBCs advisories and
guidances are listed in Table 7-5.
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'. .. ". .-"...
TABLE 7-4
POTENTIAL CHEMICAL-SPECIFIC ARARS
CLEAN WATER ACT - 33 U.S.C. ii 1251-1376
~O CFR Part 131- Ambient Water Suggested ambient standards for the
. A. Puality Criteria - protection of human health and aquatic life
~O CFR Part 403 - National Sets standards to control pollutants which
A Pretreatment Standards pass through or interfere with treatment
processes in publicly-owned treatment
works or which may contaminate sewage
sludge.
RESOURCE CONSERVATION AND RECOVERY ACT - 42 U.S.C. II 6901-6987
~O CFR Part 261 - Identification Defines those solid wastes which are
R&A ~nd Usting of Hazardous Wastes subject to regulation as hazardous wastes
under 40 CFR Parts 263-265 and Parts
124, 270, and 271.
~O CFR Part 262 - Standards Establishes standards for generators of
R&A jApplicable to Generators of hazardous waste.
Hazardous Waste
CLEAN AIR ACT - 42 U.S.C. il 7401-7642
~O CFR Part SO - National Primary Establishes standards for ambient air
R&A land Secondary Ambient Air quality to protect public he~ and welfare.
~uaJity Standards SAFE DRINKING WATER ACT - 40 U.S.C. IS 300
~ CFR Part 141- National Establishes maximum contaminant levels
A Primary Drinking Water Standards MCLs) which are health-based standards
or public water systems.
PL No. 99-339 100 Stat. 462 (1986) Establishes drinking water quality goals set
R&A ... Maximum Contaminant Level at levels of no known or anticipated
~oals (MCLGs) adverse health effects with an adequate
margin of safety.
$TATE OF GEORGIA REGULATIONS
R&A ~r Quality Ad. of 1978 et sea. Establishes standards for ambient air
quality to protect public health and welfare.
A Safe Drinking Water Act ef sea. Establishes maximum contaminant levels
(MCLs) which are health-based standards
or public water systems.
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TABLE 7-4
. POTENTIAL CHEMICAL-SPECIFIC ARARS
A Georgia Water Quality Control Act Establishes maximum contaminant levels
GA. Code Ann. ~ 12 et sea. (MCLs) which are heatth-based standards
~or public water systems.
A APPLICABLE REQUIREMENTS WHICH WERE PROMULGATED UNDER FEDERAL
LAW TO SPECIRCALl Y ADDRESS A HAZARDOUS SUBSTANCE, POLLUTANT,
CONTAMINANT, REMEDIAL ACTION LOCATION OR OTHER CIRCUMSTANCE AT THE
CEDARTOWN INDUSTRIES SITE.
R&A- RELEVANT AND APPROPRIATE REQUIREMENTS.WHICH WHILE THEY ARE NOT
-APPLICABle" TO A HAZARDOUS SUBSTANCE, POllUTANT, .CONTAMINANT,
REMEDIAl ACTION, LOCATION, OR OTHER CIRCUMSTANCE AT THE CEDARTOWN
.' aI'" . .../NDUSTR/ES SITE, ADDRESS PROBLEMS OR SITUATIONS SUFRCIENTlY SIMILAR
. TO THOSE ENCOUNTERED AT THE CEDARTOWN INDUSTRIES SITE THAT THEIR
USE IS Well SUITED TO THE SITE.
! .
TABLE 7-5
TO BE CONSIDERED (TBCs) DOCUMENTS
Document Type Description
USEPA Office of Water Guidance Water~elated Environmental Fate of 129
Priority Pollutants (1979)
USEPA Office of Water Guidance Water Quality Standards handbook
USEPA Office of Water Guidance Designation of a USDW (No. 7.1, October
1979)
OWSER 9355.4-02 Interim Guidance on Establishing Soil
Lead Clean-up Levels at Superfund Sites
Region IV, Guidance Number TSc-92~2 Management of environmental media -
groundwater, soils, surface' waters -
exhibiting a hazardous waste
characteristic
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8.0
SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
This section of the ROD provides the basis for determining which
alternative provides the best balance with respect to the
statutory balancing criteria in Section 121 of "CERCLA, 42 U.S.C.
Section 9621, and in the NCP, 40 CFR, Section 300.430. The major
objective of the FS was to develop, screen, and evaluate
alternatives for the remediation of the Cedartown Industries
Site. A wide variety of alternatives and technologies were
~dentified as candidates to remediate the cont~nation at the
Cedartown Industries Site. These were screened based on their
feasibility with respect to the contaminants present and the Site
characteristics. After the initial screening, the remaining
alternatives/technologies were combined into potential remedial
alternatives and evaluated in detail. The remedial alternative
. was "selected "from the screening .process using the following nine
evaluation criteria: .
.
Overall protection of human health and the environment;
compliance with applicable and/or relevant Federal or State
public health or environmental standards;
.
.
long-ter.m effectiveness and permanence;
.
reduction of toxicity, mobility, or volume of hazardous
substances or contaminants;
.
. short-term effectiveness or the impacts a remedy might have"
on the community, workers, or the environment during the"
course of implementation;
.
implementability, that is, the administrative or technical
capacity to carry out the alternative;
.
cost-effectiveness considering costs for construction,
operation, and maintenance of the alternative over the life
of the project, including additional costs should it fail; "
acceptance by the State, and
acceptance by the Community.
.
.
The NCP categorizes the nine criteria into three groups:
(1)
Threshold Criteria - overall "protection of human health and
the environment and compliance with ARARs (or invoking a
waiver) are threshold criteria that must be satisfied in
order for an alternative to be eligible for selection;
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(2 )
Primary Balancina Criteria - long-te~ effectiveness and
permanence; reduction of toxicity, mobility or volume;
short-te~ effec~iveness; implementability and cost are
primary balancing factors used to weigh major trade-offs
among alternative hazardous waste management strategies; and
Modifvina Criteria - state and community acceptance are
modifying criteria that are formally taken into account
after public comments are received on the proposed plan and
incorporated in the ROD.
(3)
. .""
The selected alternative must meet the threshold criteria and
comply with all ARARs or be granted a waiver for compliance with
ARARs. Any alternative that does not satisfy both of these
requirements is not eligible for selection. The Primary
: "-Balancing" Crit'eria -are the technical criteria upon which the
detailed analysis of alternatives is primarily based. The final
two criteria, known as Modifying Criteria, assess the public's
and the state agency's acceptance of the alternative. Based-on
these final two criteria, EPA may modify ~spects of a specific
alternative.
The following analysis is a summary of the evaluation of
alternatives for remediating the Cedartown Industries Superfund
Site under each of the criteria. A comparison is made between
each of the alternatives for achievement of a specific criterion.
8.1
THRESHOLD CRITERIA
8.1.1
OVERALL PROTECTION OF. HUMAN HEALTH AND THE ENVIRONMENT
The no-action alternative will not mitigate the risks associated
with contamination at or originating from the Cedartown
Industries Site. Therefore, this alternative is not protective
of human health and the environment and will no longer be
considered in this discussion.
