United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R04-91/083
August 1991
EPA Superfund
Record of Decision:
Mallory Capacitor, TN
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50272-101
REPORT DOCUMENTATION 11. REPORT NO. I ~ 3. Reclpienf. ACC888Ion No.
PAGE EPA/ROD/R04-91/083
4. 11tIe and Subti1Ie 5. Report Da1e
SUPERFUND RECORD OF DECISION 08/29/91
Mallory Capacitor, TN 6.
First Remedial Action - Final
7. Authorl.) 8. Perfonnlng Organization Rapt. No.
8. Perfonning Orgalnlzation Name and Add..... 10. ProjeCIIT88klWorI< Unit No.
11. Contract{C) or Grant(G) No.
(C)
(G)
1~ Sponaorlng Organization Name and Addre.. 13. Type of Report & Period Covered
U.S. Environmental Protection Agency 800/000
401 M Street, S.W.
Washington, D.C. 20460 14.
15. Supplementary Nolea
16. Abstract (Umlt: 200 worda)
The 8.6-acre Mallory Capacitor site is a former electrical capacitor manufacturing
facility in Waynesboro, Wayne County, Tennessee. Land use in the area is mixed
residential, commercial, and industrial, with the Green River bordering the site to the
east. There are 54 private wells located within a I-mile radius of the site that draw
on the Fort Payne Formation aquifer for ground water. The Mallory Capacitor Company
was operated from 1969 to 1979 by Duracell, and from 1979 to 1984 by Emhart Industries
to manufacture electrical capacitors onsite using TCE as part of the process. Process
liquid wastes were stored in underground storage tanks onsite. From 1976 to 1980,
clean-up actions were implemented by Emhart to remove PCB-contaminated materials from
process equipment within the manufacturing facility. These actions also included
removing the underground storage tank adjacent to the plant and associated surrounding
PCB-contaminated soil. In 1984, routine TCE still bottom testing revealed
PCB-containing still bottoms. The facility was subsequently shut down because of
unsafe working conditions. Subsequent studies revealed significant levels of PCBs on
portions of the plant structure, in process equipment, and in soil; and elevated VOC
levels also were identified in ground water.
(See Attached Page)
17. Ooc:ument Anaiyal. L Deacrlptors
Record of Decision - Mallory Capacitor, TN
First Remedial Action - Final
Contaminated Medium: gw
Key Contaminants: VOCs (1,2-DCE, TCE), other organics (PCBs)
b. ldentifiera/Open-Ended Terms
Co COSA 11 Reid/Group
18. Availability Statement 18. Security CI... (Thi. Report) 21. No. of Pagea
None 336
20. Security CIa.. (Thl. Page) 22. PrIce
Nnnp
.See ANSl-Z38.18)
See Inalrucliona on RlItteIN
(Formetty NTlS-35)
Department of Conmerce
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EPA/ROD/R04-91/083
Mallory Capacitor, TN
First Remedial Action - Final
\bstract (Continued)
This Record
The primary
1,2-DCE and
of Decision (ROD) addresses contaminated ground water as a final remedy.
contaminants of concern affecting the ground water are VOCs including
TCE; and other organics including PCBs.
The selected remedial action for this site includes ground water pumping and onsite
treatment using air stripping; removing precipitates using filtration and carbon
adsorption, followed by onsite discharge to the Green River or offsite discharge to a
publicly owned treatment works (POTW); monitoring ground water; conducting additional
investigations to assess the extent of offsite ground water contamination and the
impact to surface waters; and implementing institutional controls including deed and
ground water use restrictions. If it is determined that, based on site conditions,
PCBs are resistant to removal by pumping and that ground water cannot be restored to
beneficial use for any or all of the contaminants, all of the following long-term
management measures may be implemented: employing engineering controls as containment
measures; invoking chemical-specific ARAR waivers for aquifer cleanup based on
technical impracticability; implementing institutional controls to restrict access to
the aquifer; reevaluating remedial technologies for ground water remediation; and
continued monitoring of specified wells. The estimated present worth cost for this
remedial action is $3,005,000.
PERFORMANCE STANDARDS OR GOALS: Chemical-specific
based on SDWA MCLs, and include PCBs 0.5 ug/l, TCE
trans-1,2-DCE 70 and 100 ug/l, respectively.
ground water clean-up goals are
5 mg/l, and cis- and
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SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
RECORD OF DECISION
REMEDIAL ALTERNATIVE SELECTION
MALLORY CAPACITOR CO. SITE
WAYNESBORO, TENNESSEE
PREPARED BY:
U.S. ENVIRONMENTAL PROTECTION.AGENCY
REGION IV
ATLANTA, GEORGIA
'"
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SECTION
I.
II.
III.
IV.
V.
VI.
TABLE OF CONTENTS
PAGE
DECIARA.TION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1
SITE DESCRIPTION, SITE HISTORY, AND SUMMARY OF
ENFORCEMENT ACTIVITIES............................2-1
INVESTIGATIONS AND STUDIES COMPLETED TO DATE......2-2
SCOPE AND ROLE OF RESPONSE ACTION.................3-1
PRIOR REMEDIATION OF OTHER
MEDIA. . . . . . . . . . . . . . . . . .3-1
SUMMARY OF SITE CHARACTERISTICS............
..4-1
.....
CONTAMINANT CHARACTERISTICS...............
.4-1
.......
AFFECTED MEDIA CHARACTERISTICS............
...4-1
. . . . ..
MIGRATION PATHWAYS..........................
.4-4
EXPOSURE
SUMMARY OF SITE RISKS.. ~ . . . . . . . . . . . . . . . . . . . . . . . . . .5-; 1
ASSESMENT. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .5-1
TOXICITY
RISK CHARACTERIZATION.............................5-9
ASSESSMENT. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .5-8
ENVIRONMENTAL RISKS............................... 5-15
ALTERNATIVE
DESCRIPTION OF REMEDIAL ALTERNATIVES..............6-1
lA. . . . . . . . . . . . . . . . . . . . . . . . ~ . . . . . ~ . . . . .6-1
ALTERNATIVE
~TERNATIVE
ALTERNATIVE
ALTERNATIVE
ALTERNATIVE
ALTERNATIVE
ALTERNATIVE
18. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-1
2A. . .8 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6... 2
2B. . . . . . . . . . . . . . . . . . . . ~ . . . . . . . . . . . . . . . 6 - J
3A. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .6-4
38. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 - 5
4A. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 - 6
48. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .6-6
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SECTION
VII.
VIII.
IX.
X.
-ii-
TABLE OF CONTENTS (Continued)
PAGE
ALTERNATIVE
SA. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-1
ALTERNATIVE
SB. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .6 - 8
COMPARATIVE ANALYSIS OF REMEDIAL ALTERNATIVES.....7-1
SELECTED REMEDY........ ... . . . . . . . . . . . . . . . . . . . . . . . . .8-1
CONTINGENCY MEASURES.............................. 8 - 3
STATUTORY DETERMINATIONS..........................9-1
PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT....9-1
COMPLIANCE WITH ARARS............................. 9-2
COST- EFFECTIVENESS. . . ... . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 - 3
UTILIZATION OF PERMANENT SOLUTIONS AND ALTERNATIVE
TREATMENT TECHNOLOGIES OR RESOURCE RECOVERY
TECHNOLOGIES TO THE MAXIMUM EXTENT PRACTICABLE....9-3
PREFERENCE FOR TREATMENT AS A PRINCIPLE ELEMENT...9-4
SIGNIFICANT CHANGES TO ALTERNATIVE 4B.............10-1
APPENDIX A - RESPONSIVENESS SUMMARY
APPENDIX B - LETTERS FROM SUPPORT AGENCIES
APPENDIX C - RISK ASSESSMENT CERTIFICATION
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1-
. -.1..1..1.-
LIST OF FIGURES
FIGURE
2.1, SITE
PAGE
LOCA T I ON. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 - 5
4.1, GROUND-WATER CONTAMINANT PLUME IN SHALLOW AQUIFER...4-7
4.2, GROUND-WATER CONTAMINANT PLUME IN DEEP AQUIFER......4-8
6.1, ALTERNATIVES 2A AND 2B EXTRACTION WELL LAYOUT....... 6-10
6.2, ALTERNATIVES 3A AND 3B, EXTRACTION WELL LAYOUT......6-11
6.3, ALTERNATIVES 4A AND 4B, PHASE I EXTRACTION WELLS.... 6-12
6.4, ALTERNATIVES 4A AND 4B, PHASE II EXTRACTION WELLS...6-13
6.5, ALTERNATIVES SA AND 5B, EXTRACTION WELL LAYOUT......6-14
8.1, SELECTED GROUND-WATER TREATM!NT PROCESS SCBEMATIC...8-5
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-iv-
LIST OF TABLES
TABLE
4.1, GROUND-WATER ANALYTICAL
PAGE
DATA. . . . . . . . . . . . . . . . . . . . . . . . . 4 - 9
5.1, ESTIMATED PUBLIC HEALTH RISK - PARKLAND EXPOSURE.....5-10
5.2, ESTIMATED PUBLIC HEALTH RISK - OFF-SITE SURFICIAL
SOILS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 - 11
5.3, ESTIMATED PUBLIC HEALTH RISK - SURFACE WATER IN THE
GREEN RIVER.......................................... 5 - 12
5.4, ESTIMATED PUBLIC HEALTH RISK. - CONSTRUCTION WORKER,
ON-SITE SURFICIAL SOILS...................... ........ .5-13
5.5, ESTIMATED PUBLIC HEALTH RISK - RESIDENTIAL EXPOSURE,
ON-SITE SURFICIAL SOILS.............................. .5-13
5.6, ESTIMATED PUBLIC HEALTH RISK - GROUND WATER NORTH
OF THE SITE.......................................... 5-14
5.7, ESTIMATED PUBLIC HEALTH RISK- GROUND WATER EAST
OF THE SIT!.......................................... 5 -15
7 . 1, APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS.. 7 - 8
7.2, DRINKING WATER STANDARDS.............................7-15
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I.
1-1
DECLARATION FOR THE RECORD OF DECISION
SITE NAME AND LOCATION
Mallory Capacitor Company
Belew Circle Drive
Waynesboro, Tennessee
STATEMENT OF BASIS AND PURPOSE
This decision document represents the selected remedial action for
the Mallory Capacitor Company site 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) and, to the extent practicable,
the National Oil and Hazardous Substances Pollution Contingency Plan
(NCP).
This decision is based upon the contents of the administrative record
for the Mallory Capacitor Company site.
The State of Tennessee concurs on the selected remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this site,
if not addressed by implementing the response action selected in this
Record of Decision (ROD), may present an imminent or substantial
endangerment to public health, welfare, or the environment.
DESCRIPTION OF THE REMEDY
This final remedy addresses remediation of ground-water contamination
by eliminating or reducing the risks posed by the Site, through
treatment an~ engineering and institutional controls.
The major components of the selected remedy include:
* In.talling and maintaining a ground-water collection system
capable of capturing the ground-water contaminant plume.
* Installing and maintaining an on-Site ground-water treatment
facility to remove contaminants from the collected ground
water.
* Monitoring the ground-water collection/treatment system and the
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1-2
ground-water contaminant plume during remedial activities to
verify effectiveness of remedial measures.
* Additional investigations to better determine the northern
extent of off-Site ground-water contamination.
* Additional investigations to determine potential chemical
contamination and biota impacts to the surface water tributary
north of the Site (Cold Water Creek).
* Placing deed restrictions on the Site property title to
identify the presence of PCBs, 1,2-DCE, and TCE and prevent the
installation of ground-water extraction wells on properties
within the zone of ground-water contamination to provide
protection of human health from future consumption of
contaminated ground water.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the
environment, complies with Federal and State requirements that are
applicable or relevant and appropriate to the remedial action and is
cost-effective. This remedy utilizes permanent solutions and
alternative treatment technologies, to the maximum extent
practicable, and satisfies the statutory preference for remedies that
employ treatment that reduces toxicity, mobility and volume as a
principal element.
Because this remedy will result in hazardous substances remaining
on-Site above health-based levels, a review will be conducted at
least every five years beginning no later than five years from
commencement of remedial construction to ensure that the remedy
continues to provide adequate protection of human health and the
environment. Reviews may be conducted on a more frequent basis as
EPA deems necessary.
AUG 2 9 1991
9~tYJ~
~Greer C. Tidwell
Regional Administrator
Date
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2-1
II.
SITE DESCRIPTION. SITE HISTORY. AND SUMMARY OF ENFORCEMENT
AND COMMUNITY RELATIONS
A.
SITE LOCATION AND DESCRIPTION
The Mallory Capacitor Company Site (the "Site") is located
Circle, TQwn of Waynesboro, Wayne County, Tennessee on the
bank of the Green River. This 8.6-acre site is located in
residential/commercial/industrial/business area which lies
Green River in the eastern section of Waynesboro. Highway
just West of the Site (see Figure 2.1).
The Site is located on land which is zoned I-l, Restrictive
Industrial District. Under I-l zoning, all operations must be
performed within completely enclosed buildings and off-street parking
and loading facilities must be provided. The land to the north of
the Site is zoned R-C, Multiple Residential/Commercial District. R-C
zoning is designed to provide adequate space for office and
commercial uses mutually compatible with higher density residential
areas. To the west and south of the Site, the land is primarily
zoned R-2, Residential, Medium/High Density. R-2 zoning is designed
to accommodate relatively large numbers of dwelling units close to
public schools and other community facilities.
on Belew
western
a
on the
13 passes
The Tennessee Department of Economic and Community Development has
estimated the 1990 population of Waynesboro at 1,824 persons and that
of Wayne County at 13,935 persons.
The U.S. Department of the Interior Fish and Wildlife Service has
confirmed that there are no wetlands, endangered species or critical
habitats that are impacted by the Site. The office of the City
Manager in Waynesboro has also stated that no historical landmarks
are being impacted by the Site. Likewise, the County Agricultural
Service has stated that no agricultural lands have been impacted by
the Site.
The geology of the Site as interpreted from surface and subsurface
features consists of three stratigraphic units, namely alluvial
deposits, residual soils, and bedrock. All three units are
encountered across the Site at varying depths. The alluvial deposits
consist of red to brown silts and sands with some clay and gravel and
vary in depth from eight feet on the western side of the Site to zero
feet where it feathers out at the edge of the Green River which
borders the east side of the Site. The residual soils, with a
maximum encountered depth of approximately eight feet, consist of
brown to tan mottled clay silts resulting from the in-situ weathering
of the underlying bedrock unit. The bedrock beneath the Site
consists of three distinct units of fractured dolomitic limestone.
General ground water flow direction is northeasterly toward the Green
River and is disrupted with fractures and lenses.
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2-2
The Fort Payne Formation is the aquifer used for ground water and is
classified IIB. The city is mostly served by municipal potable water
and sewer systems, with a few private water supplies. Within a
1-mile radius of the Site, 54 private water sources have been
identified, consisting of 27 drilled wells, 19 dug wells, and eight
springs. The nearest private water source to the Site was identified
to be a spring, located approximately 1,200 feet to the west.
B. SITE HISTORY AND ENFORCEMENT ACTIVITIES
The Mallory Capacitor Company manufacturing facility located in
Waynesboro, Tennessee was used for the manufacture of electrical
capacitors from 1969 to 1984. The Site was owned by P.R. Mallory, a
subsidiary of Duracell International, Inc.'s (Duracell's) corporate
predecessors, from 1968 to July 31, 1979, after which Emhart
Industries, Inc. took over ownership of the Site. Prior to the
April 18, 1978, EPA ban on the use of polychlorinated biphenyls
(PCBs), PCBs and trichloroethene (TCE) are known to have been used
during the manufacture of capacitors at the Site. Mallory (Duracell)
used PCBs and TCE in its manufacturing process while Emhart used TCE
in its manufacturing process.
During the period of 1976 to 1980, cleanup actions were implemented
by Emhart at the Site to remove materials contaminated with PCBs from
process equipment within the manufacturing facility. These remedial
actions also included removing an underground tank located adjacent
to the plant which was used for storage of waste liquids from the
manufacturing process and removing soils contaminated with PCBs
adjacent to the underground storage tank.
Routine TCE still bottom testing in 1984 revealed PCB-containing
still bottoms. Employees expressed concern to Emhart, who in turn
notified EPA. The plant was subsequently shut down in July, 1984,
due to unsafe working conditions. As a result of litigation between
Emhart and Duracell from 1985 to 1988 over PCB liability, Duracell
agreed to take back the Mallory Site with all associated liability.
All of Duracell's liabilities concerning the Site were assumed by
it's holding company Kraft, Inc. Kraft titled the Waynesboro
facility Battery Properties, Inc.
Investigative programs were conducted at the Site during the period
of 1984 to 1988 by Emhart to identify the nature and extent of
chemical contamination at the Site. Significant concentrations of
PCBs were identified in portions of the plant structure, on some of
the process equipment within the plant, in soils in various areas of
the Site, and in ground water beneath the Site. Significant
concentrations of volatile organic compounds (VOCs) were also
identified in the ground water.
In 1985, approximately one year following closure of the plant, the
Tennessee Department of Health and Environment (TDHE) conducted an
investigation and Hazard Ranking System (HRS) evaluation of the
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2-3
Site. As a result of TDHE's evaluation, the HRS score for the Site
of 30.8 was compiled. The Site was subsequently proposed for
inclusion on the National Priorities List (NPL) in January of 1987
and was included in the March 1990 NPL.
As a result of the proposed inclusion of the Site on the NPL in 1987,
Duracell as owner of the Site, entered into negotiations with EPA
Region IV to conduct a Remedial Investigation and Feasibility Study
(RI/FS) at the Site. The negotiations culminated in an
Administrative Order by Consent (Consent Order), effective February
18, 1988, which required Duracell to conduct the RI/FS at the Site at
EPA's direction. At a meeting between EPA and Duracell on April 5,
1988, to review the RI/FS Work Plan, it was agreed that several
programs associated with remediation of the Site would be implemented
by Duracell in conjunction with the RI/FS process. The programs
included the following:
1. cleaning and disposition of equipment within the Plant,
exclusive of equipment located within the impregnation room
of the Plant;
2. cleaning and disposition of stock within the Plant;
3. demolition and removal of the impregnation room of the Plant,
including annexed buildings and all equipment contained
therein, and the Plant's air handling systems;
4. excavation and disposal of soils contaminated with PCBs at
concentrations of greater than 10 milligrams per kilogram;
and
5. cleaning of floor, wall, ceiling and overhead surfaces within
the remaining portions of the Plant (the warehouse).
Duracell retained Conestoga-Rovers & Associates, Limited (CRA) to
manage the remedial programs. Sevenson Environmental Services was
retained under the supervision of CRA to implement the equipment and
stock disposition. Chemical Waste Management, Inc./ENRAC was
retained under the supervision of CRA to implement the partial plant
demolition and soil removal at the Site.
In addition to the aforementioned removal actions, the RI consisted
of a field sampling and analysis program followed by validation and
evaluation of the data collected. The field work was conducted
during the following periods: November, 1988 - May, 1989; August,
1989; and February, 1990 - April, 1990. Duracell retained CRA to
conduct the field work. Oversight work waa conducted by Lee Wan &
Associates, EPA's TBS VII contractor. The RI is discussed in more
detail in Section 4 of this report.
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2-4
C. COMMUNITY RELATIONS ACTIVITIES
A Community Relations Plan for the Mallory Site was finalized in
December/ 1987. This document lists contacts and interested parties
throughout government and the local community. It also establishes
communication pathways to assure timely dissemination of pertinent
information.
Subsequently, at the time of RI kickoff in September 1988, an
availability session was held. Due to interest shown on
health-related topics in the first availability session, a fact sheet
was distributed and a second availability session was held by EPA on
December 5, 1988, for responding to questions from interested
parties. A representative of the Agency for Toxic Substances and
Disease Registry (ATSDR) was present to respond to health-related
questions.
The RI and FS reports were approved on January 23, 1991, and May 9,
1991, respectively. These reports and all other documents concerning
the Site have been made available to the public in the Mallory
Capacitor NPL Site Information Repository in the Wayne County
Library. The RI report was made available to the public in April,
1991 with the FS report being made available in May, 1991.
Prior to releasing the Proposed Plan, public briefings were conducted
from April 8 - 10, 1991, to brief City and County officials as well
as heads of local environmental groups. These meetings were also
used to gain insight on public opinion concerning possible remedial
alternatives. The Proposed Plan was released to the public in June,
1991. A public meeting was held in Waynesboro on June 27, 1991 to
discuss the Proposed Plan. A comment period from June 14 to August
14, 1991, was held to provide individuals with the opportunity to
comment on the Proposed Plan. The comment period was originally
planned to end on July 15, 1991, and was extended 30 days upon
request.
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-
I
\~. E--~I
fI' ,. ~
. #' ~
., ~...; .-
./c..'''''
~
II<
...
~
'"'
Z
III
..
'e
..,
FIGURE 2. 1
,,--:.......-.
Sll£ LOCA TlON
MALLORY CAPACITOR SITE RI/FS
. Wtl)tu,sboro, TtJllneSSH
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3-1
III.
SCOPE AND ROLE OF RESPONSE ACTION
The scope of this response action is to address the remaining
concerns at the Site. As discussed previously in Section 2 of
this document, actions have been implemented to excavate and
dispose of contaminated soils and remove the plant and all
associated contaminated equipment and stock. The warehouse,
which was the. only part of the plant left after removal, was
cleaned (floor, wall, and overhead surfaces). Confirmatory
sampling in the.RI demonstrated the effectiveness of the soil
removal program. The RI also revealed no significant
concentrations of PCBs, TCE, or 1,2-DCE in surface water and
sediments of the Green River or air in the vicinity of the
Site..
Therefore, the only medium of concern remaining at the Site is
ground water. During the development of the RI, areas of
ground-water contamination for PCBs, TCE, and l,2-DCE above MCLs
were delineated in the shallow aquifer (20 feet to 40 feet below
grade) and the deep aquifer (60 feet to 90 feet below grade). .
The FS determined that the most effective method of treating the
contaminated ground water, which runs through highly fractured
rock, would be to extract the water by pumping extraction wells
and then treat the water.
It was determined in the RI that the ground water beneath the
Site was migrating in a northeasterly direction. The extraction
wells also function to contain the area of contamination as
treatment progresses. After treatment, water will be discharged
to the POTW or surface water in the Green River adjacent to the
Site.
The selected alternative for the Mallory Capacitor Co. Site, in
conjunction with past actions taken, will address all known
concerns. at the Site. One remaining concern is the possibility
of contamination in the Cold Water Creek which flows in a
northeasterly direction into the Green River. Although it is
not felt that the creek is contaminated, part of the selected
remedy will include testing this tributary in a phased approach
for chemical and possibly .toxicological parameters. For more
information concerning this sampling, see Sections 4, 6, and 8
of this document which deal with site characteristics, remedial
alternative. and the selected remedy, respectively. Remedial
action(8) will be taken in Cold Water Creek as indicated by
sampling re.ults.
The selected remedy for the Site is intended to address the
entire Site with regards to the threats to human health and the
environment posed by the Site as indicated in the Risk
Assessment for the Site. The findings of the Risk Assessment
are included in the RI Report and are summarized in Section 5 of
this document.
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4-1
IV.
SUMMARY OF SITE CHARACTERISTICS
A.
CONTAMINANT CHARACTERISTICS
The primary contaminant of concern is PCBs, mostly Arochlor 1242 and
Arochlor 1248. All free flowing PCB bearing fluids, i.e. capacitor
dielectrics, have been removed from the site in remedial actions
previously described. PCBs are readily adsorbed onto soil particles
and do not leach easily from soil. Adsorption of PCBs onto soil is
related to the organic content of a particular soil type and PCBs
recovered from soil are found to be concentrated in the organic
fraction of the soil media. The low water solubility and low
volatility of PCBs also suggest that it is partitioned most heavily
in the organic fraction of a soil. The rate of PCB movement in
saturated soil has been found to be between one-tenth and
one-hundredth the rate of groundwater movement.
The other contaminants of concern at the Site are dichloroethene
(1,2-DCE) and trichloroethene (TCE). 1,2-DCE and TCE are VOCs with
high vapor pressures and will readily volatilize from surface soils.
The half-life of these ~ompounds in surface water bodies, such as the
Green River, is 15 days. The nature of these compounds lends them
well to concentrating themselves "in ground water and deep soils where
aeration does not occur to the extent that it does in surface soils
and surface waters.
B.
AFFECTED MEDIA CHARACTERISTICS
For site management purposes, the Mallory site can be divided into
specific affected media. The following discussion summarizes the
characteristics of each media that are relevant to the
identification, screening, and selection of remedial technologies and
strategies. For more detailed information on sampling and results,
please see the Remedial Investigation Report on file in the
Administrative Record for the Mallory Capacitor Co. NPL Site.
1.
Soil
From 1988 to 1989, soil removal actions taken as part of the RI by
Chemical Waste Management, "Inc. /ENRAC under CRA for Duracell removed
all contaminated soil down to the bedrock. Confirmatory soil samples
revealed the following:
ii)
on-Site background soils did not contain detectable
concentrations of PCBs, TCE, or 1,2-DCE.
surface and subsurface soils on-Site, including ditch
and swale soils and sanitary sewer bedding material
soils, had been remediated to the cleanup criterion
i)
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4-2
for on-site soils of 10 mg/kg PCBs. Residual
concentrations of PCBs at the Site were as
follows:
a)
average concentration in surficial soils of 1.35
mg/kg to 1.60 mg/kg.
b)
average concentration in subsurface soils of 3.8
mg/kg to.'.3 mg/kg.
1,2-DCE and TCE were not identified to be contaminants of
concern in any of the soils at the Site; and
iii)
of the 21 properties adjacent to the Site boundaries,
the distribution of PCBs was determined to be as
follows:
a)
14 properties did not contain detectable
concentrations, . and
b)
the remaining seven properties contained PCBs in
concentrations that were within EPA's acceptable
risk range.
1,2 DCE and TCE were not detected in any of the soils
off-Site.
2.
Ground water
~
During the initial phase of the RI, two ground-water sampling rounds
were completed for the 29 monitoring wells installed during the RI
and seven monitoring wells installed prior to the RI designated to be
included in the water quality monitoring task. The first round was
completed during May 24 to June 6, 1989 (Round 1) and the second
round was completed during the period of August 21 to 28, 1989 (Round
2) .
On December 19 and 20, 1989, ground-water samples were recollected
from six select monitoring wells; OW21-86, OW22-86, OW25-89,. OW28-89,
OW46-89 and OW51-89 (Confirmatory Round) since the analytical data
for the initial two rounds were inconclusive to determine whether the
ground water at the respective monitoring wells was contaminated.
Following installation of 11 additional monitoring wells during the
second phase of the RI (OW53-90 to OW63-90), two additional
ground-water sampling rounds were completed. The 11 additional
monitoring wells were sampled and analyzed during the periods of
April 25 to 27, 1990 (Supplemental Round 1) and June 21 to 23, 1990
(Supplemental Round 2). During the second round, monitoring wells
OW20-86, OW21-86, OW33-89, OW34-89 and OWS1-89 also were sampled to
confirm data resulting from the initial phase.
-------
1-
4-3
Referring to Table 4.1, the results of the previously-outlined
sampling can be seen. The sampling confirmed that impacts to ground
water bad occurred from PCBs, 1,2-DCE, and TeE in the shallow bedrock
(20 to 40 feet below grade) and the deep bedrock (60 to 90 feet below
surface grade) both on-Site and off-Site (See Figures 4.1 and 4.2).
The two deeper monitoring wells completed in the deeper bedrock
aquifer (95 to 120 feet below surface grade) at locations selected to
show the most probable areas of contamination in the deeper bedrock
showed no contamination. Based on the analytical data obtained,
Figures 4.1 and 4.2 show the areal extent of ground-water
contamination at concentrations above Maximum Contaminant Levels
(MCLs) in the shallow bedrock and deep bedrock, respectively.
The on-Site areal extent of ground water with concentrations above
the MCLs for one or more of the Site-specific contaminants was
estimated to be approximately 374,600 square feet. The corresponding
on-Stte contaminated ground water pore volume was estimated to be 2.7
x 10 cubic feet, assuming a bedrock porosity of 0.1 and an average
thickness of contaminated aquifer of 25 feet for the shallow bedrock
aquifer and. 60 feet for the deep bedrock aquifer.
The off-Site areal extent of ground water with concentrati~ns above
the MCLs of one or more of the Site-related contaminants was
estimated to be approximately 400,000 square feet, extending 450 feet
north of the Site and 100 feet east of the Green Rive~. The
contaminated pore volume was estimated to be 2.1 x 10 cubic feet,
assuming the same average depth of contamination and bedrock porosity
as for the on-Site aquifers. Additional investigations will be
performed to determine more about the northern extent of ground-water
contamination and are discussed later in this document.
3. Surface Water and Sediments
Sampling confirmed that surface waters within the Green River
upstream, adjacent to, and downstream of the Site did not contain
significant concentrations of PCBs, 1,2-DCE, or TCE. It was
therefore concluded that surface waters in the Green River were not
impacted by the Site.
Sampling confirmed that sediments within the sewer systems on-Site
and in the vicinity of the Site and of the Green River upstream,
adjacent to, and downstream of the Site did not contain significant
concentrations of PCBs, TCE, or l,2-DCE. One sediment sample.
collected at the location of the former storm sewer outfall contained
PCBs at a concentration of .62 mg/kg. It was still concluded,
however, that sediments in the Green river and sewer systems on-Site
and in the vicinity of the Site had not been impacted due to the low
levels obtained upstream and downstream of this sample and in all
other samples. .
As part of the remedy selected, surface water and sediment sampling
will be undertaken in the Cold Water Creek which flows in a
~
-------
4-4
northeasterly direction into the Green River. Ground-water
monitoring wells in the residential area on the side of the Creek
opposite the Site have shown elevated levels of TCE and l,2-DCE.
Chemical 8ampling conducted on June 27, 1991, ~evealed all compliant
values with the exception of two PCB hits in sediments at .32 mg/kg
and .80 mg/kg. Since chemical sampling has revealed positive
results, additional toxicological sampling will be performed to.
insure that no biological impacts have occurred. Remedial action(s)
will be taKen in the Cold Water Creek as indicated by sampling
results.
4.
Air
Sampling at this Site
for each Site-related
air at and around the
at the Site.
in the air media showed all non-detects
contaminant. It was therefore concluded that
Site had not been impacted by past activities
C.
MIGRATION PATHWAYS
The transport of the chlorinated contaminants in the environment is
controlled by their physical properties. Four potential pathways
of migration exist: atmospheric dispersion, physical contact
(tracking), surface water runoff, and/or ground water migration.
.1.
AtmosDheric DisDersion
Atmospheric dispersion of contaminants is primarily restricted to
contaminants present in surficial soils. The contaminants may be
released to the atmosphere by volatilization and/or by entrainment on
particulate matter. Once released, these contaminants may be
transported by wind. Of the Site-specific parameters (PCBs, l,2-DCE,
and TCE), the VOC parameters (l,2-DCE and TCE) would be released to
the atmosphere primarily by volatilization and the PCBs primarily by
entrainment. .
Concentrations of TCE identified in the on-Site surficial soils were
limited to only one soil sample at a concentration of 0.019 mg/kg.
l,2-DCE was not detected in any surficial soil samples. Therefore,
atmospheric dispersion by volatilization is not considered to be a
significant contaminant migration pathway.
The potential for airborne migration of PCB. from the Site is
minimal. PCBs are not highly volatile. Also, the high equilibrium
binding con8tant for PCB in soil indicates that PCBs bind tightly to
soils. Vegetation and surfacing materials on the site virtually
eliminate any migration of contaminants on particulates generated
from wind erosion. If vegetation and surfacing. materials are
removed, the resulting wind dispersion of surface soils is not
expected to result in off-site contamination greater than one
-------
4-5
mg/kg, based on the fact that PCB contamination was removed to an
average level of 1.35 to 1.60 mg/kg and a maximum concentration of
less than 10 mg/kg in the soil.
2. Physical Contact
Contaminant migration by physical contact is primarily restricted to
surficial soils. Migration may occur by direct contact with
contaminated soil particles and subsequent tracking off-site. PCBs,
the primary contaminant in soils at the Site, were identified to be
present in surficial soils at an average concentration of 1.35 mg/kg
to 1.60 mg/kg and at a maximum concentration of less than 10 mg/kg.
The surficial soils consist of either asphaltic concrete or vegetated
soils and therefore contaminant migration by physical contact is not
considered to be a significant contaminant migration pathway at the
Site.
3. Surface Water Runoff
Contaminant migration by surface water runoff is primarily restricted
to contaminants present in surficial soils and the soils in drainage
ditches and swales. Migration may occur by physical transport or
dissolution.
The western portion of the Site is contoured to promote drainage
toward shallow perimeter ditches and a central swale, which reduce to
general overland flow in the eastern portion of the Site prior to
discharge to the Green River and Cold Water Creek. Surficial soil
samples collected from the on-Site drainage ditches and swales were
identified as containing PCB and TCE at concentrations similar to
those identified in on-Site soils. None of the Site-specific
parameters, with the exception of one PCB sediment hit at a low
concentration, were detected in sediment or surface water samples
collected from the Green River. Therefore, contaminant migration by
surface water runoff is not considered to be a significant
contaminant migration pathway. This scenario may be reevaluated when
toxicological results of the Cold Water Creek Sampling are obtained.
4. Ground Water Migration
The major potential pathway of contaminant migration identified for
this Site is the regional ground-water system. The contaminants
present in the ground-water system have migrated from the former
source area, generally to the north and east of the Site.
PCBs, 1,2-DCE, and TCE have been released to the bedrock ground-water
system beneath the Site by the percolation of the contaminants
(direct and/or enhanced by surface water infiltration) through the
overburden soils to the bedrock ground water. The Plant and
overburden soils were remediated during the 1988/89 remedial actions
completed at the Site by Duracell as part of the RI activities
(outlined previously). As a result, the contaminant sources have
been removed from the Site. Therefore, continued releases to the
-------
4-6
ground water beneath the Site from residual contaminants present in
the soils (PCBs and VOCs at concentrations generally less than 10
mg/kg and 1 mg/kg, respectively) will not be significant.
PCBs are readily adsorbed from water by solid particles and only
slowly leaches from soils. PCB has poor mobility through saturated
soil. Do~ward movement of PCBs would be controlled very slowly by
water infiltration from precipitation coupled with
sorption/desorption mechanisms based on contaminant solubility.
Rapid downward movement and horizontal migration would only be
suspected if large quantities of oil-soluble solvents were allowed to
percolate through the soil.
-------
LC5CHD
— — PROPERTY MUMOAHT
MALLOW UOMTOnHC «ELL
(20 ID 40 nrr OOP)
ear UOMTDRING «cu.
(ss TO 90 nrr OOP)
APPROXIMATE EXTENT Of PCM«.
1.J-DCE ANO/OH ICE IN SIAIKIK
BtDROCX AOUfTX
1) ISSUUtD LOCAHON Of PROPERTY
BOUNOAKT BASED CM AERIAL
PHOTOGRAPH
FICUKK I, . I
EXTENT OF PCBa. 1.2-DCE AND/OR TCE
IN SHALLOW BEDROCK GROUNDWATFI-'
MALLORY CAPACITOR SITE Rl/l
Waynesboro, Tonnes*
-------
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t^
/
DOTi-to^
.
-• "
CM9»-
LLCttffi
• PROPERTY BOUNOARr
SHA11OW MONITORING VI i
(20 ID «) FQT DQH)
OCIP UONinwiNC Mil
(65 TO BO Fill DtIP)
0
UONIIUAINC MAU
(13 ID 1ZO FtET OtEP)
TEST EX1RACTK1N Mia
CMOK
APPHOXIMAIt EKTtHI Of Pi'}-,
1.2-DCt AND /OB TCt IN 01 IP
BEDROCK AQUTEK
MOTfc
1) ASSUUO) LOCATION CF PROPCRTf
•OUNOAMT BASED ON ACKIAI.
PHOTOGRAPH
L1C
ir
SMUT
ir
FIGURE
EXTENT OF PCBs. 1.2-DCE AND/OR TCE
IN DEEP BEDROCK GROUNDWATER
MALLORY CAPACITOR SITE RI/FS
Waynasboro, Tennessee
-------
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SUMMARY III' ANAU II(:AL UA IA
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MAIl UR Y ('APACIIIIR SITE RillS
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SUMMAMY IIF ANAI.YIICU IIATA
(;MIIIJNI/WAln SAMI'lI"~
MAI.IIIM Y ("JlrACITIIM SII EMili S
WA YNISMIIMII, TENNESSEE
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5-1
v.
SUMMARY OF SITE RISKS
On-Site and off-Site surficial soils, on-Site subsurface soils,
surface water in the Green River and ground water were considered to
have potentially complete exposure pathways. The risk assessment was
performed. as-part of the Remedial Investigation for the matrices
listed above. and can be found 'in the RI Report.
A.
SELECTION OF CONTAMINANTS OF CONCERN
The hazard identification involved the selection of contaminants of
concern (COCs), detected contaminants which have inherent toxic or
carcinogenic effects that are likely to pose the greatest concern
with respect to the protection of public health and the environment.
Selected contaminants of concern at .the Mallory Site include:
*
*
*
Polychlorinated biphenyls (PCBs)
l,2-Dichloroethene (l,2-DCE)
Trichloroethene (TCE)
Monitoring data from the RI Report were used to calculate exposure
concentrations for these exposure scenarios described below.
B.
EXPOSURE ASSESSMENT
The population at greatest risk of potential adverse health effects
are those people who potentially use the ground water in the areas
north and east of the Site. The primary routes of exposure to
contaminants in ground water are ingestion of the water, dermal
absorption, and inhalation of volatiles.
To quantify all exposures, potential exposure scenarios were
developed. Exposure point concentrations and the added lifetime
cancer risk and non-carcinogenic hazard presented by the
concentrations were developed for the following conditions:
cresent conditions:
i)
on-Site surficial soils - exposure from use as
park land;
ii)
off-Site surficial soils - residential use exposure;
and
iii)
ground water migration to the Green River (surface
water) - fish consumption and wading scenarios
-------
5-2
future conditions:
i)
warehouse - potential exposure to workers in the
warehouse;
ii)
on-Site subsurface soils - potential exposure of
construction worker
..
iii)
on-Site surficial soils - potential use of area for
home construction; and
iv)
off-Site ground water - potential for use as
residential water supply .
Each of these scenarios will be discussed later in this section and
in the Risk Characterization section. As mentioned above, ground
water, surface water and sediment, air, and surface and subsurface
soil data from the RI Report were used to derive exposure point
concentrations. The RI Report contains data for samples taken. for
the contaminants of concern in May through June of 1989, August of
1989, December of 1989, April of 1990, and June of 1990 for on-Site
and off-Site sampling locations.
Some of the analytical results .are reported as "non-detects", meaning
the actual concentration of the contaminant analyzed for is between
zero and the detection limit. The risk assessment calculations were
based on assuming that all non-detect samples were contaminated at a
concentration equal to the detection limit. This makes the risk
assessment more conservative. .
Three levels of assumptions were used in the Risk Assessment. "Level
1" assumptions presented the' average or mean value for the
assumption, "Level 2" presented assumptions which were more.
conservativ, and expected to include, statistically, 90 to 95 percent
of the population, and "Level 3" presented assumptions that were
considered maximum assumptions which were reasonably possible. For
example, occupancy of a residence at one location for 10 years was
considered to represent the average length of time that an individual
would reside atone location (Levell assumption). The 90th
percentile value for length of occupancy for one residence was 30
y~ars (Level 2 assumption). It is possible that an individual could
spend an entire lifetime in a single location so the Level 3 value is
assumed to be the average life span of 70 years. .
Where the data base was adequate for the application of statistical
procedures, the mean of all sample concentrations for the medium
being evaluated was used for the Levell calculations, and the
statistical 95th percentile for the mean was applied for the ~evel 2
calculations. For the Level 3 calculations, the "mean of detects"
was used as the applicable media concentration for the medium for a
possible maximum exposure. In those cases where a single or small
-------
5-3
number of sampling locations was evaluated, the representative value
was evaluated.
1.
On-Site Surficial Soils
The exposure assessment for on-Site surficial soils was conducted
based on conditions following completion of the 1988/1989 remedial
actions implemented at the Site by Duracell (previously mentioned).
The on-Site swales and ditches are an integral part of surfaces which
can be contacted, and therefore the analytical data for the swales
and ditches were included in the risk assessment for on-Site
surficial soils. This was appropriate since the concentrations in
surficial soils of the swales and ditches were similar to
concentrations reported for surficial soils in the other on-Site
areas, and the potential exposure to surficial soils was expected to
be similar to the exposure expected in the other on-Site areas.
TCE was detected only at a low concentration in one surficial soil
sample and 1,2-DCE was not detected in any surficial soil samples.
. Therefore, only exposure from PCBs was evaluated for potential
additional lifetime risk of cancer. .
The exposure assessment for on-Site surficial soils was based on the
following assumptions:
i)
ii)
iii)
iv)
v) .
vi)
the on-Site area is utilized as park land;
as a child (1 to 6 years old), the individual is
taken to the park once a week for 26 weeks of each
year for five years;
as an older child (6 to 18 years), the individual
visits the park once a week for 26 weeks each year
for 12 years;
as an adult, the individual visits the park once
every two weeks for 26 weeks each year for the rest
of his adult lifetime (53 years, meaning a lifetime
of 70 years);
the average body weight for each period is:
*
*
*
young child
older child
adult
kg
kg
kg
(34 pounds),
(90 pounds), and
(157 pounds);
15
40
70
soil exposure equals the exposure levels recommended
in US EPA Guidance Memorandum (OSWER Directive
9850.4, Interim Guidance for Soil Inaestion Rates,
1/27/89) with additional dermal and inhalation
-------
vii)
.
5-4
exposure as recommended in the document entitled
"Assessment of Health Risk from Exposure to
Contaminated Soil, Risk Analysis Vol. 5, No.4" by
John K. Hawley dated 1985 (Hawley). Us.inq these
guidances, estimated soil exposures on exposure days
were:
'* young child 220.21 milligrams per day
(mg/day)
'* older child 114.32 mqlday
'* adult 115.81 mqlday
Cancer Potency Factor (CPF) for PCBs of 7.701per
milliqram per kiloqram per day (mql kqlday)-
(Inteqrated Risk Information System, July 16,
1990).
The estimated additional lifetime risk of cancer from PCBs in soil
was calculated using the followinq formula: .
RISK = [(SE'*SC'*CE'*WE'*YE)/(DW'*WY'*YL'*BW)]'*CPF
where:
RISK
SE
SC
DE
.WE
YE
Cpp
DW
WY
YL
BW
represents added lifetime risk of cancer from soil
exposure,
represents estimated daily exposure to soil
(mql kq/day),
represents averaqe chemical concentration in soil
(mq/ kq),
represents days exposed (days per week),
represents weeks exposed
(weeks per year),
represents years exposed (years),
represents the Cancer Potency Factor (1/(mq/ kq/day»,
represents days per week (7),
represents weeks per year (52),
represents years per lifetime (70), and
represents body weiqht (kq)
-------
5-5
2.
Off-Site Surficial Soils
Using a similar approach to that described for park land, the
estimated additional lifetime risk of cancer from exposure to PCBs in
off-Site surficial soils was calculated for surficial soil
concentrations reported for the individual off-Site properties.
For the off-Site properties, the most applicable and accurate soil
concentrations were the composite sample data where individual
samples were not analyzed, and the individual sample data where
individual samples were analyzed. Where concentrations were not
detected, the detection limit (0.016) was used in the calculation of
averages. This made the assessment more. conservative.
3.
Ground Water Miqration to the Green River
No Site-related chemicals have been reported in sediments or surface
water of the Green River, with the exception of one PCB hit at a low
level in the sediments. By estimating the flux of contaminated
ground water into the Green River, an estimated instream
concentration was calculated using an appropriate assimilation
factor.
The potential exposure to the Site-related parameters in the Green
River was limited to occasional fishing and water recreation such as
wading, since the Green River is comparatively shallow adjacent to
and in the region downstream from the Site. The scenarios used to
estimate the exposure assumed that" the individual would consume one,
two, or four meals of fish per year (scenario Levels 1, 2, and 3,
respectively) since it is unlikely that fish of a size suitable for
food would be caught on a regular basis. The estimated average flow
concentration in the Green River was evaluated since cancer risk is
related to lifetime exposure. The assumptions used to estimate
chemical exposure from the consumption of fish are presented in
. Appendix I to the RI Report.
4.
Warehouse
Although inhalation is considered by far the more serious route of
exposure in the work place, there also is .a potential for dermal
contact~ Since the PCBs present in the warehouse are not new raw
materials or'products, but rather are contaminants in soil and dust
on surfaces, potential exposure would result when skin surfaces
become soiled by dirt and grime containing PCBs. For the assessment,
the amount of soil which could be expected to contact exposed
surfaces of the arms and hands was estimated. It was assumed that
the worker is fully clothed and would only soil the arms and hands.
Hawley has rep0:2ed that hands and forearms would constitute a skin
area of 1,700 cm. Hawley further estimates that with heavy
soiling there could be 1.8 mg of dust per square centimeter or a
total of three grams (gms) on both hands and forearms. He further
reports
-------
5-6
that studies have estimated that the absorption rate of a chemical
applied directly to the skin is six percent in 12 hours or four
percent in eight hours, but if the chemical is in soil the rate is
only 15 percent of the rate of absorption of the chemical when
applied directly or in a solvent. Therefore, it was calculated that
only .6 percent (0.04 x 0.15) of the chemical in the dirt on the
soiled hands and arms would be absorbed in eight hours. Assuming
that the .J gms of dirt on the hands contained 100 mg/ kq PCBs (10
times qreater than the removal criterion of 10 mq/ kq for soils
approved for the Site by EPA and achieved by Duracell), the amount of
PCBs to which the individual would be exposed would be:
3 gms x (100 ug PCBs/gm) x 0.006 = 1.8 uq PCBs
The occupational standard indicates an acceptable daily exposure
would be 5.0 mq (5,000 uq) as calculated from the acce~table air
concentrations of 0.5 milliq3ams per cubic meter (mq/m ) and a
respiratory exchanqe of 10 m per 8 hour work day. Therefore, the
1.8 ug of PCBs absorbed through the skin due to soiling by
contaminated dirt containing 100 mq/kg PCB would be a very small
part of the acceptable work place exposure. These calculations
demonstrate that the potential exposure to dirt contaminated with
PCBs at 100 mg/ kq would not represent a serious hazard for the
employee.
To determine the potential exposure from contaminated surfaces of the
warehouse, it was assumed that all the chemical on the surface was
transferred to the surface area of the palms. In other words, a
worker in contact with the working surfaces would become equally as
soiled or contaminated as the surface being worked on. A maximum
absorption of four percent was assumed, since the PCBs on the
surfaces would more likely be absorbed when in an oily matrix.
Hawley reports the surface area of hands as 0.03 s~uare meters (m2)
so the surface areas of2the palms would be 0.015 m. If a surface
contained 100 ug/100 cm (10 times the concentration detected
"during the 1989/1990 SI), the potential transfer to the hands would
be:
0.015 m2 x (1000 ug PCBs/m2) x 0.04 = 0.6 ug PCBs
Therefore, if2the work surfaces contained PCBs at a concentration of
100 ug/lOO em and the palms of the hands became soiled to an equal
degree, only 0.6 ug of PCBs would be absorbed. Therefore, dermal
exposure to the concentrations of PCBs on surfaces within the
Warehouse would not represent any potential risk of adverse effects.
5.
On-Site Subsurface Soils
Subsurface soils are a potential exposure point only if exposed to
the surface by excavation. This could occur if construction occurred
on the Site in the future. To evaluate the potential risk from the
-------
5-7
potential exposure of construction workers, the highest average
concentration of PCBs reported in subsurface soils (7.0 mg/kg) was
assumed to be the soil to which a construction worker would be
exposed on a daily basis during the construction excavation period.
Applying an exposure scenario similar
used to ~valuate surficial soils, the
soils was estimated. The assumptions
scenario were as follows:
i)
ii)
iii)
iv)
. v)
vi)
to the soil exposure scenarios
risk for a worker to subsurface
used for the worst-case
worker is exposed for 180 days during the excavation
phase of the construction;
worker ingests 100 mg of soil/dust per work day;
arms, forearms, and half of legs are soiled;
1.45 mg of soil adhere to each square centimeter of
exposed skin surface;
absorption factor of 0.15
body weight of 70 kg; and
averaging times of 25,550 days (carcinogen) and
365 days (non-carcinogen).
On-Site Surficial Soils
vii)
6.
Due to a generally attractive location of the Site in a residential
area, there is a potential for future home construction on the Site.
The potential exposure to PCB concentrations in existing surficial
soils was evaluated and the potential additional lifetime risk of
cancer and non-carcinogenic hazards were estimated.
7.
Ground Water
Elevated concentrations of the Site-specific chemicals were detected
in the shallow and deep bedrock aquifers within the boundaries of the
Site. There are residential wells which exist within a 1-mile radius
of the Site.
To evaluate the ground water health risks, the most conservative
scenario of installing a well in the most contaminated area of ground
water was assumed. The maximum contaminant concentrations detected
in the off-Site monitoring wells in both the shallow and deep bedrock
aquifers were used to evaluate the potential additional lifetime risk
of cancer and non-carcinogenic hazard related to the use of the
water for a drinking water supply, showering, and bathing. The
-------
5-8
results of the evaluations of the off-Site area north of the Site and
the off-Site area east of the Green River (east of the Site) are
presented in Tables 5.6 and 5.7, respectively.
C.
TOXICITY ASSESSMENT
Under current EPA guidelines, the likelihood of carcinogenic and
non-carcinogenic effects due to exposure to site chemicals are
considered separately. Criteria for evaluating the potential of site
chemicals to cause these two types of adverse effects are described
below.
1.
CRITERIA FOR NON-CARCINOGENIC EFFECTS
The Reference Dose (RfD) is an estimate of the highest human intake
of a chemical, expressed as mg/kg/day, that .does not cause adverse
effects when exposure is long-term (lifetime). RfD values are based
on animal or human toxicity studies from which a
no-observed-adverse-effect level (NOAEL) is experimentally
determined. The NOAEL is the highest dose at which there was no
statistically or biologically significant adverse effect observed.
The RfD is derived by dividing the NOAEL from the selected study by
an uncertainty factor. The uncertainty factqr consists of multiples
of 10 to account for specific areas of uncertainty in the available
data. .
.The dose calculated from the exposure assessment is compared to the
RfD to determine whether adverse effects might occur. If predicted
exposure concentrations are below the level of the RfD, no adverse
health effects are expected according to current EPA guidelines.
The oral RfD for 1,2-DCE is 0.02 mg/kg/day,which is calculated using
an uncertainty factor of 1,000. This RfD is based on observations of
mice with abnormal enzyme levels indicating liver injury.' Higher
doses of 1,2-DCE caused toxic effects to the immune system of mice.
An oral RfD is not currently available for TCB and PCBs, however, non
carcinogenic effects for these two contaminants are similar to those
of 1,2-DCB. .
RfDs for dermal absorption have not yet been determined by BPA for
any of the three signature contaminants.
However, for volatile organic compounds, such as the chemicals of
concern at the Mallory Site, current EPA policy is to use the oral
RfD in calculating the hazard index for dermal exposure. The hazard
index is the ratio between route-specific calculated dose and the
RfD. Ratios exceeding unity (one) indicate doses that exceed the
acceptable levels; ratios less than unity are not expected to cause
adverse health effects. One of the assumptions in using an oral RfD
-------
5-9
is that 100 , of the chemical was absorbed via the route
in the study that was used to derive the oral RfD. This
reasonable assumption for a dermal RfD for the chemicals
at this Site.
investigated
is a
of concern
2.
CRITERIA FOR CARCINOGENIC EFFECTS
EPA uses ,a weight-of-evidence system to convey how likely a chemical
is to be a human carcinogen, based on epidemiological studies, animal
studies, and other supportive data. The classification system of
the EPA for characterization of the overall weight of evidence
carcinogenicity includes: Group A - Human Carcinogen; Group B -
Probable Human Carcinogen; Group C - Possible Human Carcinogen; Group
D - Not Classifiable as to Human Carcinogenicity; and Group E -
Evidence of Non-Carcinogenicity for Humans. Group B is subdivided
into two groups: Group B1 - limited human evidence for
carcinogenicity; and Group B2 - sufficient data in animals, but
inadequate or no evidence in humans.
1,2-DCE is currently classified in Group D, not classifiable as to
human carcinogenicity, and therefore was not evaluated for
'carcinogenic risks. PCBs and TCE are classified by EPA as Group B2,
or probable human carcinogens. 'TCE and PCBs are both associated with
an increased indidence of liver tumors in experimental animals.
For chemicals with carcinogenic effects, EPA calculates the cancer
risk associated with a given dose by multiplying the dose from a
given route of exposure by a cancer potency factor or potency slope.
EPA derives potency factors from the upper 95' confidence limit of
the slope of the extrapolated dose-response curve, which shows the
relationship between a given dose and the associated tumor
incidence. As a result, the predicted cancer risk is an upper-bound
estimate of the potential risk associated with exposure.
The2cancer slope factors (CSFs) for PCBs and TCE are 7.7 and 1.1 x
10- , respectively. 1,2-DCE has no CSF since it is not
classifiable at this time as to human carcinogenicity.
D.
RISK CHARACTERIZATION
The risks for each of the scenarios presented in the exposure
assessment will be quantified in this section.
1.
On-Site Surficial Soils
Applying the assumptions for park land to the formula presented in
the exposure assessment, the added lifetime risks from the on-Site
surficial soils were calculated as summarized in Table 5.1. Taking
into account all surficial soil data for the Site, the estimated
additional lifetime risk of cancer from eXfgsure to PCBg in on-Site
surficial soils was in the range of 3 xlO ,to 3 x 10- , which
is within EPA's target range.
-------
5-10
2.
Off-Site Surficial Soils
The results of the assessment of risk for the off-Site properties are
summarized in Table 5.2. The estimated additional lifetime risk of
cancer from gxposure to PCBs in off-Site surficial soils was in the
order of 10-- for all private properties adjacent to the Site,
except for one whicg had an estimated additional lifetime risk of
cancer of 145 x 10-. All fall well within EPA's target range of
10-b to 10- . . .
TABLE 5. 1
ESTIMATED PUBLIC HEALTH RISK
PARKLAND EXPOSURE - ON-SITE SURFICIAL SOILS
Levell
Excess Cancer Risk
Level 2
Level 3
2.7E-06
8.59E-06
3.00E-05
Levell
Non-Carcinogenic Hazard
Level 2
Level 3
Only PCBs (probable carcinogen) present
-------
5-11
TABLE 5.2
ESTIMATED PUBLIC HEALTH RISK
RESIDENTIAL EXPOSURE - OFF-SITE SURFICIAL SOILS
Off-Site
Property
( 1)
OS-1
OS-2
OS-3
OS-4
OS-5
OS-6
OS-7
OS-8
OS-9
OS-10
OS-11
OS-12
OS-14
OS-15
OS-16
OS-17
OS-18
OS-19
OS-20
OS-21
Concentrations of
PCBs in Surficial Soils
(mg/kg)
0.19
0.16(ND)
0.20
0.54
0.16(ND)
0.18
0.43
0.16(ND)
0.16(ND)
0.16(ND)
0.16(ND)
0.16(ND)
0.16(ND)
0.16(ND)
0.16(ND)
0.16(ND)
1.91
0.16(ND)
0.16(ND)
0.30
Estimated Lifetime
Cancer Risk
1. 5E-06
1. 2E-06
1.SE-06
4.1E-06
1. 2E-06
1.4E-06
3.3E-06
1. 2E-06
1. 2E-0 6
1. 2E-06
1. 2E-06
1. 2E-06
1. 2E-06
1. 2E-06
1.2E-06
1.2E-06
1. SE-05 (2)
1.2E-06
1.2E-06
2.3E-06
( 1 )
( 2 )
Locations are presented in Figure 4.2 of the RI Report.
This is the maximum risk value.
3.
Ground Water Miaration to the Green River
Usinq the estimated averaqe flow concentrations referred to in,the
exposure assessment for this scenario for the Green River, the
estimated additional lif;time risk 0t cancer from the consumption of
fish ranqed from 3 x 10- to 1 x 10-. ihe max!fum estimated
risk borders BPA's tarqeted ranqe of 10- to 10-. For the
non-carcinogens, the calculated hazard indices were 9to 10 orders of
maqnitude below 1.0, the EPA acceptable hazard index.
Due to the shallow depth of water in the Green River, swimminq was
not considered a probable exposure. More appropriately, wadinq is a
potential ,activity in a shallow stream in a suburban area. For a
more conservative scenario, the potential estimated risks and hazards
were still calculated for swimming in the Green River. The
calculations and assumptions used for the estimation are presented in
-------
5-12
Appendix I of the RI Report. The estimated additional lifetimg risk
of cancer Srom swimming in the Green River ranged 6rom 1 x410- to
3.33 x 10- , which is less than EPA's range of 10- to 10-
For the non-carcinogens, the calculated hazard indices were five to
six orders or magnitude below 1.0, the EPA acceptable hazard index.
In addition, the swimming scenario exposure significantly
over-estimates the exposure that would be expected while wading.
Therefore, the estimated risks and hazard from wading would be
significantly less than those calculated for swimming.
4.
Warehouse
Please see page 5-5 for the discussion of the warehouse scenario
under the exposure assessment.
5.
On-Site Subsurface Soils
More details of this scenario and calculations are presented in
Appendix I of the RI Report. As can be seen in Table 5.4 the.
addttional estimated risk of cancer ranged from 4.8 x 10-' to 2.9 x
10-6 which is acceptable according to the EPA target range of
10- to 10-4 .
TABLE 5.3
ESTIMATED PUBLIC HEALTH RISK
SURFACE WATER IN THE GREEN RIVER
Scenario
Fish
Consumption
Swimming
Level 1
. 3.30E-07
Excess Cancer Risk
. Leve 1 2 .
1.66E-05
Level 3
1. 29E-04
1.172-09
6.82E-09
3.33E-08
Scenario
Non-Carcinogenic Hazard
Level 1 Level 2 Level 3
Fish 2.34E-11 3.91E-10 1. 31E-09
Consumption
Swimming 6.29E-07 1. 22E-06 2.55E-06
-------
5-13
TABLE 5.4
ESTIMATED PUBLIC HEALTH RISK
CONSTRUCTION WORKER - ON-SITE SUBSURFACE SOILS
Scenario
Excess Cancer Risk
Level 1 Level 2 Level 3
Construction
Worker 4.8E-07 1. 44E-06 2.88E-06
Non-Carcinogenic Hazard
Level 1 Level 2 Level 3
Construction
Worker Only PCBs (probable carcinogen) present
TABLE 5.5
ESTIMATED PUBLIC HEALTH RISK
RESIDENTIAL EXPOSURE - ON-SITE SURFICIAL SOILS
Excess Cancer Risk
Level 1 Level 2 Level 3
3.79E-06 6.03E-05 1.05E-04
Non-Carcinogenic Hazard
Level 1 Level 2 "Level 3
Only PCBs (probable carcinogen) present
6.
On-Site Surficial Soils
Additional details on the scenario and calculations are presented
in Appendix I of the RI Report. Results are summarized in Table 5.5;
7.
Ground Water
The estimated additional lifetime risk of cancer from drinking water,
-------
5-14
showering, and bathing exposures using ground water in the most
contaminated area immed~ately north1of the Site was estimated to be
in the range of 3 x 10- t061 x 10-4' which significantly exceeds
the EPA target range of 10- to 10-. The risks were estimated
to be lower for drinking water, showering, and bathing exposures in
the area of ground water immediately east of the Site. These risks,
however, we~e s3ill unacce~table to the EPA risk range, falling
between I x 10- to 7x 10-. In both areas, the estimated
non-carcinogenic hazard indices were approximately two orders of
magnitude greater than the EPA hazard index of 1.0. Tables 5.6 and
5.7 present the respective ground-water risks .north and east of the
Site.
TABLE 5. 6
ESTIMATED PUBLIC HEALTH RISK
GROUND WATER - NORTH OF THE SITE
Lifetime Upper Bound
CSF Excess Cancer Risk
(mq/kq/dav)A-1 Level 1 Level 2 Level 3
Contaminant
PCBs 7.70E+00 9.77E-03 2.21E-02 4.22E-02
TCE 1.1E-02 2.40E-02 4.81E-02 9.42E-02
1,2-DCE O.OOE+OO O.OOE+OO O.OOE+OO
Totals 3.38E-02 7.02E-02 1. 36E-Ol
RfD Hazard Index
(mq/kq/day) Level 1 Level 2 Level 3
Contaminant
PCBs O.OOE+OO O.OOE+OO O.OOE+OO
TCE O.OOE+OO O.OOE+OO O.OOE+OO
1,2-DCE 2.0EO-2 1. 83E+02 1. 85E+02 1. 85E+02
Totals 1.83E+02 1.85E+02 1.85E+02
-------
. 5-15
TABLE 5.7
ESTIMATED PUBLIC HEALTH RISK
GROUND WATER -EAST OF THE SITE
CSF
Cmq/kq/day) "-1
Levell
Lifetime Upper Bound
Excess Cancer Risk
Level 2 Level 3
Contaminant
TCE
1.1E-02
1. SE-03 3.6E-03 6.8E-03
1. 6E-06 3.8E-06 7.2E-06
O.OOE+O O.OOE+O O.OOE+OO
1. SE-03 3.6E-03 6.8E-OJ
PCBs
7.70E+OO
1,2-DCE
Totals
RfD
(mq/kq/davl
Level 1
Hazard Index
Level 2
Level J
Contaminant
1,2-DCE
Totals
2.0EO-2
O.OOE+OO O.OOE+OO O.OOE+OO
O.OOE+OO O.OOE+OO O.OOE+OO'
2.5E-02 2.5E-02 3.4E-02
2.5E-02 3.4E-02 3.4E-02
PCBs
TCE
E.
ENVIRONMENTAL RISKS
The U.S. Department of the Interior Fish and
confirmed that there no wetlands,' endangered
habitats that are impacted by the Site. The
Agricultural service has also stated that no
impacted by the Site.
The phased chemical and biological surface water and sediment
sampling previously mentioned will be conducted to insure that no
adverse impacts have occurred in Cold Water Creek.
Wildlife Service has
species or critical
Wayne County
agricultural lands are
-------
5-16
F. UNCERTAINTIES
Regardless of the type of risk estimate developed, it should be
emphasized that all estimates of risk are based upon numerous
assumptions and uncertainties. In addition to limitations associated
with Site-specific chemical data, other assumptions and uncertainties
that affect ~he accuracy of the Site-specific risk characterizations
result from the extrapolation. of potential adverse human health
effects from animal studies, the extrapolation of effects observed at
high-dose to low-dose effects, the modeling of dose response effects,
and route-to route extrapolation. .
The use of acceptable levels (established standards, criteria and
guidelines) and unit cancer risk values which are derived from animal
studies introduces uncertainty into the risk estimates. In addition,
the exposure assumptions used in estimating individual dose levels
are often surrounded by uncertainties. As such, these estimates
should not stand alone from the various assumptions and uncertainties
upon which they are based. In developing numerical indices of risk,
an attempt is made to evaluate the effect of the assumptions and
limitations on the numerical estimates.
The uncertainty factors which are incorporated into the risk
estimates are believed to be conservative. As such, when they are
considered collectively, exposure and subsequently risk may be
overestimated. On the other hand, these risk calculations were based
on present conditions at the Site, including present concentrations
of contaminants. in the aquifer. Additional risk could occur should
the concentrations increase in the ground water.
G. CONCLUSIONS
Exposure to PCBs, TCE, and 1,2-DCE were estimated for ground water in
the areas north and east of the Site. In both areas, the existing
concentrations will exceed EPA's target risk levels if wells were
installed for showering, drinking, and bathing. Ground water is the
sole exposure route for the Site which is not within EPA's acceptable
risk range. Other routes eval~ated and results are as follows:
The surface waters of the Green River were evaluated for potential
risk from chemical exposure due to f~sh consumptton a~d wading. The
estimated values ranged from 6 x 10-to 1 x 10- which are
within EPA'8 target range of 10-6 to 10-4. The hazard indices
ranged from five to 10 orders of magnitude below the index of 1.0
deemed acceptable by EPA.
Concentrations of PCBs in surficial soils were compared to the
approved on-Site action level of 10 mg/kg and the approved off-Site
delineation action level of 1 mg/kg. In addition, exposure to PCBs
was assessed for potential additional lifetime risk of cancer using a
park land scenario for evaluation of off-Site areas. TCE and 1,2-DCE
-------
5-17
were identified in only a few of the subsurface soil samples
analyzed, at concentrations of less than 1 mg/kg. Therefore, TCE and
1,2-DCE were not considered in the risk assessment for exposure to
soil. The average on-Site concentration of PCBs in soils ranged from
1.35 mg/kg to 1.60 mg/kg and reprgsented an agditional lifetime risk
of cancer i~ the range of 3 x 10- to 3 x 10- for a parklang
exposure scenario. This is within EPA's target range of 10- to
10-4.
Only two discrete samples of surficial soils from the off-Site
properties exceeded the approved off-Site delineation action level of
1 mg/kg. The average concentrations of PCBs in individual off-Site
properties did not exceed the approved off-Site delineation action
level of 1 mg/kg. The estimated additional lifetime risk of cancer
cal~ulated for each of the off-Site properties was in the order of
10- , except5for one private property which had an es~imated risk
of 6.5 x 10;. All, however, were within the EPA target range of
10- to 10- .
Dermal exposure to PCB concentrations on surfaces within the
warehouse was evaluated and found to be minimal. Therefore,
potential exposure pathway would not represent any potential
adverse effects.
this
risk of
The estimated drinking water exposures to chemicals in off-Site
ground water from hypothetical wells in the immediate vicinity of the
Site represented risks and non-carcinogenic health hazards above the
target levels established by EPA.
Estimated concentrations of chemicals in the surface waters of the
Green River based on calculated flux contaminated ground water
represented a range of risks which did not represent a significant
concern. The estimated chemical concentrations were well below
surface water quality criteria concentrations for all parameters.
Estimated exposures did not present a non-carcinogenic hazard index
of concern.
On-Site and off-Site soils meet the approved action delineation
levels for PCBs and do not present an estimated risk of cancer in
excess of acceptable levels for PCBs for the conditions evaluated.
With the exception of Cold Water Creek where more data is required,
risks to the environment have been found to be insignificant.
Actual or threatened releases of hazardous substances from this site,
if not addressed by implementing the response action in this ROD, may
present an imminent and substantial endangerment to public health,
welfare and the environment.
-------
6-1
VI.
DESCRIPTION OF REMEDIAL ALTERNATIVES
All portions of the plant thought to be contaminated were
demolished and removed from the Site. The only portion of the
plant left standing was the warehouse, which was remediated to
remove contamination to the maximum practicable extent.
Approximately 20,000 tons of soil containing PCBs in excess of
10 mg/kgwere excavated and disposed of off-Site. Referring to
the previous section of this document entitled SummarY of Site
Risks, seven exposure scenarios were evaluated. Of these
scenarios, the only one exceeding EPA's target risk range was
exposure to ground water if wells were installed for showering,
drinking, and bathing in the area of the contaminated
ground-water plume.
A total of 10 alternatives were evaluated fQr remediating ground
water at the Site. With the exception of alternatives 1a and 1b
which involve no action and institutional controls and
monitoring, respectively, all alternatives involve collecting
ground water using a series of extraction wells and pumping to
an on-Site treatment system. Alternatives 2a, 3a, 4a, and 5a
involve treatment with UV enhanced chemical oxidation.
Alternatives 2b, 3b, 4b, and 5b involve treatment by air
stripping in series with bag filtration and carbon adsorption.
The alternatives are as follows: .
ALTERNATIVE 1A - NO ACTION
The National Contingency Plan requires the development of a no
action alternative as a basis for comparison of alternatives.
Therefore, remedial alternative 1a consists of implementing no
remedial action at the Site, including no restriction on future
installation of ground-water extraction wells and no further
monitoring of the contaminated ground water beneath and
hydraulically downgradient from the Site.
Because this alternative would result in contaminants remaining
on- and off-Site, CERCLA requires that the Site be reviewed
every five years. If justified by the review, remedial actions
would be implemented at that time to remove or treat
contamination.
There is no present worth cost or implementation time associated
with this remedial alternative since no action would be taken
and the Site would remain in its present condition.
ALTERNATIVE 1B - INSTITUTIONAL CONTROLS AND MONITORING
-------
6-2
Alternative 1b consists of placing deed restrictions on the Site
property title to identify the presence of PCBs, 1,2-DCE and TCE
in ground water beneath the Site and a ban on installation of
ground-water extraction wells on properties above the
contaminated ground-water plume to provide protection of human
health from potential future consumption of contaminated ground
water. These instutional controls would alert future property
owners to potential Site-related risks. Deed and ground-water
restrictions could be implemented by State and local officials.
In addition, a long term monitoring program consisting of
sampling and analyses of ground water beneath the Site and
off-Site for 30 years are part of this alternative for
monitoring attenuation/degradation of PCBs, 1,2-DCE and TCE in
the ground-water system.
Time associated with implementing this alternative is 30 years.
The present worth cost of this alternative for a 30-year period
is approximately $710,000.
ALTERNATIVE 2A - COLLECTION OF CONTAMINATED GROUND WATER WITH
SIX EXTRA~TION WELLS. TREATMENT BY UV/CHEMICAL OXIDATION
Remedial alternative 2a consists of the extraction of
contaminated ground water from areas of the on- and off-Site
contaminated aquifers which exhibit the highest concentrations
of the Site-related contaminants and treatment by UV/Chemical
Oxidation. Referring to Figure 6.1, five extraction wells would
be installed on-Site and one extraction well would be installed
off-Site. .
Ground-water treatment would be on-Site, with the process
consisting of UV/Chemical Oxidation, which utilizes ultraviolet
light in combination with a strong oxidant, such as hydrogen
peroxide, to transform PCBs, TCE, and 1,2-DCE into carbon
dioxide and water. Discharge piping would be installed to pump
treated water either to adjacent surface waters or to the local
water treatment plant via a gravity sewer.
Operation of remedial alternative 2a for 20 years would result
in the removal of approximately 98 percent of the mass of TCE
andl,2-DCB within the bedrock aquifers affected by the .
extraction wells. Site-related contaminants not within the zone
of influence of the six proposed extraction wells would be left
to attenuate/degrade by natural processes.
PCB removal for this remedy and all others is estimated at less
than one percent due to the separate phase of this contaminant
-------
.6-3
in the many fractures at the Site, making it resistant to
removal. However, the cosolubility effect, which pertains to
PCBs being dissolved in TCE and 1,2-DCE', may aid in extraction
of a greater percentage of PCBs. The difficulty with PCBs does
not lie in treatment of the contaminant in ground water (PCBs
can be successfully treated in water), rather it lies in
extraction ?f the contaminant from the aquifer.
Environmental monitoring would be required during the life of
the treatment process. Because this alternative would result in
PCBs, TCE, and 1,2-DCE remaining on- and off-Site above MCLs,
CERCLA requires that this Site be reviewed every five years from
commencement of remedial construction. If justified by the
review, additional remedial actions would be implemented at that
time to remove or treat contamination. In addition, deed
restrictions would be placed on the Site property title and a
ban would be implemented on installing extraction wells in areas
influenced by the contaminated ground-water plume (Alternative
1b). .
Present worth cost of this alternative for a 20-year time period
is approximately $2,565,000.
ALTERNATIVE 2B - COLLECTION OF CONTAMINATED GROUND WATER WITH
SIX EXTRACTION WELLS. TREATMENT BY AIR STRIPPING IN SERIES WITH
BAG FILTER AND CARBON ADSORPTION .
Remedial alternative 2b is identical to remedial alternative 2a,
with the exception of the treatment method used. Ground water
from areas of the on- and off-Site contaminated aquifers which
exhibit the highest concentrations of the Site-related
contaminants would be extracted by the same well scenario
referred to in Figure 6.1.
Ground-water treatment would be on-Site, with an air stripper to
remove volatiles (TCE and 1,2-DCE).' As stripping columns
normally raise the pH of the ground water being cleaned, a bag
filter would follow the stripper to remove precipitates and
prevent fouling of the carbon adsorption unit which would follow
the bag filter. The carbon adsorption unit would be installed
for polishing to meet final discharge criteria. Discharge
piping would be installed to pump treated water either to
adjacent surface waters or to the POTW via a gravity sewer.
Operation of remedial alternative 2b for 20 years would result
in the removal of approximately 98 percent of the mass of TCE
and 1,2-DCE within the bedrock aquifers affected by the.
extraction wells. PCB removal is again estimated at less than
one percent. Site-related contaminants not within the zone of
-------
6-4
influence of the six proposed extraction wells would be left to
attenuate/degrade by natural processes.
Environmental monitoring would be required during the life of
the treatment process. Because this alternative would result in
PCBs, TCE, and 1,2-DCE remaining on- and off-Site above MCLs,
CERCLA requires that this Site be reviewed every five years from
commencement of remedial con~truction. If justified by the
review, additional remedial actions would be implemented at that
time to remove or treat contamination. In addition, deed
restrictions would be placed on the Site property title and a
ban would be implemented on installing extraction wells in areas
influenced by the contaminated ground-water plume (Alternative
1b) .
The present worth cost of this alternative for a 20-year time
period is approximately $2,113,000.'
ALTERNATIVE 3A - COLLECTION OF CONTAMINATED GROUND WATER WITH
SEVEN EXTRACTION WELLS, TREATMENT BY UV/CHEMICAL OXIDATION
Remedial alternative 3a consists of the extraction of
contaminated grqund water from on-Site aquifers only. Treatment
would consist of UV/Chemical Oxidation. Referring to Figure
6.2, seven extraction wells would be installed on-Site.
Ground-water treatment would be on-Site, with the process
consisting of UV/Chemical Oxidation, which, as explained
previously, utilizes ultraviolet light in combination with a
strong oxidant, such as hydrogen peroxide, to transform PCBs,
TCE, and I,2-DCE into carbon dioxide and water. Discharge
piping would be installed to pump treated water either to
adjacent surface waters or to the POTW via a gravity sewer.
Operation of remedial alternative 3a for 60 years would result
in the removal of approximately 100 percent of the mass of TCE
and I,2-DCE within the bedrock aquifers on-Site only. PCB
removal is estimated at less than one percent.
Environmental monitoring would be required during the life of
the treatment process. Because this alternative would result in
PCBs remaining on- and off-Site above MCLs and TCE and 1,2-DCE
above MCLs off-Site, CERCLA requires that this Site be reviewed
every five years from commencement of remedial construction. If
justified by the review, additional remedial actions would 'be
implemented at that time to remove or treat contamination. In
addition, deed restrictions would be placed on the Site property
-------
6-5
title and a ban would be implemented on installing extraction
wells in areas influenced by the contaminated ground-water plume
(Alternative 1b).
The time estimated to remove TCE and 1,2-DCE to acceptable
applicable or relevant and appropriate requirement (ARAR) levels
in on-Site aquifers is 60 years. The present worth cost of this
alternative- for a 30-year time period is approximately
$2,858,000.
ALTERNATIVE 3B - COLLECTION OF CONTAMINATED GROUND WATER WITH
SEVEN EXTRACTION WELLS. TREATMENT BY AIR STRIPPING IN SERIES
WITH BAG FILTER AND CARBON ADSORPTION
Remedial alternative 3b is identical to remedial alternative 3a,
with the exception of the treatment method used. Contaminated
ground water would be extracted for treatment from on-Site
aquifers only. The same extraction well scenario referred to in
Figure 6.2 would be used.
Ground-water treatment would be on-Site, with an air stripper to
remove volatiles (TCE and 1,2-DCE). As explained previously,
since air stripping columns normally raise the pH of the ground
water being cleaned, a bag filter would follow the stripper to
remove precipitates and prevent fouling of the carbon adsorption
unit which would follow the bag filter. The carbon adsorption
unit would be installed for polishing to meet final discharge
criteria. Discharge piping would be installed to pump treated
water either to adjacent surface waters or to the POTW via a
gravity sewer.
Operation of remedial alternative 3b for 60 years would result
in the removal of approximately 100 percent of the mass of TCE
and 1,2-DCE within the bedrock aquifers on-Site only. PCB
removal is again estimated at less than one percent.