Alternatives 2 and 3 (EX-Situ Solidification/Stabilization and
Excavation/Off-Site Disposal, respectively) provide for
remediation of soils and groundwater monitoring for protection of
human health and the environment. Alternative 4, capping with
groundwater monitoring, contains the contaminated soil and would
monitor groundwater, but may not allow for the natural
attenuation of groundwater contamination. Alternatives 2, 3, and
" 4, soil ex-situ solidification/stabilization, excavation, and
capping respectively, all reduce the risk of direct soil contact
and ingestion. Alternatives 5, 6, and 7 combine each of the soil
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remediation alternatives with groundwater extraction and
treatment to prevent potential migration of the contaminated
plume.
Alternatives 2, 3, 5, and 6 either treat and/or remove the source
of metals contamination, thereby,' allowing the shallow
groundwater to attain the COCs MCL through natural attenuation or
by extraction and treatment. These alternatives protect human
health and the environment through restoring the Class IIA
aquifer and preventing any potential migration of the
contaminated plume. Since there is not a current direct exposure
route to groundwater and an increase in contaminant .
concentrations has not been detected in the receiving stream,
groundwater extraction and treatment may not significantly reduce
risks to human health or the environment. Therefore, source
...'.treatment 'or~removal with groundwater monitoring and natural
attenuation of the groundwater contamination is protective. A
contingency groundwater remedy of extraction and treatment of
groundwater, if natural attenuation is determined ineffective,
would be most protective. .
Natural attenuation is expected to remediate the cadmium
contamination in the groundwater in approximately two years upon
treatment or removal of the contaminated soils.
8.1.2
COMPLIANCE WITH ARARS
The only' location-specific ARAR applicable to the Site is. the
Site's location within the floodplain. However, the Site is
protected from the100-year flood by a levee. All alternatives,
except the no-action alternative, will meet all of their
respective ARARs. .
Groundwater ARARs include Maximum Contaminant Levels (MCLs) that
establish chemical-specific limits on certain contaminants in
cOIml\UIlity water systems. Even though the groundwater data
suggests that representative concentrations of constituents are
above the established MCLs, natural attenuation is expected to
achieve MCLs over time upon treatment of. the source area. Long-
term monitoring is included in alternatives 1,2, 3, and 4.
Additional statistical analysis of data will further substantiate
the presence/absence of a groundwater plume. This l~ng-term
monitoring will provide the data necessary for a statistical
determination of constituent concentrations in groundwater. If,
in EPA's sole discretion, it becomes apparent that MCLs will not
be.met through attenuation, a contingency pump and treat remedy
as described in 'alternative 5 will be considered and at EPA's
sole determination be implemented.
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For Alternative #2, consolidation of the soils for ex-situ
solidification/stabilization treatment of contaminated soils is
not expected to require a waiver for the RCRA Land Disposal
Restrictions because the treated soils are not expected to
exhibit a hazardous waste characteristic. However,
characteristic leaching tests shall be performed to confirm this
expectation. The remedial action will include further sampling.
and analysis of groundwater to verify that groundwater beneath
the Site will meet ARARs through attenuation in a reasonable
time-frame. Surface water on site currently meets ARARs.
For Alternatives 2, 3, 5, and 6, Region IV, Guidance Number TSC-
92-02, concerning management of contaminated media is a TBC
guidance relevant to the application of RCRA to the management of
contaminated media and for the protection of Human Health and the
.."Environment,,'If.themedium (soil) is contaminated by
constituents identified in 40 CFR S 261, Appendix VIII, and
exhibits a hazardous waste characteristic, then the contaminated
medium must be treated in accordance with RCRA subtitle C
requirements until it no longer exhibits .the characteristic.
Since the medium (soil) on site was contaminated thorough contact
with a characteristic waste (Slag piles) and testing during the
RI determined that the media exhibits a hazardous waste
.characteristic (TCLP), this medium must than be managed, per this
guidance, in accordance with RCRA Subtitle C until the medium
does not exhibit hazardous waste characteristics upon which best
management practices for disposal will apply. Treatment of
contaminated medium- (soils). through ex-situ solidification/.',. .a
stabilization is expected to remove the hazardous waste
characteristic and attain health-based risk levels.
Alternatives 2, 3, 5, and 6 would be able to meet all Federal and
State standards for contaminants and proposed actions.
A:&.ternatives 4 and 7, capping, may not be able to meet Chemical
Specific ARARs for groundwater contamination MCLs since the
source of potential groundwater contamination will remain on site
or be left untreated. Alternative 1, no action, would not be
able to meet ARARs.
8.2
PRIMARY BALANCING CRITERIA
8.2.1
LONG-TERM EFFECTIVENESS AND PERMANENCE
Alternatives 2 and 5 would have the highest. degree of long-term
~ffectiveness and permanence because th~ would use a permanent
and reliable treatment process to reduce risks posed by
contaminated soils and monitoring for natural attenuation'
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(alternative 2) or groundwater treatment (alternative 5) to
protect against risks posed by the contaminated groundwater. Ex-
Situ Solidification/Stabilization would reduce the mobility of
COCs by more than 95 percent. .
Alternatives 3 and 6 would have a high degree of long-term
effectiveness since the source material would be excavated and
disposed off-site at a regulated landfill. However, long-term
liabilities associated with disposal in a secure landfill or
treatment facility would exist. Additionally, long-term
protection of groundwater would be accomplished through
monitoring for natural attenuation (alternative 3) or groundwater
treatment (alternative 6) to protect against hazards posed by the
contaminated groundwater.
.'>0..'. '."Alternatives -4 .and.7 would rely on a cap to contain contaminated
soils and control infiltration. Upon completion, long-term
monitoring and maintenance would be required for both
. alternatives. Although capping is an effective and accepted
approach for reducing risk from direct contact with wastes, it is
less reliable in the long-term than permanent remedies described
in alternatives 2, 3, 5 and 6 in which ex-situ solidification/
stabilization or off-site disposal are used to treat or remove
contaminated soil. The inherent hazard of the COCs would remain
on the Site if alternatives 4 and 7 were implemented.
Additionally, these alternatives may allow for potential
continued exposure and/or migration of COCs to groundwater, and
as a .result . the: probability. that.:groundwater.contamination..would_.
attenuate is reduced.
. Alternatives 2, 3, and 4 would incorporate groundwater monitoring
while alternatives 5, 6, and 7 would incorporate groundwater
extraction and treatment for groundwater protection and .
remediation. While groundwater treatment appears to be the most
expeditious and per.manent method. for groundwater protection,
groundwater modeling indicates that natural attenuation of the
groundwater contamination would take approximately 2 years from
source treatment or removal versus 1.3 years for groundwater
extraction and treatment. Therefore, natural attenuation
(alternatives 2, 3 and 4) is nearly as effective as extraction
and treatment (alternatives 5, 6, and 7).
Alternatives 2 and 5 would provide the greatest long-term
effectiveness and permanence because they use treatment to reduce
hazards' posed by contaminated soils and monitoring or treatment
to protect against future threats from use of the shallow
.aquifer.
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8.2.2
REDUCTION OF TOXICITY, MOBILITY, OR VOLUME THROUGH
TREATMENT
Alternatives 2 and 5 use ex-situ solidification/stabilization to
reduce the mobility and toxicity of the approximately 1'9,280 cu
yd of contaminated soils and meets the CERCLA preference for
treatment rather than containment; however, an increase in volume
of material due to the nature of the treatment may occur.