Environmentai monitoring would be required during the life of
the treatment process. Because this alternative would result in
PCBs remaining on- and off-Site above MCLs and TCE and 1,2-DCE
above MCLs off-Site, CERCLA requires that this S.ite be reviewed.
every five years from commencement of remedial construction. . If
justified by the review, additional remedial actions would be
implemented at that time to remove or treat contamination. In
addition, deed restrictions would be placed on the Site property
title and a ban would be implemented on installing extraction
wells in areas influenced by the contaminated ground-water plume
(Alternative Ib). .
The time to remove TCB and 1,2-DCE to acceptable ARAR levels in
on-Site aquifers is estimated to be 60 years. The present worth
-------
6-6
cost of this alternative for a 30-year time period is
approximately $2,362,000.
ALTERNATIVE 4A - COLLECTION OF CONTAMINATED GROUND WATER WITH 14
EXTRACTION WELLS. TREATMENT BY UV/CHEMICAL OXIDATION
During the public comment period, changes were submitted by the
PRP which would slightly modify the well placement and number
for Alternatives 4a and 4b presented in the Proposed Plan.
Please refer to Section X of this document for more
information.
Remedial alternative 4a consists of the extraction of
contaminated ground water from on-Site and off-Site aquifers.
Treatment would consist of UV/Chemical Oxidation. Refering to
Figures 6.3 and 6.4, approximately five extraction wells (phase
I) would be installed on-Site in the "hot spots", or areas of
highest ground-water contamination. After approximately one
year of extraction and monitoring, an additional nine wells
(phase II) would be installed at the downgradient edge of the
plume to contain and remove contamination.
Ground-water treatment would be on-Site, with the process
consisting of UV/Chemical Oxidation, which, as explained
previously, utilizes ultraviolet light in combination with a
. strong oxidant, such as hydrogen peroxide, to transform PCBs,
TCE, and 1,2-DCE into carbon dioxide and water. Discharge
piping would be installed to pump treated water either to
adjacent surface waters or to the POTW via a gravity sewer.
Operation of remedial alternative 4a for 30 years would result
in the removal of approximately 100 percent of the mass of TCE
and 1,2-DCE within the bedrock aquifers both on- and off-Site.
PCB removal is estimated at less than one percent.
Environmental monitoring would be required during the life of
the treatment process. Because this alternative would result in
PCBs remaining on- and off-Site above MCLs, CERCLA requires that
this Site be reviewed every five years from commencement of
remedial construction. If justified by the review, additional
remedial actions would be implemented at that time to remove or
treat contamination. In addition, deed restrictions would be
placed on the Site property title and a ban would be implemented
on installing extraction wells in areas influenced by the
contaminated ground-water plume (Alternative Ib).
The time estimated to remove TCE and I,2-DCE to acceptable ARAR
levels in both on-and off-Site aquifers is 30 years. The
previously estimated present worth cost of this alternative was
approximately $3,860,000. This cost does not reflect the
adjusted well placement scenario comments received during the
public comment period.
-------
6-7
ALTERNATIVE 4B - COLLECTION OF CONTAMINATED GROUND WATER WITH 14
EXTRACTION WELLS. TREATMENT BY AIR STRIPPING IN SERIES WITH BAG
FILTER AND CARBON ADSORPTION .
Remedial alternative.4b is identical to remedial alternative 4a,
with the exception of the treatment method used. Referring to
Figures 6.3- and 6.4, approximately five extraction wells (phase
I) would be installed on-Site in the "hot spots", or areas of
highest ground-water contamination. After approximately one
year of extraction and monitoring, an additional nine wells
(phase II) would be installed at the downgradient edge of the
plume to contain and remove contamination.
Ground-water treatment would be on-Site, with an air stripper to
remove volatiles (TCE and 1,2-DCE). As explained previously,
air stripping columns normally raise the pH of the ground water
being cleaned. A bag filter would follow the stripper to remove
precipitates and prevent fouling of the carbon adsortion unit
which would follow the bag filter. The carbon adsorption unit
would be installed for polishing to meet final discharge
. criteria. Discharge pipinq would be installed to pump treated
water either to adjacent surface waters or to the POTW via a
qravity sewer.. .
Operation of remedial alternative 4b for 30 years would result
in the removal of approximately 100 percent of the mass of TCE
and 1,2-DCE within the bedrock aquifers both on- and off-Site.
PCB removal is again estimated at less than one percent.
Environmental monitoring would be required during the life of
the treatment process. Because this alternative would result in
PCBs remaininqon- and off-Site above MCLs, CERCLA requires that
this Site be reviewed every five years from commencement of
remedial construction. If justified by the review, additional
remedial actions would be implemented at that time to remove or
treat contamination. In addition, deed restrictions would be
placed on the Site property title and a ban would be implemented
on installing extraction wells in areas influenced by the
contaminated ground-water plume (Alternative 1b).
The time to remove TCE and 1,2-DCE to acceptable ARAR levels in
both on-Site and off-Site aquifers is estimated to be 30 years.
The. present worth cost of this alternative for a 30-year time
period is approximately $3,005,000.
ALTERNATIVE SA - COLLECTION OF CONTAMINATED GROUND WATER WITH 22
EXTRACTION WELLS. TREATMENT BY UV/CHEMICAL OXIDATION
Remedial alternative Sa consists of the extraction of
contaminated ground water from on-Site and off-Site aquifers.
-------
6-8
Treatment would consist of UV/Chemical Oxidation. Referring to
Figure 6.4, the extraction scenario would consist of the
following: seven wells installed on-Site along the northern and
eastern boundaries, six wells installed off-Site along the
downgradient boundary of the Site-related contaminated ground
water, six wells installed on-Site in the areas of highest
contaminant concentrations, and three wells installed off-Site
in area~ of highest contaminant concentrations.
Ground-water treatment would be on-Site, with the process
consisting of UV/Chemical Oxidation, which, as explained
previously, utilizes ultraviolet light in combination with a
strong oxidant, such as -hydrogen peroxide, to transform PCBs,
TCE, and l,2-DCE into carbon dioxide and water. Discharge
piping would be installed to pump treated water either to
adjacent surface waters or to the POTW via a gravity sewer.
Operation of remedial alternative Sa for 30 years would result
in the removal of approximately 100 percent of the mass of TCE
and l,2-DCE within the bedrock aquifers both on- and off-Site.
PCB removal is estimated at less than one percent.
Environmental monitoring would be required during the life of
the treatment process. Because this alternative would result in
PCBs remaining on- and off-Site above MCLs, CERCLA requires that
this Site be reviewed every five years from commencement of
remedial construction. If justified by the review, additional
remedial actions would be implemented at that time to remove or
treat contamination. In addition, deed restrictions would be
placed on the Site property title and a ban would be implemented
on installing extraction wells in areas influenced by the
contaminated ground-water plume (Alternative Ib).
The time estimated to remove TCE and l,2-DCE to acceptable ARAR
levels in both on-and off-Site aquifers is 30 years. The
present worth cost of this alternative for a 30-year time period
is approximately $5,216,00-0.
ALTERNATIVE SB - COLLECTION OF CONTAMINATED GROUND WATER WITH 22
EXTRACTION WELLS. TREATMENT BY AIR STRIPPING IN SERIES WITH BAG
FILTER AND CARBON ADSORPTION
Remedial alternative Sb is identical to remedial alternative Sa,
with the exception of the treatment method used. Contaminated
ground water would be extracted from on- and off-Site aquifers
and treatment would consist of UV/Chemical Oxidation. Referring
to Figure 6.4, the extraction scenario would consist of the
following: seven wells installed on-Site along the northern and
eastern boundaries, six wells installed off-Site along the
downgradient boundary of the Site-related contaminated ground
-------
6-9
water, six wells installed on-site in the areas of highest
contaminant concentrations, and three wells installed off-Site
in ~re8:s of highest contaminant concentr.~ti,?ns. . ~."', .
Ground-water treatment would be on-Site, with the process
consisting of an air stripper to remove volatiles (TCE and
1,2-DCE). As explained previously, since air stripping columns
normally raise the pH of the. ground water being cleaned, a bag
filter would follow the stripper to remove precipitates and
prevent fouling of the carbon adsortion unit which would follow
the bag filter. The carbon adsorption unit would be installed
for polishing to meet final discharge criteria. Discharge
piping would be installed to pump treated water either to
adjacent surface waters or to the POTW via a gravity sewer.
Operation of remedial alternative 5b for 30
in the removal of approximately 100 percent
and 1,2-DCE within the contaminated bedrock
on-Site and off-Site. PCB removal is again
than one percent.
Environmental monitoring would be required during the life of
the treatment process. Because this alternative would result in
PCBs remaining pn- and off-Site above MCLs, CERCLA requires that
this Site be reviewed every five years from commencement of
remedial construction. If justified by the review, additional
remedial actions would be implemented at that time to remove or
. treat contamination. In addition, deed restrictions would be
placed on the Site property title and a ban would be implemented
on installing extraction wells in areas influenced by the
contaminated ground-water plume (Alternative lb).
years would result
of the mass of TCE
aquifers both
estimated at less
The time to remove TCE and 1,2-DCE to acceptable ARAR levels in
on-Site aquifers is estimated to be 30 years. The present worth
cost of this alternative for a 30-year time period is
approximately $4,035,000.
-------
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PROPERtY BOUNDARY
APPROXlIIA T[ E)lT[N' Of"
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PROPOSED LDCA nON f1Jft
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AI.TERNATIVES 2A AND 28
PROPOSED GROUNDWATER EXTRAC1l0N WELL LA YOU I
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CONTAMINANT MASS REMOVAL AL TERN A r
MALLORY CAPACITOR SITE RI
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If AI.TERNATl VES 3A AND 3 B F I CURE b. 1
PROPOSfO GROUNDWATER EXTRACTION WELL' LA YOlJ
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-------
LEGEND
PROPERTY BOUNDARY
EW1
PROPOSED LOCATION FOR
ON-STE CONTAMINANT
MASS EXTRACTION WELL
PROPOSED SHALLOW
BEDROCK MONITORING WELL
-» TRBUTARY
APPROXIMATE EXTENT OF
CONTAMINATION IN BEDROCK
AQUIFERS
1) ASSUMED LOCATION OF PROPERTY
BOUNDARY BASED ON AERIAL
PHOTOGRAPH.
ALTERNATIVES 4A and 4B
figure 6-3
PHASE I GROUNDWATER EXTRACTION WELL LAYOUT
PREFERRED REMEDIAL ALTERNATIVE
MALLORY CAPACITOR SITE RI/PS
Wayneaboro, T*
-------
LEGEND
PROPERTY BOUNDARY
PROPOSED LOCATION FOR
CONTAINMENT EXTRACTION
WELL
TRIBUTARY
v> APPROXIMATE EXTENT OF
CONTAMINATION IN BEDROCK
AQUIFERS
NOTES:
1} ASSUMED LOCATION OF PROPERTY
BOUNDARY BASED ON AERIAL
PHOTOGRAPH.
ALTERNATIVES 4A and 4B
figure 6-4
PHASE I
MALLORY CAPACITOR SnER!/FS
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AI.TENNATIVES SA ANII '>"
PROPOSED GROIJNDWA TfR fX1RAC nON ~u, lAYOil
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RUAOVAl AND HYDRAULIC CON1AIN~[Nl
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-------
.7-1
VII.
COMPARATIVE ANALYSIS OF REMEDIAL ALTERNATIVES
A detailed comparative analysis was performed on the 10 remedial
alternatives developed during the FS and the modifications
submitted during the public comment period using the nine
evaluation criteria set forth in the NCP. The advantages and
disadvantages of each alternative were compared to identify the
alternative with the best balance among these nine criteria.
Threshold criteria:
A.
OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
This criterion addresses whether or not an alternative provides
adequate protection and describes how risks are eliminated,
reduced or controlled through treatment and engineering or
institutional controls.
PCBs, which have the consistentency of heavy oil to wax at room
temperature, are bound in. the many fractures at the Site in a
separate phase from the ground wate~ and can most likely not be
extracted from the aquifer in significant quantities at this
time. It is for this reason that it is most likely technically
infeasible to remove PCB contamination to levels that are
protective of public health and the environment. None of the
remedies evaluated will in all probability eliminate risks due
to PCBs, however, several reduce volatiles to acceptable risk
levels. The discussion which follows focuses on overall
protection of human health and the environment from the VOC
contamination at the Site (i.e., TCE and 1,2-DCE).
Alternatives 4a and 4b and Sa and sb are the most desirable and
are estimated to reduce TCE and 1,2-DCE contamination by 100%
within 30 years. Alternatives Sa and sb, which employ 22
extraction wells are a more conservative scenario than
Alternatives 4a and 4b with 14 extraction wells. It is felt,
however, that the point of diminshing returns will be reached
with the approximate number and placement of wells in
Alternatives 4a and 4b, after. which the additional wells
proposed for Alternatives Sa and sb may be extracting a great
deal of clean water.
Alternatives 3a and 3b are estimated to remove 100% of VOC
contamination in on-Site aquifers only, which would not be
considered protective since the Site is surrounded on three
Sides by private residences. While there are no residences
within the area of influence of the plume not on city water
besides three springs which were tested and found to be clean, a
great percentage of Wayne County is on well water, as are many
residences as close as one mile downgradient of the Site.
Alternatives 3a and 3b treat the on- and off-Site aquifers as
-------
7-2
two independent systems, whereas they are one. The whole system"
must be remediated. For these reasons, Alternative 3 was not
given further consideration.
Alternatives 2a and 2b provide protection for both on- and
off-Site aquifers, however, they are only estimated to contain
approximate~y 81% of the contaminated ground-water plume.
Within the 81% of the plume contained, it is estimated that TCE
and 1,2-DCE will be reduced by 98% in 20 years. Remaining
contamination is still in excess of those levels deemed
protective of human health and the environment for TCE and
l,2-DCE by EPA.
Alternatives la and lb are not protective of public health and
the environment because they do not eliminate, reduce, or
control risks by treating contamination in the environment.
Remedial alternatives 2b, Jb, 4b, and 5b (air stripping, bag
filtration and carbon adsorption for the extracted ground-water
treatment process) provide greater protection to human health
and the environment than remedial alternatives 2a, Ja, 4a, and
Sa (UV/Chemical Oxidation for the extracted ground-water
treatment process) since the reliability of UV/Chemical
Oxidation is suspect at low flow rates and subject to varying
effluent water quality proportionate to varying concentrations
of contaminants in the influent ground water.
B.
COMPLIANCE WITH APPLICABLE OR RELEVANT AND APPROPRIATE
REOUIREMENTS lARARS)
This criterion addresses whether or not an alternative will meet
all ARARs or provide grounds for invoking a waiver. Each
alternative was evaluated for compliance with ARARs, including
chemical-specific, action-specific, and location-specific
ARARs. These ARARs are presented in Table 7.1. ARARs are
broken down in the table by Federal and State regulations.
Standards set specifically for drinking water are presented in
Table 7.2.
Because of the infeasibility of removing sufficient amounts of
PCBs from the aquifer for treatment, none of the alternatives
are estimated to comply with the Safe Drinking Water" Act (SDWA),
40 C.F.R. 141, Primary Drinking Water Standards for PCBs. The
Maximum Contaminant Level (MCL) set for PCBs, which is .5 ug/l,
will most likely not be attained by any of the alternatives.
Alternatives 4a and 4b and Sa and 5b comply with all regulations
besides the MCL for PCBs.
Alternatives 3a and 3b do not comply with federal MCLs for TCE
and 1,2-DCE in off-Site aquifers. Likewise, these two
-------
7-3
alternatives do not comply with MCLs established by the
Tennessee Department of Environment and Conservation (TDEC) for
TCE in off-Site aquifers. Alternatives 2a and 2b do not comply
with these standards .for on- or off-Site aquifers. Alternatives
1a and 1b do not comply with any federal or State drinking water
standards for PCBs, TCE, and I,2-DCE.
Alternatives 2b, 3b, 4b, and 5b comply with ARARs for
discharge effluent requirements, whereas alternatives
4a, and Sa may not comply with these requirements due
effluent quality.
Land Disposal Restrictions ("LDRslf) as set forth in the
regulations promulgated pursuant to RCRA (40 C.F.R. Part 268)
may be applicable to the residuals of the ground-water treatment
facility, specifically the bag filters between the air stripper
and the carbon adsorption unit. It will probably be. possible to
regenerate spent carbon from the treatment process for reuse. .
treated
2a, 3a,
to varying
All of the remedial alternatives comply with Clean Air Act ARARs
. for air emissions.
Primary Balancina Criteria:
C.
LONG TERM EFFECTIVENESS AND PERMANENCE
This refers to the ability of an alternative to maintain
reliable protection of human health and the environment,
time, once cleanup objectives have been met.
The only risk scenario considered harmful to human health and
the environment identified by the public health assessment is
potential ingestion, showering and bathing with contaminated
ground water. While none of the alternatives may offer
effective solutions in the long term (or even the short term)
for PCBs, Alternatives 4a and 4b and Sa and 5b offer the
greatest degree of long-term effectiveness in that they are
estimated to remove approximately 100 percent of TCE and 1,2-DCE
in both on- and off-Site aquifers. Thus, the potential for
ingestion of and contact with these VOCs would be minimized by
removing them with treatment.
over
Alternatives 3& and 3b and 2a and 2b can be considered partial
for long-term effectiveness and permanence since 3a and 3b do
not remediate TeE and 1,2-DCE in off-Site aquifers and 2a and 2b
only partially contain the contaminated ground-water plume (by
81'), reducing levels of these two contaminants by 98' within
the contained zone only (not an adequate reduction for
protection of human health). Long term effectiveness and
permanence for alternatives 1a and Ib is considered negligible
since there is no reduction in contamination by treatment.
-------
7-4
Alternatives 2b, 3b, 4b, and 5b (air stripping, bag filtration,
carbon adsorption for extracted ground-water treatment) provide
greater long-term effectiveness and permanence than alternatives
2a, 3a, 4a, and 5a (UV/Chemical Oxidation for extracted
qround-water treatment) since the reliability of UV/Chemical
Oxidation is suspect at low flow rates and subject to varyinq
effluent. water quality proportionate to varyinq influent
concentrations.
D.
REDUCTION OF TOXICITY. MOBILITY OR VOLUME THROUGH TREATMENT
This is the anticipated performance of the treatment
technologies an alternative may employ. The degree of reduction
of toxicity, mobility or volume throuqh treatment varies
depending on the methods of ground-water extraction and
treatment employed.
The negative movement of qround water caused by the extraction
pumpinq for each well will act to prevent contamination from
spreading further in the vertical or horizontal direction. The
extraction well scenarios presented for the 5,4,3, and 2
alternatives will contain mobility of the contaminant plume in
this order of effectiveness, respectively.
Alternatives 2b, 3b, 4b, and 5b utilize air stripping, bag
filtration, and carbon adsorption as the treatment process for
extracted qround water, thus reducing toxicity, mobility and
volume of contaminants in the treated qround water. This
combination of treatment technoloqies provides a reliable
treatment process, adaptable to varyinq concentrations of
contaminants in the influent ground water. In addition, the
typical configuration of two carbon adsorption units installed
in series provides additional treatment assurance in the event
of contaminant breakthrough in the first carbon adsorption
unit. .
Alternatives 2a, 3a, 4a, and 5a utilize UV/Chemical Oxidation as
the primary treatment process for the extracted qround water,
reducing the toxicity, mobility, and volume of contaminants by
converting them to carbon dioxide and water. However, the
reliability of UV/Chemical Oxidation treatment is suspect at low
flow rates and subject to varyinq effluent water quality
proportionate to varying concentrations of contaminants in
influent ground water.
E.
SHORT-TERM EFFECTIVENESS
This involves the period of time required to achieve protection
and any adverse impacts on human health and the environment that
-------
7-5
may be posed during the construction and implementation period
until cleanup objectives are achieved. The following factors
were used to evaluate the short-term effectiveness of each
alternative: protection of the community during remedial
actions, protection of workers during remedial actions,
environmental impacts from implementation of alternatives, and
the time u~til remedial action objectives are met.
With respect to protection of the community, Alternatives 2 - 5
will not pose additional risk to the community although there
may be slight inconveniences in some cases. Likewise,
Alternatives 1a and 1b pose no additional risk to the community
over what already exists.
Alternatives 2b, 3b, 4b and 5b are more effective and protective
of the community in the short-term than alternatives 2a, 3a, 4a
and 5a, respectively, since the air stripping, bag filtration
and carbon adsorption treatment process is more reliable and
adaptable to low flow rates and varying concentrations of
contaminants in the influent ground water.
Risks to workers during remedial action in Alternatives 1a and
1b through Sa and 5b can be controlled with safe working.
practices. Alternatives 2a and 2b through 5a and 5b may expose
workers to TCE and 1,2-DCE volatilization when extraction wells
are installed but levels should be within applicable PELs and
. TLVs.
With respect to environmental impacts, the well .placement
scenarios for the Alternatives 5, 4, 3, and 2 will halt
migration of contaminated ground water and treat it in this
order of effectiveness, respectively. Alternatives 1a and 1b
will allow for continued migration of contaminated ground water
from the Site, as they include no actions for collection and
treatment.
Evaluation of the time until protection is achieved reveals the
following estimates: Alternatives Sa and 5b achieve protection
from VOCs in 30 years. Alternatives 4a and 4b achieve the same
degree of protection as the is alternatives in 30 years. The
alternatives 2 and 3 only achieve partial protection from VOCs
in 20 and 60 years, respecively. Alternatives 1a and Ib will
not achieve protection for VOCs. As stated previously,
protection from PCBs is expected to be minimal, at best.
F.
IMPLEMENTABILITY
This is the technical and administrative feasibility of an
alternative, including the availability of goods and services
needed to implement the solution.
-------
. 7-6
The alternatives 1 through 5, technically and administratively,
will be feasible. Required services and materials generally are
available, and the technologies used for all alternatives rely
on standardized construction methods and demonstrated
technologies. However, where low flow rates and varying
influent concentrations exist, it will be mo+e simple to
.implement effective treatment of the contaminated ground water
for the alternatives involving air stripping, bag filtration and
carbon adsorption, as UV/Chemical Oxidation contaminant
reduction efficiencies are suspect under these conditions.
Alternatives 1a and 1b would be the most implementable, as they
involve no and very few remedial activities, respectively.
Alternatives 3a and 3b would be considered the second set most
easily implemented since this well extraction scenario involves
no off-Site wells. The alternatives 2, 4 and 5 will require
access agreements for the installation, operation and
maintenance of the off-Site extraction wells and associated
piping and electrical systems. Since Alternatives 2a and 2b
require only one off-Site extraction well (compared to six and
nine off-Site extraction wells for the alternatives 4 and 5,
respectively), Alternatives 2a and 2b may be slightly more
adaptable to securement of off-Site access agreements than 4a
and 4b and 5a and 5b, depending on location of objects and
structures in the neighborhood and the residents' willingness to
have wells placed on their property.
G.
COST
Cost includes capital costs, as well as operation and
maintenance costs and is presented in present value. This
evaluation examines the estimated costs for implementing the
remedial alternatives. The estimated present worth value of
each alternative is as follows:
Alternative 1a
Alternative 1b
$0
$710,000
$2,565,000
$2,113,000
Alternative 2a
Alternative 2b
Alternative 3a
. Alternative 3b
Alternative 4a
Alternative 4b
$2,858,000
$2,362,000
$3,860,000 *
$3,005,000
Alternative 5a
Alternative 5b
$5,216,000
$4,035,000
*
See Section. X of this document.
-------
7-7
Modifvina Criteria:
B.
STATE ACCEPTANCE
This indicates whether, based on review of the RI Report, FS
Report, and Proposed Plan, u.S. EPA and TDEC agree on the
preferred alternative. EPA and TDHE are in agreement on the
. selected a~ternative. Please refer to Appendix B which contains
a letter of concurrence from TDHE.
I.
COMMUNITY ACCEPTANCE
This indicates the public support of a given
criterion is addressed in the Responsiveness
10, of this document. The community accepts
remedy.
alternative. This
Summary, Section
the selected
-------
Pag
f7"
TABLE 7.1
APPLICABLE OR RELEVANT AND API'ROPRIA TE REQUIREMENTS (ARAR.)
MALLORY CAPACITOR SITE RIIFS
WA YNESBOKO, TENNESSEE
Ambit"' or ChtmicQI PtrforrnQflct. Dnigrt or Actiofl L.oc:a,io"
Law or Rtgll'aliofl ktftrtflct Sl'tCifiC ARAR, Sl'tcific ARARs Sl'tcifiC ARAR.
fEDERAL
1. National Oil and Hazardous Substances 40 CFR 300 Not Applicable (NI A) Establishes basis for determining N/A
Pollution Contingency Plan (NCP) remediation of a site
2. Toxic Substances Control Act ffSCA; I'L 94-469)
a) USEI'A Rules Governing Uandling and 4U CFR 761 N/A Applicable to transportation and dispos~l N/A
Disposal of l'olychlorinall...J of PCD wastes and maintenance of !'CD
Biphenyls (!'CDs) (4) waste disposall'L'Cords
3. Safe Drinking Water Act (SOW A; Pl93-523)
a) Primary Drinking Waler Standards 4UCFR 141 Applicable 10 drinking waler Applicable 10 groundwaler MCL, and water N/A
supplies using Maximum which may be consumed after any treatment
Contaminant levels (MCLs) alternative
b) Secondary Drinking Water Standards 40 CFR 143 Applicable to drinking water Applicable to groundwater MCl, and water N/A
,upplies using MCls which may be consumed alter any treatment
alternative
4.
Federal Waler Pollution Conlrol Act (CW A; PL 92-500)
a) Effluent Guidelines and Standards
40 CFR 400
N/A
Applicable to alternatives involving
discharge to a 'publically owned treatment
works (POTW)
N/A
b) Federal Standards for Toxic I'ollutant
Effluent
40 CFR 129
N/A
Applicable to alternatives involving
discharge to the Gwen I{iver (rcgulall.od by
State NI'DES pcnni!)
N/A
-------
L"w 0' RrS"'"tio..
FEDERAL «continued)
5.
Resource Conservallon and Recovery Act
(RCRA; PL 94-5110)
a) EPA Regulations on Land Disposal
Reslrictions (LDRs)
b) Hazardous Malerials r !gulalions
6.
Clean Air Act (CAA;PL 98-213)
7.
Worker Safety and Heallh Proll.'Ction
8.
Underground Injection Control (UIC)
Program: Criteria and Standards
9.
Permit for Structure of Work in or
Affecting Navigable Walers (Section 10
of River and Harbors Act)
TABLE 7.1
AI'PLICABLE OR RHEVANT ANOAPPROPRIATE REQUIREMENTS «ARAR.)
MAI.tORY CAPACITOR SITE RifFS
W A YNESBORO, TliNNESSEE
Rrfr,r..tr
Ambir..t 0' Chrmit",
Sprdfic ARARs
Prrfo"""lttr, Drsign 0' Actio..
Sprcific ARARs
40 CFR 268
N/A
Restricts laod disposal of
wastes such AS filter bags
and spent carbon from gw
treatment process
49 CFR 17U 10 179
N/A
Applicable 10 transportation of hazardous
malerials
N/A
Applicable 10 air emissions from any on-sile
treatment alternatives
Occupational Sakoty
and Heal,h
Adminislration.
(OSHA)
Applicable to worker safety during
remt.odial construction
N/A
40 CFR Part 146
N/A
Applicable 10 alternatives involving
discharge to groundwater
J.) CFR "art 320
N/A
N/A
-In:--j!9i ~1:rln
Loc"tio..
Sprdfic ARAR.
N/A
Relevant and
appropriale in
conjunction with
action specific
ARARs
N/A
N/A
N/A
N/A
-------
I'i
~f 7
TABLE 7.1
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARI)
MAl-LORY CAPACITOR SITE RifFS
WA YNESBORO, TENNESSEE
A".bi""t or Ch"".i,," P"rf0rm"",,,, Vuip or Adio" Locatio"
L"w or R"gulatio" R,,/"r""'" Sp"dfi' ARAR, Sp"cifi' ARAR, Sp"dfic ARAR,
FEDERAL (continued)
\0. Response in a Auodplain or Wetlands 40 CFR )'art 6, N/A N/A Applicable to
Appendix A alternatives
Involving
Green River
floodplain.
II. National Envirunrnentall'olky Ad NEI'A St.dion N/A Applicable to actiuns determined to have N/A
(NEI'M 102(2)(c) significant impad on the Iluality of the
human environment. CEKClA Feasibility
Study guidance documents state that
CEKClA actions may be exempt
12. Interguvernmental Review of Federal 40 CFR 29 N/A N/A N/A
I'rogram
13. Relocation Assistance and Property Uniform Relocatiun N/A N/A N/A
Acquisitions Assistance and Real
Property Acquisition
I'ollcies Act of 1979,
4OCFR4
\4. Clean Water Act CW A Section 402, N/A Applicable to alternatives involving NIA
40 CFR 122, discharge to the Green River
125 Subchapter N (administered by the State). National
I'ollutant Discharge Elimination System
(NI'DES) I'ernlit
15. Dredge or FiIIl'ermit CW A Sectiun 404 N/A N/A N/A
-------
LIIW 0' Regulatio"
fEDERAL (continued) .
16. Conservation of Wildlife RI.'SourC\.'S
17. Preservation of Scientific', Historic or
Archaeological Data
18. Preservation of Rivers on the National
Inventory
19. Protection of Threatened or Endangered
Species and Their Habitats
20. State Approval of Shoreline Use
21.. Federal Ocean Dumping Requirements
22. Pretreatment Standards
TABLE 7.1
APPLICABLE OR RHEV ANT AND APPROPRIATE REQUIREMENTS CARARI)
MALLORY CAPACITOR SITE RI/FS
WAYNESBORO, TENNESSEE
Rejrre"ce
Ambie"t 0' Chemical
Specific ARAR.
Performa"ce, De.igre 0' Actio"
Specific ARAR.
Fish and Wildlife
Coordination Act
N/A
Applicable to alternatives involving
discharge to the Grl.'en River
Archaeological and
Historical
Prescrvation Act of
1974
N/A
N/A
Wild and Scenic' .
Rivers Act 40 CFR
!'art 6.302
N/A
N/A
Endangered Species
Act 50 CI-l( !'art 402
N/A
N/A
Coastal Zone
Management Act of
1972
N/A
N/A
40 CFR 220-224
33 CFR 220, 224
N/A
N/A
40CFR 40.35
N/A
Applicable 10 alternatives involving
discharge of extracted groundwater to a
!'OTW
;'dg-d~roU-1
Locatio..
Specific ARAR.
Relevant and
appropriate in
conjunction with
action specific
ARARs
N/A
N I A, not on
National
Inventory
N/A
N/A
N/A
N/A
-------
TABLE 7.1
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARARI)
MAtLORY CAPACITOR SITE RifFS
WA YNESBORO, T~NNESSEE
Law or R'gulatio..
R'f,r,..c,
Ambi,..t or Ch,mical
Sp,cific AHARs
p,rformanc" D,sign or Actio..
Sp,cific AHARs
ST ATE OF TEN NESSEE
I. Tennessee Solid Waste
Disposal Act
Tennessee Code Title
68, Health and
Safety, Chapter 31,
Solid Waste
Disposal
N/A
Applicable to construction of new landfills
oH site. General administrative
n."quirements for solid waste dispOsal in
solid waste landfills
2. Tennessee Hazardous Wa~le
Management Acts
Tennessee Code Title
68, Health and
Safety, Chapter 46,
Hazardous Waste
Management
Applicable 10 construction of hazardous
waste facilities and remedialion of
abandoned siles
N/A
J. Tennessee Sanitary
landfill Areas Act
T ennesSt.'C Cude Tit Ie
53, Health and
Safety, Chapter 45,
Sanitary Lmdfill
Areas Act
. N/A
. N/A
4. Tennessee Solid Waste
Regulations
N/A
Applicable to solid waste and special
waste to be disposed of at a solid waste
facility
Rule 1200-1-7
5. TennesleeSuperfund
Regulatlonl
Applicable to shipments of hazardous
waste oH site, generator fees and excluded
wastes
Chapter 1200-1-13-
H;tzardous Substance
Site Remedial Action
N/A
. 6. TennesseeCommcrcial
Hazardous Waste
Facility Rules
Chapler 1200-1-14-
Commercial
Hazardous Waste
Management.
Facilities
N/A
N/A
Pagl
Loc.tlo..
Sp,cific AHAR. .
N/A
N/A
N/A
N/A
N/A
N/A
-------
LIIW or R~g,,'"';oN
STATE OF TENNESSEE (continued.
7. Tennessre tlazardous Waste
Management Rules
8. TennesSt.'C'Water Quality
Control Act
).
.,
,
9. Tennessre Petroleum Underground
Storage Tank Act
10. Tennessee General
Regulations
11. Tennessee Water Quality
Criteria
Page "~oi '/
TAllLE 7.1
APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS (ARAR..
MAllORY CAPACrrOR SITE RifFS
WA YNESBORO, {TENNESSEE
. R~f~rrNc~
Amb;~,,' or C"~m;ca'
SfHcific ARARs
LoclI ';011
S"rcific ARAR.
P~rfO""aNCr, D~.iK" or AcI;oN
S,,~cific ARARs
Chapter 1200 - N/A Applicable to hazardous waste N/A
Hazardous Waste management to comply with the State
Management RCRA program
Tenness(.'C Code Title N/A Applicable to surface water discharges. N/A
69, Waters, General administrative rL'quirements for
Waterways, Drains, State PDES program
and Levees, Chapll'r
3 - Water Pollulioj,
Control
T emlesSCL'C Code N/A N/A N/A
Tille 68, Safety and
Health, Chapter
52-Petroleum
Underground Storage
Water Quality N/A Applicable to surface water discharges. N/A
Control Uoard Establishes authority, administrative
General Regulations requirements and permit application
Chapters 1200-4-1, procedure for State rDES program
1200-4-2 (off-Site discharges)
Chapter 1200-4, Rule Applicable to Ambient Water N/A N/A
3 - General Water Quality Criteria (AWQC)
Quality Criteria for
the Definition and
Control of Pollution
.in the Waters of
Tenness(.'C
-------
Law or RegulatioN
STATE OF TENNESSEE (continued»
12. Tennessee Emuent
limitations and Standards
13. Tennessee Air Quality Act
14. TennesS(.'e Air I'ollution Conlrul
RI."gulalions
15. Ruk'S of the Water Quality Contntl
Board
16. Rules of Tennessee Department of
Health and Environment - Dureau of
Environment, Division of Water
Management
I'at
,7"
TABLI~ 7.1
APPLICABLE OR RHEV ANT AND APPROPRIATE REQUIREMENTS (ARARI»
MAI.LORY CAPACITOR SITE RifFS
WA YNESBORO, T,ENNESSEE
kefereNce
AmbieNt or Chemica'
Specific ARARs
Loe.tioN
Specific ARAR.
PerformaNce, De.iK" or ActiON
Specific ARARs
Chapter 12110-4-5 N/A Applicable 10 wastewater discharges to N/A
Emuent Umitalions surface waler. Effluenllimitalions for
and Standards convenlional analytical parameters
Tennessee Code Tille N/A N/A N/A
68, Safety and
Health, Chapler 25
Air Pollution
Contntl
Chapter 1200-3 N/A Applicable to construction of new air N/A
contaminant sources
Chapter 121X1-4-6 N/A Applicable to injt.'Ction of Ouids into an N/A
aquifer
Chapter 1200-5-1 Regulates and establishes Slate. Establishes operation and maintenance N/A
Public Water System MCLs for drinking waters r'-'quirements for public water systems
-------
TAJILK 7. 2
SUMMARY OF DRINKING WATER STANDARDS AND WATER QUALITY CRITEIUA
MALLOltY CAltACITOR SITE IUlI;S .
WAYNESBORO, TENNESSEE
PI",~meter Detected
in Groundwater
MCL (a)
(pglU
US£PA WQC
"uman Health (b)
(pglU
""C (c)
(JIgIlJ
MC1.G(,1)
(II8/1J
Tennessee
MCL (e)
(pgll.)
Trichloroethene
5
3.2
2.7
II
5
1,2-Dichloroethene
cis -70
trans-100
cis -70
trims-Ion
PCBs
0.5
5.0E-03
4; 4 E-OS
II
Notes:
(b)
(c)
MCt - maximum contaminant level as stated in National Primary Drinking Water Standards (40 CFR 141) and National
Secondary Drinking Water Standards (40 CFR 143).
Water quality criteria for ingestion of water at an incremental increase of cancer risk estimatl>d at l.nE-h.
HHC - human health consumption of aquatic life and drinking water, 1.1IE-6 cancer risk as presentl'\t in Water Quality
Criteria Documents, federal Register, November 1980.
MCtG - maximum contaminant level goals, 40 CFR 141.
Tennessee Department of Health and Environment Volatile Organic Chemicals in Drinking Wilter, November 198/i.
(a)
(d)
(e)
-------
,8-1
VIII.
SBLECTED REMEDY
The results of the RI/FS show that elevated concentrations of
. the three site-related contaminants exist in ground water
beneath and hydraulically downgradient of the Site.
Specifically, these contaminants were detected up to the
following concentrations:
PCBs:
TCB:
1,2-DCE:
100,000 parts per billion (ppb)
250,000 ppb
36,000 ppb
Based upon consideration of the requirements of CBRCLA, the
detailed analysis of the alternatives, and public comments, both
EPA and TDEC have selected Alternative 4b, which involves
installing approximately 14 ground-water extraction wells in a
phased approach and pumping collected water to treatment
on-Site. Treatment of contaminated ground water will be
accomplished by passing it through the treatment process shown
. in Figure 8.1 and will extend beyond the points of compliance at
Site boundaries to approximately 45'0 feet north of the Site and
300 feet east of the Site where contaminated ground water is
estimated to have migrated to. If contamination has migrated
past these points, it will be remediated as far out as it is
found to occur. After being passed through an air stripper for
removal of the volatile components, ground water will be passed
through a bag filter for removal of solids and precipitates,
followed by a carbon adsorption column for removing remaining
contaminants.
Treated ground water will either be discharged to the Green
River or the local water treatment plant after exiting the
system. Should the Green River be chosen as the discharge
option, the following limits shall apply to discharge, based
upon the EPA Ambient Water Quality Criteria for PCBs, TCE and
1,2-DCB (EPA 440/5-80-068, BPA 440/5-80-077, and BPA
440/5-80-041, respectively, all promulgated in October, 1980.)
These National Pollutant Discharge Blimination System (NPDBS)
levels' have been adopted for the Tennessee Water Quality
Criteria and are regulated by the State of Tennessee.