Alternatives 3, 4, 6, and 7 do not utilize any treatment to
reduce the toxicity, mobility, or volume of the contaminated
soils and do not meet the statutory mandate for treatment.
Alternatives 5, 6, and 7 would treat groundwater contamination to
reduce toxicity, volume, and mobility, whereas alternatives 2, 3,
. "and'4 would utilize' 'natural attenuation of the groundwater to
reduce toxicity, volume, and mobility.
Therefore, alternatives 2 and 5 best satisfy CERCLA's statutory
preference for treatment and use of treatment to reduce toxicity,
mobility, and volume of contaminants. .
8.2.3
SHORT-TERM EFFECTIVENESS
Alternatives 4 and 7, capping, would have the greatest short-term
effectiveness since the cap would be constructed in six months
without disturbing .the contaminated soils. .
Alternatives 2, 3, 5, and 6, ex-situ solidification/stabilization
and off-site disposal, would present a similar time frame for
implementation as capping; however, potential risk to workers,
the community and the environment, during implementation may be
increased due to potential release of fugitive dust emissions
during excavation. This potential increase in risk would be
greatly mitigated by the short implementation time and engineered
controls to prevent or limit dust emissions.
Alternatives 5, 6 and 7 (groundwater treatment) would need
additional studies to determine groundwater treatment design
specifications. Otherwise, they would have the nearly same
effectiveness .as Alternatives 2, and 3 due to the similar time
periods for remediation of groundwater contamination as
extraction and treatment.
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8.2.4
IMPLEMENTABILITY
Alternative 2, ex-situ solidification/stabilization, and 4,
capping, would be easily implemented and followed. 'Alternative 4
would be the simplest to construct because the technology is
proven and materials are available locally. Alternatives 2 and 5
are relatively simple to do with the proper equipment and soil
mix ratios and expertise and materials are readily available.
Additional treatability studies would be required to insure
maximum effectiveness.
-, '
Alternatives 5, 6 and 7 would require more complex designs for
the groundwater treatment system. Treatability studies and an
operator to maintain the system would also be required. In
addition, further groundwater analyses would be required to more
.' '~accurately "determine 'treatment time to reach groundwater cleanup
levels.
Alternative 3 and 6, off-site disposal, would be the most
difficult to implement, because of limited treatment and disposal
capacity and necessary State approval at regulated off-site
facilities.
8.2.5
~
Cost details are provided in Appendix 5 of the FS and are
,.. summarized below, in Table 8-1. Alternative 4,.. capping,' ~s ,the,"":;:;"
lowest present worth cost and alternative 6, off-site disposal
with groundwater treatment, is the highest. Alternatives 5, 6,
'and 7 are significantly more'expensive to construct and operate
because of the groundwater extraction and treatment 'component.
Alternatives 3 and 6 cost/benefit ratio is poor due to high off-
si~e disposal costs. Alternative 2 provides for the best ratio
of costs to benefit received through the per.manent reduction of
risks to human health and the environment.
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TABLE 8-1
COMPARISON OF COSTS
30 Year . Annual Monitoring and
Present. . Maintenance Cost (30-yr)
AlternatIVe worth Cost Capital Cost
1. No-Action $ 324,860 NONE $ 23,600
2. Ex-8itu SolidiflCatiorv $ 3,372.180 $2.931,700 $32.000
Stabilization; Groundwater
Monitoring t
3. Soil Excavation and Off-Site $ 9,594,060 $9,153.sso $32.000
Disposal; Groundwater
Monitoring
4. Capping; Groundwater $ 1,136,S40 $ 438,655 $50,700
Monitoring
5. Ex-8itu Solidificatiorv $ 4,923,700 $3,809,330 $ 192,000 Years 1 - 5
StablTlzation; Groundwater $32.000 Years 6 - 30
Extraction and Treatment
6. SOU Excavation and Off-Site $ 11,145,570 $10.031.200 $ 192,000 Years 1 - 5
Disposal; Groundwater $32.0000 Years 6 - 30
Extradion and Treatment
7. Capping; Groundwater $ 2.688.040 $ 1,316,280 $ 210.700 Years 1 - 5
Extradion and Treatment $ so. 700 Years 6 - 30
t If the groundwater contingency remedy Is 1rt1)lemented, the estimated total cost of $4.923,700
as IncflCated in altemative S would apply.
8.3
MODIFYING CRITERIA
8.3.1
STATE ACCEPTANCE
The State of Georgia has concurred with the selection of
Alternative #2 to remediate the Cedartown Industries Site.
8.3.2
COMMUNITY ACCEPTANCE
Based on comments expressed at the January 14, 1993, public
meeting and receipt of four written comments during the comment
period, it appears. that the Cedartown community generally agrees
.with the selected remedy; however, various comments received
during the meeting and two of the written responses did indicate
a preference for Alternative 4, capping. Specific responses to
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issues raised by the community can be found in Appendix A, The
Responsiveness Summary.
9.0
SUMMARY OF SELECTED REMEDY
Based upon consideration of the requirements of CERCLA, the NCP,
the detailed analysis of alternatives and public and state
comments, EPA has selected, alternative 2, a source control,
groundwater monitoring, and a groundwater treatment contingency
remedy for this Site. At the completion of this remedy, the risk
associated with this Site will be protective of human health and
the environment.
The selected alternative for the Cedartown Industries Site is
'," consistent.. with: the requirements of Section 121 of CERCLA and the
National Contingency Plan. The selected alternative will reduce
the mobility, toxicity, and volume of contaminated soil at the
Site. In addition, the selected alternative is protective of
human health and the environment, will attain all Federal and
State applicable or relevant and appropriate requirements, is
cost-effective and utilizes permanent solutions to the maximum
extent practicable. The selected alternative is consistent with
previous removal actions conducted at the Site.
Based on the information available at this time, the selected
alternative represents the best balance among the criteria used
to evaluate remedies. . Alternative .No.2 .is .believed..to be. .
protective of human health and the environment, will attain
ARARs, will be cost effective, and will utilize permanent
solutions and alternative treatment technologies or resource
recovery technologies to the maximum extent practicable~
The total present worth cost of the selected remedy, Alternative
No.2, is estimated at $3,372,180 or $4,923,700 if the.
contingency groundwater remedy is implemented.
A.
SOURCE CONTROL
Source control remediation will address the contaminated surface
and subsurface soils at the Site. Source control shall include
the excavation of contaminated soils, transport, treatment
through ex-situ solidification/stabilization, placement of
treated materials and backfilling and regrading, repaving
(asphalt or gravel) and/or vegetative cover of excavated areas. -
-Following source control remediation, institutional controls in
the form of deed restrictions and record notices will be placed
on the Site.
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A.1. The ma;or components of source control to be
implemented include:
Based on the comparative analysis, EPA's preferred cleanup
alternative for the Cedartown Industries Site is Alternative
2, treatment of affected surface and subsurface soils by ex-
situ solidification/stabilization. This alternative
includes: .
.
Excavating surface and subsurface soils with a lead
concentration over 500 ppm (500 mg/kg). The surface
soil clean-up levels will be used to determine the
excavation locations and boundaries for surface soil.
The subsurface soil clean-up level will be used to
establish vertical and horizontal treatment boundaries
for subsurface soil. A sampling program shall be
conducted to confirm the actual volumes. of surface soil
and subsurface soil requiring remedial action as
indicated in Table 9-1 and Figure 7-1. Based on the
excavation performance standard of 500 mg/kg for lead,
the volume of contaminated soil to be solidified
/stabilized is approximately 19,280 cu yds. Prior to
excavation of subsurface contaminated soils, any clean
backfill would be excavated and stockpiled on. site for
reuse after the ex-situ solidification/stabilization
process has been completed;
TABLE 9-1
. CONTAMINATED SOILS.ESTIMATED AREAs AND VOLUMES ..
edia/Depch
.
removal of buildings or structures in areas requiring
excavation if required. Currently, there is no
evidence that contamination exists under the buildings.
However, if contamination is found during the remedial
design, appropriate action involving demolition of
impacted structures may be undertaken;
conducting bench and field-scale. treatability studies
and implementation of ex-situ solidification/
stabilization of excavated subsurface soils and surface
.
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.
soils. Prior to designing the final solidification
system, bench and pilot-scale treatability studies or
testing shall be required to verify the effectiveness
of the process optiucization parameters and attainment
of the performance staridards;
treating of contaucinated soils to meeting treatment
performance standards including meeting the toxicity
characteristics regulatory levels, through ex-situ
solidification/stabilization of the excavated soils;
.
placement or disposal on site of treated soils upon
meeting treatment performance standards including
toxicity characteristics regulatory levels;
"~coveringexcavated and treated areas with clean,
compacted, native fill; regrading excavated and
placement areas, and repaving with gravel or asphalt or
establishing a vegetative cover to excavated and/or
placement areas as deter.mined in the remedial design to
reduce rain infiltration and direct contact with the
treated soils;
.
.
placement of institutional controls, such as deed
restrictions and record notices, on the Site which will
be established to preclude usage of groundwater and
uciniucize land use; and
monitoring particulate air emissions from the Site to
ensure compliance with the Clean Air Act. Air .
monitoring will be conducted to ensure that contaminant
concentrations do not exceed levels considered to be .
safe for human health. If levels are exceeded,
mitigation procedures, such as dust suppression or
vapor capture, shall be employed to prevent harmful
levels of air emissions from leaving the Site; and
.
.
testing.of the treated soils to ensure that performance
requirements are met. A testing plan shall be
approved by EPA as deter.mined during the remedial
design.
A.2. EX situ treatment of excavated soils and materials
Alternative 2 consists of the treatment of contaminated
surface and subsurface soils by ex-s~tu solidification/
stabilization.
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Process optimization parameters to be deter.mined during
treatability studies and remedial design include, but not
limited to, selection of stabilizing agents and other
additives, the waste-.to-additive ratio, mixing and curing
conditions, and availability of reagents and vendors.
Performance standards include, but are not limited to, TCLP,
unconfined compressive strength, per.meability, and
leachability.
A.3. Performance Standards for Soils
The Performance Standards for this component of the selected
remedy include the following excavation and treatment
standards:
a'.'
,. Excavation Standards
Contaminated surface and subsurface soils and related
materials shall be excavated for treatment. Excavation
shall continue until the remain~ng soil and material
achieve the maximum lead concentration levels of 500
ppm (mg/kg). Testing methods approved by EPA shall be
used to determine if the maximum allowable lead
concentration levels hav~ been achieved.
b.
Treatment Standards
The .stabilized. soils ..from this Site shall.achieve all. ,
of the following four requirements' for the technology
to be considered effective. However, during the
remedial design and at EPA's sole discretion, these
'requirements may be varied within a reasonable range as
a result of unexpected site specific conditions and in
. consideration of the effectiveness of the technology
. and the clean-up goals for the Site.
1.
The ex-situ solidification/stabilization mixture
shall achieve and treated soils shall be
characterized as non-hazardous as determined by
TCLP testing.
The ex-situ solidification/stabilization mixture
and treated soils shall achieve a minimum of 50
psi compressive strength. A professional
engineer must certify that the soils of the Site
have sufficient strength to structurally support
the stabilized mass.
2.
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3.
'The ex-situ solidification/stabilization mixture
and treated soils shall demonstrate a
permeability of 1x10-6 or less
4.
The ex-situ solidification/stabilization mixture
and treated soils shall demonstrate a leachablity
of less than 1X10-12 according to procedures
described in modified ANS 16.1.
This decision is consistent with Superfund's guidelines
for effective treatment which recommends a treatment
range of 90 to 99 percent reduction in the
concentration or mobility of the COCs.
Contaminated soils treatment and disposal
"implementation shall be detennined during the Remedial
Design ,phase and approved by EPA. Soil treatment and
disposal shall comply with applicable or relevant and
appropriate requirements.
B.
GROUNDWATER MONITORING/RESTORATION
Groundwater monitoring will be implemented at this Site to assess
the movement of contamination through groundwater. If cadmium
levels do not meet monitoring performance standards or post
cleanup sampling indicates soil CQC's have migrated and
., contaminated--the.groundwater,'above. their respective"MCL, a", .' .._-~
contingency pump' and treat ~stem described in Alternative 15
shall be considered and at EPA's sole detennination be
implemented.
B.l. The maior COInDonents of aroundwater
monitorina/restoration to be iInDlemented include:
.
Long-term monitoring of groundwater shall consist of
the following:
1.
Cleanup of cadmium-contaminated groundwater to
the drinking water standard or MCL of 5 ua/l
(0.005 mg/l) through natural attenuation.
Cadmium is the only groundwater contaminant
detected above MCLs and appears to be confined to
one area in the surficial unit. Monitoring shall
consist of sampling and analyzing for cadmium
contamination at four existing downgradient (in
the direction of groundwater flow) wells and one
existing upgradient well. Monitoring shall be
accomplished on a quarterly basis. Sampling may
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be discontinued at the discretion of EPA upon
attainment of the performance standards. Once
the source is immobilized through treatment,
natural attenuation of the cadmium contamination
is expected to take approximately two years. EPA
shall consider and' at EPA's sole determination
implement a pump and treat system as described in
Alternative No.5, if the following conditions.
occur:
. cadmium levels increase during two consecutive
quarters of sampling; and/or,
. if natural attenuation has failed to achieve
the cleanup standard of 5 ug/l after completing
the third year of post-treatment groundwater
monitoring.
.
Groundwater monitoring of soil COCs, including
lead, shall be done through the post-cleanup
period to verify that the treatment of soils
and/or treated soils and material has not and
will not release COCs to the groundwater. If two
consecutive quarters of sampling indicate that
soil COCs, including lead exceed their respective
MCL, EPA shall consider initiating a pump and
treat system as described in Alternative No.5.
S-ampling.maybe.discontinued.at the.discretion .of..,
EPA upon attainment of the source and groundwater
performance standards;
Placement of institutional controls, such as deed
restrictions and record notices, on the Site which will
be established to preclude usage of groundwater and
minimize land use; and .
2.
.
rmplementation of a pump and treat system as a
contingency remedy shall be at the sole discretion of
EPA through determination that performance standards
described in B.1 have not been met. The contaminated
groundwater will be pumped to the surface and treated
in accordance with performance standards established in
B.2 below.