EB.! :
.2 ug/l (maximum' allowable concentration in one day)
.014 uq/l (for continuous,discharge)
7.9 x 10-4 'ug/l (allowable concentration in the,
Green River for eating fish and
drinking river water since this is
possible as per Section V of this
document. )
-------
8-2
TCE:
No discharge pipe effluent concentrations promulgated.-
2.7 ug/l
(allowable concentration in the Green River
for eating fish and drinking river water
since this is possible as per Section V of
this document.)
1. 2-DCE:
3,030 ug/l (maximum concentration allowable in one
day)
(for continuous discharge)
303 ug/l
.057 ug/l
(allowable concentration in the Green River
for eating fish and drinking river water
since this is possible as per Section V of
this document.)
These limits will be stated in an operation and maintenance plan
for the treatment system which will be approved by EPA prior to
commencing treatment. Any surface water discharge will be
required to meet NPDES limits that are regulated by the State of
Tennessee. Discharge will not require an NPDES permit since the
Site abuts the Green River, therefore, classifying discharge as
on-Site (i.e., compliance required only with substantive
requirements).
The air stripper will be monitorea regularly, on a frequency
approved by EPA in the water treatment plant O&M plan prior to
start-up, to insure that levels of TCE and 1,2-DCE exiting the
stack to the atmosphere are compliant with the Clean Air Act,
which allows no more than two tons per year total of these
contaminants to be emitted from this device. Should it be
determined, based on monitoring, that levels of contaminants
exiting the stack will exceed allowable limits for the air
media, control equipment, such as a carbon bed, will be placed
on the stack to reduce these emissions.
The extraction well layout for the selected remedy is shown in
Figures 6.3 and 6.4. Initially, five wells will be installed in
"hot spotS" of contamination. After one year of extraction and
monitoring, nine more wells will be installed at the outer edge
of the contaminated plume for containment and additional
removal. These wells are expected to contain contaminated
ground water from moving further towards residential use
(approximately one mile away) as well as removing it for
treatment. Monitoring after the extraction system is in place
may show the need to move existing extraction points or add new
ones for more effective removal of contaminated ground water.
It is presently estimated that the time to remove approximately
100' of the VOCs will be 30 years.
The selected remedy includes the following ancillary activities:
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8-3
'*
Investigations to better determine the northern extent of
off-Site ground-water contamination.
Investigations to determine possible impacts to Cold Water
Creek. (See page 4-4 of this document.)
'*
'*
Institutional controls and monitoring.
An effectiveness monitoring program.
'*
Referring to Table 7.2, all three Site-related contaminants have
Maximum Contaminant Levels (MCLs) as promulgated under the Safe
Drinking Water Act (40 C.F.R. 141,143). The MCLs for TCE, cis
and trans 1,2-DCE are 5 ppb, 70 ppb,' and 100 ppb, respectively
and will be used as the remediation levels for these
contaminants within and beyond the points of compliance at the
Site boundaries. Ground-water pumping and treatment will
continue until these levels are achieved. Presently, it is
estimated that 100 percent of the TCE and cis and trans 1,2-DCE
will be removed in approximately 30 years. The present value
cost of this' remedy is estimated at $3,005,000.
Desian Considerations
To insure that the design of the system is optimized,
modifications may be considered prior to invoking contingency
measures. Any or all of the below may be employed.
a)
at individual wells where cleanup goals have been
attained, pumping may be discontinued;
alternative pumping at wells to eliminate stagnation
points;
b)
c)
pulse pumping to allow aquifer equilibration and to
allow adsorbed contaminants to partition into ground
water; .
d)
installation of additional extraction wells to
facilitate or accelerate cleanup of the contaminant
plume; .
Continaencv Measures
Due to the many fractures in the rock beneath the Site and PCBs
being in separate phases in these cracks, PCBs may be resistant
to removal by pumping. (The MCL for PCBs is .5 ppb.) It is
-------
8-4
theorized that PCBs, TCE, and 1,2-DCE may co-exist as dense
non-aqueous phase liquids (DNAPLs). If it is determined, on the
basis of the preceding MCL criteria in Table 7.2 and system
performance data, that certain portions of the aquifer can not
be restored to their beneficial use for any or all of the
Site-related contaminants, all of the following measures
involving long-term management may occur, for an indefinite
period of time, as a modification of the existing system:
a)
engineering controls such as physical barriers, or
long-term gradient control provided by low level
pumping, as containment measures;
b)
chemical specific ARARs will be waived for the cleanup
of those portions of the aquifer based on the technical
impracticability of achieving further contaminant
reduction;
c)
institutional controls will be provided/maintained to
restrict access to those portions of the aquifer which
remain above remediation goals for PCBs or any of the
Site-related contaminants; .
d)
continued monitoring of specific wells; and
periodic reevaluation of remedial technologies for
ground-water restoration.
e)
The decision to invoke any or all of these measures may be made
during a periodic review of the remedial action, which will
occur in accordance with CERCLA Section 121 (c), which specifies
that a formal review be conducted at least every five years for
sites with contaminants remaining above health-based levels. If
any or all of these measures are determined to be necessary, an
Explanation of Significant Differences (ESD), or a ROD Amendment
will be issued to document these measures and inform the
public.
-------
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PREFERRED GROUNDWATER TREATMENT PROCESS
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WO)f1esboro, TtJnnessetJ
---
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9-1
IV.
STATUTORY DETERMINATIONS
Under its legal authorities, EPA's primary responsibility at
Superfund sites is to undertake remedial actions that achieve
adequate protection of human health and the environment. In
addition, Section 121 of CERCLA establishes several other
statutory requirements and preferences. These specify that when
complete, the selected remedial action for this Site must comply
with applicable or relevant and appropriate environmental
standards established under Federal and State environmental
laws unless a statutory waiver is justified. The selected
remedy must also be cost effective and utilize permanent
solutions and alternative treatment technologies or resource
recovery technologies to the maximum extent practicable.
Finally, the statute 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.
A.
PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
The selected remedy protects human health and the environment
through ext~~ction and treatment of contaminants in ground
water. All contaminants removed from the aquifer will be
permanently taken out. Volatile contaminants dissolved in the
groundwater will be transferred to the gaseous phase in the air
stripper and will exit the air stripper for release into the
atmosphere at concentrations not estimated to be harmful to
human health. Since volatile contaminants have been found to be
migrating from the Site at a greater speed than the PCBs, air
stripping will protect populations using well water downgradient
of the Site from these contaminants.
While their physical properties render PCBs difficult to remove
to acceptable health-based levels, PCBs will be removed and
treated to the maximum technically possible extent. PCBs
extracted from the aquifer will be retained with precipitates in
the bag filter and trapped in'the pores of the carbon adsorption
unit. Removal of the volatiles'combined with the tendency that
PCBs already have to move very slowly will insure that PCBs do
not move appreciably from the Site. All three signature
contaminants will be kept from migrating farther by the.
containinq action of the pumps.
Institutional controls and monitoring will insure that the,
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.--------
------~
9-2
public is not affected by Site-related contaminants at a future.
time. The Cold Water Creek will be tested to insure that this
tributary does not contain concentrations of the signature
contaminants which are detrimental to human health or the
environment.
Implementation of Alternative 4b will not pose any unacceptable
short-term-risks or cross-media impacts to the Site, the
workers, or the community. No environmental impacts have been
identified for the Site.
B.
ATTAINMENT OF APPLICABLE OR RELEVANT AND APPROPRIATE
REOUIREMENTS OF ENVIRONMENTAL LAWS
The selected remedy of extraction, on-Site treatment, and
discharge of treated effluent to either the Green River or the
local water treatment plant will comply with all applicable or
relevant and appropriate chemical, action, and location-specific
requirements (ARARs). The ARARs are presented below.
ActionScecific ARARs:
*
Clean Water Act (40 C.F.R. Part 122)
*
Tennessee Water Quality Control Act, TN Code 69-3-104
National Pretreatment Standards (40 C.F.R. Part 403)
*
*
Clean Air Act (40 C.F.R. Parts 50-62)
RCRA (40 C.F.R. Parts 262 - 264)
*
Chemical Scecific ARARs:
*
Safe Drinking Water Act (40 C.F.R. Parts 141 and 143).
EPA Ambient Water Qual~ty Criteria (EPA 440/5-80-068,
077, 041)
*
*
Tennessee Water Quality Criteria
(1200-4)
RCRA LDRs are generally not applicable to the ground-water
extraction and treatment process; however, should levels in the
waste residuals in the bag filters from the treatment process
exceed allowable standards, bag filters will be disposed of in
accordance with LDRs.o
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9-3
Other criteria To Be Considered:
An agreement shall be reached in the future between EPA and the
City of Waynesboro or Wayne County to prohibit construction of
water supply wells in the area of the contaminated ground-water
plume. Thi~ will prevent direct contact or ingestion of
contaminated ground water.
C.
COST-EFFECTIVENESS
The selected remedy is cost-effective because it has been
determined to provide overall effectiveness proportional to its
costs, the net present worth value being $3,005,000.
Alternatives 2a and 2b and 3a and 3b are only partially
protective since the '2 alternatives are only estimated to
contain approximately 81% of the TCE and 1,2-DCE and reduce
these compounds within the contained area only by approximately
98%. The'3 ~lternatives only reduce volatiles on-Site. Thei4
alternatives and the '5 alternatives are equally protective of
human health and the environment, however, the '4 alternatives
are more cost-effective. Alternativ~ '4b is more cost-effective
than Alternative #4a since it relies on a more proven technology
and is also more economical. .
D.
UTILIZATION OF PERMANENT SOLUTIONS AND ALTERNATIVE TREATMENT
TECHNOLOGIES (OR RESOURCE RECOVERY TECHNOLOGIES) TO THE
MAXIMUM EXTENT PRACTICABLE
EPA and the State of Tennessee 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 Mallory Capacitor Co. Site. Of
those alternatives that are protective of human health and the
environment ~nd comply with ARARs, EPA and the State of
Tennessee have determined that this selected remedy provides the
best balance of tradeoffs in .terms of long-term effectiveness
and permanence, reduction of toxicity, mobility, or volume
achieved through treatment, short-term effectiveness,
implementability, cost, also considering the statutory
preference for treatment as a principal element and community
input.
The selected remedy reduces the toxicity, mobility, and volume
of the contaminants in the ground water; complies with ARARs;
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j-
9-4
provides short-term effectiveness; and protects human health and
the environment. The selected remedy will be easier to
implement technically because the air stripping/bag
filtration/carbon adsorption system is a widely used technology
for this type of Site and has been proven effective at this Site
in treatability studies. Of Alternatives 4a and 4b and Sa and.
Sb, which aF~ equally protective, alternative 4b is the most
cost-effective. The major tradeoffs that provide the basis for
this selection are long-term effectiveness, implementability and
cost.
E.
PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT
By treating contamination in the ground-water plume through air
stripping, bag filtration and carbon adsorption and restricting
access to contaminated ground water, the selected remedy
addresses the threat of future direct contact with or ingestion
of contaminated ground water. Extraction pumping will contain
contamination as well as removing it for treatment. In
addition, the selected remedy contains provisions for review of
the Site at least every five years since contaminants will
remain in the ground water above health-based levels for an
estimated 60 years. If, at the time of. review, a new technology
for treatment of the PCBs in the ground water is available, its
implementability will be assessed at that time. Therefore, the
statutory preference for remedies that employ treatment as a
principal ~lement is satisfied.
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10-1
x.
SIGNIFICANT CHANGES TO ALTERNATIVE 4B
During the public comment period on the Proposed Plan, EPA received
comments from Conestoga Rovers & Associates, Limited (CRA) with
suggestions for modifications to the ground-water extraction portions
of the selected remedy, Alternative 4b, and Alternative 4a. CRA
proposed a_hybrid which would combine the hydraulic containment and
treatment features of Alternative 4b with the "hot spot" mass removal
feature of Alternatives 2a and 2b. This hybrid places extraction
wells in a phased approach, which EPA believes is practical for the'
Mallory Site. (Refer to Figures 6.3 and 6.4 for phase I and phase II
well placements.) The hybrid estimates that 14 extraction wells will
be employed which is one more than the proposed plan at 13 estimated
extraction wells and that the time to achieve performance standards
will be 30 years, whereas Alternatives 4a and 4b had originally
estimated 60 years.
EPA feels that these changes are practical for the Mallory Site and
has incorporated these changes into Alternatives 4a and 4b throughout
this document. One item on page 7-6 which has been noted is t~e cost
for Alternative 4a. CRA provided a revised cost for Alternative 4b,
the selected remedy, at $3,005,000, as opposed to the orig~nal
$3,105,000. This figure has been incorporated for Alternative 4b,
however, the original estimate has been left in place for Alternative
4a since no revised cost estimate was provided.
. Please see Appendix A to this document, which is the Responsiveness
Summary to the Proposed Plan. The Responsiveness Summary contains
greater details on CRA's modifications.
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APPENDIX A
RESPONSIVENESS SUMMARY
-------
1.
RESPONSIVENESS SUMMARY OVERVIEW
The U.S. Environmental Protection Agency (EPA) held a public comment period from
June 17 through August 14, 1991, for interested parties to comment on the
Remedial Investi~ation/Feasibility Study (RI/FS) results and the Proposed Plan
for the Mallory Capacitor Company Site (Mallory Site or the site) in Waynesboro,
Tennessee.
The Proposed Plan, included in Attachment A of this document, provides a summary
of the site's background information leading up to the public comment period.
Specifically, the Proposed Plan includes the following sections: Introduction;
Background Information; The Remedial Investigation and Key Findings ; Risk
Assessment; The Feasibility Study; Developing and Evaluating Remedial
Alternatives; Criteria for Evaluating Remedial Alternatives; Technologies
Considered in Developing Remedial Alternatives; and Glossary.
EPA held a public meeting at 7:00 p.m. on June 27, 1991 at the Wayne County
Courthouse, Waynesboro, Tennessee, to outline the RI/FS .and describe EPA' s
proposed remedial alternatives for the Mallory Site. All comments received by
EPA during the public comment period will be considered in the final selection
of a remedial alternative for the areas of contamination at the Mallory Site.
The Responsiveness Summary, required by the Superfund Law, provides a summary of
citizens' comments and concerns identified and received during the public comment
period, and EPA's responses to those comments and concerns.
This Responsiveness
attachments:
Summary
is organized into the
following
sections and
I.
RESPONSIVENESS SUMMARY OVERVIEW: This section outlines the purposes
of the public comment period and the Responsiveness Summary. It
also references the appended background information leading up to
the public comment period.
II.
BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS:
provides a brief history of community concerns
regarding the Mallory Site.
This sec tion
and interest
1
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III.
SUMMARY OF MAJOR QUESTIONS AND COMMENTS RECEIVED DURING THE PUBLIC
MEETING AND EPA' S RESPONSES TO THESE COMMENTS: This section
summarizes the oral comments received by EPA at the June 27, 1991,
public meeting, and provides EPA's responses to these comments.
IV.
SUMMARY OF MAJOR QUESTIONS AND COMMENTS RECEIVED
OFFICIALS AND EPA'S RESPONSES TO THESE COMMENTS:
summarizes oral comments from public officials
during a briefing held on June 27, 1991.
FROM PUBLIC
This section
received by EPA
V.
WRITTEN COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD AND EPA'S
RESPONSES TO THESE COMMENTS: This section contains letters received
by EPA as well as EPA's written response to the letters.
ATTACHMENT A: Attachment A contains the Proposed Plan which was
distributed to the public during the public meeting heid on June 27,
1991 and mailed to the information repository and those included on
the mailing list.
ATTACHMENT B: Attachment B includes the sign-in sheets from the
public meeting held on June 27, 1991 at the Wayne County Court House
in Waynesboro, Tennessee.
ATTACHMENT C: Attachment C includes names, addresses and phone
numbers of the information repository designated for the Mallory
Site.
ATTACHMENT D: Attachment D includes public notices regarding the
Mallory Site that were published in area newspapers.
ATTACHMENT E: Attachment E includes the official transcript of the
Public Hearing on the Proposed Plan for the Cleanup of the Mallory
Site located in Waynesboro, Tennessee.
II.
BACKGROUND ON COHKUNITY INVOLVEMENT AND CONCERNS
A.
Background on Community Involvement
Concerns regarding hazardous waste
and environmental .degradation in
general are widespread and longstanding. Over the last ten years concerns
regarding the extent of contamination caused by the Mallory Site have
increased.
Although residents and officials have expressed differing
degrees of concern. about polychlorinated biphenyls (PCBs), two local
environmental groups, Save Our Streams (50S) and Neighbors Involved in
County Ecology (NICE), have been consistently vocal. Both groups have
researched environmental issues and have been instrumental in informing
2
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the community of potential health and environmental threats posed by the
Mallory Capacitor Plant. NICE, for example, prepared. a report in 1983
entitled Yayne's Yonderful Yater, which provided detailed information to
the community. The report explained briefly that mixed feelings among"
area residents accompanied the news that the Mallory plant was moving into
Yaynesboro. It explained that although some residents welcomed new job
opportunities, others were concerned because they had learned that Mallory
was building a plant in Yaynesboro when the" company's Indiana plant
burned. Furthermore, some people were concerned about PCBs, a concern the
NICE report may have sparked or simply confirmed as part of a growing
national awareness about environmental pollution.
As incidents of contamination and sources of environmental pollution were
traced to the Mallory plant, concerns grew among local plant neighbors as
well as among county residents, some of whom live as far as 25 miles from
the site. Their concerns, noted throughoJ,lt the interviews. included
degraded water quality, fish kills, and onsite and offsite waste disposal
practices. While primary concerns varied from one group to the other, all
interviewees expressed their concern about public health. Residents and
officials agree there are too many unknowns regarding level of exposure to
PCBs.
The concerns about the site have not diminished despite closure of the
facility. Residents and officials describe action to bring clean up about
as being very slow.
B.
Communi tv Concerns
The following issues and concerns regarding the site were identified
during the briefing trip conducted on April 8 and 9, 1991:
1.
Health risks including ingestion of PCB-contaminated fish and PCB-
contaminated groundwater and the alleged high incidence of cancer in
the site area and Beech Creek;
3
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10.
11.
12.
2.
The use of PCB-contaminated gravel obtained from the Green River bed
as construction material and leakage of PCB-contaminated water while
hauling the gravel to construction sites;
3.
Family members and pets bringing PCB-contaminated soil into homes;
4.
Conversion of the existing site warehouse, potentially contaminated
with PCBs, into a shopping center;
5.
Site-contaminated wastes allegedly transported to the old city
landfill and county dump for disposal and resultant contamination of
Beech Creek originating from the county dump;
6.
The negative impact that closure of the site had on the local
economy;
7.
The lack of trus t
state and local government and
Federal,
in
regulatory officials;
8.
The validity of the RI/FS soil and groundwater sampling activities.
Community members question if representative soil samples were
collected and if an adequate number of groundwater monitoring wells
were installed and sampled north/northeast of the site to determine
the extent of the plume;
9.
The alleged inadequate closure of the old county dump;
The alleged use of PCB-contaminated sewer sludge as fertilizer;
The lack of warning signs and the presence of picnic tables in the
site area on the Green River;
The rate and direction of contaminated groundwater migration;
4
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13.
Potential contaminant migration upstream of the Green River to the
public water supply intake;
14.
The reuse of plant-contaminated equipment; and
15.
The number of disposal sites yet to be identified.
III.
SUMMARY OF MAJOR QUESTIONS AND COMMENTS RECEIVED DURING THE PUBLIC MEETING
AND EPA'S RESPONSES TO THESE COMMENTS
The following is a summary of the major verbal comments, concerns and questions
raised during the public meeting on June 27, 1991 by the local residents together
with EPA's responses.
COMMENT: A resident asked how the northeast boundary of the contaminated area
was determined when wells were placed only within the boundary and none were
located outside the boundary.
RESPONSE: EPA stated that additional wells will be placed further outside the
boundary until the extent of contamination is determined. This -has not been done
to date in order to concentrate on furthering the remedial effort in the area
known to be contaminated.
COMMENT: A resident asked if the current boundary was determined by a noticeable
decrease in contaminant concentrations in wells located further away.
RESPONSE: EPA stated that the method described above was used to estimate the
boundary of contamination and the Agency will continue to use this method until
the exact boundary is determined.
COMMENT: A resident asked if modeling was. conducted to gather groundwater
information.
RESPONSE: EPA stated that groundwater modeling was conducted to predict
contaminant migration through time to the Green River.
EPA added that the Agency strives to expedite the clean-up process by avoiding
unnecessary delays such as more extensive investigations. For this site, EPA
decided that the current information was sufficient to begin clean-up activities
while continuing additional investigations.
5
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COMMENT: A resident asked if it will be two years before the remedial action
begins; and if so, will the contamination problem change before the remedial
action is implemented.
RESPONSE: EPA stated that it could take up to two years before the clean-up will
begin; however, the contaminants will not migrate significantly during that time.
The contaminant& in the groundwater. will migrate, but not very quickly. The
contamination has spread only approximately 300 yards to date.
COMMENT: A resident asked if the contamination will spread during the 30 years
required to complete the remedial action.
RESPONSE: EPA stated that the pump and treat system will provide a hydraulic
barrier that will keep groundwater from migrating. Even if the PCBs aren't
effectively reduced, the contamination should be contained.
COMMENT: A resident stated that during an earlier public meeting, only two
contaminants, PCBs and TCEs I were discussed. However, the resident had read that
1,2-DCE was also present on the site and could irritate skin. The resident asked
if l,2-DCE posed a significant health risk.
RESPONSE: EPA stated that 1,2-DCE may not have been discussed as extensively as
the other contaminants since it is not a carcinogen. However, contact with 1,2-
DCE will irritate the skin and ingestion of the chemical over time can cause
liver damage.
COMMENT: A resident asked if ingestion of l,2-DCE can cause cirrhosis of the
liver. The resident added that EPA may not have discovered that 1,2-DCE was
present at the site at the time of the last meeting referred to above.
RESPONSE: EPA stated that ingestion of 1,2-DCE over time could cause liver
damage. In addition, 1,2-DCE is typically found in areas contaminated with TCE.
There probably wasn't sufficient evidence in 1986 or 1987, at the time of the
meeting, to discuss 1,2-DCE. However, during the RI, areas such as the main
facility were sampled and 1,2-DCE, PCBs and TCE were found.
COMMENT: A resident asked when the site property would be productive and
available for use.
RESPONSE: EPA stated that since the site is private property, the Agency cannot
dictate its use, although they can place restrictions on further use. At this
time, the only restrictions on land use involve prohibiting the installation of
wells and ingestion of water from the site. .
Future users of the property should be warned, however, that the site is an NPL
site and current and past users of the property can be liable for any further
contamination.
6
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COMMENT:
A resident asked if the site will ever be used as a park.
RESPONSE: EPA stated that the potential for
considered and the Agency does not anticipate a
into a park in the future.
use of the site as a park was
problem if the site is developed
COMMENT: A resident expressed concern regarding his property located adjacent
to the site. He was concerned about the potential liability of the landowners
around the site if their property became contaminated and they sold the property
to someone else. In addition, he expressed concern about the health risk for his
family while living next to a Superfund site.
RESPONSE: EPA stated that according to the reports there is no contamination
problem on the properties surrounding the site property. However, the Agency has
placed restrictions on well installation and consumption of water from those
wells because that would present a potential exposure pathway.' EPA is not
concerned, however, with imposing liability claims on the residents living around
the site.
COMMENT: A resident asked if there will be any health risks to the people
surrounding the site.
RESPONSE: EPA stated that according to several years of investigations and
resulting analytical data, the soil, sediment and air do not pose a health risk.
Groundwater may pose an unacceptable risk if wells are drilled and used for
drinking water. Therefore, restrictions have been placed on. future use of the
site in this manner.
COMMENT: A resident asked how EPA will document the restrictions placed on the
site. The resident expressed concern that in 30 years, people may forget about
the site and drill wells in an unsafe area. .
RESPONSE: EPA stated that institutional controls will be placed on the site as
described in the proposed plan. The controls may be implemented in the form of
an ordinance against drilling in the area and/or restrictive notations on the
deed to warn potential buyers of the problems at the site.
COMMENT: A resident who lived across from the storage building asked why EPA
sampled topsoil in residents' yards.
RESPONSE: EPA stated that surficial soil was tested because the Agency felt that
contact with surface soil was a potential exposure pathway. In addition, deeper
soil samples were taken in the residents' gardens surrounding the site.
COMMENT:
air.
A resident expressed concern about contamination of her property via
7
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RESPONSE: EPA stated that any contamination that may have occurred via air would
have eventually settled on the surface soil. The surface soil was tested for
this reason and if problems were found, deeper soil tests will be conducted.
COMMENT: A resident expressed concern that the surface samples collected on her
property were taken from fresh topsoil that she had recently placed on her flower
bed and that the sample was not representative of her property.
RESPONSE: Conestoga Rovers & Associates stated for EPA that several residents
expressed similar concerns and when this situation arose, the resident's property
was resampled.
COMMENT: A resident asked how much the work at the site has cost thus far and
who paid for it.
RESPONSE: EPA stated that the PRPs incurred the costs for the RI/FS work via the
Consent Agreement. EPA may have incurred expenses when ranking the site, but
attempts will be made to recover those costs. Negotiations will be conducted
regarding the costs of the remedial action at the site. The cost is 'estimated
at $5 million; however, if the costs exceed the estimate, the party responsible
for payment, according to the settlement, will incur the additional costs.
COMMENT: A resident asked if the total cost, from initial stages to final clean-
up, will be less than $10 million.
RESPONSE: EPA stated that according to the estimate in the proposed plan, the
total work should cost under $10 million. However, the costs stated in the
proposed plan are estimates.
COMMENT: A resident asked for clarification regarding the lack of contamination
in the deep, 90-foot wells and expressed concern about the air evaporator. He
asked how it will effect the air and why this method was, chosen instead of
Alternative 4A.
RESPONSE:
detected.
EPA stated that two deep wells were installed and no contamination was
EPA added that Alternatives 2 through 5 have A and B parts. The A alternatives
involved ultraviolet oxidation of contaminants and are effective when treating
a high volume of water that originates from a consistent source. However, the
. Mallory Site involves a low volume of water that will vary through time. The
preferred treatment for this site involves air stripping, bag filtration, and
carbon adsorption.
As mentioned, air monitoring will be conducted during the remedial action and if
contamination is detected at unacceptable levels, the air stream will be run
through, a carbon bed to prevent further release of contaminants to the air.
8
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In addition, the ground-water contamination is discussed in parts per billion.
A person cannot be acutely poisoned by drinking this water. The consumption of
water from the site is considered a health risk because if an individual consumed
the water every day over a 70-year span, he or she may suffer ill effects.
The air stripper described in the preferred alternative will release very small
amounts of contamination and it will fall below the acceptable limits.
COMMENT:
A resident asked how often the air stripper discharge will be checked.
RESPONSE: EPA stated that the actual frequency will be determined during the
remedial design. Typically the air is monitored frequently in the beginning,
followed by a less intensive monitoring plan to ensure that levels remain safe.
COMMENT: The resident stated that she had been told that EPA would monitor every
five years.
RESPONSE: EPA stated that the five-year plan is misleading. In accordance with
the National Contingency Plan, EPA will review all the data, as a whole, every
five years. The Consent Decree will require the PRPs to send monitoring data to
EPA on a routine basis. EPA will continually examine the data to ensure that it
is within the acceptable range. The five-year review is conducted to evaluate
the acceptable levels to make sure that, among other things, any new scientific
discoveries can be incorporated into the plans at the site.n
COMMENT: A resident asked if any of the site contaminants have been detected
outside the plant property, and if so, why the remediation efforts only address
the site area. The resident suggested that the PRPs be required to buy the
surrounding contaminated land from the current property owners.
RESPONSE: EPA stated that PCBs were found outside of the Plant property;
however, they were not detected at levels that are considered detrimental to the
people living in the area.
COMMENT: The resident stated that the levels of contamination must be fairly
high to warrant the costs of the work completed to date and the work planned for
the future. . He added that perhaps EPA was only concerned with the site property
and not concerned with the property and residents surrounding the site.
RESPONSE: EPA stated that the costs for past removal activities were justified
in the effort to remove unacceptable levels of PCB's in the soil.. The costs
estimated for the remedial action are justified in the effort to make the
groundwater in the area safe for human consumption. EPA is concerned with the
property and residents surrounding the site; however; it has been determined that
there are no unacceptable risks posed to those residents or their property.
9
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COMMENT:
A resident asked for a definition of acceptable risks.
RESPONSE: EPA stated that during the remedial investigation, data was collected
regarding the concentration of contaminants in the soil, sediment, groundwater,
and air. During the risk assessment, the concentration of contaminants was
analyzed in relation to the media the contamination was detected in and any
possible exposur,e pathways. For example, if contamination is detected in the
surface soil, a potential exposure pathway would be children playing outside and
coming in contact with the contaminated media. The possible exposure pathways
are considered along with the contaminant concentrations to determine whether a
risk to human health or the environment exists.
The National Contingency Plan has set specific guidelines for what determines an
unacceptable risk. PCB's and TCE, both found at the Mallory Site, are considered
probable carcinogens; i.e., they cause cancer in laboratory animals and are,
therefore, considered probable carcinogens in humans. Since we don't know for
sure what effect PCB and TCE will have on humans, the acceptable risk levels are
set on the side of being overprotective.
COMMENT: A resident asked how many additional cases of cancer in the area would
still be considered within the acceptable range.
RESPONSE: EPA stated that the acceptable risk is one new case of cancer in ten
thousand people to one in one million people. This is the additional risk posed
by the site that is considered acceptable. Residents in the area, just like
people allover the country, are already exposed to cancer causing agents in the
environment, e.g., in food. The acceptable risk is set so that no more than one
in ten thousand to one in one million additional cases of cancer will. occur as
a result of the contamination at the Mallory Site.
COMMENT: A resident asked if the risk assessment for the site was different than
the risk assessment conducted for a resident's yard.
RESPONSE: EPA stated that the risk assessment was conducted using the scenario
that the site could become a park. Under this scenario, is was determined that
the soils did not pose an unacceptable risk. The possibility that someone may
build a house on the site in the future was also considered. Under this
scenario, it was determined .that if a well was drilled and the water consumed,
it would present an unacceptable risk. . Therefore, residential concerns were
evaluated and during the risk assessment and current zoning regulations were
disregarded in order to anticipate a full range of possible developments on the
site.
COMMENT: A resident asked if PCBs can be found in motor oil and other oils that
are sold at service stations. These oils are often spilled on the floor at these
service stations.
10
-------
. .
RESPONSE: EPA stated that PCBs and TCE are often found in waste oil, but not in
normal motor oil. Years ago, when a waste hauler picked up PCB-contaminated
waste from one facility, they often collected more waste from another facility,
such as a service station, before finally disposing of all the waste. In such
a case, all the waste would be contaminated simply because it was hauled
together.
This question is related to acceptable risks or acceptable levels discussed
earlier. Before the use of PCBs was banned, they were used in transformers,
paints and many other products. These PCBs found their way into the environment
and into humans. EPA was forced to determine what is an acceptable level that
will not pose a significant risk to human health or the environment.
COMMENT: Residents asked if PCBs are present in asphalt and inquired about other
products that contain PCBs.
RESPONSE: EPA stated that PCBs should not be present in asphalt unless some
irregular contamination took place. PCB's may. be on the roads, however, because
they are used in transformers. PCBs were also used in inks at one time, but the
most frequent use of PCBs was as dielectrical fluid in transformers. Of course,
they were used in capacitors which are put in cars and homes and when the
capacitors are no l~nger useful, they are disposed of in landfills which can
cause contamination of the environment. .
COMMENT: A resident stated that following a recent appraisal of her home, she
learned that her property value had decreased. The resident asked who can be
held responsible for this personal loss: Mallory or EPA.
RESPONSE: EPA stated that the Agency is not liable for the effect of
contamination on area residents. However, anyone can file a civil suit against
anyone else to seek damages. If you feel that you have been harmed, you can take
action against the party that inflicted the harm upon you.
This is a common problem at National Priorities List sites across the country.
However, EPA's role at the site is only to determine the extent of contamination
and remediate the site, if necessary. .
COMMENT: A resident stated that even though EPA determined the neighboring
property to be safe, the property values still declined. It would be difficult
to file a successful civil suit when EPA has determined the property to be safe.
The resident asked if EPA can provide written documentation that the property is
safe.
RESPONSE: ~PA stated that property value is relative. Even though the Agency
has determined the property to be safe, public perception may still be that the
property is contaminated, which will effect the property value. Written
documentation that the property is safe can be found in the Record of Decision
and after the remedial efforts are complete, there will be a document that states
that the site has been cleaned up to meet EPA standards.
11
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COMMENT: ~ resident stated that such a document will not exist for thirty or
more years. which is too late for most current property owners. Another resident
asked who the residents in the area should file a civil suit against and whether
the statute of limitations has already run out.
RESPONSE: EPA stated that the statute of limitations had not run out because the
residents had only recently learned. through EPA documentation, the extent of the
damage to their property. However, the Agency can not provide further legal
advice since this is not the function of EPA.
COMMENT: A resident asked what kind of assistance EPA can provide to citizens
who pursue legal action.
RESPONSE: EPA stated that Congress defined the role of EPA to protect human
health and the environment. The Agency does not become involved in property
disputes. The only assistance EPA could provide would be in the form of
documentation of the contamination at a site.
COMMENT: A resident stated according to the Feasibility Study Report, four
pounds of VOCs could be released into the air per day. The resident asked if
this will cause an odor.
RESPONSE: EPA stated that they were unsure whether this would cause an odor and
could not be certain until the unit was operating.
COMMENT: A resident described several paper mills in the area from which strong
odors are emitted. The resident continued by describing what she felt were other
environmental problems in the area. (The conversation continued between the
resident and EPA in the form of an analogy regarding whether EPA should redirect
their attention from the Mallory Site to other environmental problems in the
area: problems that the resident felt were potentially more serious.)
RESPONSE: EPA stated that there may be problems with other programs. However,
Congress has determined the purpose of the EPA and set the regulations that EPA
is tasked to enforce. The Clean Air Act, for example. has been revised. and EPA
will enforce these new regulations.
COMMENT: A resident asked how information regarding site progress will be
disseminated in the future. The resident expressed concern that there has not
been a steady flow of information. .
RESPONSE: EPA stated that as soon as new documents become available. they are
sent to the information repository. There may be periods where no new
information is available. but this does not mean that work has stopped. The
Agency has admittedly fallen behind on sending information to the information
repository. There is a concentrated effort now to catch up on any out-of-date
repositories and strive to keep the repositories current.
12
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COMMENT:
A resident asked EPA to define the term "Natural Resource Trustees."
RESPONSE: EPA stated that the National Contingency Plan includes a list of
agencies such as the Department of Interior, Fish and Wildlife Service and the
Bureau of Mines that must be given the opportunity to review EPA's plan in order
to evaluate the .ylan in relation to the natural resource they are designed to
protect. If.a Natural Resource Trustee states that EPA's plan is not protective
of a particular resource, then the responsible parties may be liable in future
litigation regarding damage to a natural resource.
COMMENT: A resident asked for a description of the issues involved in deciding
whether to discharge directly to the Green River or indirectly through a
treatment facility.
RESPONSE: EPA stated that in many cases, agreements are made to discharge to a
PON and two or three years into the process, the POTW refuses to continue
accepting the discharge. This may happen for a variety of reasons. Therefore,
during the design phase, the engineers will determine how much water will be
generated and what the residual contaminants will be. The engineers will
approach the POTW officials to find out if the POTW can accept the volume and to
determine the associated cost. . After this task is completed, the. engineers will
determine how much water will be discharged to a stream. They will check with
the State to determine discharge limits, and based on all this information, an
economical decision is made.
COMMENT: A resident stated that an error exists in the description of
stratigraphy in the site geology section of the RI report and asked if this could
be corrected.
RESPONSE: EPA acknowledged speaking with the resident about this problem before
and assured him that the problem would be corrected in the Remedial Design.
COMMENT: A resident expressed concern that the four pounds of contaminants
coming from the air purifier will further contaminate area property over the next
30 years.
RESPONSE: EPA state that VOCs will be discharged and they do not settle on
surfaces; instead they will disperse into the air. EPA added that this. discharge
will be continually monitored to ensure that the contaminant levels are
acceptable. If they are found to be unacceptable, they will be treated before
o release.
COMMENT: A resident asked if releases to the atmosphere occur with UV oxidation
treatment.
13
-------
RESPONSE: EPA stated that carbon dioxide and water would be released with UV
oxidation. This method was determined to be less efficient for the Mallory Site
because of the low volume of water to be treated. .
COMMENT: A resident asked if a person will move to Waynesboro and be tasked with
monitoring the equipment.
RESPONSE: EPA stated that it depends on how automated the plan is. Typically,
a self -monitoring system with alarms that requires little custodial care is
desireable.
COMMENT: A resident expressed concern that some area residents will respect the
restrictions EPA has put in place regarding site use, but some other residents
won't care. The resident cited past removal and use of contaminated gravel by
area residents as an example of disregard for the problems at the site.
RESPONSE: EPA concurred with the citizen's concerns and stated that the Agency
can return at the end of the remedial design to discuss the exact plans for
monitoring and custodial care. EPA stated that this gravel was sampled as
sediment during the Remedial Investigation and found to be safe.
COMMENT: A resident asked what the function of bag filtration was at the
wastewater treatment plant.
RESPONSE: EPA stated that it will trap fines that could clog the carbon
adsorption system. The bag may contain PCBs since PCBs adhere to solids;
however, the VOCs will come out with the air stripping.
If the bag contains hazardous wastes, it will be landfilled or incinerated
according to the regulations for that particular waste.
COMMENT: A resident expressed concern that the locations of the thirteen wells
be carefully selected.
RESPONSE: EPA stated that the thirteen wells described were only estimates for
costing purposes. During the remedial design, EPA may determine that a greater
or lesser number of carefully placed wells are sufficient.
COMMENT: A resident expressed gratitude to EPA for the time, money and effort
that has been invested in investigating and remediating this site.
RESPONSE: EPA stated that changes may still occur in the plan for the site. .The
process of predicting what will be the most effective way to treat a site is very
difficult and once field work begins, alterations in the. plans may become
necessary. If changes are proposed, they too will be brought before the public.
14
-------
COMMENT: A resident asked if the clean-up process would be faster if additional
wells were installed.
RESPONSE: EPA stated that additional wells were considered in other alternatives
and it was determined that thirteen wells were as efficient as 22 wells. EPA
added that each well has an area it influences and if the areas overlap too much,
the effectiveness of additional wells is lost.
COMMENT: A resident stated that an unused well is located on Brewer Drive and
that EPA may want to sample it.
RESPONSE: EPA stated that it would appreciate receiving further information
about the well; however, sampling private wells does not always provide valid
data since little is known about well depth, or how it was installed, etc.
COMMENT: A resident asked if a threat could result from a well pumping a high
volume of contaminants into the treatment system or the city water.
.RESPONSE: EPA stated that the scenario described is highly unlikely; however,
monitoring systems will be in place to protect other water sources. In addition,
the system will discharge into the Green River or PON, not the city water
s~p~. .
COMMENT: A resident asked if some form of control, either a custodian or shut-
down system, would be in place in case this type of unforeseen accident does
happen.
RESPONSE: EPA stated that the design engineers will use the best available
information to determine the type of monitoring and controls required.
IV.
SUMMARY OF MAJOR QUESTIONS AND COMMENTS RECEIVED FROM PUBLIC OFFICIALS AND
EPA'S RESPONSES TO THESE COMMENTS
The following comments were received at the briefing with public officials at
10:00 a.m. on the morning of the Mallory Capacitor Company Proposed Plan Public
Meeting on June 27, 1991. All questions were answered immediately with the
exception of one, which was answered on July I, 1991, by telephone.
COMMENT: An official asked if problems with air pollution could result from
implementation of the proposed remedy.
15
-------
RESPONSE: EPA stated that no pollution should be introduced to the atmosphere
as a result of the Proposed Remedy, with the exception of very small levels of
volatiles exiting the stack of the air stripper. The air stripper will be
monitored on a regular basis and should volatile emissions to the air exceed
allowable Clean Air Act limits, control equipment, such as a carbon bed, may be
installed to capture these emissions.
COMMENT:
problem.
An official asked if chlorine in the atmosphere would present a
RESPONSE: EPA stated that no known problem exists at this time although the
volatiles may discharge from the air stripper and will be monitored and treated,
if necessary, as described.
COMMENT:
An official inquired about the volume.of water to be treated.
RESPONSE: EPA stated that the contaminated pore volume of groundwater to be
treated is 4.8 million cubic feet. This exact figure was unavailable at the time
of the briefing and was reported later by telephone on July 1, 1991.
COMMENT:
An official.asked how many monitoring wells exist at the site to date.
RESPONSE: EPA stated that between 60 and 70 wells have been used for groundwater
monitoring at the site. The figure is not exact since some were abandoned and
some others were not used for all of the sampling rounds. .
COMMENT: An official asked if the remedy can extend beyond the 30-year period
if necessary for clean-up.
RESPONSE: EPA stated that the 30-year time frame is based on engineering
estimates and may change during the remedial action.
COMMENT: An
restrictions.
official
asked
who
is
responsible
for
implementing
deed
RESPONSE:
EPA stated that city and local officials are responsible.
COMMENT: An official asked if the plant site can be used or if restrictions will
be in place.
RESPONSE: EPA stated that the site is on private property. Durace11 may decide
future use of the property. Duracell may not wish to have additional operations
at the site which could increase contamination and their liability. Likewise,
a potential site user will need to give careful consideration to the problem
before subjecting themselves to possible contamination liability.
16
-------
COMMENT:
be.
An official asked how large the on-site water treatment facility will
RESPONSE: EPA stated that the water treatment facility will not cover the entire
8.6 acres. It should all be brought in by 5 or fewer tractor trailers. The
treatment facility may be placed at the western wide of the site so that the
river could be enjoyed by the public. However, the feasibility of this will be
assessed at a later time.
V.
WRITTEN COMMENTS RECEIVED DURING THE PUBLIC COMMENT PERIOD AND EPA' S
RESPONSES TO THESE COMMENTS
The attached written comments were received during the public comment period.
EPA's responses to these comments are attached and were mailed to the parties
addressed.
17
-------
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:991
:-!s. Bet"!:.: Bauman
~ou"!:e 1, Eox 295A
Waynesboro, Tennessee
38435
Dear Ms. Bauman:
The U.S. Environmental Protection Agency (EPA) is in rec=~~1: 0=
August 8, 1991, letter to Debbie ~ourdan or EPA. Thank ~~u =or
~ak~~g t~~e t= wri~ei your letter is greatly ap9rec~a~e=.
ycu=
In your letter, you express several concer~s. The Mal:=r: :~?ac~~==
Superfund Site is one item mentioned. As you may be aware, remed~al
actions have previously been conducted at the Mallory S~~e. The cnly
media remaining which could pose risk is ground water. :~ is
expected that a Record of Decision (ROD) will be signed =y September
16, 1991, to finalized EPA's preference for the method 0=
ground-water cleanup in the Proposed Plan issued to the public in
June 1991.
Should you wish to gain additional
an information repository has been
County Library, located on Highway
(615) 722-5537.
information on the Mal:o~l Site,
set up for your use i~ t~e Wayne
64 in Waynesboro, Tenr.essee at
I am the Remedial Project Manager for the Site and will serve as your
contact at EPA Region IV. Should you have any questions at any time
concerning .the Mallory Site, please do not hesitate to ~ontact me at
(404) 347-7791. Any concerns you may have regarding potential
hazardous waste sites in your area can be directed to Susan Deihl of
the North Unit of the Site Assessment Section, EPA Region IV, at
(404) 347-5065.
Sinc..erely,
/ J-f- . /' l.~ --L-
'I' A-I..- k~<4'.... - . "1) tf/ ~:7'~1
Patricia C. Fremont
Remedial Project Manager
Kentucky/Tennessee Section
North Superfund Remedial Branch
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~'""""'" MrI Carl Bauman
. .- .,R1 Bx 295A
'. Waynesboro TN
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UNITED ST ATES ENVIRONMENT AL.. PROTECTION AGENCY
REGION IV
345 COURTLAND STREET. N.::.
ATLANTA. GEORGiA 30365
4WD-NSRB
August 21, 1991
Jack Michels, P.E.
Conestoga-Rovers &
651 Colby Drive
Waterloo, Ontario,
Associates Limited
Canada
N2V 1C2
Re:
Mallory Capacitor Co. Superfund Site
Waynesboro, Tennessee
Proposed Plan.
Dear Mr. Michels:
As you are aware, the extended public comment period for the
above-referenced document concluded on August 14, 1991. This letter
is in response to your letter to me dated August 13, 1991, which
contains comments on the u.S. Environmental Protection Agency (EPA)
Proposed Plan for ground-water remediation at the Mallory Site.
In your letter, you suggest an alternate ground-water extraction
system for moving contaminated ground water to the treatment facility
on-Site. The alternate which you suggest is a "hybrid" between EPA's
.Proposed Plan (Alternative 4B) and the alternative which you have
expressed a preference in (Alternative 2B). EPA's Proposed Plan,
Alternative 4B, consists of on-Site and off-Site hydraulic
containment and treatment. Alternative 2B consists of contaminant
mass removal, or extracting ground water from areas of highest
volatile organic compound (VOC) concentrations both on- and off-Site
and removing approximately 98 percent of the VOCs within the zones of
influence of the extraction wells..
EPA's Proposed Plan includes complete hydraulic containment of the
contaminated ground-water plume, whereas, Alternative 2B only
provides partial containment. Both alternatives employ the same
method for treatment once ground water is extracted. from the aquifer
system. .
The hybrid remedy you suggest combines the hydraulic containment and
treatment feature. of Alternative 4B with the "hot spot" mass
Pnnred on Recycled P3per
-------
Page 2 .
Jac;< ~1i=hels
Augus"t. 15, 2.99:
c~ntami~an"t. =emova: i~ Al~e=~ative 23. ~~ accitic~! tie ~yb=id
would i~cl~ce a ~hased ap~==ach t~ ~==u~c-wa~== ==med~~~~cn. ~~e
hy~=id is es~i~a"t.ec to ~ee~ t~e same ~e=f~~ar.ce s~a~ca=cs fe= VCC3
i~ 30 yea~s ~hi=h A:~e=~a~~7e ~3 es~~~atss 5S y~a=s ~= ac~~sve.
~?_~ ::as =s"',,-.:.eT.'W.ec
-~_sscci.::tss :' ::t.;:
. .. . ~ . ~ .
~~: ~~?~~~ :~?~~ac~. :~~;7s~=c 77
a~c =e_~=v=s ~~a~ ~~e== ~s =e=~~
C~~2s~=sa ~cve=~ ~
'":.= -=~e n ::.=-= s=c~ ,t
. :nass '::=n":.am.:..:-...a::~ -:!IlCV-~ ~ =: ~ -: -,.,c :: c: -'''c:''- -::!!1.C";;=" :"5 a:'sc a-=~cm-__c.r.-=-=~
, .. '7 - . ~- I - --. ~ --... - -- 7 - ..- -: -..... -- . -
=y ~=mp~:~= c=n~~~~en~ c=..~~e cc~~~~~a~=c.;=~u~=~wa~=~ p~~e. ~E
we nave c~sc~ssec ?rev~ous~7, ~a="t.~a- con~a~=me~"t. ~3 ~o"t. a~
acceptable cp~ion as t~ere a== ?r~va~= ==si~ences, ~= t~e ?o~=n~~~:
for future private residences, using ?rivate we:: water cowng=a~ia~~
of the Site. We also believe t~at t~e chased a~croac~ whici vou
recommend is reasonable for the hydraulic situation at tie Site.
The changes in well placeme~t which you have recommended, as well as
the phased approach, do not pose major changes to t~e selected
7emedy. ~lex~bili~~ is ~~:~rporatec into t~e selected remedy to
~~cor?ora"t.e "t.nese, ~~cr c~==ere~ces. ~?A ~~ll. take your ccmme~~3
in~~ consideration when t~e selected remedy for tie Mallorl Site is
finalized via the Record of Decision (ROD): -
As stated in the Feasibili~y Study (FS) report and the Proposed Plan,
surface water and sed~ent samples were to be collected in the
surface water tributary north of the Site, or Cold Water Creek, for
chemical and biological parameters as part of the selected remedy.
Biological testing was to be conducted based on the results of
chemical sampling. Your August 13 letter presents the results of
chemical sampling conducted in the tributary on June 27, 1991.
Sampling revealed two sediment PCB hits at .32 mg/kg and .80 mg/kg.
You state that these results form the basis for CRA to delete any
subsequent chemical and/or biota sampling from the selected remedy.
CRA is not given the authority to delete or add items to the selected
remedy. This is the authority of EPA. Furthermore, based on Effects
Range-Low (ERL) limits set by the National Oceanic and Atmospheric
Administration (NOAA), toxic effects have been observed in
populations of fresh water and salt water sed~ent dwelling organisms
at .05 mg/kg. Upon consideration of these levels and the results
above, a solid phase toxicity test such as an amphipod type bioassay
. will be necessary to determine if toxic effects have occurred to Cold
Water Creek. Based on the results of th~s test, further chemical
and/or toxicological monitoring may be required.
One last item to be addressed is that of cleanup costs. In the FS
report, CRA estimated the cost of Alternative 4B, the proposed Plan,
in present value dollars to be $3,105,000 and provided a detailed
cost breakdown to support this estimate. In your August 13 letter,
CRA changes its cost estimate for Alternative 4B to $9,005,000. CRA
suggests that this amount is in present value figures {1991
-------
Page 3
Jack Michels
August 16, 1991
dollars). This is a great change from the approximately $200,000
dollar difference in costing if Alternative 4B were costed over a 30
year versus a 60 year period. You stated this approximate difference
in. our July 11, 1991, meeting. Furthermore, you have provided no
cost justification to support this $9,005,000 figure.
As for EFA's misprint in the Proposed Plan which stated that the
selected remedy would take 30 years to achieve performance standards
(the correct amount of time is 60 years), an announcement was sent
out on July 17, 1991, to all members of the Community Relations Plan
mailing list which reflected this error and gave the public ample
opportunity to comment on it. The same announcement was printed
later that week in the Wayne County News. No comments besides yours
have been received.
EPA has discussed your comments with the State of Tennessee
Department of Environment and Conservation (TDEC). TDEC is in
concurrence with EFA on the positions supported in this letter.
Should you have any questions concerning this letter, please do not
hesitate to contact me at (404) 347-7791.
Sincerely,
?Jr~
Patricia C. Fremont
Remedial project Manager
Kentucky/Tennessee Section,
North Superfund Remedial Branch
{' ..l11!n1Ld-
cc:
Bill Forrester, Tennessee Department of Environment, and
. Conservation . ,
Bob Powell, Tennessee Department of Environment and Conservation
Mark Wilson, u.S. Department of Fish and Wildlife
Carol Wood, King and Spalding
-------
CRA
Consulting Engln..rs
CONESTOGA-ROVERS & ASSOCIATES LIMITED
651 Colby Drive.
Waterloo. Ontarto. Canada N2V 1C2
(519) 884.0510
August 13, 1991
Reference No. .2319 .
Ms. Patricia Fremont
Environmental Manager
United States Environmental Protection Agency
Region IV'
North Superfund Branch
Waste Management Division
345 Courtland A venue
Atlanta, Georgia.
U.S.A. 30365
Dear Ms. Fremont:
Re:
Comments on the Feasibility Study and Proposed Plan
Mallory Capacitor Site
Waynesboro. Tennessee
Conestoga-Rovers & Associates (CRA) has prepared, on behalf of Duracell
International, Inc. (Duracell), the following comments on the Fact Sheet and
Proposed Plan published by United States Environmental Protection Agency
(USEPA) with respect to the Mallory Capacitor Site (Site) in Waynesboro, Tennessee.
USEP A's Fact Sheet and Proposed Plan suggest that the preferred remedial action is
Remedial Alternative 4b as described in the Feasibility Study (FS) report - consisting
of the installation of extraction wells to contain and remove for treatment
trichloroethylene (TCE) and 1,2-dichloroethylene (l,2-DCE) contaminated
groundwater ove!; a period of 60 years. .
BACKGROUND
Duracell submitted a final FS report for the Site on May 8, 1991. As stated in the FS
report, the remedy preferred by Duracell was Remedial Alternative 2b - contaminant
mass removal. This remedy would extract groundwater from the areas with the
highest concentrations of volatile organic compounds (VOCs) both on Site and off
Site, removing approximately 98 percent of the VOCs from the bedrock aquifers
within the zones of influence of the extraction wells. The remainder of the
Site-related contaminants would naturally attenuate. As USEPA recognized in the
FS and the Community Relations Fact Sheet describing the remedial alternatives,
the remaining VOCs would not pose additional risks to public health or the
environment above USEP A's acceptable range. In fact, if no remedial action was
performed at the Site, the existing and predicted maximum mass flux to the Green
-------
August 13, 1991
Reference No. 2319
-2-
River do not and will not pose additional risks to public health or the environment
in excess of the range deemed acceptable by USEP A.
Regardless of the remedy selected, it is technically impracticable to remediate the
groundwater to federal drinking water standards. Restoration of the aquifer on Site
and off Site, is not technically feasible due to the presence and immobility of
polychlorinated biphenyls (PCBs) in the aquifer. Therefore, the groundwater
applicable, relevant and appropriate requirement ("ARAR") cannot be met. There
are no existing or innovative technologies which can reliably, logically and feasibly
remediate the PCBs to the federal drinking water standard. Due to the PCB
contamination, USEP A must rely on institutional controls and not active
remediation to ensure that the contaminated groundwater will not be utilized as a
water supply source.
The aquifers in the area of the Site are not currently used as a drinking water source
as the area is served by a municipal water system. In addition, it is extremely
unlikely that the groundwater would ever be used as a drinking water source given
the characteristics of the aquifers. During the Remedial Investigation (RI), it was
shown that the aquifers do not produce appreciable quantities of water such that
they would be a viable potaple water source. Therefore, given the characteristics of
the Site, it is unnecessary to remediate the groundwater to federal drinking water
standards, even if it was technically practicable, as the groundwater contamination
does not pose an actual threat to health or the environment.
Even though the groundwater cannot be remediated, Duracell understands that
USEPA continues to support Remedial Alternative 4b, on-Site and off-Site hydraulic
containment and treatment. .
In selecting Remedial Alternative 4b as its preferred remedial action, USEPA
initially assumed, incorrectly, that the remedy would involve groundwater
extraction and treatment over a period of 3q years. It also assumed that ~he cost of
Remedial Alternative 4b would be $3,105,000. In fact, the remedial period of
Remedial Alternative 4b is estimated in the"FS report to be 60 years and its total cost
is estimated to be $9,301,000 (1991 dollars), with a present value of $3,426,000 using
the six percent discount factor assumed in the FS.
As recently discussed with USEP A, it is possible to combine the mass contaminant
removal advantage of Remedial Alternative 2b with the hydraulic containment
feature of Remedial Alternative 4b. Such a 2b/4b combination would include
on-Site source control wells in addition to the hydraulic containment wells
-------
August 13, 1991
Reference No. 2319
- 3-
proposed at the downgradient edge of the Site-related contaminated groundwater.
In addition, such 2b/ 4bcombination would include a phased or iterative approach
to groundwater remediation which would be most appropriate for the Site. Under
the 2b/4b combination, groundwater extraction would begin expeditiously, thus
providing an opportunity to determine the optimum location for the hydraulic
containment wells under actual operating conditions of aquifer performance and
contaminant migration rather than modeled or estimated conditions.
CRA believes the groundwater extraction system suggested herein will satisfy
USEP A's objective of hydraulic containment (and treatment) of the Site-related
contaminated groundwater over a shorter period in the order of 30 years. This
proposed remedy, as for all the remedial alternatives considered in the FS, will not
remediate the groundwater to the federal drinking water standards. As noted above,
it is technically impossible to achieve this objective. Therefore, it is requested that
USEP A include in the Record of Decision (ROD) the flexibility to re-evaluate the
groundwater remedial objectives on a periodic basis.
PROPOSED 28/48 COM81NA TION GROUNDWATER EXTRACTION SYSTEM
Phase I - On Site
The initial phase of groundwater extraction for the Site would include the
installation, operation and monitoring of five on-Site source control wells. The
purpose of these wells would be to reduce the mass of contaminants in the
groundwater while at the same time provide operational and performance data to
be used in the design of the off-Site contaminated groundwater containment wells.
The need for this type of approach is well justified by the results of the aquifer .
testing conducted during the RI, where the testing illustrated the variability of well
yields that may be encountered as well as the anisotropic response in the bedrock to
pumping.
The data presented in the final RI report indicated that on Site, the areas of highest
concentrations of Site-related contamincmts in the shallow and deep bedrock
aquifers occur in the vicinity of the following monitoring wells (refer to Figures 1
and 2, attached): .
-------
August 13/ 1991
Reference No. 2319
- 4 -
Shallow Bedrock
Deep Bedrock
OW37-89
OW33-89
OWSO-89
OW31-89
OW47-89
OW 48-89
OW49-89
OW41-89
OW38-89
OW34-89
The proposed locations of the Phase I source control wells are illustrated on the
attached Figure 3. The five proposed extraction wells would be located in the areas
of highest groundwater contamination on Site. Proposed extraction wells EW-l and
EW-2 would be located on the north property boundary in the vicinity of OW37-89
and OW38-89. Proposed extraction well EW-3 would be located adjacent to OW41-89
and OW49-89 and proposed extraction well EW-4 would be located in the vicinity of
OW47-89 and OWSO-89. Proposed extraction well EW-S would be placed in the
vicinity of monitoring wells OW31-89, OW33-89, OW34-89 and OW48-89. The
placement of the proposed Phase I extraction wells in the area of the above-noted
monitoring wells would allow for the collection of sufficient hydraulic and
analytical data to assess the systems performance and to determine the design for the
off-Site contaminated groundwater containment wells.
In addition to the installation of the Phase Ion-Site source control wells/two
additional shallow bedrock monitoring wells would be installed off Site to
determine the northern extent of 1/2-DCE and TCE contamination in the shallow
bedrock aquifer. The proposed locations of the additional shallow bedrock.
monitoring wells are illustrated on the attached Figure 3.
Phase n - Off Site
Following operation of the on-Site source control system for a period of
approximately one year, sufficient data wjll have been collected to determine the
technical practicability of further groundwater extraction and treatment. If it is
determined to be technically practicable to continue groundwater extraction based
on aquifer productivity, the data collected would be utilized to finalize the design of
the Site-related contaminated groundwater containment system. The system
should be similar to that of Alternative 4b in the final FS report which presented a
system of nine extraction wells (three on-Site wells and six off-Site wells) to
-------
August 13, 1991
Reference No. 2319
- 5 -
hydraulically c~ntain the Site-related contaminated groundwater. However, given
the fact that the northern extent of the 1,2-DCE and TCE contaminants in
groundwater were not defined during the RI, and also the anticipated public concern
with the proposed locations in the FS report of the off-Site extraction wells, some of
the proposed off-Site extraction well locations could be moved to the north.
A possible layout of the estimated nine Phase II Site-related contaminated
groundwater containment extraction wells is presented on the attached Figure 4. .
The proposed extraction wells as shown are spaced at approximately ISO-foot centers
along the. Green River. This proposed well layout would provide hydraulic
containment of the Site-related contaminated groundwater based on the data
generated during the RI and evaluations conducted under the FS, and the modified
locations of some of the off-Site extraction wells may make them more acceptable to
local residents. However, the actual locations and number of the contaminated
groundwater containment wells may be altered as a result of data to be collected
during the operation of the Phase I system and the delineation of the extent of the
northern off-Site contaminated groundwater. .
Calculations presented in the FS indicated that estimated cleanup times for the
removal of Vex: contaminants from the aquifer for these alternatives would range
from 20 to 60 years. It is anticipated that the cleanup times for the 2b/4b remedial
alternative combination as presented herein will be in the order of 30 years for the
VOCs. However, as for all alternatives in the final FS report, the PCBs are not
expected to be remediated from the bedrock aquifers. Given that the operation of
the Phase I system will provide actual operational data, it was not considered
necessary to re-evaluate the proposed remedy using the batch-flushing calculations.
ESTIMATED CLEANUP COSTS
The present value cost to implement, operate, maintain and monitor the 2b/4b
remedial alternative combination is estimated to be $3,035,000, using the six percent
discount factor assumed in the FS report. As detailed in the attached table, the
present value estimated cost is comprised of $1,130,000 for implementation,
$1,000,000 for 30 years of operation and maintenance, and $905,000 for 30 years of
moni toring. .
-------
- - -- ~ - -~- - - - - - .
August 13, 1991
Reference No. 2319 .
- 6 -
SURFACE WATER TRIBUTARY
As stated in the final FS report, surface water and sediment samples were to be
collected from the surface water tributary north of the Site as part of the selected
remedy for the Site. As agreed to with USEP A, the surface water and sediment
samples were collected on June 27, 1991 at the three locations shown on Figure 5.5 of
the final FS report. The samples were collected with representatives of USEPA
present, in accordance with the procedures and protocols specified in the Project
. Operations Plan (POP) approved for the Site. All samples were submitted to the
project laboratory and analyzed for the Site-specific parameters in accordance with
the methods and protocols specified in the POP approved for the Site.
The analytical results for the surface water and sediment samples as reported by the
'project laboratory are as follows:
Sample
Location
Sample (see Figure Contaminant Concentration
Identification 5.5 of FS) Description PCBs TCE 1,2-DCE
CW-062791-JM-OOl upstream of
Hassell Street surface water NO(1.U ~g/L> ND (1.0 ~g/L> NOn.O ~g/L>
C5-062791-JM-DOl upstream of
Hassell Street sediment NO NOn.O ~g/L) NOn.O ~g/L>
C5-062791-JM-oD2 upstream of
Butler Street sediment 0.32 mg/kg NO(O.OO2 mg/kg). NO(O.OO2 mg/kg)
CW-062791-JM-003 downstream of
Butler Street surface water NOn.O ~g/L> NOn.O ~g/l) ND<1.0 ~g/L)
C5-062791-]M-D03 downstream of
Butler Street sediment 0.80 mg/kg ND
-------
1-
CONESTOGA.ROVERS & ASSOCIATES LIMITED
Consulting Engineers
August 13, 1991
Reference No. 2319
- 7-
impacts, no longer are required and will be deleted from the selected remedy for the
Site. Copies of the laboratory analytical reports are enclosed.
Should you have any questions, please do not hesitate to contact the undersigned.
Yours truly,
CONESTOGA-ROVERS & ASSOCIATES
~~
Jack Michels, P. Eng.
JM/ ec/24
Ene!.
c.c.:
Romer Wilsek
Gerald Thursby
Carol Wood
Rick Shepherd
Mike Mateyk
-------
~
LEGEND
---~IT BOUNDARY
150n
I
PROPOSED SHALJ.OW 8fDROQ(
MONITORING wnJ.. FOR SAWPUNC
AND H'YDRAUUC MONITORING
O~8I OW21-8I
-:': "
,~~~"" ,:
tmD.
1) FOR WOHITtRNG WE1J.S IGTALLED BY eRA.
1)£ LAST TWO DIGITS (85. .. .. 80) ,
DESIGNATED 'TME YEAR OF INSTAIJ.A 110N
(1- 1888. 1H1. 1180).
2) ASSUWED LOCA 110N OF PROPeRTY
BOUNDARY BASED ON A£RAL
PHQ1"OCJWIH. '
figure 1
ON-SITE SHALLOW BEDROCK MONITORING \\nLS
EXHIBlllNG HIGHEST LEVELS OF CONT AMINA 110N
MAU.ORY CAPAOTOR sa1£ RIfFS
HtlJn ~ TlII1nNS..
CRA
2311-1'/07 !I1-l-o
-------
/'(1" S THEE
/
2)
~
,) FOR MONITORING WELLS INSTALLm BY atA.
THE LAST 1\110 DIQTS (85, II. M. 90)
DESlGNATm THE YEAR CF INSTAlJ.Al1ON
(1985, 1911. 1981. 1910).
2) ASSUMED LOCA l10N CF PROPERTY
BOUNDARY BASED ON AERIAL
PHOTOGRAPH.
~
LEGEND
- - - PROPERTY BOUNDARY
OWl3-1O .
OYe7-101J
I~
o
I
150n
I
DEEP BEDROCK 1IIONIl'(]RN; WELL
DEEP£R IIEDROCk WONmRHG WElL
ON-SIT[ DEEP BEDROCK
WoNlTORING "ELL. EXHllIl1HG
HIGHEST L£YnS OF CONTAWlNAl1ON
mlBUTARY
.--...---.,
I
APPROXIMA T[ EX'T[NT OF
CONTAWINAl1QN IN DEEP
BEDROa< AQUIF(R
21/
//
:~./.
:~
OW2l-8I &.
, ~;,;
fig~re 2
ON-SITE DEEP BEDROCK MONITORING YtnLS
EXHIBlllNG HIGHEST LEVELS OF CONT AMINA 11 ON
MALLORY CAPACITOR Sl1E RI/FS
Ht7)tJ~ TMns""
CRA
2J11-11/07/I1-L-O
-------
~
LEGEND
l50n
I
EW1@
PROP£RT'r BOUNDARY
PROPOSED LOCA T10H FOR
ON-SiTE CONTAI
-------
-
I
~----
~
LEG9ID
---
1'"mJt"U111 BOUNDARY
PROPOSED LOCA'liON FOR
CONTAINMENT EX'TRACl1ON
'tII£l.L.
150ft
I
EW8@
-... - 'mIElUTARY
APPROXIMATE EXTENT OF'
CONTAWINAl1ON IN BEDROCK
AQUIF9S
HILL S rR£
EWl4
wm:i;.,
,) ASSUMED LOCA liON OF PROPERTY
BOUNDARY BASED ON AERIAL
PHOTOGRAPH.
CRA
2311-18/07/11-L-o
figure 4
PROPOSED PHASE ]I GROUNDWATER EX1RAC110N WELL LA YOUr
PRt.t tJ'CRED REMEDIAL AL TERN A l1VE
MALLORY CAPAaTOR SITE RIfFS
Ht7)t7"~ renn..-
-------
SUMMARY OF ESTIMATED COSTS Page 1 of 2
PREFERRED REMEDIAL AL TERNA TIVf:
MALLORY CAPACITOR SITE
W A YNESBORO,TENNESSEE
Amuud
Cost Presmt
Item Description Yellr 1 Yellr 2 Yellr 3 (yellrs 4 to 30) Worth (1)
ESTIMATED IMPLEMENTATION COST
1) DIREcr CAPITAL COSTS. Phase UYear 11; Phase IIIYear 3)
Mobiliza tion I Demobilization 5 30,000 40,000
Wells
- 2 Shallow extraction wells (O-Phase I; 2-Phase II) 0 10,000
- 12 Deep extraction wells (5-Phase I; 7-Phase II) 45,000 63,000
. Close existing wells 0 6,000
. Health and Safety 3,000 3,000
Pump Chambers
- Structura I 25,000 45,000
. Mechanical 25,000 45,000
. Electrical/Instrumentation 25,000 45,000
Services
- Piping (wells to treatment plant) 32,000 95,000
. Piping (treatment plant to discharge) 30,000 0
. Electrical/Instrumentation (wells to treatment plant) . 48,000 142,000
- Franchise, utilities to treatment plant 20,000 0
Treatment Facility
- Structural 20,000 0
- Master control/Instrumentation 25,000 7,000
- Equilization tank 10,000 0
. Air stripping tower 20,000 0
. Bag filter 2,500 0
. Carbon contactor unit 2,500 0
Plume Delineation
- 4 Monitoring well installations (4-Phase I; O-Phase IT> 16,000 0
Sub-total Direct Capital Costs S 379,000 0 501,000
2) CONTINGENCY COST
General- 15% of Direct Capital Cost 57,000 0 75,000 .
Sub.total Contingency Coeta S 57,000 0 75,000
3) INDlREcr CAPITAL COSTS
Administration and Legal (5'K. of Direct 19,000 0 25,000
Capital Costs)
Engineering Design (15% of Direct - 57,000 0 75,000
Capital Costs)
Construction Supervision 00% of Direct 38,000 0 50,000
Capital Costs)
Sub-total Indirect Capital Costs S 114,000 0 150,000
Total Estimated Implementation Costa S 550,000 0 726,000 $ 1,130,000
-------
SUMMARY OF ESTL\1A TID COSTS Page 2 of 2
PREFERRED REMEDIAL AL TIRNA TIVE
MALLORY CAPACITOR SITE
W A YNESBORO, TINNESSEE
AmIJI4Z1
Cost Present
rtem Description Year 1 Ye4Zr 2 Ye4Zr 3 (years 4 to 30) Worth (Z)
ESTIMATED OPERATION AND MAINTENANCE COSTS
Routine inspection and maintenance
- pe~onnell ( 1 full time) 25,000 25,000 25,000 25,000
- Capital Depreciation (2% per year of Direct 8,000 8,000 8,000 19,000
Capital Cost)
Groundwater extraction and treatment
- Power consumption and treatment consumables 7,000 7,000 7,000 19,000
- Discharge of treated effluent 5,000 5,000 5,000 15,000
- Disposal of treatment wastes 1,000 1,000 1,000 2,000
Total Estimated Operation and Maintenance Costs S 46,000 46,000 46,000 80,000 S 1,000,000
ESTIMATED MONITORING COSTS
Monthly sampling and analysis of 6,000 6,000 6,000 6,000
treatment plant discharge
Groundwatet monitoring program
- Monitoring wells, extTaction wells and surface water . 25,000 97,000 50,000 29,000
Data Management and Reporting 10,000 35,000 30,000 25,000
Total Estimated Monitoring Costs S 41,000 138,000 86,000 60,000 S 905,000
TOTAL ESTIMATED COST. REMEDIAL ALTERNATIVE 4b $ 637,000 184,000 858,000 S 3,035,000
Notes:
1. Present Worth Cost Estimate based on a discount rate of 6%.
-------
PREFERRED REMEDIAL AL TERNA TIVE
MALLORY CAPACITOR SITE
W A YNESBORO, TENNESSEE
1.0
DESCRIP-TION
The preferred remedial alternative for the Site (consisting
of a combination of remedial alternatives 2b and 4b described in the final FS
report) provides for hydraulic containment of Site-related contaminated
groundwater and on-Site contaminant mass removal utilizing extraction
wells, treatment of the extracted groundwater by air stripping, bag filtration
and carbon adsorption, and disposal of the treated effluent to the POTYV or
surface water a.djacent to the Site. The preferred remedial alternative would
be implemented in two phases as described in the following sections.
1.1
PHASE I
Phase I of the preferred remedial alternative can be
summarized as follows:
i)
implementation of a ban on the installation of groundwater extraction
wells;
ii)
installation of two additional.shallow bedrock monitoring wells north
of the Site (including sampling and analysis for the Site-specific .
parameters) at the approximate locations shown on Figure A, to
1
-------
1-
~
LEGEND
---
f'ROPERTY BOUNDARY
150ft
I
EW1 @ ~Slo:nC~~;:~~~OR
WASS EX'TRAC110N WElL.
tA' f'ROPOSED SHAl..L.OW
~ BEDROa< WONITORING WElL.
HILL S TREE
-...- TRIBUTARY
APPROXIWA T£ EXTENT OF
CONT AW'NA 110N IN BEDROO<
AQUIFERS
.
: J!fl; /
. .~' - ~:~;.
. ,<
'.
//
/;
(\
,
"
, ,
"
"
"
"
II
,10
.1'/'/
.--., .
--""'': .
tQD..
') ASSUWED LOCA 11 ON OF PROPERTY
BOUNDARY BASED ON AERIAL
PHOTOGRAPH.
CRA
flgure A
PROPOSED PHASE I GROUNDWAlER gw~Jb~~ ~~X~
. PR~Ir~ORY CAPAOTOR 511£ RI/FS
'"'J'7~ Tenn.....
2311-11/07/11-1.-0
-------
determine the northern off Site extent of Site-related contaminated
groundwater in the shallow bedrock aquifer;
iii)
contaminant mass removal from the on-Site contaminated aquifers by
the installation and operation of a total of five extraction wells (at the
approximate locations shown on Figure A) in areas of the on-Site
contaminated aquifers that exhibit the highest concentrations of the
Site-related contaminants;
iv)
construction of individual forcemains and controls from each
extraction well to a proposed on-Site treatment facility;
v)
treatment of the extracted groundwater by air stripping, bag filtration
and carbon adsorption, as schematically illustrated on Figure B;
vi)
discharge of treated groundwater to the POTW or surface water
adjacent to the Site;
vii)
implementation of an effectiveness monitoring program to monitor
the effectiveness of the remedial actions, as discussed in Section 2.0;
and
viii) assessment of the on-Site groundwater extraction system~ performance
for a period of approximately' one year, including determination of the
technical practicability of further groundwater extraction and
treatment.
2
-------
GROUNDWA TER
CRA
2319-19/07/91-L-0
VENT TO ATMOSPHERE
EOUILIZA TION
. TANK
INDIVIDUAL EXTRACTION PUMPS
CF-
AIR BLOwER
AIR
STRIPPING
TOWER
AIR STRIPPER OFF-GAS
DISCHARGE TO ATMOSPHERE
GRANULAR
ACTIVATED
CARBON
CONT ACTORS
1
EQUILIZA TION
TANK
DISCHARGE
TO POTW OR
SUHr ACE WA Ill<
figure B
SCHEMA TIC FLOW DIAGRAM
PREFERRED GROUNDWATER TREATMENT PROCESS
. MALLORY CAPACITOR SITE RI/FS
WOy7esboro, Tennessee
-------
1.2
PHASE IT
Phase II of the preferred remedial alternative can be
summarized as follows:
i)
ii)
iii)
iv)
finalization of the design of the hydraulic containment of Site-related
contaminated groundwater based on Site-specific data from the
one year's operation and performance of the five on-Site extraction
wells installed during Phase I;
installation of the hydraulic containment extraction wells
(provisionally located as shown on Figure C) and individual
forcemains and control from each extraction well to the groundwater
treatment facility installed during Phase I;
operation of the on- and off-Site extraction wells until the remedial
action objectives for the Site-related contaminated groundwater at and
in the vicinity of the Site are satisfied; and
continuation of the effectiveness monitoring program initiated during
Phase I, as discussed in Section 2.0
3
-------
~
150"
I
---
L£GfND
ERTY BOUNDARY
PROP
CATION FOR
PROPOSED L~ EXTRACTION
CONTAINWEN
I'I€U..
E'1WI@
ffilBUTARY
- ... - EX'T9IT OF
APPROXIWA ~ IN BEDROO<
CONTAWINA
AQUIFERS
tQJES;. ON OF PROPERTY
,) ASSUW~yL~ ON AERIAL
BOUND"",........
PHOTOGR.-rn.
figure C
'. WEU. LAYOUT
EX1RACl1~ ALlERNA ~
GROUN~:t~~ ~Ffb1t)R S}~
MALLOR HtI)t7estHro.
PROPOSED PHASE n
CRA
2311-18/07/81-l-o
-------
:.0
EFFECflVENESS MONITORING PROGRAM
2.1
GENERAL
The objective of the effectiveness monitoring program
during the first year of operation of the on-Site contaminant mass removal
extraction wells would be to provide data for:
i)
collection of sufficient hydraulic and analytical data to assess the
performance of the on-Site extraction wells; and
ii)
finalization of the design of the hydraulic containment extraction well
array, if it is determined to be technically practicable to do so.
The objective of the long term effectiveness monitoring
program wouk 'e to provide data for:
i)
demonstration of hydraulic containment and collection of significant
Site-related contaminated groundwater;
ii)
demonstration of the reduction of the concentrations .of Site-related
contaminants in on- and off-Site groundwater; and
iii)
demonstration of impact, if any, to surface waters of the Green River
and the tributary immediately north of the Site from discharge of
Site-related contaminated groundwater.
4
-------
The effectiveness monitoring program would consist of
hydraulic monitoring (groundwater levels beneath and in the vicinity of the
Site and surface water levels in the Green River), and groundwater and
surface water quality monitoring. The evaluation of the data collected during
the ground water monitoring period would determine whether the
groundwater extraction system performs to its design objective. The data also
would be used to determine when the operation of the groundwater
extraction system may be terminated and to identify the need, if any, for the
modification of the preferred remedial alternative.
2.2
EXTRACTED GROUNDWATER MONITORING
The extracted groundwater would be monitored to
determine flow rate and contaminant concentrations.
Flow rates from each extraction well would be monitored
and recorded on a monthly basis.