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B.2. Extraction, Treatment, and Discharqe of Contaminated
Groundwater Continqencv Remedy
The groundwater plume.with levels of cadmium greater than
the cleanup level or MCL of 5 ug/l (0.005 mg/l) has an
approximate area of 22,500 square feet (ft2). The thickness
of the surficial unit at the affected area is about 9 feet.
Assuming an estimated average effective porosity of 0.35,
the estimated volume of water to be treated is approximately
0.5 million gallons. The 30-year present worth estimated
cost of implementing this contingency is an additional
$1,551,520 for extraction and treatment system construction
and O&M.
If implemented, the groundwater extraction system shall
... ..: consist. of.aqroup of wells located within the estimated
area of the plume designed to intercept the contaminated
groundwater and treat to remove it to below the cleanup
level or MCL. The pumping system shall be designed to
provide a capture zone sufficient to. intercept the
delineated plume shall be targeted for extraction.
The effectiveness of the groundwater extraction system is
dependent upon the aquifer characteristics, transmissivity
and storativity. TYPically, these design criteria are
developed by aquifer testing based on constant discharge
pumping and/or recovery tests. Additional pump tests and
. modeling shall. be required prior to extraction. Based on . ...~
conservative design criteria to be confirmed during the
remedial design, transmissivity of 330 g/day/ft and
storativity of 0.01, a minimum of 3 wells at a depth of
approximately 15 feet would be needed to remediate the
cadmium-contaminated groundwater. These wells will be
spaced approximately 60 feet apart and located downgradient
from MW-4 to intercept the delineated plume and provide a
hydraulic barrier against plume migration. Each well would
be pumped at an approximate rate of 1 gallon per minute with
the total discharge of the extraction system totaling
approximately 3 gpm. At this rate, approximately 4,300
gallons would be discharged for treatment per day.
Extracted groundwater concentrations are anticipated to be
lower than the limits (0.3 mg/l) set for discharges to the
public sewer system (Cedartown Code 22-64). Therefore, the
.groundwater will be discharged.directly from the extraction
system to the city sewer.
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Cedartown Industries Site
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If discharge to the POTW cannot be obtained, NPDES standards
shall be met for discharge to an off-Site surface water
body. Any required groundwater treatment shall be
accomplished by ion exchange or reverse osmosis.
Treatability studies shall be done at implementation of this
contingency remedy to determine design parameters and
procedures. The treated effluent. would be discharged to the
surface water and the system will be designed to meet
Federal and State NPDES limitations for discharge to the
surface water.
If deemed necessa~ by EPA, the groundwater may require
additional treatment on site with granular activated carbon
or other treatment. The spent granular activated carbon
will be sent to a hazardous waste facility for disposal as
required.
B.3. Performance Standards for Groundwater
a.
Treatment Standards
If the following standards are not met by natural
attenuation, groundwater shall be. treated until the
following maximum concentration level is attained at
the wells designated during the design and approved by
the EPA as compliance points.
Cadmium
0.005 mg/l
If treatment of soils and/or treated soils and material
releases COCs to the groundwater and if sampling
indicates that soil COCs, including lead, exceed their
respective MCL; the groundwater shall be treated until
the MCL or drinking water standard for the released
COCs is attained at the wells designated during the
design and approved by EPA as cOIIl)liance points.
Discharge Standards
b.
Discharges from the groundwater treatment system shall
comply with all substantive requirements of the NPDES
permitting program under the Clean Water Act, 33 U.S.C.
1251 ~ sea., and all effluent limits established by
EPA and the State of Georgia.
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Cedartown Industries Site
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c.
Design Standards
The design, construction, and operation of any
groundwater treatment system shall be conducted in
accordance with all Pe~formance Standards, including
the RCRA requirements set forth in 40 CFR Part 264
(Subpart F).
C.
Comcliance Testina
Groundwater and treated soils monitoring shall be conducted. at
this Site. After demonstration of compliance with all
Performance Standards, sampling and monitoring may be .
discontinued at the discretion of EPA. If groundwater sampling
. .0- "or -monitoring-indicates that the Performance Standards set forth
in paragraph B.1 and B.3 are being exceeded at any time after
monitoring and/or pumping has been discontinued, extraction and
treatment of the groundwater may recommence until the performance
standards are once again achieved. If monitoring of the treated
soil indicates performance standards set forth in paragraph A.3
have been exceeded, the effectiveness of the source control
component may be re-evaluated.
10.0
STATUTORY DETERMINATION
- -. Under CERCLA Section.. 121,. 42 U.S.C'.. S. 9621, .EPA must. select... '-..
remedies that are protective of human health and the environment,
comply with applicable or relevant and appropriate requirements
(unless a.statutory waiver is justified), are cost effective, and
utilize permanent solutions and alternative treatment
technologies or resource recovery technologies to the maximum
exLent practicable. In addition, CERCLA includes a preference
for remedies that employ treatment that permanently and
significantly reduce the volume, toxicity, or mobility of
hazardous wastes as their principal element. The following
sections discuss how the selected remedy meets these statutory
requirements. .
10.1
PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
The selected remedy protects human health and the environment
through isolating and treating the principal threat by ex-situ
solidification/stabilization of contaminated soils at the Site.
The minimum level of overall protection provided by ex-situ
solidifLcation/stabilization is 1.0 x 10-6 for the lifetime
excess cancer risk and under 1 for t~e Hazard Index because the
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Cedartown Industries Site
Page 71
soil excavation and treatment performance standards of the
affected soils limit risks to these values. .Source excavation
and treatment will minimize the potential for future migration of
waste constituents to human receptors and the environment in and
around the Site. Long-term exposure from direct contact with,
ingestion of and inhalation of, affected soil and dusts will be
minimized by treatment of all affected soils.
Groundwater monitoring will be implemented in accordance with
performance standards described in Section 9.0 - SUMMARY OF
SELECTED REMEDY, subsection B.1 (Groundwater Monitoring) to
ensure that no exposure through ingestion of contaminated
groundwater occurs. Currently only a single contaminant in one
sampling location is above MCL at the Site. Therefore, no active
remediation is to be immediately implemented for groundwater.
However, if contamination in the groundwater does not attenuate
to below or soil released COCs exceed their respective MCLs
according to performance standards described in Section 9.0 -
SUMMARY OF SELECTED REMEDY, subsections B..1 (Groundwater
Restoration); the performance standards described in Section 9.0
- SUMMARY OF SELECTED REMEDY, B.2 (Extraction, Treatment, and
Discharge of Contaminated Groundwater Contingency Remedy) and B.3
(Performance Standards For Groundwater) shall apply and the
aquifer shall be actively restored through treatment.
The selected remedy provides protection of human health and the
. environment.d by -eliminating, . reducing, and. controlling risk. ._-
through treatment, engineering controls and/or institutional
controls as delineated through performance standards described in
Section 9.0 - SUMMARY OF SELECTED REMEDY, subsections A (Source
Control) and B (Groundwater Restoration). .
ATTAINMENT OF THE APPLICABLE OR RELEVANT AND
APPROPRIATE REOUIREMENTS (ARARs)
Remedial actions performed under CERCLA, Section 121, 42 U.S.C.S
9621 must comply with all applicable or relevant and appropriate
requirements (ARARs). All alternatives considered for the Site
were evaluated on the basis of the degree to which they complied
with these requirements. The selected remedy was found to meet
or exceed ARARs identified in Tables 7-1, 2, 3 and 4 and TBC's
listed in Table 7-5. The following is a short narrative in
support of attainment of the pertinent ARARs.