Extracted groundwater samples would be collected from
each extraction well on a monthly basis during the first year of operation of
Phase I and on an annual basis thereafter. Analysis would be for the
Site-specific parameters.
Samples of treated groundwater would be collected at the
. discharge point from the treatment system. Samples would be collected on a
5
-------
monthly basis during the operation of the treatment facility and all samples
would be analyzed for the Site-specific parameters.
2.3
MONITORING WELL NETWORK
Selected existing monitoring wells would be used to
monitor the performance of the groundwater extraction system. The
proposed monitoring well network for Phase I and Phase II is shown on
Figure 0 for the shallow bedrock aquifer and on Figure E for the deep bedrock
aquifer. The proposed shallow ~edrock monitoring network consists of 25
existing groundwater monitoring wells and two proposed groundwater
monitoring wells. The proposed monitoring well network for the deep
bedrock consists of 18 existing monitoring wells. Included in this number are
the two existing monitoring wells completed in the deeper bedrock.
Certain existing monitoring wells will not be included in
the monitoring network and will therefore be abandoned. A listing of the
monitoring wells proposed to be abandoned is provided in Table A, along
with the justification for abandonment. In all cases, the wells either exhibit
. .
very slow water level response and therefore unrepresentative water levels,
have an inappropriate well construction or are redundant with other wells.
The distribution of existing and proposed monitoring
wells would provide the required data to assess the effectiveness of the
groundwater extraction system, and to determine the groundwater quality in
the bedrock aquifers.
6
-------
~
LEGEND
- - - ~I" BaJNOARY
150ft
J
@
~ SHAlLOW WOHITORING
\oElJ. FOR SAIo6PUNG AND
H~AWC IoIONITORING
OW"3-89 SHALLOW IoIONITORING ~
@ F"~ H'l'DRAUUC 1oI000TORING
~...-
SHALLOW t.lONITORING 't\€l.L
F~ SAWPUNG AND
H'tURAUUC IoIONITORING
TRIBUTARY
OWSS-90
.
10" S r"cc
APPROXlWA'TE EX"TtNT OF' PCBs.
1,2-DC[ AND lOR TCE IN
SHALLOW BEDRQQ< AQUIftR
~
tI.Q1E:s..
1> FOR MOHITCRINQ 'IWlL.S INSTAUm BY etA.
'THE LAST 'rNO DlGI'TS (85. 88. at. 80)
DESGNA1m THE YEAR aF INSTAU.Al1CIN
(1i85. 19" 1911. 1110),
2) ASSUMED LDCAl10H aF PROP£RTY
BOUNDARY BASED ON AERIAL
PHOTOGRAPH.
figure D
PROPOSED MONITORING WEll. N~J
SHALLOW BEDROCK AQUI
PRtrt.teRED REMEDIAL AL TERN A l1/FSVE
MALLORY CAPACITOR SITE RI
HtI)f'7M1D1'O, r.,n--..
CRA
2319-19/01/91-L-O
-------
ifiLL S TRee T
/
2)
"
",
.,...'
~
1) FOR MONITORING WElJ.S INSTAU.ED BY CRA.
THE lAST TWO DIGl15 (85, 88. 89. 90)
DESIGNA 1m THE YEAR (:F INSTALJ..A l10N
(1985, 1988. 1981. 19iO).
2) ASSUWED LOCAl1ON (:F PROPERTY
BOUNDARY BASED ON AERIAL
PHOTOGRAPH.
CRA
2319-19/07/91-l-0
~
; EGEND
- - - ?ROPERTY BOUNDARY
o
I
150n
j
Owe3-9Q &.
DEEP MONI~ING ....nL
FOR H't1)RAUUC MONITORING
DEEP MONITORING WEU.
FOR SAMPUNG AND HYORAUUC
t.lONITORING
0W26-S9.
0W57-9O~
DEEPER BEDROO< IoCONITORING 'Ifnl.
FOR SAMPUNG AND H'rt)RAUUC
t.lONITORING
---'... ~
TRIBUTARY
APfIROXlWA TE EXTtNT OF PCBs.
1.2-DCE AND/OR TCE IN DEEP
BEDROO<. AQUIFER
I
"
~, Oweo-90 .
, ,
"
"
"
"
II
"
I
--.... /,
- -.....-:,
);,'
/,
0W28-S9 ~ ,W; .
..,
figure E
PROPOSED M~~I~
-------
TABLE A
PROPOSED MONITORING WELLS TO BE ABANDONED
MALLORY CAPAOTOR SITE RllFS
WAYNESBORO, TENNESSEE
Aquifer Monitoring
Limit Well No. Reason
Shallow Bedrock OW53-90 . Access Problems
. WM is upgradient and not impacted
OW7-85 . Well Construction
OW4-85 . Replaced by OW3S-89
MW-23 . Well Construction
E2-A . Well Construction
OW51-89 . Poor Water level Response
Deep Bedrock E2oC . Well Construction
. Redundant
OW2Q-86 . Poor Water level Response
OW22-86 . Poor Water level Response
OW54-90 . Upgradient
. Property Access
-------
SURFACE WATER MONITORING LOCATIONS
2.4
Surface water samples would be collected from three
locations in the Green River and three locations in the unnamed creek to the
north of the Site, as shown on Figure F.
The distribution of surface water sampling locations as
proposed would provide the required surface water quality data to assess
impact, if any, to surface water quality in both the Green River and. the surface
water tributary north of the Site.
2.5
HYDRAULIC MONITORING
All extraction wells and monitoring wells designated for
hydraulic monitoring on Figures D and E would be used in the hydraulic
monitoring program. In addition, water levels in the Green River would be
measured at the location directly opposite the north-east .comer of the Site.
Groundwater elevations would be measured at the follqwing frequency:
i)
monthly for the the first year of operation of each phase of the
proposed remedial action; and-
ii)
annually thereafter.
7
-------
1-
~
LEGfND
- - - pRQPUi; T'r BOUNDARY
8
SURFACE WATER SAMPLE
LOCAT1ON
TRIBUTARY
...~
APPROXIWA TC: ~T Of' PCBS.
1,2-0CE ANO/OR TCE IN SHALLOW
BEDROO< AQUI~
1<,," S rllEE
J¥;/ :
.,
"
:t
~
1) ASSUWm LOCA T10N OF PROPERTY
BOUNDARY BASED ON AERIAL
PHOTOGRAPH.
CRA
flgure F
PROPOSED SURFACE WA1ER MONITORING LOCAllONS
PRt.r~RED REMEDIAL AL TERN A l1/FSVE
MAlLORY CAPAQTOR 511£ RI
Ht7)t7~ r.,n....-
2319-19/07/91-L-O
-------
After any significant adjustments to the groundwater
extraction system, the frequency of water level monitoring would be
increased to monthly for a period of three months.
2.6
GROUNDWATER QUALITY MONITORING
The monitoring wells designated for sampling on
Figures D and E would be utilized in the groundwater quality monitoring
program.
The initial round of groundwater samples would be
collected immediately after the commencement of the extraction system, and
annually thereafter. Groundwater samples would be analyzed for the
Site-specific parameters.
2.7
SURFACE WATER QUALITY MONITORING
The surface water monitoring locations shown on
Figure F would be utilized in the surface water quality monitoring program.
The initial round
-------
3.0
v)
SCHEDULE OF ACfIVITIES
The preferred remedial alternative (hydraulic
containment of Site-related contaminated groundwater and on-Site
contaminant mass removal utilizing extraction wells, treatment of the
extracted groundwater by air stripping, bag filtration and carbon adsorption,
and disposal of the treated effluent to the POTW or surface water adjacent to
the Site) would be implemented within the time frames as follows:
i)
delineation of the extent of VOC contamination in the shallow bedrock
aquifer north of the Site (installation of two additional monitoring
wells, two rounds of sampling and analysis, and reporting) -
six months following securement of off-Site access agreements;
ii)
detailed design of the Phase I remedial components - five months
following agreement to proceed with the design;
iii)
implementation of the Phase I remedial components - five months
following approval of the detailed design;
iv)
compilation and analysis of Phase I operation and performance -
lS months following startup of the Phase I remedial components;
detailed design of the Phase II remedial components - two months
. following agreement to proceed with the design;
9
-------
vi}
vii}
implementation of the Phase II remedial components - three months
following approval of the detailed design and securement of off-Site
access agreements; and
effectiveness monitoring program - from start up of groundwater
remedial components until groundwater remedial goals and objectives
are achieved.
10
-------
"';: .. -
'I 1
f .
j
I
-
--~_.
..-.;11-,... ~
..'~':"<.
<~:~I
--
WADSWORTHI - _-:::-
L.ABORATORIES. INC.
3.:-::./"'C; :~s: iq. .,.,o::ae aos
~~01 Shuffel Dr. N.W
i'Jcnn Canlon. OhiO J.J. 720
ANALYTICAL REPORT
PROJECT NO. 2319
WAYNESBORO
Presented to :
GRAHAM CHEVREAU
CONESTOGA-ROVERS &: ASSOCIATES, LTD.
WADSWORTH/ALERT LABORATORIES, IRC.
/L~.L
r Tho.as M. Rifts .
Project Manager
"j/yj 0 / / .'~ ~...,--,
" .' / ~ ~'. ..;J...1":.i:1.'~~
Marvin W. Stephens, J.D.. .
Vice President&: Corporate Technical Director
Jub' 26, 1991
CORPORATE AND LABORATORY: Nortn Canton. Onio (216) 497-9396
LABORATORY: Cleveland. Onio (216) 642-9151
LABORATORY: Pitt!Durgn. PennsylvanIa (412) 826-5477
LABORATORY: Tampa. Florida (813) 621-0784
24-HOUA ALE.C1T LiNE (216) 497-9338
-------
j t
1.1
'N ADSWORTH: ALERT
LABORATORIES. INC.
::ARR.n! I;E
The following report contains the analytical results tor three water
samples. three solid samples and one quality control sampl~
submi tted to wadsworth/ALERT Laborator ies, [nc. by Conestoga Rovers
& Associates, LTD. from the waynesboro Site, project number 2319.
The samples were received on June 28, 1991, accordIng to documented
sample acceptance procedures.
'.;adslo'orth/.-\LE?T Laboratories, ~nc. utllizes only lSEP.-\ approved
methods and instrumentation in all analytIcal work. The sa.mples
presented in this report Io'ere analyzed for the parameters 11sted 1n
the following table in accordance with the methods indicated.
\".erbals ;,,;ere prov ided to Graham Chevreau at Conestoga Rovers and
Associates, LTD. on July 19, 1991. Chromatograms for selected
samples and a summary at QC data for these analyses is included at
the rear of the report.
A~ALYTrCAL ~ETHODS
Parameters
'iethods
Volatile OrganIc Compounds
Polychlorinated Biphenyls
5\0;846 8010
5\0;846 8080
Reference:
SW8~6.
"Test methods for Evaluating Solid Waste Phrsical/Chem1cal
~1ethods," Third Edition, September, 1986.
-------
II
.V AOSWORTH.' ALERT
LABORATORIES. iNC.
ANALYTICAL RESULTS
The analytical results of the samples listed below are presented
on the folLowing pages.
LABORATORY
:-H!~IBER
6695-560H
6695-56045
6695-56046
6695-56047
6695-56048
6695-56049
6695-56050
S~~PLE IDEST!FICATION
CW-062j91-JM-001 CREEK-001
CS-062i91-J~-OOl CREEK-001
CW-062791-J~-002 CREEK-002
CS-062791-JM-002 CREEK-002
CW-062791-JM-003 CREEK-003
CS-062791-JM-003 CREEK-003
TRIP BLANK 6-25-91
6-27-91 11:30
6-27-91 11:30
6-27-91 11:50
6-27-91 11:50
6-27-91 12:10
6-27-91 12: 10
-------
I
'NADSWORTHI ALEMT
LABORATORIES. iNC.
COMPANY: CONESTOGA-ROVERS & ASSOCIATES, LTD.
LAB t: 6695-560~4
!4ATRIX: wATER
DATE RECEIVED:
DATE EXTRACTED:
DATE ANALYZED:
SAMPLE ID: CW-062i91-JM-OOI CRE~K-OOI
5-2i-91 11:30
SELECTED ORGANIC COMPOUNDS ANALYTICAL REPORT
6/28/? :
'JA
i/1~/91
PARAMETER
RESULT (ug/l )
1,2-Dichlo~oethene, Total
Trichloroethene
~D
SO
NOTE:
(None Detected) as rec'd
(Detected, but below' quanti tat ion limit; estimated value)
ND
J
SURROGATE RECOVERY:
ACCEPTABLE LIMITS
WATER SOLID
%
Tri fluorotoluene
1,4-Dichlorobutane
118
84
(75-125)
(75-125)
(75-125)
(75-125)
DETECTION
LIMIT
-------
.
.'JAOSWORTH' ALE:;!
~';BORATORIES. iNC.
COMPANY: CONESTOGA-ROVERS & ASSOCIATSS, LTD.
LAB I: 6695-56044
MATRIX: WATER
DATE RECEIVED:
DATB EXTRACTED:
DATE ANALYZED:
SAMPLE ID: CW-062i91-J~-001 CREEK-OOI
6-2i-91 11:30
SEU:CI'm ORGANIC COMFOUNDS AHALY'l'ICAL REPORT
6/28/91
5/29/9L
i/ 5/91
PARAMETER
RESUL~ (ug/l )
Total Polychlorinated Biphenyls
~D
NOTE:
(None Detected) as re~'d
(Detected, but below Quantitation limit; estimated value)
~D
J
SURROGATE RECOVERY:
ACCEPTABLE LIMITS
WATER SOLID
%
Tetrachloro(m)xylene
104
(60-150) (60-150)
DETECTION
LIMIT
-------
~
N AOSWORTH . ALEMI
LABORATORIES. iNC.
COMPANY: CONESTOGA-ROVERS & ASSOCIATES. ~TD.
LAB t: 6695-56045
MATRIX: SOLID
DATE RECEIVED:
DATE EXTRACTED:
DATE ANALYZED:
SAMPLE ID: CS-062j9l-J~-OOl CREEK-OOl
6-27-91 1::30
SELECTED ORGANIC COMPOUNDS ANALrI'ICAL REPORT
'31281'3~
;/11/91
;111n1
PARAMETER
RESULT (ug!kg)
1.2-Dichloroeth~ne, Total
Trichloroethene
SO
NO
NOTE:
(None Detected) as rec'd
(Detected. but below quantitation limit: estimated value)
ND
J
SURROGATE RECOVERY:
ACCEPTABLE LIMITS
WATER SOLI D
%
Trifluorotoluene
Bromochloromethane
91
109
(75-125)
(75-125)
(75-125)
(75-125)
DETECTION
LIMIT
2
.,
-------
I
,VAOSWORTH' ALc~T
LABORATORIES. INC.
COMPANY: CONESTOGA-ROVERS & ASSOCIATES. LTD.
LAB #: 6695-56045
MATRIX: SOLID
DATE RECEIVED:
DATE EXTRACTED:
DATE ANALYZED:
SAMPLE ID: CS-062i9l-JM-OOI CREEK-OOI 6-2i-91 11:30
SELECTED ORGANIC COMPOUNDS ANALY'l'ICAL REPORT
6/28/91
6/29/91
i/23/91
PARAMETER
RESULT (-g!kg)
Total Polychlorinated Biphenyls
~D
NOTE:
(None Detected) as rec'd
(Detected, but below ~uantitation limit; estimated value)
ND
J
SURROGATE RECOVERY:
ACCEPl'ABLE LIMITS
WATER SOLID
%
Tetrachloro(m)xylene
66
(60-150) (60-150)
DE'l'ECTION
LIMIT
0.16
-------
j
,VAOSWORT1-i' ALE::;,
G;SORATORIES. :,\JC.
COMPANY: CONESTOGA-ROVERS & ASSOCIATES, ~TD:
LAB I: 6695-56046
MATRIX: WATER
DATE RECEIVED:
DATE EXTRACTED:
DATE ANALYZED:
SAMPLE ID: CW-062i91-J~-002 CRE~K-002
5-27-91 11:50
SELECTED ORGANIC COMPOUNDS ANALYTICAL REPORT
~/28n'.
~A
7/~~/3:
PARAMETER
RESULT (ug/l )
l,2-Dichlor~et~ene, Total
Trichloroethene
~o
~O
NOTE:
(None Detected) as rec'd
(Detected, but below quanti tat ion limit; estimated value)
NO
J
SURROGATE RECOVERY:
ACCEPTABLE LIMITS
WATER SOLID
%
Trifluorotoluene
1,4-Dichlorobutane
(75-125)
( 75-125.)
117
83
(75-125)
(75-125)
DETECTION
LIMIT
-------
J
.
.'J ACS'NORTH . ALE:=1T
~~60RATORIES. ;,\JC.
COMPANY: CONESTOGA-RovERS & ASSOCIATES. LTD.
~ I: 6695-56046
1ItATRIX: WATER
DATE RECEIVED:
DATE EXTRACTED:
DATE ANALYZED:
SAMPLE 10: CW-062791-J~-002 CREE~-002
3-27-91 11:50
SELECTED ORGANIC COMPOUNDS ANALY'l'ICAL REPORT
.,/28/3:
3/20/9 ~
;/10/91
PARAMETER
RESULT (ug/l )
Total Polychlorinated Biphenyls
so
NOTE:
(None Detected) as rec'd
(Detected, but below quantitation limit; estimated value)
~D
J
SURROGATE RECOVERY:
ACCEPTABLE LIMITS
WATER SOLID
%
Tetrachloro(m}xylene
71
(50-1 50} (50-150)
DETECTION
LIMIT
1
-------
J
,v AOSWORTi-i . ALE::.!
i...A80RATORIES. :0JC.
COMPANY: CONESTOGA-~OVERS & ASSOCIATES. L;D.
LAB ,: 6695-56047
Il(ATRIX: SOLID
SAMPLE ID: CS-062791-J~I-002 CREEK-002
DATE RECEIVED:
DATE EXTRAcrED:
DATE ANALYZED:
0-27-31 11:50
SELEC'I'ED ORGANIC COMPOUNDS ANALYTICAL REPORT
5/2g/~~
7/ll/S1
i/ll/31
PARAMETER
i,2-Dichloroethene, Total
Trichloroethene
RESULT. (ug/kg)
SO
~D
NOTE:
ND
J
(None Detected) as rec'd
(Detected, but below quanti tat ion limit; estimated value)
SURROGATE RECOVERY:
Trifluorotoluene
Bromochloromethane
ACCEPl'ABLE LIMITS
WATER SOLID
(75-125)
(75-125)
%
(75-125)
(75-125)
86
93
DETECTION
LIMIT
.,
2
-------
I
.v AOSWORTH ' ,~Lc;:;!
LABORATORIES. :NC.
COMPANY: CONESTOGA-ROVERS & ASSOCIATES, LTD.
LAB I: 6695-5604;
MATRIX: SOLID
DATE RECEIVED:
DATE EXTRACTED:
DATE ANALYZED:
SAMPLE ID: CS-062i91-J~'-002 CREEK-002
6-2i-91 11:50
SELECTED ORGANIC COMPOUNDS ANALYTICAL REPORT
0/29/91
6/29/91
i/23/91
PARAMETER
RESULT (8g!kg)
0.32
Total Polychlorinated Biphenyls
NOTE:
(None Detected) as rec'd
(Detected, but below quantitation limit; estimated value)
ND
J
SURROGATE RECOVERY:
ACCEPTABLE LIMITS
WATER SOLID
%
Tetrachloro(m)xylene
(60-150) (60-150)
67
DETECTION
LIMIT
O. 16
-------
J
.VADSWORTH' ALc;;i
LABORATORIES. ;NC.
COMPANY: CONESTOGA-ROVERS & ASSOCIATES, LTD.
LAB I: 6695-56048
fltATRIX: WATER
SAMPLE ID: C~-062791-J~-003 CREEK-003
DATE RECEIVED:
DATE EXTRACTED:
DATE ANALYZED:
rj-2;-91 lZ: lO
SELECTED ORGANIC COMPOUNDS ANALYTICAL REPORT
-3/23/: :
" ,
....
- ,_. .t"'\.
I ~ . I ~ .
PARAMETER
1,2-Dichloroethene, Total
Trichloroethene
RESULT (ug/l )
ND
SO
NOTE:
~D '
J
(None Detected) as rec'd
(Detected, but below quantitation limit; estimated value)
SURROGATE RECOVERY:
Tri f 1uot'otoluene
1,~-Dichlot'obutane
ACCEPTABLE LIMITS
WATER SOLID
(75-125)
(75-125)
%
(75-125)
(75-125)
117
81
DETECTION
LI~IT
-------
II
,'/ADSWORTH' ALE::;i
~:"80RATCRIES. .~~C.
COMPANY: CONESTOGA-ROVERS & ASSOCIATES. LTD.
lAB I: 6695-56048
MATRIX: wATER
DATE RECEIVED:
DATE EXTRACTED:
DATE ANALYZED:
SAMPLE ID; CW-062791-J~-003 CREEK-003
6-2i-91 12: 10
SELECTED ORGANIC COMPOUNDS ANALY'l'ICAL REPORT
0/28/91
5/29/91
i/10/9i
PARAMETER
RESULT (ugjl )
Total Polychlorinated Biphenyls
~m
NOTE:
(None Detected) as rec'd
(Detected, but below quantitation limit; estimated value)
~D
J
SURROGATE RECOVERY:
ACCEPTABLE LIMITS
WATER SOLID
%
Tetrachloro(m)xylene
i5
(60-150) (60-150)
DETECTION
LIMIT
-------
! I
.11
'N ADSWORTH! ALE~T
LABORATORIES. iNC.
COMPANY: CONESTOGA-ROVERS & ASSOCIATES. lTD.
LAB ,: 6695-56049
MATRIX: SOLID
DATE RECEIVED:
DATE EXTRACTED:
DATE ANALYZED:
SAMPLE ID: CS-062i91-JM-003 CREEK-003
6-27-9112:10
SELECTED ORGANIC COMPOUNDS ANALY'I'ICAL REPORT
5/23/91
7111/'?~
7:'i~/9~
PARAMETER
RESULT. (ug/kg)
1,2-Dichloroethene, Total
T:-ichloroethene
~b
~D
NOTE:
(None Detected) as rec'd
(Detected, but below quantitation limit; estimated value)
ND
J
SURROGATE RECOVERY:
ACCEPrABLE LIMITS
WATER SOLID
%
Trifluorotoluene
Bromochloromethane
(75-125)
(75-125)
96
86
(75-125)
(i5-125)
DETECTION
LIMIT
')
....
-------
I
. V AOSWORTH.' ALc;:;'
LABORATORIES. INC.
COMPANY: CONESTOGA-ROVERS & ASSOClATES, LTD.
LAB ,: 6695-56049
!otATRIX: SOLID
DATE RECEIVED:
DATE EXTRACTED:
DATE ANALYZED:
SAMPLE ID: CS-062791-J~I-003 CREEK-003 6-27-91 12: 10
SELECTED ORGANIC COMPOUNDS ANALYTICAL REPORT
5/23n 1
5/29/91
ij23/9i
PARAMETER
RESULT (.gjkg)
0.8
Total Polychlorinated BiphenYLs
NOTE:
(None Detected) as r~c'd
(Detected, but below quantitation limit; estimated value)
ND
J
SURROGATE RECOVERY:
ACCEPTABLE LIMITS
WATER SOLID
%
Tetrachloro(m)xylene
76
(60-150) (60-150)
DETECTION
LIMIT
0.4
-------
I
.VAOSWORTH' ALE~T
LABORATORIES. iNC.
COMPANY: CONESTOGA-ROVERS & ASSOCIATES, LTD.
LAB t: 6695-56050
MATRIX: WATER
DATE RECEIVED:
DATE EXTRACTED:
DATE ANALYZED:
SAMPLE IQ: TRIP SLANK
6-25-91
SELECTED ORGANIC COMPOUNDS ANALYTICAL REPORT
6/23/91
~~
;/17/91
PARAMETER
RESULT (ug/l )
1,2-Dichloroethene. Total
TLichloroethene
~D
~D
NOTE:
(None Detected) as rec'd
(Detected. but below quantitation limit; estimated value)
ND
J
SURROGATE RECOVERY:
ACCEPTABLE LIMITS
WATER SOLID
%
Trifluorotoluene
Bromochloromethane
(;5-125)
(75-125)
101
113
(i5-125)
(75-125)
DETECTION
LIMIT
,
..
-------
I
',v ADSWORTH . ALcHI
W;SORATORIES. ;NC.
COMPANY: CONESTOGA-ROVERS & ASSOCIATES, LTD.
LAB I: 6695-56050
MATRIX: WATER
DATE RECEIVED:
DATE EXTRACTED:
DATE ANALYZED:
SAMPLE ID: TRIP BLANK
6-25-91
SELECTED ORGANIC COMPOUNDS ANALYTICAL REPORT
6/28/9t
6/29/91
7/10/91
PARAMETER
RESULT (ugjl )
Total Polychlorinated Biphenyls
so
NOTE:
(None Detected) as rec'd
(Detected, but below quantitation limit; estimated value)
~D
J
SURROGATE RECOVERY:
ACCEPTABLE LIMITS
WATER SOLID
%
Tetrachloro(m)xylene
(60-150) (60-150)
83
DETECTION
LIMIT
1
-------
I
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-------
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POOR QUALITY
ORIGINAL
1'.1"
-------
~
',VADSWORTH, ALeRT
L-\BORATORIES. iNC.
~tj.u.::-: C::NnOL 5ZC::::N
-------
I
'NADSWORTH: ALERT
LABORATORIES. !NC.
j u 1 :.' :: s. : 99 1
QCALITY COSTROL ~ARRATIVE
The results included in this report have been reviewed for c~mpliance ~ith the
laboratory QA/QC plan. All data have been found to be compliant I."lth the
exception of those items noted.
The client requested the analysis of Volatile Organic Compounds (VOCs) ~hich have
a recommended holding time of 1~ days from sampling to analysis. By the time
sample 56050 I."as analyzed, the holding time was expired.
The following samples Ioiere analyzed within the continuing calibration established
on July 10; therefore, the July 10 method blank provided in the Quality Controi
Section is associated I."ith these samples.
Laborator\' r.D.
560H
560~6
560~8
Samples 56045, 56047, and 56049 were originally extracted for Polychlorinated
Biphenyls wi thin the recommended holding time of H days from sampling to
extraction. The original samples were extracted for medium level analys is;
however, a low level analysis was required. Therefore, the samples were re-
analyzed to achieve the lower detection limits.
The samples submitted for organic analysis were not chilled when received, but
were refrigerated upon receipt. Correct sample preservation requires that the
samples be chilled to ~oC.
-------
I
'N ADSWORTH ! ALE;:;,
LABORATORIES. iNC.
:i-:EC:\
SA~IPL£ DA T,~ '
.;C
'A~AtYSIS E=ERCDT CO~;BC~
[..-1.3 fD DATE ?l.R,;:IE:E~ ~ECOVERY \IATRf X i..I:IITS
30i10 i/10/91 Benzene 89 wATER ( 63-120)
Chlorobenzene 82 51-1Z:}
1,2-Dichloroethene 82 ' 5i-11I)
\
Toluene 8i ( 6.'5-122;
Trichloroethene 83 ( 6i-1211
90 i 11 i/11/91 Benzene 109 ioi,UER ( 68-l2'J)
Chlorobenzene 108 ( 6i-l:21)
1,2-Dichloroethene i6 ' 51-:::'")
\
Toluene 110 ' "'... . ')n \
\ 0,)-1__1
Trichlor-oethene 102 ( 6:-1Z1)
90i1i i/1i/91 Benzene 11i Io'ATER ( 68-1201
Chlorobenzene 106 ' 67-(21)
\
1,2-Dichloroethene 108 ( 5i-11i)
Toluene 103 ( 55-122)
Trichloroethene 121 ( 6i-121.)
-------
i j II~
~
WADSWORTH I ALEMT
LABORATORIES. iNC.
CHECK SA~PLE DATA
',~
~'-
A:iALYSIS PERCC:~T COSBCL
LAB ID D.HE PAR.-\.'IETER RECOHRY ~A TR IX LI ~II 7S
90629 i/ 3/91 Polychlorinated Biphenyls 110 \oiATC:R ( i8-~5~:
92629 i/ 3/91 Polychlorinated Biphenyls 104 SOLID ( 59-1';0;
90630 i/ 3/91 Polychlorinated Biphenyls 85 wATER ( i8-152)
92i23 ;/2-1/91 Polychlorinated Biphenyls 100 SOLID ( 59-HC)
-------
~
~
I
'f V ADSWORTH! ALERT
LABORATORIES. iNC.
COMPANY: Wadsworth/ALERT Laborat~ries
LAB #: 9091-90ilO
r-tATRIX: ",'.HER
SAMPLE ID: I~TRA-LAB BLA~K , 7 /lO/Sl
DATE RECEIVED:
DATE EXTRACTED:
DATE ANALYZED:
SELECTED ORGANIC COMPOUNDS ANALYTICAL BLANK REPORT
7/~J:91
:.A
7 nO/?l
PARAMETER
1,2-Dichloroethene, T0tal
Tr-ichloroethene
NOTE:
~D
(~one Detected)
St:RROGATES:
Trifluorotoluene
l,~-Oichlorobutane
RESULT (ug/ 1 )
\0
\0
ACCEPTABLE LI~!TS
WATER SOLID
(i5-125 )
(i5-125)
..,
-;,
(i5-125)
(i5-125)
i,j
98
DETECTION
LIMIT
-
-------
II
IV ADSWORTH.' ALEnT
LABORATORIES. iNC.
COMPANY: ~adsworth/ALERT Laboratorles
LAB t: 9091-90i11
MATRIX: WATER
DATE RECEIVED:
DATE EXTRACTED:
DATE ANALYZED:
SAMPLE ID: l~TRA-lAB BLA~K , ; /11/91
SELECTED ORGANIC COMPOUNDS ANALYTICAL BLANK REPORT
7/11/9l
SA
;111/31
PARAMETER
RESULT (ug/l )
1.2-Dichloroethene, Total
Trichloroethene
so
:-;0
NOTE: ND (None Detected)
SURROGATES: ACCEPTABLE LI:-tITS
WATER SOLID %
Bromochloro~ethane (;5-125) (;5-125) 106
Trifluorotoluene (;5-125) (;5-125) 99
DETECTION
LIMIT
-------
III
WADSWORTH I ALE;:;!
LABORATORIES. :NC.
COMPANY: wadsworth/ALERT
LAB #: 9291-92711
MATRIX: SOLID
Laborator les
DATE RECEIVED:
DATE EXTRACTED:
DATE ANALYZED:
SAMPLE ID: r~TRA-LAB BLA~K . ; 111/91
SELECTED ORGANIC COMPOUNDS ANALY'l'ICAL BLANK REPORT
7/11/9i
i/1i/91
7/1l/91
PARAMETER
RESULT (ug/kg)
1.2-Dichloroethene,Total
Trichloroethene
~D
~D
NOTE: ~D (~one Detected)
SljRROGATES: ACCEPTABLE LDIITS
WATER SOLI D %
Bromochloromethane (75-125) (75-125) 106
Trifluorotoluene (;5-125) (75-125) 99
DETECTION
. LIMIT
.2
"
-------
~11I WADSWORTH/ALERT
LABORATORIES. iNC.
III COMPANY: -adsworthlALERT lahoratorie.
~ LAB ,: 9091-90i1i
MATRIX: WATER
DATE RECEIVED:
DATE EXTRACTED:
DATE ANALYZED:
SAMPLE ID: I~TRA-lAB BlA~K . i /1i/91
SELECTED OaGANIC COMPOUNDS ANALYTICAL BLANK REPORT
- 11 - .... ~
I I 1. I " ~ ..
SA
7/17/91
PARAMETER
aESULT (u"g/l )
1,2-Dichloroethene, Total
l:"ichloroethene
~D
SD
NOTE: ~D (~one Detected)
SuRROGATES: ACCEPTABLE LIMITS
WATER SOLID %
Bromochloromethane (;5-1251 (;5-1251 112
Trifluorotoluene (;5-125) (;5-125) 101
DETECTION
LIMIT
1
1
-------
.
OJ
'NAOSWORTH, ALERT
LA.BORATORIES. iNC.
COMPANY : ~adsworth/Alert Laboratories
LAB #: 9091-90629
MATRIX: "'ATER
SAMPLE ID: :,;';TRA-lAB aLANK , 06/29/91
POLYCHLORINATED BIPHENYLS
ANALY'l'ICAL BLANK REPORT
DATE RECEIVED:
DATE EXTRACTED:
DATE ANALYZED:
-'?I1'O'
,")/_~/~~
5iZ9/91
7/ 3/91
PCB-10l5 ~D
PCB-1221 ~D
?CB-IZ32 ~D
?CB-12-l2 ~O
?CB-lZ-l8 ;-;0
PCB-125-l ;-;0*
PCB-1260 ~D*
PCB-1262
NOTE:
~D
~D*
(~one Detected, lower detectable limit = 0.5
(Sone Detected, lower detectable limit = 1
(~ot Analyzed)
u~!l) as rec I d
u~/ 1) as rec I d
SURROGATE RECOVERY:
Tetrachlorolm)xylene
%
iO
ACCEPTABLE LIMITS
WATER SOLID
160-150) 160-1S0}
-------
~J WADSWORTH!ALEriT
LABORATORIES. INC.
. II I COMPANY: .ads-orth/Alert Lahoratories
LAB I: 9091-90630 '
MATRIX: WATER
SAMPLE ID: ~STRA-lAB BLANK, J6/30/91
POLYCHLORINATED BIPHENYLS
ANALY'l'ICAL BLANK REPORT'
DATE RECEIVED:
DATE EXTRACTED:
DATE ANALYZED:
;)/30/9:
5/,30/9 (
71 :3/9:
PCB-1016 ~D
PCB-122l :-iD
?CB-1232 SD
PCB-1242 ~D
?CB-1248 SO
PCB-125~ SD*
PCB-1260 ~D*
PCB-1262
NOTE:
(~one Detected, lower detectable limit = 0.5
(None Detected, lower detectable limit = 1
(~ot Analyzed)
~D
SD*
SURROGATE RECOVERY:
%
Tetrachloro{m)xylene
~?
1-
ugj 11. as rec' d
ugj 1) as rec I d
ACCEPTABLE LIMITS
wATER SOLID
(60-150) (50-ISO)
-------
.
I' ','/ADSWORTHrALERT
LABORATORIES. iNC.
II II II COMPANY.: 'adswo.th/Alert laboratories
LAB #: 9291-92629
MATRIX: SOLID
SAMPLE ID: I~TRA-LAB BLA~K , 06/29/91
POLYCHLORINATED BIPHENYLS
ANAL IT! CAL BLANK REPORT
DATE RECEIVED:
DATE EXTRACTED:
DATE ANALYZED:
5/29/91
6/29/91
i/ 3/91
PCB-1016 ~O
PCB-1221 NO
PCB-1232 ~D
?CB-12-l2 ~D
?CB-12-l8 ~O
PCB-125-l ~D
PCB-1260 ~O
PCB-1262
NOTE:
(None Detected, lower detectable limit = 160
(None Detected, lower detectable limit =
(~ot Analyzed)
~D
~O*
SURROGATE RECOVERY:
%
Tetrachloro(m)xylene
120
ug/kg) as rec'd
ug/kg) as rec' d
ACCEPTABLE LIMITS
loiATER SOLID
(60-150) (60-150)
-------
J
WADSWORTH! ALERT
LABORATORIES. iNC.
LA.B ID
560-l6
560-l7
~ATRIX SPIK~ DATA
A~ALYSIS
DATE
PARA.'1ETER
SPI~E SPK/DCP
PERCE~T PERCE~T SPIK~
RECOVERY ~ECOVERY ~ATRIX
GC VOL~TI LE CO~POCNDS
7/15/91 1.1-Dichloroethene 120 105
Trichloroethene 85 115
Chlorobenzene 105 115
Toluene 105 105
Benzene 105 100
7/17/91 1,1-Dichloroethene 103 121
Trichloroethene 103 106
Chlorobenzene 100 106
Toluene 9; 109
Benzene 103 103
.iA TER
SOLID
';C
COSTROL
Li~Ir:S
( 5,*-1281
( 55-1231
( 67-i.261
( 60 -131 )
( 6i-12il
( 52-123)
( 51-130;
( 59-132)
, -I9-P;)
( 63-136)
-------
I
'N ADSWORTH . ALER7
LABORATORIES. iNC.
~ATRIX SPIKE DATA
SPIKE SPK/DUP ,~C
- ANALYSIS PERCE~T PERCE~T SPIKE CO~TROL
LAB ID DATE PARA.'fETER RECOVERY RECOVERY ~ATRIX U~ITS
560.+6 ;/10/91 Polychlorinated Biphenyls 97 70 SOLI D ( iO-13C
560.+; 7/10/91 Polychlorinated Biphenyls 97 92 SOLID ' 70-13C
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-------
Attachment A
MALLORY CAPACITOR COMPANY SITE
PROPOSED PLAN
-------
w
cO
This Fact ShHt Wl71 provide
. An overall review of the site.
. The results of the remedial
investigation.
. The possible health risks
posed by the sit..
A summary of the Feasibility
Study.
. A summary of treatment
alternatives.
Information on U.S. EPA's
recommended alternative.
Information on how the
public can participate in the
final selection of the treat-
ment alternative.
. Places to get more informa-
tion.
. Upcoming activities in the
remediation and Superfund
process.
Public Meeting
Mallory
Capacitor
Co.
Superfund
Site
A
o
EPA
Date: June 27. 1991
lime: 7 p.m.
Location: Wayne County
Courthouse.
Waynesboro. TN
United S t.a1es
Environmental ProteCtion .
Agency
North Superfund Remedial Branch
Region 4
34S Counlmd SI, NB
AIlwa, GA 30365
u.s. EPA Issues. A Proposed Plan For
Ground-Water Cleanup At The Mallory
Capacitor Co. Superfund Site
~~
-
.....
Exhibit 1: Site LDcation Map
n
The United States Environmental ducted to determine the nature and ex-
Protection Agency (U.S. EPA) recently tentofground-watercontaminationatthe
completed a cofT1)rehensive study of Mallory Capacitor Co. Superfund Site.
treatment alternatives for ground-water The RI also evaluated the risks the Site
contamination found at the Mallory Ca- may present to human health and the
pacitor Co. Superfund Site (the site) in environment. The second part of the
Waynesboro, Tennessee. The study was study. the Feasibility Study (FS).
conducted in two parts and Is a part of evaluated ahematives for protecting hu-
the federal SUperfund program which man health and the environment based
providesfortheinvestigationandcleanup on problems that were identified during
of hazardous substances at sites the RI. This fact sheet outlines the major
throughout the United States. fincrangs of the RI and summarizes the
remedial alternatives evaluated during
The first part of the study, the Re- the FS. Words appearing in bold type are
medial Investigation (RI). was con- defined in the glossary (See Exhibit 4).
1
-------
U.S. EPA's preferred method, known as a Pro~O~ed
Plan for addressing the ground-water contaminatIOn
problems located at the Mallory Capacitor Co. Superfund
Site, is presented in this document. Also included ,is
information on how interested members of Ihe comrrunity
can participate in U.S. EPA's remedy selection process
by submitting comments on the RI and FS Reports and
the Proposed Plan. Section J 17(a) of the Comprehen-
sive Environmental Response, Compensation, and
Liability Act (commonly referred to as CERCLA or the
.Superfund Lawj requires that U.S. EPA publish its
Proposed Plan for addressing contamination problems at
S'.;;.-erlund sites and provide the public with an opportunity
/.: .~~mment on the proposed course of action.
ND INFORMATION
The Mallory Capacitor Co. Superfund Site is a former
electrical capacitor manufacturing plant located on Belew
Circle Drive in Waynesboro, Tennessee. The Site, bor-
dered on the east by the Green River, approximately 8.6
acres in size, is in a residential! commercial! industrial!
bUsiness area in the eastern section of the city. The Cold
Water Creek passes the northwest comer of the Site and
meets the Green River approximately seven hundred feet
north of the Site. Houses are located to the north of the
Site along Belew Circle Drive I to the west of the Site along
Hassell Street, and to the south of the Site along Mariva
Street.
The Site was originally developed in the late 1940's
as a manufacturing facility for the footwear industry. In
1968, the Site was acquired by P.R. Mallory & Co., Inc.
(Mallory), a subsidiary of Duracell International, Inc.
(Duracell's) corporate predecessors. In 1969, Mallory
(DuraceJ/) commenced the manufacture of electrical ca-
pacitors at the facility. In 1979, Emhart Industries, Inc.
(Emhart) purchased the Site and its operations. On July
27, 1984, Emhart ceased manufacturing operations at the
Site. ONnership of the Site was transferred to Duracell in
1988. During periods within the time frame of 1969 to
1978, polychlorinated biphenyls (PCBs) were used as
the dielectric fluid in the electriCal capacitors manufac-
tured at the Site. Trichloroethene (TCE) was used in the
manufacturing process as a degreaser.
During the period of 1976 to 1980, remedial actions i)
were implemented at the Site to remove materials con-
taminated with PCBs from process equipment within the
plant, to remove an underground tank located adjacent to iij
the plant which was used for storage of waste liquids from
the manufacturing process and to remove soils contami-
nated with PCBs adjacent to the underground storage
tank. From 1984 to 1988, investigative programs con-
, ,'"ad at the Site identified significant concentrations of
.Bs in portions of plant structure, on some of the
.OCfo';::; equipment within the plant and in soils in some
areas of the Site. Significant concentrations of specific
volatile organic compounds (VOCs) and PCBs were
also identified in the ground water. The VOCs identified
were TCE and 1,2-DCE.
Pursuant to the 1987 proposed inclusion of the Mallory
Capacitor Co. Superfund Site on the National Priorities
List (NPL), Duracell signed an Administrative Order on
Consent (Consent Order) to conduct the RI and FS at the
Site under U.S. EPA's supervision.
As a result of the findings of the 1984 to 1988
investigative programs, additional remedial actions were
undertaken in accordance with the terms of the Consent
Order and were ir11>lemented at the Site during 1988 and
1989. The remedial actions included the disposition of all
equipment and stock, the removal of the plant (exclusive
of the Warehouse) and all ancillary buildings, and removal
of all soils significantly contaminated with PCBs from the
Site. Sampling of surfaces within the Warehouse con-
firmed that the Warehouse had not been significantly
impacted by past operations at the Site.
The 198811989 remedial actions resulted in the dis-
posal of approximately 18,700 tons of soil and concrete
contaminated with PCBs, 410 tons of equipment con-
taminated with PCBs, 330 cubic yards of non-hazardous
equipment and 3,540 cubic yards of non-hazardous
building concrete and debris at the Chemical Waste
Management facility in Emelie, Alabama. In addition, the
excavation and removal of contaminated soils resulted in
the removal of most of the sanitary and storm sewer
systems on-Site. Regrading of the Site allowed elimina-
tion of all point source discharges of storm water runoff to
the Green River.
The RI at the Mallory Capacitor Superfund Site was
conducted from early 1988 to late 1990. Activities per-
formed can be grouped into the following categories:
planning and preparation, field activities (including sam- .
piing), laboratory analyses, data validation, evaluation
and analysis, and report preparation. Specific objectives
of the RI were: .
To characterize all wastes remaining at the Site after
the 198811989 remedial actions;
On the basis of the waste characterization, to define
the set of Site-specific contaminants attributable to
the Site;
iii) To define the areal and vertical extent of soil contami-
nation in the grass areas west of the Plant, in the
grass area south of the security fence south of the
Plant, on private properties In the vicinity of the Site
and in overburden soils beneath the Plant;
2
-------
iv) To evaluate contamination, attnbutable to past ac-
tivities at the Site, if any, in the Green River sediments:
v) To confirm the alignment of the. Site and the City of
Waynesboro sanitary sewer systems and to delin-
eate the extent of sediment contamination, if any,
attributable to past activities at the Site in both the
storm sewer and sanitary sewer systems on-Site and
in the City of Waynesboro sanitary sewer system
downflow of the Site;
vij To define the ground-water flow regime beneath the
Site and its relationship to the Green River;
viij To define the extent of ground-water contamination
attnbutable to the Site;
viii) To confirm the extent of contamination, if any,
attnbutable to the Site in the surface water of the
Green Riveror in ambient air at or adjacent to the Site;
and
be) To collect sufficient data to complete an accurate Site
map including the location of all services and build-
ings, the location of all drainage ditches and swales
and elevation data to show the topography of the Site.
The following field safT1)ling activities were under-
taken as part of acco~lishing these objectives:
ij Soil samples were collected from:
a) The grass areas east, south and west of
the Plant;
b) Private properties adjacent to the Site;
c) Beneath the on-Site drainage ditches and
swales;
d) Beneath the former Plant; and
e) Beneath the sanitary sewer pipe invert on-
Site.
iij Sediment ~es were coOected from:
a) The Green River upstream. downstream, and
adjacent to the Site;
b) The on-Site sanitary and storm sewers; and
c) The City of Waynesboro sanitary sewer in the
vicinity of the Site.
iiij .Two rounds of ground-water samples were collected
from monitoring wells located:
a) On-Site;
b) On properties adjacent to the Site:
iv) Surface water samples were collected from the Green
River; and
v) Air sa~les were collected from locations situated
about the perimeter of the Site.
KE FINDIN F THE REMEDIAL
~
SQI1
The 1988/1989 soil remedial actions referred to in the
-Background" section of this report were found to be
successful in removing soil contamination.
Sampling and analysis confirmed the following:
ij On-Site background soils (southern and western por-
tions of the Site) did not contain detectable concentra-
tions of PCBs, TCE, or 1,2-DCE;
iij Surface and subsurface soils on-Site, including ditch
and swale soils and sanitary sewer bedding material
soils, had been remediated to the cleaoop criterion
for soils of 10 mglkg for PCBs. Residual concentra-
tions of PCBs in soils at the Site were as follows:
a) Average concentration in surficial soils of 1.60
R'Ig/1(g; and
b) Average concentration in subsurface soils of
4.3 mglkg.
1,2-DCE and TCE were not identified to be contaminants
of concern in any of the soils at the Site.
iiij Of the 21 properties adjacent to the Site boundary,
the distribution of PCBs was determined to be as
follows:
a) 14 properties did not contain detectable concen-
trations;
b) The remaining seven properties contained
PCBs in concentrations that were within EPA's
acceptable risk range for a residential scen-
ario; and
1,2-DCE and TCE were not detected in any of the off-
Site soli safT1)les. .
Sediment.
Sampnngconfirmed that sediments within the sewer
systems on-Site and in the vicinity of the Site and of the
Green River upstream, adjacent to and downstream of
~
-------
~ "e Site did not contain significant concentration of PCBs,
I .2-DCE, or TCE. Therefore, it was concluded that sedi-
,""ents had not been significantly impacted by past Site
operations.
Surface Water
Sampling confirmed that surface waters within the
Green River upstream, adjace-nt to and downstream from
the Site and from the spring on private property loCated
west of the Site, did not contain detectable concentrations
of PCBs. 1,2-DCE, or TCE. Therefore. it was concluded
that surface waters were not being impacted by the Site.
All:
Samples collected did not reveal PCBs, 1,2-DCE, or
TCE. Therefore, it was concluded that air was not being
impacted by the Site.
Ground Water
Samples confirmed that impact to ground water had
occurred for PCBs, 1,2-DCE, and TCE in the shallow
bedrock (20 to 40 feet below surface grade)and the deep
bedrock (60 to 90 feet below surface grade) both on-Site
and on-Site. Monitoring wells in the deeper bedrock
aquifer (95 to 120 feet below surface grade) at locations
selected to show the most probable areas of contamina-
tion in this aquifer showed no contamination.
Summary
Based on the findings of the RI, the contaminants of
concern at the Site were identified to be PCBs, 1,2-DCE,
and TCE. Sampling' in all media confirmed that ground
water was the only media impacted at the Site, besides
soil, which had been previously remediated to EPA's
acceptable levels. .
The route of concem for contaminant movement is
ground water. Ground water was found to be moving in
the northeasterly direction. However, all homes adjacent
to and in the area of influence of the Site were found to be
on municipal water.
All other information on the saJT1)ling and analysis
program and results can be found in the RI Report on file
in the Mallory Capacitor cO. Superfund Site Information
Repository in the Wayne County Library.
ME NT
The final phase of the RI was an assessment of
potential risks to public health and the environment.
Earfier phases of the study determined which contami-
nants are present, the levels at which they are present,
and where they are located. Using this information, the
risk assessment examined whether existing or future
contact with contaminants poses a public heahh or envi- .
ronmental risk. The risk assessment determines an upper
bound estimate of risk assuming no further action is taken
to clean up the Site.
EPA has classified PCBs and TCE as probable hu-
man carcinogens based on animal studies. 1,2-DCE has
. been shown to cause abnormal blood chemistry of labo-
ratory animals and is therefore considered to be a sys-
temic toxicant.
To be considered acceptable and within EPA's target
risk range, the additional risk of cancer from these
chemicals to an exposed individual must be no greater
than 1 in 10,000 and preferably no greater than 1 in
1,000,000. For systemic toxicants, the hazard is deemed
unacceptable if the estimated expOsure level exceeds
that level which has been determined to not cause any
adverse effects in humans. The hazard is unacceptable
based on residential use of ground water north of the Site.
Future exposure to PCBs, TCE, and 1,2-DCE was
considered for ground water in the areas north and east
of the Site. In both areas, the existing concentrations will
exceed EPA's target risk levels if wells were installed for
residential use. At this time, no private wells exist within
the area of ground-water contamination. Three springs
within the area of influence have been tested. All were
found to be clean of Site-related contaminants.
The surface waters of the Green River were evalu-
ated for potential risk from chemical exposure due to fish
consumption and wading. The risk from these pathways
is within EPA's target range for acceptable risk.
A recreational exposure scenario was evaluated for
on-Site soils. The additional lifetime risk of cancer was
well within EPA's acceptable range. All residential soil
samples were evaluated for additional lifetime risk of
cancer and were also found to be within EPA's acceptable
range of risk.
Dermal exposure to PCBs from surfaces in the
warehouse was evaluated and found to be minimal.
Therefore, this potential exposure pathway would not
represent any significant health risk.
In summary, the only risk found to be unacceptable
was that of ground-water consuJT1)tion, bathing, and
showering from a hypothetical well in areas north and east
of the Site. This scenario is the basis for remedial action
at the Site.
For more details on the human exposure calculations
in the Risk Assessment, please see Appendix t of the RI
Report on file in the Mallory Capacitor Co. Superfund Site
Information Repository in the Wayne County Library.
A
-------
THE FEASIBILITY STUDY: DEVELOPING AND EVALUATING
REMEDIAL (CLEANUP) ALTERNATIVES
Based on the re~ults of the RI, a Feasibility Study (FS) REMEDIAL ALTERNATIVE 2A
was co nducted "to identify. develop and evaluate appropri-
ate remedial alternatives for minimizing risks to public. Install Six Qround-Water Extraction Wells
health and the environment caused by the contaminated
groundwater-plume. Ten remedial (cleanup) alternatives. Install an On-Site UV Chemical Oxidation Ground-
were developed in the FS. Each alternative was screened Water Treatment Facility
for effectiveness, implementability and cost. Based on
this screening process, altematives which did not meet. Treat Ground Water to Remove TCE and 1.2-DCE
these remedial objectives were eliminated from further
analysis and consideration. Alternatives Ia and Ib were. Discharge Treated Ground Water to City Water
eliminated because they did not permanently limit expo- Treatment Plant or Surface Waters Near the Site
sure to contaminated materials or reduce the release of
contaminants. Details on each remedial alternative are
presented below.
REMEDIAL ALTERNATIVE IA
. No Action
The National Contingency Plan (NCP) requires the
development of a no action alternative as a basis for
comparison of alternatives. Therefore, remedial Alterna-
tive la, consists of implementing no remedial action at the
Site I including no restriction on future installation of ground-
water extraction wells and no further monitoring of the
contaminated ground water both beneath and hydrauli-
cally downgradient from the Site. Because no further
action would be taken and the Site would remain in its
present condition. there are no costs associated with this
remedial alternative.
REMEDIAL ALTERNATIVE 18
. Institutional Controls and Monitoring
Alternative b consists of placing deed restrictions on .
the Site property title to Identify the presence of PCBs,
1,2-DCE and TCE In ground water beneath the Site. a ban .
on installation of ground-water extraction wells on appro-
priate properties to provide protection of human health
from potential future consufT1)tIon of contaminated ground-
water, and safT1)ling and analyses of ground water be-
neath the Site and off-Site to monitor the attenuatlonl
degradation of PCBs, 1,2-DCE and TCE In the ground-
water system. The estimated cost of this alternative is
$710,000.
This altemative consists of extraction of the contami-
nated ground water at an estimated rate of six gallons per
minute from five locations on-Site and one off-Site that
exhibit the highest concentrations of Site-related con-
taminants. The extradion wells would prevent further
migration of contaminants. Extracted ground water would
be pUfT1)ed to the on-Site UV Chemical Oxidation facility
for treatment. Site-related contaminants not within the
zones of influence of the six extraction wells would not
receive treatment. but would not pose additional risks to
public health or the environment in excess of the range
deemed acceptable by EPA.
This alternative is estimated to remove approxi-
mately 98% of the TCE and 1,2-DCE in 20 years. The
estimated cost of this alternative is $2.565.000 .
REMEDIAL ALTERNATIVE 28
.
Install Six Ground-Water Extraction Wells
.
Install an On-Site Air Strfpping/Bag FiltrationlCarbon
Adsorption Ground-Water Treatment Facility
Treat Ground Water to Remove TCE and 1,2-DCE
Discharge Treated Ground Water to City Water
Treatment Plant or Surface Waters Near the Site
This alternative is Identical to Alternative 2a with the
exception Of the treatment method used. Extradedground
water would be pu~ to the on-Site air stripping tower
followed by a bag filter followed by a carbon adsorbtion
unit. Ouality of treated ground waterwould be the same as
for Alternative 2a, which Is removal of approximately 98%
of the TCE and 1,2-DCE In 20 years. The estimated cost
for this alternative is $2,113,000.
-------
This alternative consists of extraction of the contami-
nated ground water at an estimated rate of seven gallons REMEDIAL ALTERNATIVE 48
per minute from seven locations on-Site. In addition to. '
, pumping water to the UV Chemical Oxidation facility for. Install 13 Ground-Water Extraction Wells
treatment, the pumping would serve to contain the con-
taminated ground-water plume.
This alternative is estimated to remove approximately
1000/0 of the TCE and 1,2-DCE cOntamination in on-Site.
.~~uifers within SO years. Off-Site aquifers would not be
',"'?diated. The estimated cost of this alternative is .
.).":,858,000.
REMEDIAL ALTERNATIVE 3A
.
Install Seven Ground-Water Extraction Wells
Install an On-Site UV Chemical Oxidation Ground-
Water Treatment Facility
.
Treat Ground Water to Remove TCE and 1,2-DCE
.
Discharge Treated Ground Water to City Water
Treatment Plant or Surface Waters near the Site
REMEDIAL ALTERNATIVE 38
i .
Install Seven Ground-Water Extraction Wells
.
Install an On-Site Air StrippinglBag FiltratiorVCarbon
Adsorption Ground-Water Treatment Facility
Treat Ground Water to Remove TCE and 1,2-DCE
.
.
Discharge Treated Ground Water to City Water
Treatment Plant or Surface Waters Near the Site
This alternative is identical to Alternative 3a with the
exception of the treatment method used. Extraded ground .
water would be pu"1>8d to the on-Site air stripping tower
~ollowed by a bag filter followed by a carbon adsorbtion .
unit. Ouality of treated ground waterwould be the same as
ior Alternative 3a, which is removal of approximately
, 100% of TCE and 1,2-DCE from on-Site aquifers in 50 .
years. The estimated costforthis alternative Is $2,362,000.
REMEDIAL ALTERNATIVE 4A
.
Install 13 Ground-Water Extraction Wells
.
Install an On-Site UV Chemical Oxidation Ground-
Water Treatment Facility
Treat Ground Water to Remove TCE and 1,2-DCE
.
..
Discharge Treated Ground Water to City Water
Treatment Plant or Surface Waters Near the Site
This alternative consists of extraction of the contami-
nated ground water at an estimated rate of 13 gallons per
minute from seven locations on-Site and six locations off-
Site. In addition to pufT1)ing water to the UV Chemical
Oxidation facility for treatment, the pumping would serve
to contain the contaminated ground-water plume.
This altemative 'is estimated to remove approximately .
100 % of the TCE and 1,2-DCE contamination in on-Site
and off-Site aquifers within 30 years. The estimated cost
of this alternative is $3.860,000.
.
Install an On-Site AirStrippinglBag FiltratiorVCarbon
Adsorption Ground-Water Treatment Facility
Treat Ground Water to Remove TCE and 1,2-DCE
Discharge Treated Ground Water to City Water
Treatment Plant or Surface Waters Near the Site
This alternative is identical to Alternative 48 with the
exception of the treatment method used. Extraded ground
water would be pu~d to the on-Site air stripping tower
followed by a bag filter followed by a carbon adsorbtion
unit. Quality of treated ground wate r would be the same as
for Alternative 48, which is removal of approximately
100% of TCE and 1,2-DCE in both on- and off-site
aquifers in 30 years. The estimated cost for this alterna-
tive is $3,105,000.
REMEDIAL ALTERNATIVE SA
Install 22 Ground-Water Extraction Wells
Install an On-Site UV Chemical Oxidation Ground-
Water Treatment Facility ,
Treat Ground Water to Remove TCE and 1,2-DCE
.
Discharge Treated Ground Water to City Water
Treatment Plant or Surface Waters Near the Site
This alternative consists of extraction of the contami-
nated ground water at an estimated rate of 22 gallons per
minute from 13 locations on-Site and nine locations off-
Site. In addition to puf11)ing water to the UV Chemical
Oxidation facility for treatment, the pumping would serve
to contain the contaminated ground-water plume.
This alternative is estimated to remove approximately
100% of the TCE and 1,2-DCE contamination In on-Site
and off-Site aquifers within 30 years. The estimated cost
of this alternative is $5,216,000.
~
-------
This altemative is identical to Alternative Sa with the
exception of the treatment method used. Extraded ground
water would be pufT1)ed to the on-Site air stripping tower
followed by a bag filter followed by a carbon adsorbtion
unit. OuaJityoftreated ground waterwould be the same as Due to the strong binding nature of PCBs and the
for Alternative Sa, which is removaJ of approximately many fractures in roc:k In the area, listechnicaDy inlX>ssibie
100% of TCE and 1,2-DCE in 30 years. The estimated at this time to develop an alternative which will remove
cost for this alternative is $4,035,000. ' PCBs from the ground water to levels which EPA deems
acceptable. The ground-water extradion systems pro-
posed will remove some of the PCBs In the aquifer,
however, none of the alternatives being considered will
remove PCBs to health-based levels. Several alterna-
tives wiD remove TCE and 1 ,2-DCE to these standards.
A review wOl be conducted at this Site every five years by
U.S. EPA since PCBs win remain above health-based
levels. Should Innovative technologies for PCB removal
become available, feasibility at the Site will be assessed.
REMEDIAL ALTERNATIVE sq
.
Install 22 Ground-Water Extraction Wells
.
Install an On-Site Air StrippinglBag FiltratiowCarbon
Adsorption Ground-Water Treatment Facility
Treat Ground Water to Remove TCE and 1,2-DCE
.
.
Discharge Treated Ground Water to City Water
Treatment Plant-or Surface Waters Near t~ Site
To avoid redundancy in the summary of each
alternative, several specific components which are com-
mon to all remedial alternatives except for Altematives Ia
and Ib are listed below:
ij AdditionaJ investigations to better detennine the
northern extent of off-Site ground-water contamina-
tion;
b) AdditionaJ Investigations to detennine potentiaJ
chemical contamination,lf any, and biota impacts, If
necessary, to the surface water tnbutary north of the
Site (Cold Water Creek);
iiij Institutional controls and monitoring (Alternative Ib);
iv) An effectiveness monitoring program consisting of
testing wells around the Site to insure that:
. a) Contamination has been hydraulically contained;
b) Concentrations of Site-related contaminants 'are
being reduced in on-Site groundwater and off-Site
ground water downgradlent (north) of the Site;
and
c) The Cold Water Creek Is not receiving contamina-
tion from the aquifer.
RemediaJ Altematives 28,38,48, and 5a aJl utiDze the
same ground-water treatment process, as do Remedial
Alternatives 2b, 3b, 4b and Sb. The 8a- alternatives Involve
UV Chemical Oxidation, which uses ultraviolet rJghlln
combination with a strong oxidant, such as hydrogen
peroxide, to transfonn TCE and 1,2-DCE Into caIbon
d'lOxlde and water. The "b8 alternatives Involve treatment
of extracted ground water by air stripping, filtration, and
carbon adsorption.
U.S. EPA prefers the 'b8 alternatives because UV
Chemical Oxidation will not produce consistently dean
effluent given the relatively low IncomirJg flow rates and
fluctuating COncentrations.
Alternatives 2 through 5 are similar in that extraction
wells will be Installed and ground water wm be extraded
and treated. The differences in these alternatives lie in
weD placement and oomber. The various well placement
and number scenarios in Alternatives 2 through 5 are
different strategies for containing and treating the con-
taminated ground-water plume. For more Information on
these strategies. consult the FS Report In the Maliory
Capacitor Co. Superfund Site Information Repository in
the Wayne County Ubrary.
7
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u.s. EPA'S PROPOSED PLAN FOR REMEDIAL ACTION
Based on the FS, U.S.EPA has identified Alternative 4b as the best course of action for the ground-water
contamination and migration problem at the Mallory Capacitor Co. Superfund Site. U.S.EPA's preferred course of action
includes:
. Install 13 Ground-Water Extraction Wells
. Install an On-Site Air StrippingJ8ag FiltrationlCarbon Adsorption Ground-Water Treatment Facility
. Treat Ground Water to Remove TCE and 1,2-DCE
. Discharge Treated Ground Water to City Water Treatment Plant or Surface Waters Near the Site
. Investigations to better determine northern extent of off-site ground-water contamination
. Investigations to determine possible impacts to Cold Water Creek
. Institutional controls and monitoring
. An effectiveness monitoring program
This alternative is estirnated to remove approximately 100% of TCE and 1,2-DCE in both on-Site and off -Site aquifers
within a 30 -year period. The estimated cost is $3,1 05,000. The exad locations and numberof wells chosen are estimates
and may be modified during the design phase which precedes remedial action.
Alternative 1 was not chosen because it did not permanently limit exposure to contaminants or reduce the release
of contaminants. Alternative 2 was not chosen because concentrations of Tee and 1,2-DCE attained would not comply
with federal and state regulations pertaining to cleanup of hazardous waste Sites. While Alternative 3 provided for cleanup
of the on-Site aquifer, it did not address cleaning up the off.Site aquifer. Alternatives 4 and 5 achieve the same cleanup
concentrations within the same time frame (approximately 100% reduction in TCE and 1,2-DCE in 30 years). Because
Alternatives 4 and 5 give the same end results, Alternative 4 was chosen as the more cost-effective alternative. As
discussed previously, U.S.EPA prefers the~. part of this alternative, which is air strippinglfiltrationlcarbon adsorption,
because it achieves more consistent effluent concentrations.
o
THE NEXT STEP'
The public convnent period on the FS and Proposed Plan is the next step in selecting a final remedial action
forthe Mallory Capacitor Co. Superfund Site. The comment period provides an opportunity for local residents
to submit their convnents to U.S. EPA on allthe remedial alternatives considered for the Site. Based on public
comments or new infonnation, U.S. EPA may modify the recOnvnended remedial alternative or choose
another ci the remedial alternatives developed in the FS. The Proposed Plan outlines In detail U.S. EPA's
recommended remedial alternative.
Following the publ"lC comment period, U.S. EPA will sign a Record of Decision (ROD) for the Site. The
ROD will detail the remedial action chosen for the Site and Include U.S. EPA's responses to cornrnents
received during the public comment period. After the ROD Is signed, a design plan for Implementing the
remedial action will be prepared. Or1C8 the design Is complete, construction of the remedial action can begin.
A review will be conducted every fIVe years at this Site since PCBs wnl remain above health-based levels. This
review will Insure that contaminants In the ground-water plume (Including PCBs) are being effectively
contained and that the TCE and 1,2-DCE are being reduced In concentration.
8
-------
Criteria for
Evaluating
Remedial
Alternatives
In selecting its preferred reme-
dial alternative, U.S. EPA uses the fol-
lowing criteria to evaluate each of the
cleanup alternatives developed in the
Feasibility Study. The first seven crite-
ria are used to evaluate all the remedial
alternatives, based on environmental
protection, cost, and engineering feasi-
bility issues. The final two criteria, state
and community acceptance, are used to
further evaluate U.S. EPA's Proposed
Plan after the public comment period is
over and comments from the commu-
nity have been received. Exhibit 5 on
pages 13 and 14 summarizes how all the
alternatives were evaluated using the
following criteria:
1) Overall protection of public health and the environment
U.S. EPA assesses the degree to which each alternative eliminates, reduces, or
controls threats to public health and the environment through treatment.
engineering methods (e.g. ground-water treatment), or institutional controls
(e.g., deed restrictions on future uses of the property).
2) Compliance with federal and state regulations.
The alternatives are evaluated for compliance with those environmental
protection regulations determined to be applicable or relevant and appropriate
to the site conditions.
3) Cost
The benefits of implementing a particular remedial alternative are weighed
against the cost of implementation.
4) Implementability.
U-S.EPAconsiders the technical feasibility (e.g.. how difficult is the alternative
to construct and operate?) and administrative ease (e.g., the amount of coordi-
nation with other government agencies that is needed) of a remedy, including
the availability of necessary goods and services.
5) Short-term effectiveness.
The length of time needed to implement each alternative is considered and US.
EPA assesses the risks that may be posed to workers and nearby residents
during implementation (e.g.. would contaminated dust be produced during soil
excavation?).
6) Long-term effectiveness,
The alternatives are evaluated based on their ability to maintain reliable
protection of public health and the environment after implementation.
7) Reduction of contaminant tatitity, mobility, and volume.
U.S. EPA evaluates each alternative based on how it reduces (1) the harmful
nature of the contaminants, (2) their ability to move through the environment,
and (3) the amount of contamination.
8) State acceptance.
U.S EPA requests state comments on the Remedial Investigation and Feasibil-
ity Study Reports, as well as the Proposed Plan, and must take into consider-
ation whether the state concurs with or opposes U.S. EPA's preferred remedial
alternative.
9) Community acceptance.
To ensure that the public has an *A*fjtt? opportunity to provide input, U.S.
EPA holds a public comment period and considers and responds to all
comments received from the community prior to the final selection of a
remedial action.
-------
The fint step in suc-
cessfully meeting the
objectives established
for the Feuibiliry
StUdy involved idaui-
fYinI v8rioul cleanup
options tha wouJd be
appropriate for the
Mallory C8p1citor Co.
Superfund Site. U.S.
EP A ca1C1uded that to
meet thex objectives
technologies were
needed to:
!
j
i i
VJtravioiet-Enhauced Oxidation
This technology converts hazard-
ous waste to leu toxic .forms of
compounds, using a chemical reac-
tion to increase the oxygen content
in the compounds, thueby reduciD&
die level of many OfJmic con1Imi-
nmts in warer, p8nicu1a:rlyTCE and
1.2.DCE. This method is G1 inDo-
valive treaJmeD1 technology, lad
would require pilot testing to be
CClJducted 11 the Site. Although very
effec:dve in lddressingTCE md 1.2-
DCE contaminalion. ithas I varying
r8D[;~ of effectiveness on other
compounds suc:h as PCB..
1
1) extrlCt the ground
war.c:r;
2) treal it to reduce
c:ontI:IJ1in.m1 levels to
aa:epUble levels; and
3) dispose of it in a way
thlt protects public
health and the environ-
ment.
The fonowing diagram
describes each of the
specific technologies
included in the reme-
dial alternatives for the
Mallory Capacitor Co.
Superfund Sire.
---
€rouud Water Ema~
ExtractioD WeUs
Similar to I drinking water-
supply weD. but CCI1StrUCted 10
th81llt'ge volumes of water can
be drawn from below the ground
surfll:C. U.s. EP A deumrin.ed
!hit extraction welli could
provide an effective method of
intercepting contaminated
ground WIIeZ before it enun
surface water bodiesormigrara
further.
~roUDd Water Trea~
FUtratioa
This technology typic:aIJy is used
as I concluding step in ground
WIIeZ trel1menL The water to be
treated is percola1ed through I
filter that may include sevenl.
types of mar.erials. including sand.
fabric bags, md crushed glass
among o!hen. By passing the
Wlter thJOugh this material. SUI-
pended solidslR filtered out. This
method is often used fonowing
processes such as carbon Idsorp-
tion. to filter out suspended solids,
thus in:tproviDa the quality of !be
treated water.
C 3) Disposal
Treated GrouDd Water
Dlspc8l
Contaminlted ground Wlter
would be treated to ensure that
National PollutioD DiJcharge
Elimination Systan (NPDES)
.tanduds administered by !be
State of Tenneucc. are met.
Once Icceptable levelJ are
reached. feaible tecImologies
for dispouI of die treated WIIeZ
iDc1udedischarae into the Green
River ar discharge to the public
wutewlter treatment plant.
known u I publicly owned
treaImaU works (POTW).
Air Strlpplq
Air stripping is I proven technol-
ogy for removing VOCs. Treated
water enters either I packed tower
or sprlY chamber and flows
downward while air Oows upward
from the bottom of the chamber.
stripping VQCa from the WIleZ.
The treated water is col1ec:ted at
the bonom of the tower and
pumped to dischlrge ar subse-
q\!ent processeI, while air con-
taining VOCs exits the top of the
tower aid either exits to the atmo-
sphere or is treated further using a
carbaa adsorber.
Carbon Adsorptloa
Carbon adsorption is I pr0-
ven. reliable treI1maI1 pr0-
cess for removing I variety of
orgmic compounds. It in-
volves passing warer through
I chamber that is pacbe! with
cubon granular particles.
Conwninan1s attach onto the
carboa. effectively removing
contamin.mts from the water.
~
Hazardous W ute Disposal
As the conwninaJed ground 110'1-
ter is treated.. used carbon and
bag filters would be remo~ed and
collected for proper disposal.
Two dispoIaI methods are pos-
sible options: landfilling the
waste at G1 off-site. federa1Jy ~
proved haz8rdouJ waste flCility.
or incineration of the materials at
moff-lite federUly approved fa-
cility. One ocher option for diJ-
polll of the used carbon is regen-
er8Iion. Under rqeneratioD, the
carbcm is placed in I hi&h tem-
perature oven. Alt6:t contami-
nants '"bUc" off, d1e carbon may
.
10
-------
Air Stripping
A treatment system that removes or" strips" volatile.
organic compounds (VOCs) from contaminated
ground water by forcing an airstream through the
water and causing the VOCs to evaporate.
Carbon Adsorption
A process for removing a variety of organic com-
pounds. It involves passing the water through a
chamber that is ~ with CaIbon particles. where
contaminants attach to the carbon particles, effec-
tively removing contaminants from the water.
Comprehensive Environmental Response,
Compensation, and UabUity Act
See definition for "Superfund."
1,z-Dichloroethene (1, 2-DCE)
A colorless pleasant-smelling liquid which is known
to be toxic when absolbed by skin. l.2-DCE is used
as an industrial degreaser, among other applica-
tions.
Endangerment
A site-specific Sbldy of the actual or potential
Assessment danger to human health or welfare and
the environment from the release of hazardous
substances.
Extraction Wells
Similar to municipal drinking water-supply wells,
but constructed so that large volumes of water can
be drawn from below the ground surface.
. Feasibility Study (FS)
The second pan of a two-part study called a Reme-
diallnvestigationJFeasibility Study (RIIFS). The
FS identifies and evaluates remedial alternatives
that are designed to address contamination prob-
lems found during the RI at the Superfund site.
(See definition for RI on next page.)
Filtration
A method of separating solid particles from a
o liquid or gas by passing it through a porous sub-
stanCe.
~
~ National Priorities List (NPL)
. U.S. EP A's list of the top priority hazardous waste
< sites that are eligible for Federal money under
CI) Superfund.
CI)
o
~
d
11
Ground Water
A term penaining to any water below the surface of
the earth. filling the spaces between soil, sand,
rock, and gravel particles beneath the eanh's sur-
face. Ground water typically nows very slowly
compared to surface water, along routes that often
lead to rivers and lakes. Rain that does not evapo-
rate or immediately now along the surface to
streamS and rivers slowly percolates through the
son until it reaches the level where the ground is
saturated with water.
Monitoring WeD
A well used to collect ground water, and other
samples. ~ samples are typically analyzed in a
laboratory to determine the amounts, types and
distribution of COJ1taminaru beneath the site.
National Contigency Plan (NCP)
The federal regulation that guides the Superfund
program.
Organic Compounds
One of two large classes of chemical compounds,
organic and inorganic. It is a term used to describe
chemicals containing carbon. Examples of organic
materials include petroleum products, solvents,
oils and pesticides.
Polychlorinated Biphenyl (PCB)
A chlorinated organic compound which is color-
less and may vary inconsistency from oUy to waxy
at room temperature. PCBs are probably carcin0-
genic (cancer-cauSing) and are moderately toxic.
PCB-bearing nuids are used inelecuical equipment
manufacturing.
Potentially Responsible Parties (PRPs)
An individual, business, or government organiza-
tion idemified by U.s. EP A as potentially liable for
the actual or threatened release of hazardous sub-
stances from an uncomrolled hazaldous waste site.
-------
Proposed Plan
A document that describes all the remedial alter-
natives considered by U.S. EPA, including the
alternative U.S. EPA prefers.
R~ i of Decision
A C....JJDent issued after the Remedial Investiga-
tion and Feasibility Stqdy that describes U.S.
EPA's selective remedies for cleanup of a site.
Remedial Action
Under Superfund, cleanup is considered a reme-
dial action when it involves a remedy to address
site contamination to proteCt the public from ex-
posure. An interim remedial action is a remedial
action that is not considered final but is consistent.
with a final remedy.
Remedial Alternatives ~
A combination of technical and administrative ,,-:
methods developed and evaluated in a Feasibility ~
Study that can be used to address contamin~tion at ~
a Superfund site. ~
en
en
o
~
CJ
Remedial Investigation
The first pan ofa two-part study called a Remedial
Investigation/Feasibility Study (RJ/FS). The RI is
a study in which information is colleCted and
analyzed to determine the nature and extent of
contamination at the Superfund site.
Risk Assessment
A site specific study performed by U.S.
EP A to determine the actual or potential dangclS
to human hea1thand theenvironmemfrom releases
of hazardous substances at a site under its current
and conceivable future uses.
Sediment
Materials such as sand, soil, mud and decompos-
ing animals and plants that settle to the bottom of
a ditch, Stream, lake, river or pond.
Soil Borings
A hole advanced into the ground by means of a
drilling rig or hand auger to obtain soil samples.
~
. Superfund
'The name commonly used in reference to the
Comprehensive Environmental Response. Com-
pensation, and Liability Act (CERa.A) of 1980,
as amended by the Superfund Amendments and
Reauthorization Act. (SARA), in 1986. It is a law
that provides the means for investigation and
cleanup of hazardous waste sites. .
Surface Water
Streams, lakes, ponds, rivers, or any otherbody of
water above the ground. .
Toxicity
The measure of a poisonous su~'s ability to
harm living tissues when ingested, inhaled or ab-
sorbed through the skin. Overexposure to some
elements can result in a toxic effect as well. For
example, overexposure to the sun or alcohol can
result in a toxic effect on the human body.
Trichlorethene (TCE)
A colorless chloroform-smelling heavy liquid; a
chlorinated organic compound which is thought to
be carcinogenic (cancer-causing) and is toxic by
inhalation. Symptoms of inhalation include
drowsiness. TCE is used as an industrial degreaser,
among other applications.
Ultraviolet- Enhanced Oxidation
A treatment method used to conven hazardous
chemicals into less harmful compounds. This con-
vemon takes place when a chemical reaction causes
oxygen to bind with a hazardous compound, in-
creasing the oxygen content in the compound.
Volatile Organic Compounds (VOCs)
Organic compounds that are characterized by be-
ing highly mobile in ground water and which are
readily volatilized into the atmosphere.
12 .
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... tar aI-Sill1IhcIian
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14
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bat lilt- 8111 aI.sa
v.
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bat lilt- Md aI.sa
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$5,218,1XXI
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bat lilt- Md aI.sa
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S4,035,1XXI
-------
PUBLIC ~1EETING
.----..