10.2
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Cedartown Industries Site
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Clean Air Act
Air emissions from the remedial cleanup activities at the Site.
including treatment. will be monitored to ensure compliance with
the substantive requirements of the Clean Air Act. Air
monitoring will be conducted to ensure that contaminant
concentrations do not exceed levels considered to be safe for
human health. If levels are exceeded. mitigative procedures such
as dust suppression or vapor capture will be employed to prevent
harmful levels of air emissions from leaving the Site.
Chemical-Soecific ARARs
Soil treatment and disposal and groundwater restoration
performance standards are consistent with RCRA ARARs identified
.". . in- Table "7'-4 'concerning Identification and Listing of Hazardous
Wastes and Standards Applicable to Generators of Hazardous Waste.
'. ~ .
Groundwater restoration performance standards identified as MCLs
and non-zero MCLGs (where each is available) are the Groundwater
Protection Standards set out in this ROD as the remedial action
goals. If it becomes apparent that MCLs will not be met due to
attenuation. a contingen~ pump and.treat system will be
implemented in accordance with performance standards identified
in the selected remedy section to insure that MCLs are met.
Action-Soecific ARARs
Performance and treatment standards are consistent with RCRA
ARARs identified in Tables 7-2 and 7-3 and these regulations will
be incorporated into. the design and implementation of this
remedy. If a PUlIi> and treat systems becomes necessary, . all
National Pretreatment Standards will be met before off-Site
discharge of treated groundwater to a POTW or all groundwater
treatment standards will be met prior to discharge of effluent to
aU. S. water under an NPDES permit.
Location-Soecific ARARs
Performance standards are consistent with ARARs identified in
Tables 7-1 and floodplain considerations~ if determined necessary
during the remedial design will be incorporated into the
implementation 'of this remedy.-
. The recommended remedial alternative is protective of species
listed as endangered or threatened under the Endangered Species
Act. Requirements of the Interagen~ Section 7 Consultation
Process, 50 CFR Part 402, will be met. The Department of the
~nterior, Fish & Wildlife Service, will be consulted during
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Cedartown Industries Site
Page 73
. remedial design to assure that endangered or threatened species
are not adversely impacted by' implementation of this remedy.
Waivers
Section 121 (d) (4) (C) of CERCLA, 42 U.S.C., ~ 9621(d) (4) (c),
provides that an ARAR may be waiv~d when compliance with an ARAR
is technically impracticable from an engineering perspective.
However, no waivers are anticipated to be invoked at this Site.
Other Guidance To Be Considered
Other Guidance To Be Considered (TBCs) include health-bas.ed'
advisories and guidance. TBCs have been utilized in estimating
incremental cancer risk numbers for remedial activities ' at the
Sites and in determining RCRA applications to 'contaminated media.
10.3
COST EFFECTIVENESS
Although Alternative No.2, Ex-Situ Solidification/Stabilization
is not the least expensive alternative, does provide more
protection than the less expensive alternatives, no action and
capping. In addition, this alternative satisfies the policy for
treatment of the contaminated media. However, Alternative No.2
is not as expensive as Alternative No.3, off-site disposal,
which is estimated to cost $9.6 million dollars. Alternative No.
3 also does not satisfy the preference for treatment and the
three-fold cost increase is not warranted since Alternative No.2
, will, also protect human health and the environment. '
EPA believes the selected remedy, alternative No.2 will
eliminate the .risks to human health at an estimated cost of
$3,372,180 or $4,923,700 if the contingency groundwater remedy is
implemented; therefore, the selected remedy provides an overall
effectiveness proportionate to its costs, such that it represents
a reasonable value achieved for the investment.
10.4
UTiLIZATION OF PERMANENT SOLUTIONS TO THE MAXIMUM
EXTENT PRACTICABLE
EPA and the State of Georgia have determined that the selected
remedy represents the maximum extent to which permanent solutions
and treatment technologies can be utilized in a cost~effective
manner for the final source control at the Cedartown Industries
Site. Of those alternatives that are protective of human health
and the environment and comply, with ARARs, EPA and the State have
determined that ,this selected remedy provides the best balance of
trade-offs in terms of long-ter.m effectiveness and permanence,
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Cedartown Industries Site
Page 74
reduction in toxicity, mobility, or volume achieved through
treatment, short-term effectiveness, implementability, and cost,
while also considering the statutory preference for treatment as
a principal element and consideration of state and community
acceptance. The selected remedy is the only alternative that
satisfies the statutory preference for treatment. The selected
remedy provides for the long-te~ effectiveness and permanence,
is easily implemented, reduces toxicity, mobility or, volume, and
is cost effactive. Most importantly this remedy reduces
toxicity, mobility or, volume using a permanent .treatment
process.
The State of Georgia was concerned in that soil excavation
performance standards~ while protective of human health and the
environment, would leave lead concentrations over site specific
background values. Additionally, concerns were discussed that
- . during... the.. treatment of soils and after placement of the
solidified/stabilized monolith, that the soil COCs may leach to
the groundwater. To address these concerns, the selected remedy
section, consistent with the proposed plan, requires analyzing
groundwater for all soil COC's during the groundwater monitoring
program to ensure groundwater is adequately protected.
The Cedartown community generally agrees with the selected
remedy; however, various comments received during the meeting and
written responses did indicate a preference for Alternative 4,
capping.
10.5 ..
. PREFERENCE FOR "TREATMENT AS A 'PRINCIPAL ELEMENT. ..... ....
By treating the contaminated soils b¥ ex~situ solidification/ .
stabilization, the selected remedy addresses one of the principal
threats posed b¥ the Site through the use of treatment
technologies. By utilizing treatment as a significant portion of
the remedy, the statutory preference for remedies that employ
treatment as a principal element is satisfied.
11.0
DOCUMENTATION OF SIGNIFICANT CHANGES
There have been no significant changes in the selected remedy,
alternative No.2, ex-situ solidification/stabilization fram the
preferred remedy described in the proposed plan. However, there
was a typographical error in clean-up goals presented in the
Proposed Plan issued December 1992. The error was corrected at
the Public Meeting held on. January 14, 1993. The summary of
clean-up levels for Beryllium was listed as .2 mg/kg. The
correct value is 2.0 mg/kg. This correction. does not affect the
selection nor implementation of the selected remedy.
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Cedartown Industries Site
Page 75
APPENDIX A - RESPONSIVENESS StJMHAJly
-------
APPEND:IX A:
RESPONS:IVENESS SUMMARY - CEDARTOWN :INDUSTR:IES,
RECORD OF DEC:IS:ION
The U.S. Environmental Protection Agency (EPA) held a 3D-day public comment
period was from December 28, 1992, through January 27, 1993 for interested
parties to give inp~t on EPA's Proposed Plan for Remedial Action at the
Cedartown Industries Superfund Site in Cedartown, Georgia. A public
meeting has conducted on January 14, 1993, at the Cedartown Public Library,
245 East Avenue, Cedartown, Georgia. The meeting presented the results of
the Remedial Investigation anQ Feasibility Study (RI/FS) and EPA's
preferred remedy for the Cedartown Industries Site.
A responsiveness summary is required to document how EPA addressed citizen
comments and concerns about the Site, as raised during the public comment
period. All comments summarized in this appendix have been factored into
the final decision of the remedial action for the Cedartown Industries
Site.
smJHARY OF KAJOR QOBS'1'ZONS AND COMHENTS RBCB%V3D Dt7RIHa '1'HB PUBLIC
.. .COlOmN'r PER.I:OD ANI) BPA' 8 RESPONSBS
BPA RESPONSB
ZSSt1B
1.
The preferred remedy, Alternative 2, may generate
dusts containing Site contaminates; therefore, it is
not protective of human health and the environment.
Additionally, capping would be able to meet aD
Federal and State regulations, would be the simplest
to constJUct, and satisfies short term effectiveness.
Therefore, Alternative 4, capping, should be the
chosen remedy instead of EPA's preferred remedy
of stabilization.
2.
Alternative 4, capping, reduces toxicity from
contaminants on Site.
Alternative 2, stabDization, meets aU 9 evaluation
criteria and provides the best balance among all
alternatives. Since stablflZation is a method of
treatment, Alternative 2 also meets the agency's
preference for a treatment technology. WhUe the risk
reduction for containment is stmDar to that of
stabilization, the aclcfltional criteria of reducing toxicity,
mobility, and volume through treatment is not met by
capping. Moreover, EPA has strong preference for
permanent treatment, and the stabIUzation is a .
permanent solution. CappIng, on the other hand,
would not treat the contaminated solis at all, only
contain It, which may not allow cadmium contaninated
groundwater to naturally attenuate to the drinking
water standards. Airborne dusts wID be controlled
through air monitoring and dust control measures as .
required. AIr monitoring wDI be conducted during all
field activities during the re~ action. Precautions
wiD be taken to minimize any airborne releases. The
Health and Safety Plan for the remedial action wUl
estabDsh procedures to be taken to minimize air
releases as weD as set forth response actions In the
event a release occurs.
Alternative 4 is a containment remedy and will not
reduCe toxicity of the contamlriated media. WhUe
containment wiD reduce exposure, capping does not
reduce the toxicity of the contaminated solis. Toxicity
and mobiUty wli be reduced ttvough the solidlfacatlon
and stabilization remedy described In altemative 2.
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SOMHARY OF KAJOR QOESTXONS AND COMHEN'l'S RECB:IVED DtJ1lXNG THE POBLXC
COMMENT PERXOD AND EPA'a RESPONSES
XSSt7B
3.
Cedartown area residents were overwhelmingly in
favor of alternative 4, capping.
4.
The pound-volume of contaminants at any Site
should be factored in before arriving at a preferred
clean-up procedure. The emphasis should be not
be the fact that the area is contaminated, but rather
by the volume or mass of disposed of waste
(11ateriaL
s.
It Is highly significant that groundwater Sal11)les from
. only one of . seve" wells showed any measurable
amount of cadmium which may be related to
potential sulfuric acid draining from lead battery
plates and decayed organic refuse.
6. While the soils In the area are contaminated with a
. ... number of heavy metals, what Is not appreciated Is .
that most of the contaminates are In the same water
Insoluble fonn they were In 1980. Cadmium
..i contamination was..1n the fonn of oxide and Is
completely insoluble in water. Lead compounds or
~ have an extremely Dmited solubUity in water,
thetefore. the amount of lead solubilized from a
contaminated area during a rain stann would be
close to nil such that migration Into the surrounding
soDs would be rrinlscule. Therefore. altematlve 4.
capping Is the most practical solution.
7. How long wiD . take to ir\1)lement the remedy and
for the Site to be In compDance?
EPA RESPONSB
Public meeting transcripts and written comments
indicate the convnunity does not overwhelmingly favor
either altemative 2 or 4. Responses indicate both
altematives are supported by differing segments of the
community with neither alternative achieving a clear
majority. However, neither alternative was rejected by
the community as unacceptable.
. While data indicating the pound-volume, mass, and
composition fonn of all disposed waste materials
disposed is not available. data coDected during the
remedial Investigation Is suffICient to detem1ine
concentrations of contaminants In the soils and
groundwater. to detennine I an unacceptable risk to .
human health and the environment exists, and to
select a remedy.
Sampling data Indicates that Site-related cadmium
contamination Is present in the groundwater in
concentrations above the Federal drinking water
standard; therefore. groundwater remecrlation must be
addressed. If the contaminated soils are treated or
removed, the cadmium contamination In the
groundwater should attenuate to the drinking water
standard and ambient water quality criteria. While
evidence does not exist of prior battery cracking and
refuse handDng on Site. this comment does support
and demonstrate the need to treat or remove these
soDs to allow for natural attenuation of groundwater.
SampUng data Indicates that Site-related cadmium
contamination exists in the groundwater at levels
above the drinking water standard. Since evidence
Indicates that cadmium contamination Is moving to the
groundwater. the contamination source should be
removed for this current drinking water aquifer to most
effec::tively allow attenuation to the drinking water
standards. Therefore. alternative 2. which treats the
soUrce material defined as contaminated soils, Is the
most effective remedy and best provides for the
process of natural attenuation to occur. .
Negotiation and lodging of a consent decree between
EPA and Potentially Responsible Parties (PRPs) for
remedy lri1pIementation may take up to a year. The
remedial design generally takes 1.5 years. The
remedial action construction from Site mobilization wiD
take an estimated 6 to 12 months to cofT1)lete. Natural
attenuation of groundwater contamination may take
approximately two years from cofT1)letion of the soli
treatment pIOC8SS. Groundwater monitoring to ensure
protection of human health and the environment wiD be
required.
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SUMMARY OJ! MAJOR QtJESTIONS AND COMHEN'1'S RECEIVED DOR:ING THE PUBLIC
COMMENT PERIOD AND EPA'8 RESPONSES
EPA RESPONSE
:ISSUE
8.
What is the impact on aquatic rife in Cedar Creek?
9.
What is the regulatory level of cadmium for drinking
water? What is the estimated area of CO~minatil:)o
and when does the contamination go below the
ambient water quality criteria for cadmium?
10.
Why Implement alternative 2 and spend In excess of
$3,000,000 to clean up one smaD area of
groundwater contamination?
Based on a benthic macro invertebrate survey and
collected water sart1)ling data, the Site has not
adversely affected the water and aquatic quality of .
Cedar Creek.
The Maximum Contaminant Level (MCL) for cadmium
is.S JIO'I or S parts per billion. The estimated cadmium
contaminated groundwater volume is 0.5 million gallons
. located in an estimated 10,000 to 22,500 sq ft area.
Groundwater modeling Indicates that groundwater
contaminant concentrations are below ambient water
quality criteria standards and MCLs weD before
discharge to Cedar Creek.
Altematlve 2, stabDization, In adcfltion to protecting
groundwater, Is being implemented to protect human
health and the environmental risks associated with
exposure to contaminated soils. Alternative 2 meets aU
9 evaluation criteria and provides the best balance
among aU alternatives. Since stablrlzation Is a method .
of treatment, Alternative 2 alSo meets the EPA's
preference for a treatment technology.
11.
Since there are trilrlons and trilrlons of gallons of
water underground, It would appear there should be
no contamination worth worrying about?
12.
IS it possible if contaminated soils were left In place
that groundwater In the aquifer could become
contaminated? If soDs are not solldifl8d, how long
would it take for the cadmium contaminated
groundwater to go Nay?
13.
Since the risk assessment Indicates an unacceptable
residential future risk, would it not be more
appropriate to not allow residential use rather than
doing a cleanup?
Results of. analysis conducted during the RI/FS
Indicates that groundwater has been Impacted by the
contaminants of concern. Further data demonstrates
that the cadmium groundwater contamination exists In
concentrations over the drinking water standard. Since
this aquifer Is a current source of drinking water, the
aquifer mJst be restored to its benefICial use and meet .
the Federal and State drinking water standards
following remediation.
Yes, contaminants left in place untreated may continue
to leach into the aquifer. AdditionaUy, contaminants left
In place untreated may not aDow for the natural
atteooatlon of cadmium contamination to below
drinking water standards, and may resul over time In
other soli contaminants of concem exceeding their
respective Federal and State drinking water standard.
Following removal of the source of cordamlnatlon, the
abil"lty of this aquifer to naturally attenuate Site related
contaminants Is heightened.
EPA has a policy of using the future on Site residential
scenarios on aD Sites unless the Site Is In a heavily
industrialized area with no residences Marty. The
assumptions and methodologies required by EPA are
intended to err. if they mJst. on the more protective
side in ord~r to protect human health and the
enviroM18nt. Since the potential for future residential
development does exist, the deaoop remedy IIIJst be
protective and permanent.
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StJMHARY OF MAJOR QOBSTIONS.AND COMMENTS RECEIVED Dt:JRING THE PtJBLIC
COMMENT PERIOD AND EPA'8 RBSPONSES
ISSt7B
14. The volume of soils excavated and treated could
probably be reduced from 19.000 to S.OOO cu yds and
get 99% of the lead out?
15.
What kind of threat and Impact Is there to the
existing businesS on Site?
EPA RBSPONSE
The cleanup goal of SOO mgJkg has been detennined
to be protective of human health and the environment
Sampling data indicates that approximately 19.000 cu
yds of soils are contaminated with lead levels greater
. than SOO mglkg. While it is possible for 5.000 cu yds of
contaminated soils to contain 99% of the lead mass.
the volume of soils treated is based on the reduction of
risk to an acceptable concentration and not on total
. contaminant quantity. volume. or mass. Based on
available data, approximately 19.000 cu yds of soil
must be excavated and treated to reach the clean-up
goals.
The business located on site may be impacted during
the remedial action construction as a result of work
stoppages caused by construction activities. If
sampUng during remedial design or action indicates
contamination exists undemeath build"1I1g foundations.
appropriate action which may involve demolition of
impacted structures may be undertaken. All efforts wiD
be made during the remedial design and action to
minimize impacts to this business. A future threat
does exist if no remedial action were undertaken;
however. Stabilization treatment wW reduce risks to an
acceptable level Airbome dusts will be controDed
through air monitoring and dust control measures as
required. Air monitoring win be conducted during all
fl8ld ac:tivities during the remedial action. Precautions
wiD be taken to minimize any airborne releases. The
Health and Safety Plan for the remedial action will
estabflsh procedures to be taken to minimize air
releases as wen as set forth response actions in the
event a release occurs.
16.
Are parameters such as clean up goals and the
protec:tive of human health caranogen risk of 10"' or
hazard quotient (HQ) set by regulation or law or is it
an EPA Nle7
17.
Was benzene detected on Site?
Maxm.am Contaminant Levels for drinking water and
risk-based goals are consistent with regulatory and
EPA policy and can be found In the National
Contingency Plan (NCP). the Federal regulation which
Implements the Superfund law. .
No benzene was detected on site.
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. - - - .- .--"
-.- .- --. + - . .---.
SUMMARY OF MAJOR QtJ'ES'r:IONS AND COMHEN'l'S RECE:IVED Dtm.:ING THE POBLIC
COHMEN'r PER:IOD AND EPA'a RESPONSES
:ISSUE
18.
The State of Georgia requires that all sites where
releases of hazardous waste or hazardous
constituents have oCcurred be remediated back to
background. In cases where these constituents are
left in place, groundwater monitoring is required.
Since the cleanup level for lead far exceeds the
background values at the Site, lead should be a
Contaminant of Concem for groundwater.
SPA RESPONSB
While the contaminated soils wiD not be cleaned up to
background, the remedy fulfills the requirement of
being protective 01 human health and the environment
and meeting all Applicable and Relevant Regulations.
The requirement to clean to background is Georgia
Environmental Protection Division (EPD) policy, not
regulation or law. .
. SampUng results and analysis indicate the lead is not a
contaminant of.concern for groundwater with levels
well below the applicable drinking water standard.
However, the proposed plan states that groundwater
monitoring of soil contaminants of concem would be
done during the post-deanup period to verify and
ensure treated materials do not release contaminants
of concern, including lead. to the groundwater. The
performance standards addressing monitoring of soil
contaminants of concem can be found In the Selected
Remedy Section of the ROD. Since the contaminated
sons are being treated, it is anticipated that soils would
not exhibit hazardous waste characteristics. Therefore.
release of soil contaminants of concern to the
groundwater is unlikely.
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6 (
ROD
Cedartown Industries Site
Page 76
APPENDIX B - STA'l'B CONCt1RRENCB: LE'1"1'ER
-------
Georqia Department of Natural Resources
205 Butler Street, S.E., Suite 1252, Atlanta, Georgia 30334
Joe D. Tanner, Commissioner
Harold F. Reheis, Director
Environmental Protection Division
.. _0'-" ._-
0." ",
Mr. Jay V. Bassett
Remedial Project Manager
South Superfund Remedial Branch
U.S. Environmental Protection Agency
345 Courtland Street, N.W.
Atlanta, Georgia 30345
~
April 12, 1993
Re:
State Concurrence
Record of Decision (ROD)
Cedartown Industries NPL Site
Cedartown. Georgia
Dear Mr. Bassett:
The State of Georgia Environmental Protection Division has reviewed the Record of
Decision for the Cedartown Industries Superfund site located in Cedartown, Georgia. EPD has
reviewed this document and has detennined that all comments outlined in EPD's letter dated
March 26. 1993 have been sufficiently addressed in the fmal Record of Decision. Therefore, the
State of Georgia concurs with the U.S. Environmental Protection Division in selecting Alternative
#2 for the final remedy.
Should you have any additional questions regarding this mauer, please do not hesitate to
cOntact Ms. Merrill Meek of my staff at 4041656-7802. .
~O!'A1
Harold F. ~~l 'VI \N' -v
Director
cc: Jim Ussery
HFRImlm
f:~-
File: Ced8.rtown Industries NPL Site
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U.S. DEPARTMENT OF COMMERCE
N8tlan81 Technlc811nfarm8tlan Service
SWlllgfl,,'d. Ve. 22 f 0 f
AN EOUAl OPPORTUNITY EMPLOYER
UHICIAl nUSINESS
r,,"ulty 'or "rlvetu' Use, $30U
POSTAGE AND FEES PAIl)
U.S. OEPARTMENT OF COMMEnCE
COM-211
FIRST CLASS
'~
.....MAIL
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