PUBLIC COMMENT PERIOD
Mallory
Capacitor
Co.
Superfund
Site
U.S. EPA relies on public comment to ensure
that the remedial alternatives being evaluated
for each Superfund site are fully understood
and that the concerns of the local community
have been considered. Beginning June 14. 1991.
U.S. EP A will initiate a public comment period
during which comments on the Proposed Plan
and the RIlFS should be forwarded to:
6
~
EPA
Patty Fremont
Remedial Project Manager
U.S. EPA Region N
345 Counland St., NE
Atlanta, GA 30365
U.S. EPA will hold a public mceting to discuss the results of the
Remedial Investigation and the treatment allcmatives identi-
fied during the Feasibility Study. U.S. EPA representatives
will be present to respond to questions and comments about the
Remedial Investigation and the Feasibility Study.
Date: JUDe 27,1991
Time: 7 p.m.
LocatioD: Wayne County Courthouse
Waynesboro, TN
DATES: June 14, 1991 through July IS. 1991.
FOR MORE INFORMATION
U.S. EPA CONTACTS
TECHNICAL ASSISTANCE
GRANTS
Please contact the following U.S. EP A
personnel if you have further questions
and/or comments about the Mallory
Capacitor Co. Superfund Site.
Suzanne Durham
Community Relations
Coordinat.or
(404) 347-7791
Patricia Fremont
Remedial Project Manager
(404) 347-7791
U.s. EPA. Region 4
345 Counland SL. NE
Atlanta, GA 30365
INFORMA 11 ON REPOSITORY
If you are interested in learning more about
the Mallory Capacitor Co. Superfund Site.
please review the documents in the infor-
mation Repository. Information Reposito.
ries contain laws. work plans. community
rclaUons plans and other documents rel-
evant 10 the investigation and cleanup of
Superfund sites. This respository also con-
tains the Administrative Record which in-
cludes all information used by the lead
agency 10 make its decisioq on the selection
of a response action. Citizens are encour-
aged to consult these documents at the fol-
lowing location:
WI1De CoUDty Public Library
U.s. HIghWl164 Eat
WIJDesboro, TN
Houn: MOD., Wed., Than. aDd Fri. IN
Tues. 10-1
SaL 10-2
EP A is providing communities with
the opportunity to apply for Techni-
cal AssistanccGrants (TAGs). These
grants. of up to $50.000 (per site).at'C
designed to enable residents or a
community group 10 hire a technical
advisor or consultant to assist them in
intetpreting and commenting on site
findings and the remedial action.
There is a limit of one TAG per site.
Citizens who are interested in the
TAG program may obtain an appli-
c:a1ion package by calling or writing
the EPA Community Relations C0-
ordinator listed on this page.
15
-------
MALLORY CAPACITOR CO. SUPERFUND SITE
PUBLIC COMMENT SHEET
USE THIS SPACE TO WRITE YOUR COMMENTS
Your input on the Proposed Plan for the Mallory Capacitor Co. Superfund Site is imponant to U.S. .
EPA. Comments provided by the public are valuable in helping U.S. EPA select a final remedy for
the site. .-
You may use the space below to write your comments, then fold and mail. Additional comments
may be attached to this fonn or mailed separately to U.S. EPA.
Name
Address
Cry
Zip
State-
-------
----------------------------------------------------------------------------------------------------------------------
Fold on Dashed lines, Staple, Stamp and Mail
Place
Stamp
Here
Name
Address
City
Zip
State
Patricia Fremont
Remedial Project Manager
U.S. EPA Region IV
345 Counland SL, NE
Atlanta, GA 30365
-------
United States
Environmental Protection Agency
Region 4
345 Courtland Street, NE
Atlanta, GA 30365
Official Business
. Penalty for Private Use
$300
-------
Attachment B
MALLORY CAPACITOR COMPANY SITE
PUBLIC MEETING
SIGN IN SHEETS
-------
- -
'-,. =. - c..~. 1""".
""1"" Lll'...'.
003
~~ 1)...'1 ,qq I .'
~.ui'H
-------
Attachment C
MALLORY CAPACITOR COMPANY SITE
INFORMATION REPOSITORY LOCATION
-------
INFORMATION REPOSITORY
Wayne County Public Library
u. S. Highway 64 East
Waynesboro, Tennessee
Hours:
Monday, Wednesday, Thursday, and Friday - 10-6
Tuesday - 10-8
Saturday - 10-2
-------
Attachment D
MALLORY CAPACITOR COMPANY SITE
PUBLIC NOTICES
-------
..
THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
ANNOUNCES A PUBLIC KElTING ON
THE PROPOSED PLAN rOR THE
MALLORY CAPACITOR COMPANY SUPERFUND SITE
VAYNESBOllO, TENNESSEE
The U.S. Envi~onmental Protection Agency (EPA) has developed a Proposed Plan to
address the contamination at the Mallory Capacitor Company National Priorities
List (NPL) Site. Before selecting a final remedy, EPA vill consider written and
oral comments on the proposed alternatives from June 14 through July 15, 1991.
During this time, the public is invited to review and comment on the
Administrative Record, including the Proposed Plan, and the Remedial
Investigation/Feasibility Study Reports. Selection of the final remedy will be
made following consideration of public comments received. Comments received will
be addressed in the Responsiveness Summary section o~ the Record of Decision for
the site.
EPA will hold an informational public meeting on June 27 at 7:00 p.m. at the
Wayne County Courthouse, Waynesboro, Tennessee to discuss results of the Remedial
Investigation/Feasibility Study, answer questions and receive comments on EPA's
preferred cleanup alternative. Interested citizens are encouraged to attend this
meeting.
The alternatives considered for addressing the contaminated ground-water plume
at the Mallory Capacitor Company Site are as follows:
IA)
IB)
No Action: Alternative lA consists of implementing no remedial
action at the site, including no restriction on future installation
of ground-water extraction wells and no further monitoring of the
contaminated ground water both beneath and hydraulically
downgradient from the site.
Institutional Controls and Monitoring: Alternative lB consists of
placing deed restrictions on the site property title, a ban on
installation of ground-water extraction wells on appropriate
properties to provide protection of human health, and ground-water
monitoring beneath the site and off-site. .
Alternatives 2 through 5 are similar treatment methods in that extraction
wells will be installed and ground water will be extracted and treated.
Differences between these alternatives lie in well placement and number
and the chosen ground-water treatment technology. Extracted ground water
will be treated to remove trichloroethylene (TCE) and l,2-dichloroethylene
(DCE), and subsequently discharged to a city water treatment plant or
surface waters near the site. Alternatives 2 through 5 are as follows:
2A)
2B)
Ground Vater Eztraction and Treatment: Alternative 2A involves
installation of 6 ground-water extraction wells, 5 on-site and I
off-site, and utilization of an on-site Ultraviolet Chemical
Oxidation treatment facility. .
Ground Vater Eztraction and treatment: Alternative 2B involves
installation of 6 ground-water extraction wells,S on-site and 1
-------
3B)
4A)
4B)
5A)
5B)
off-site, and utilization of an on-site Air
FiltratIon/Carbon Adsorption treatment facility.
Stripping/Bag
f\)
Ground Vater Extraction and Treatment: Alternative 3A involves
installation of 7 on-site ground-water extraction wells and
utilization of an on-site Ultraviolet Chemical Oxidation treatment
f~cllity .
Ground Vater Extraction and Treatment: Alternative 3B involves
installation of 7 on-site ground-water extraction wells and
utilization of an on-site Air Stripping/Bag Filtration/Carbon
Adsorption treatment facility.
Ground Vater Extraction and Treatment: Alternative 4A involves
installation of 13 ground-water extraction wella, 7 on-.ite and 6
off-site, and utilization of an on-site Ultraviolet Chemical
Oxidation treatment facility.
Ground Vater Extraction and Treatment: Alternative 4B involves
installation of 13 ground-water extraction wells, 7 on-site and 6
off-site, and utilization of an on-site Air Stripping/Bag
Filtration/Carbon Adsorption treatment facility.
Ground Vater Extraction and Treatment: Alternative SA involves
installation of 22 ground-water extraction wells, 13 on-site and 9
off-site, and utilization of an on-site Ultraviolet Chemical
Oxidation treatment facility.
Ground Vater Extraction and Treatment: Alternative SA involves
installation of 22 ground-water extraction wells, 13 on-site and 9
off-site, and utilization of an on-site Air Stripping/Bag
Filtration/Carbon Adsorption treatment facility.
U.S. EPA has identified Alternative 4B as the preferred cleanup alternative for
ground-water contamination and migration at the Mallory Capacitor Company NPL
Site.
The Proposed Plan, Remedial Investigation Report, Feasibility Study Report, and
other site-related documents, including the Administrative Record, are available
for review and/or copying at the following location:
Wayne Councy Public Library
U.S. Highway 64 East
Waynesboro, Tennessee
WITTEN COMMENTS ON THE PllOPOSED ALTE1lNATIVES SHOULD BE SENT TO:
Patty Fremont
Remedial Project Manager
U.S. EPA Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
(404) 347-7791
Comments must be submitted to the above address, .postmarked on or before
July 15, 1991.
-------
EPA Announces The Availability Of The Final
Feasibility Study (FS) Report For The
Mallory Capacitor Company Superfund Site
The Final FS Report will be available for public review by Kay 20,
1991, at the Mallory Capacitor Superfund Site Information Repository
located at:
The Wayne County Public Library
U.S. Highway 64 East
Waynesboro, Tennessee 38485
(615) 722-5537
Hours:
Monday, Wednesday, Thursday and Friday:
Tuesday: 10:00 a.m. - 8:00 p.m.
Saturday: 10:00 a.m. - 2:00 p.m.
10:00 a.m. - 6:00 p.m.
For questions or comments regarding the Final FS Report, please
contact:
Patty Fremont
Remedial Project Manager
U.S. EPA Region IV
345 Courtland Street,'N.E.
Atlanta, Georgia 30365
(404) 347-7791
.?
--:c.-
-------
~tO S",.
.:.'" ~r
, I .
~ I, ~ 1
! ~ 11 ~
'-,,"'. .~!
"'> c.'
., ""'01'-
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION. IV
345 COURTLAND STREET N.E.
ATLANTA. GEORGIA 30365
THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
ANNOUNCES AN EXTENSION OF THE PUBLIC COMMENT PERIOD
FOR THE PROPOSED PLAN
MALLORY CAPACITOR COMPANY SUPERFUND SITE
WAYNESBORO, TENNESSEE
The u.S. Environmental Protection Agency will extend the public
comment period for the Mallory Capacitor Superfund Site Proposed
from July 15,1991, to August 14, 1991. written comments on the
Proposed Plan alternatives should be sent to:
Plan
Ms. patricia Fremont
Remedial Project Manager
u.S. EPA Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Comments must be submitted to the above-mentioned address; postmarked
on or before August 14, 1991. A copy of the Proposed Plan is
available at the Mallory Capacitor Co. Information Repository in the
Wayne County Library on u.S. Highway 64 East, (615) 722-5537.
PLEASE NOTE: The Proposed Plan Fact Sheet contains an error. The
estimated time of completion for Alternatives 4A and 4B is 60 years
and not 30 years as stated. EPA apologizes for this error and
welcomes any questions or comments regarding this discrepancy. EPA
has determined that Alternative 4B, the preferred alternative, is
protective of human health and the environment and provides the best
balance of the criteria considered for evaluation.
Pr!nted on Recycled Paper
-------
Attachment E
MALLORY CAPACITOR COMPANY SITE
OFFICIAL PUBLIC MEETING
TRANSCRIPT
-------
TRANSCRIPT OF
PUBLIC MEETING CONCERNING
POTENTIAL SUPERFUND SITES
IN THE WAYNESBORO AREA
WAYNE COUNTY COURTHOUSE
WAYNESBORO. TENNESSEE
JUNE 27. 1991
APPEARANCES:
Brenda Apple, State of Tennessee, Department of Health and
Environment, Head of Nashville Field Office.
Bob Powell,
State of Tennessee, Department of Health and
Environment, Project Manager/Geologist with
Nashville Field Office.
Harold Taylor, EPA, Chief, Kentucky/Tennessee
Patricia Fremont, EPA, Remedial project Manager
Jack Michels, Conestoga-Rovers & Associates, Site Manager
Tony Able, EPA, Hydrologist
Suzanne Durham, EPA, Community Relations Coordinator
Hon. Alvin Lenoir, Esquire, EPA Attorney
cAf~ff!l :13. cSigmon
COllft cl?epottn & '1/iJeol}fapGef
406 'Walel cl?oaJ
'Ylllaiki. 'Jennellee 38478
363.6200
-------
INDEX
INTRODUCTION
By Harold Taylor
Pages
PRESENTATION ON THE OLD WAYNESBORO DUMP
By Brenda Apple
PRESENTATION ON THE WAYNE COUNTY/HARDIN
HOLLOW LANDFILL SITE
By Bob Powell
PUBLIC QUESTION AND ANSWER SESSION
CERTIFICATE OF COURT REPORTER
cMeny qJ. cSigmon
COllft cI?epOftn & rv;deo9fapGn
406 r'Walel eRoad
PIllal.;. :Jennellee .38478
363.6200
4 -
8 - 14
2 -
4
8
15
-------
?age 1
PUBLIC
MEETING
2
STATE OF TENNESSEE ISSUES
3
At the end of a Public Meeting held concerning
4
the Mallory Capacitor Company National Priorities List Site
5
on June 27, 1991 in the Circuit Courtroom of the Wayne
6
County Courthouse in Waynesboro, Tennessee, there followed
7
an additional Public Meeting concerning State of Tennessee
Environmental Issues, where the following proceedings were
8
9
had, to-wit:
10
11
HAROLD TAYLOR:
Let me, by way of introduction,
12
just state that I know through some of our talks, mainly
Patty's, with some of the citizens, we realized that there
13
14
were other concerns other than the Mallory Capacitor Site
15
as far as potential. Superfund Sites in the area.
We've
16
asked the State in particular to come and at least give you
17
an up-date as to where they are on some of these sites.
So
18
the State primarily is under a cooperative agreement with
the Environmental Protection Agency and is doing the
19
20
majority of the Preliminary Assessment and Site
21
Investigation work that I ,went through earlier as part of
22
the Superfund Process before a site goes on the NPL.
So
23
with that introduction in mind, I'll at least turn it over
24
initially to Brenda Apple, who's the Head of the Field
Office in Nashville.
25
-------
1- -
Page 2
BRENDA APPLE:
We're glad to be here tonight
2
anyway.
It is a little bit longer than we're used to, but
3
we'l] stay here with the best of you.
Bob and I are going
4
to real briefly summarize activities at the Old Waynesboro
5
Dump and the Wayne County Landfill, which are probably the
6
two sites that most of you are interested in, other than
7
the Mallory Site.
That really shouldn't take long.
We've
8
handed out a hand-out that basically puts in writing what
9
we're going to tell you, so we'll just go on with it and
10
see if you have any questions.
11
There's a fairly long history with the Waynesboro
12
Dump, which is the one I'm going to cover first.
I'm
13
really not going to get into the history.since I did
outline the highlights on the hand-out for you.
14
15
One of the main interests, I guess, is a lot of
16
the sampling that was done on the Site, and I'm going to
17
really briefly summarize that for you.
18
The two main concerns that I'd like to break it
19
down into, the leachate, the Beech Creek water and
sediment, that being the surface type contamination, and
20
21
then the second category would be the ground water.
First of all the leachate and Beech Creek water
22
23
and sediment.
Early in the '70's, PCB's, TCE, vinyl
24
chloride and other VOC's were found either in the leachate,
.25
the Beech Creek water or the Beech Creek sediment.
More
-------
Page 3
sampling was done in the 1980's, including an eighteen (18)
2
month study.
PCB's during that sampling both increased and
3
decreased in the sediments taken at different locations.
4
So it's hard to say there was any trend found, because
5
there certainly wasn't.
At one time in the sample the
6
concentrations would go up and the next time they'd be
7
down.
Later sampling or the most recent sampling done
8
between 1987 and 1988 showed PCB's decreasing at four (4)
9
or five (5) locations.
It's hard to say one sampling then
10
is a trend.
There is a definite tendency for the level of
11
the PCB's to decrease with increasing distance from the
12
Dump.
That's really not hard to believe.
No vinyl
13
chloride or TCE was found in the latter sampling, however
14
other VOC's, including DCE, were found.
1S
As far as the ground water is concerned at the
Old Waynesboro Dump, PCB's have not been found in the
16
17
ground water.
A slight trend toward increasing nickel
18
levels has been observed, and VOC's were detected
19
sporadically in some of the wells.
Most of the levels were
20
typically below ten (10) parts per billion.
21
As far as where the Site is now, there has been a
22
recent visit to the Site.
We have made field trips over
23
the years, but most recently we were at th~ Site this past
24
week.
It did show that some operational maintenance was
2S
needed, such as cutting the grass and removal of sediment
-------
Page 4
which had built up in the concrete channels which drain
2
from the Site.
Overall the Site did look fairly well.
3
Leachate was observed at three (3) locations, and
4
basically as far as future activities, there is definitely
5
a need for periodic sampling of the ground water, the
6
leachate, Beech Creek water and sediment.
Further
7
investigations by the State under the Federal Program are
8
also planned.
A Site Investigation which will include
9
additional sampling and a preliminary ranking for the Site
10
is scheduled for the Spring of 1992.
I'll let Bob bring us kind of up to date real
11
12
Quick on the Wayne County Landfill iite.
13
BOB POWELL:
Is anybody interested in the Hardin
14
Hollow situation?
I'll bring us up to date on that.
Some
15
of my comments will be restricted tonight for technical
16
reasons and mainly too because our contractual arrangements
17
with USGS to produce a report which gives us a real good
baseline on the hydrogeology, the stream sediment, the
18
19
surface water, all the contaminants associated with the old
20
Wayne County/Hardin Hollow Site are still out.
I've got a
21
very, very provisional draft form that I just got in May,
and I'm not even allowed to quote it yet, because it's
22
23
still undergoing in-house review, but I will refer to it in
24
terms of the conceptual findings of the Site.
Just to get back briefly to the history of what
25
-------
Page 5
2
the State has done, just to hit a few highlights, of course
the Landfill operated from '76 until 1984 and was ordered
3
to close by the Division of Solid Waste Management, and we
don't feel like that closure was properly done based on
4
5
several factors.
Also in 1987 we screened the Site through
6
the Site Inspection Program for the NPL List and it scored
7
only twenty point five (20.5).
At that time it was
8
referred back to the State for further consideration.
9
At that time we then felt like well there might
be other problems associated with the Site, particularly in
10
11
lieu of some lawsuits that were made, and since we knew
12
that some of the streams were losing streams down gradient
13
and everything, the USGS was contracted.
They submitted a
14
Proposal in 1987 to investigate the Site.
The
15
investigation got under way in 1988 and we're just now
16
getting the final results.
You know, we are concerned
17
about the delay, but the basic overall finding is that they
found nine (9) parts per billion of PCB's in the head of
18
19
Moser Branch in the sediments only; no leachate indicated,
20
PCB's.
There were fifty-seven (57) parts per billion of
21
PCB's and. thirteen (13) found in two (2) sediment cores
22
from the retention pond at the bottom or the ba$e of the
23
Landfill.
No PCB's were found in any of the sixteen .(16)
24
wells, just a very trace of ethyl benzene and
25
toluene xylene in very, very low levels, and some
-------
Page 6
incidental metals were found be'low drinking water limits.
2
Some of the leachate, the stream sampling data, indicated
3
limits above water pollution control limits, which I think
4
is mainly associated with the condition of the cap.
5
On March 22nd of 1990, the County Executive,
Cory Anderson, Joe Walkup, Tom Moss and myself, Joe is with
6
7
the Division of Solid Waste Management, we did a complete
8
Site Recon to look for potential 'further action to take.
At that time we did sample the leachate and it did have
9
10
cadmium, copper and lead above water pOllution limits in
"
the leachate, but the cap seems to be settling.
It seems
12
to be ponding.
You've got large chert fragments in the cap
13
and the leachate is just collecting in these potholes---I
14
mean the infiltration is, and just forming as leachate
along the flanks, and we believe that it's because the cap
15
16
was not ever properly closed.
So that is a concern.
17
Brenda and I really planned, if it was
18
significant enough, that as soon as we got a final report
from the USGS, and you're welcome to look at this, then we
19
20
would maybe come down 1f there was concern and maybe up-
date further, do our own pUblic meeting, but we're really
21
22
not at liberty at this time to discuss those kind of
particulars.
23
24
The future of the Site, as you mayor may not
know, they put in sixteen (16) wells adjacent to the
25
-------
Page I
facility on two sides and down in Hardin Hollow, the Banjo
2
Branch Area.
The USGS is in the process of turning those
3
wells either over to us or the Division of Solid Waste
4
Management, depending on who is going to end up with the
5
Site.
That will be resolved once we get the conclusions
6
from this Report finalized, because it may be that they
would want to close the cap under Solid Waste Management
7
8
because they began that process back in what was it, '85, I
9
think.
But anyway, since there were some incidental
10
contaminants indicated in som~ of the sampling, there has
11
been a consideration to resample some wells, to continue to
12
monitor the leachate and definitely to see about getting
this cap properly constructed, because we believe that's
13
14
the best way to alleviate this problem since there's been
15
no off-site contamination indicated in any of the wells to
16
any extent away from the Landfill.
We believe that
17
basically we have just a leachate problem.
The geology lends itself such that you have a
18
19
siliceous Fort Payne and you have the Chattanooga
20
underneath that, so the water that goes through the
Landfill tends to just level out and issue out as leachate
21
22
on the flanks, because those units are hydrologically
23
impermeable.
They don't transmit much water, but as it
24
goes out into surface in-flow, it's indicated by the
25
Report, and like I say, these are some of the conclusions
-------
Page 8
that the USGS wants to refine and that's why I'm not at
2
liberty to go into any more detail, but they are losing
streams and all the basal units below the valleys do tend
3
4
to be hydrologically connected, but I can't really comment
5
any more on the conclusions at this time.
That's pretty
6
much it.
The Site will continue to be monitored.
The main
7
thing we see is that the cap needs to be addressed.
It's
8
in very poor quality.
9
Somebody had a question.
10
BILLIE JEAN HOLLIS:
I was going to ask you, did
11 .
I understand that there had been no leachate off-site?
12
There's been no contamination
MR. POWELL:
13
indicated off-site.
There's leachate emanating from the
14
sides of the Landfill in the headwaters of Moser Branch and
15
over in the Banjo Branch Area.
16
MS. HOLLIS:
MR. POWELL:
But not contaminants?
17
But no contaminants have been
18
detected down stream from that.
19
DAVID BAKER:
MR. POWELL:
In the surface water?
20
In the surface waters, right, or
21
even the wells.
22
MR. BAKER:
MR. POWELL:
What about the Gallaher's well?
23
Well see, the problem with that is,
24
and I'm not really going to get into that, but see, if you
25
have a losing stream, which was indicated, and this is my
-------
recollection now.
Flage 9
2
that Report, but her well i8 potentially tied to those
It's been a long time since I've read
4
streams down there.
losing streams, the gravels associated with those losing
So that doesn't necessari1y---
3
5
MR. BAKER:
6
MR. POWEll:
What do you mean by "losing stream"?
Okay.
The water comes out, but it's
7
in contact with surface flow for a certain a~ount of time,
and then it goes into fractures and---
8
9
MR. BAKER:
MR. POWEll:
10
Oh, I see.
11
contamination directly on the Wayne County landfill.
---so you necessarily can~t pin that
13
there?
MS. HOllIS: . But there was contamination in
12
14
MR. BAKER:
15
MR. POWEll:
Well the lawsuit pinned it on them.
17
don't know.
it was, but it was reversed, the way I understand it, so I
The lawsuit, I think, initially said
16
18
MS. HOllIS:
20
MR. POWEll:
something thousand dollars.
But we paid her a hundred and
19
21
supplied some money to her, I think, but I think the actual
Yeah, you supplied water and you
Findings were reversed later on appeal, but I'm not at
22
That's a long time ago.
24
MR. BAKER:
liberty to even comment on that.
I'd like to go back to the Old Wayne
23
25
County Dump.
The thing that concerns me and a lot of
-------
Page 10
people who aren't here, but who I'm aware of their
2
concerns, especially people, friends of mine, who live on
3
Beech Creek, is just the large Quantity of hazardous
4
materials that was buried out there.
They look at what was
5
done over at the Mallory Site where they spent all this
6
money to dig up stuff and haul it away.
I mean they
7.
weren't digging up oil filled capacitors and drums full of
8
oil and stuff like that.
They were just digging up dirt.
9
I mean why is there a double standard here?
Why can't we
10
get this removal action for this?
11
i guess to put it in a nutshell, the
MS. APPLE:
12
original idea was to go back in and cap the Site.
There
13
is, like you said, a large quantity and naturally the most
cost effective thing, whether to go in and dig up a
14
15
mountain, is to cover it.
Hopefully the cap was going to
16
stop the leachate from migrating from the Site.
it didn't do that.
Obviously
17
18
Well why didn't they just put a cap
MR. BAKER:
19
over on the Belew Circle Site, the Mallory Site?
20
MS. APPLE:
MR. POWELL:
That's not my---
21
Well the ground water concerns here
22
are much more---
23
MR. BAKER:
Well the question comes down to,
24
"What are the parameters that determine a high score on
this HRS" and honestly I don't want to burden you with
25
-------
Page 1
going into it, but just to bring up the issue and then
2
leave it.
Is it because of---
3
MS. APPLE:
You look at pathways and targets and
4
observe releases.
5
MR. BAKER:
MS. APPLE:
People, the population; you know,
And the number of people?
6
7
there are 'a lot of factors that are taken into the ranking.
and supposedly or hopefully by us ranking the Site, you
8
9
know, considering the conditions of the Landfill now, even
though it was capped it does have leachate still emanating
10
11
from the Site.
So all of those things will be taken into
12
consideration.
There has been monitoring done.
13
MR. BAKER:
Here's what I'm thinking.
Okay.
14
You've got all of this stuff here and as long as it's
15
there, it's there.
The cap and the little concrete run-
16
ways and all that stuff are not being well maintained.
17
Over a period of time they're going to deteriorate if
18
they're not upgraded over time.
As long as that stuff is
19
there, it's like a hammer suspended over that whole
20
Community.
21
MS. APPLE:
Well after the Site is ranked, that
22
decision, at least on a Federal level now, will be made as
to "Yes, this warrants further investigation and/or
23
24
remediation," dig it up or whatever the solution might be,
25
or on a Federal level they'll decide, "This doesn't rank up
-------
Page 12
here with other Federal sites, so we give it back to the
2
State."
3
MR. BAKER:
4
and let the State---
5
MS. APPLE:
And they'll turn it back to the State
Then the State will look at that and
6
say, "Yeah, we've got a problem, but where does that fit
Is it up here with the other
7
into this scheme of things?
Is it up in the top and we
8
two hundred sites in Tennessee?
10
~ant to go in there and require someone to spend millions
of dollars to dig it up," or, you know, based on the
9
12
MR. BAKER:
problems that we have there, "Can we do something else?"
So your office will be doing the
11
13
hazardous ranking?
14
MS. APPLE:
15
MR. POWELL:
16
MS. APPLE:
17
that.
18
MR. BAKER:
Right.
Well we do that for---
We're under contract to do that.
We're under contract with EPA to do
19
with the Mallory Site, at what point does information
What about, and this was a problem
21
MR. POWELL:
develop during this investigation become public?
All our files are open.
Our fil es
20
22
are open.
23
MS. APPLE:
MR. BAKER:
24
25
When the Report is complete.
On the Mallory Site, it was like
pulling teeth to get information.
-------
Pa:;,~ \ 3
MR. POWELL:
Our files are open, Sir.
You're
2
welcome to see them.
3
MS. APPLE:
Well as soon as the Report is
4
complete. you're welcome to them.
5
MR. BAKER:
See, they were sharing
Oh, no.
6
information with Mallory all along, even getting some of
the information from Mallory, and they were giving Mallory
7
8
all of the information that they were developing, but they
9
wouldn't bother to release it to the Public.
There's a
10
little double standard there.
11
MS. APPLE:
Well we compile a Report and once
12
it's submitted to EPA they either say, "Yeah, you've
13
completed it," or "No, you haven't."
Once they say,
"Yes,
14
it's complete," then as far as we're conc~rned, it's, you
15
know.
16
MR. POWELL:
Are you talking about after it's
17
kicked back to the State and we're working on it and
gener~ting information, or are you talking in the pre-
18
19
remedial. screening process, because there is a difference?
20
MR. BAKER:
I don't know.
I'm tired.
That was a
21
long time ago.
22
MS. APPLE:
As soon as, EPA says, "Yeah, that's a
23
complete report," I mean, it's pUblic information.
24
MR. POWELL:
I mean, we're under contract with
25
them.
-------
r
.~age '4
MR. BAKER:
Well if you were to be sharing
2
information about the Site with Mallory or some other PRP
3
and not with the Public, that would seem to me to be pretty
4
inconsistent.
5
We don't do that.
Our files are open
MS. APPLE:
6
to whoever walks in the door.
So if you beat Mallory up
7
there, then you get it first.
If they don't come, then
8
they don't get it.
We don't have a mailing list.
9
But that is what happened in this
MR. BAKER:
10
other instance to my personal knowledge.
I was just trying
11
to find out what the ground rules are beforehand.
Like the
12
other time, it was like I was just trying to find out what
13
was going on and I hit a brick wall.
14
MS. APPLE:
Well you shouldn't hit any brick
15
walls.
Once the Report is complete, you're welcome to it.
16
MR. POWELL:
Is that it?
17
(No further Questions were posed.)
18
MR. POWELL:
Thank you.
19
Again, we thank you all for
HAROLD TAYLOR:
20
taking your own personal time to come out tonight and talk
21
to us.
22
23
(WHEREUPON THIS MEETING WAS CONCLUDED.)
24
25
-------
Page 15
STATE OF TENNESSEE
COUNTY OF WAYNE
I. Merry B. Sigmon, Court Reporter and Notary
PUb1ic-at-Large wlthin and for the State of Tennessee, do
hereby certify that the foregoing pages constitute a full,
true and correct transcript of a Public Meeting held in the
Wayne County Circuit Courtroom in the Wayne County Court-
house in Waynesboro, Tennessee, on June 27, 1991.
I further certify that the Public Meeting was
held in regard to Potential Superfund Sites in the Waynes-
boro Area and was conducted by employees of the Department
of Health and Environment from the State of Tennessee.
I further certify that this transcript contains
all of the presentations made by the Department of Health
and Environment employees, as well as comments and
Questions offered by the Public.
I do further certify that I am neither of kin.
counsel nor interest to any party hereto.
WITNESS my hand and seal this 12th day of July,
)991.
on, Court R orter
c-at-Large/Tennessee
My Commission Expires:
July 20, 1992
cA1eff!j r.B. <:Sigmon
COllft d?eportn & q)iJeof}fap&n
406 r"Wa!eJ d?oaJ
'J'1I!aJ&i, tJenneuee 38478
363.6200 .
-------
TRANSCRIPT OF
-
PUBLIC MEETING CONCERNING
MALLORY CAPACITOR COMPANY
NATIONAL PRIORITIES LIST SITE
WAYNE COUNTY COURTHOUSE
WAYNESBORO, TENNESSEE
JUNE 27, 1991
APPEARANCES: .
Harold Taylor, EPA, Chief, Kentucky/Tennessee
Patricia Fremont, EPA, Remedial Project Manager
Jack Michels, Conestoga-Rovers & Associates, Site Manager
Tony Able, EPA, Hydrologist
Suzanne Durham, EPA, Community Relations Coordinator
Hon. Alvin Lenoir, Esquire, EPA Attorney
cMn'lY qJ. cSigmon
Court d?eportn & f1)iJeo9rQP/'n
. 406 rwQfel d?OQJ
PufQlki. 'Jennellee 38478
363-6200
-------
INDEX
WELCOME AND OPENING COMMENTS
By Harold Taylor
EXPLANATION OF AGENDA AND
INTRODUCTION OF PARTICIPANTS
By Harold Taylor
DETAILS OF SUPERFUND PROCESS
By Harold Taylor
DETAILS OF SITE HISTORY
By Patricia Fremont
DETAILS'OF SITE SAMPLING INVESTIGATIONS
By Jack Michels
DETAILS OF HYDROGEOLOGY IN AREA
By Tony Able
DETAILS OF PROPOSED REMEDIAL ALTERNATIVES
By Patricia Fremont
DETAILS OF COMMUNITY RELATIONS PROCESS
By Suzanne Durham
DETAILS OF THE EPA ENFORCEMENT PROCESS
By Alvin Lenoir
SUMMARY
By Harold Taylor
PUBLIC QUESTION AND ANSWER SESSION
CERTIFICATE OF COURT REPORTER
cM~ff!l <]3. <:Sigmon
Couft d?tpodn & CViJto1faphn
406 quart. d?oaJ
tyura.&i. 9tnntlltt 38478
363.6200
Pages
1 -
2 -
5 -
9 -
12 -
22 -
25 -
33 -
36-
42 -
44 - 102
2
4
9
12
22
25
33
36
42
44
103
-------
Page 1
2
PUBLIC MEETING
MALLORY CAPACITOR COMPANY NATIONAL PRIORITIES LIST SITE
3
4
A pUblic meeting in regard to the Mallory
Capacitor Company National Priorities List Site was held on
5
6
June 27, 1991 in the Circuit Courtroom of the Wayne County
7
Courthouse in Waynesboro, Tennessee, where the following
8
proceedings were had, to-wit:
9
10
MR. TAYLOR:
I'd like to welcome everybody
11
tonight.
My name is Harold Taylor, and I'm the Chief of
12
the Tennessee/Kentucky Remedial Section with the United
13
States Environmental Protection Agency, Region IV, and we
14
work in Atlanta, Georgia.
From the Atlanta Office we work
15
the eight southeastern, southern states, Alabama, Georgia,
16
Mississippi, Tennessee, Kentucky, North Carolina, South
17
Carolina and Florida.
We're here, and I'm sure everybody
18
knows; for the proposed plan on the Mallory Capacitor Site.
I'll go over the Agenda real briefly here with you.
19
20
The first thing I'd like to do i8 I'd like to
thank the City and County for their work putting the
21
22
meeting together tonight, putting the building together for
23
us.
Cory Anderson was real helpful getting everything put
24
together.
We met with Ken Burress today and Ken .was
25
helpful.
Floyd Matthis has helped us get 811 of the
-------
Page 2
equipment and everything together and we really appreciate
2
that.
We do have a
I hope everyone signed in out front.
3
Sig~-In sheet, because we'd like to have a record of who
4
was here and particularly if you want information in the
5
future, there's a place to mark out there.
Also out there,
6
if any of you didn't get a copy of the proposed plan 1n the
7
mail, there are extra copies out there.
There are copies
8
of tonight's agenda.
There are some slide packets with
9
some of the overheads that we'll show tonight.
There is
10
some general information on the Superfund process.
There's
11
some envelopes for people that would like to mail in
12
comments during the public comment period.
There's some
13
Site Assessment Petitions for those of you that know about
other sites that you want to identify to the Agency.
14
15
There's some information on technical assistance grants
16
that we'll describe a little bit later tonight.
There's
17
some calling cards for Patty, who's the Remedial Project
Manager for EPA, and there's two sets of fact sheets on
18
19
PCB's for those of you that want additional technical
20
information on PCB's.
21
If I could, I'll go over the agenda and explain a
few of the participants who are here today and who are
22
23
sitting up front and in the audience.
Again, I'm Harold
24
Taylor and I'm going to basically conduct the meeting
25
tonight.
We'll have a Question and answer period at the
-------
1-
Page 3
2
end and what I'd like for you to do i8 hold your questions.
We've got about a one hour presentation that we'd like to
3
go oyer with you and then we'll have questions and answers
4
until you run out of Questions or we run out of answers.
5
And because we do know there are other interests in the
6
area besides the Mallory Capacitor Site, when we get
through with the questions and answers on the Mallory Site,
7
8
we'll take about a ten minute break and we'll have EPA and
9
some of the State personnel to answer any other questions
10
that you have or discuss some of the other activities that
11
are going on in the environment around this area.
12
If I could, I'll introduce Patty Fremont.
Patty
13
is the Remedial Project Manager for the Mallory Capacitor
14
Site.
She works in
She's an EPA employee just like I am.
15
Atlanta, Georgia.
She works on Tennessee and Kentucky NPL
16
sites, National Priority List Sites.
17
Jack Michels, Jack, if you could, just stand up
18
real quick.
Jack is a consultant with Conestoga-Rovers &
19
Associates.
As you know they did a lot of the work out
20
here after '88.
21
Tony Able, would you stand up?
Tony is a
22
Geologist who's in our Ground Water Division, ~nd Tony
23
gives the Superfund Program expertise on geology and
24
hydrogeology.
He's the Project Manager for that aspect of
25
the Project at the Mallory Site.
-------
Page 4.
Suzanne Durham, you should have met Suzanne when
2
you came in.
Suzanne is a Community Relations Coordinator
3
for the Mallory Site and for every other site in Tennessee
4
and Kentucky.
5
Alvin Lenoir, Alvin is an attorney.
Alvin is an
6
Assistant Regional Counsel with the Environmental
7
Protection Agency.
He also works in Atlanta, Georgia, and
8.
he's the case attorney for the Mallory Superfund Site.
9
Kevin Koporec, Kevin is a Toxicologist.
Kevin
10
works in EPA's Risk Assessment Group and gives expertise ,to
both the Superfund Program and our ongoing Hazardous Waste
11
12
Program for toxicology and health assessments and risk
13
assessments.
14
We've got a few State people here.
Brenda, if you would, just raise your hand.
Brenda is with
Brenda Apple,
15
16
the Nashville Field Office and I guess works in the mid
17
part of the State for the Superfund.
Robert Powell is also with the Nashville Office,
18
19
and Daniel Roop.
So basically what we'll do tonight in hopefully
20
21
about an hour is we'll go over the Site history briefly; 90
over the Site sampling investigation that was done as part
22
23
of the Remedial Investigation.
We'll 90 over the
24
hydrogeology, in other words, the ground water in the
25
We'll go over the proposed alternative
Waynesboro area.
-------
r
Page 5
that EPA has chosen for the Mallory Capacitor Site.
We'll
2
go briefly over the Community Relations Process.
We'll go
3
ove~ the EPA Enforcem~nt Process, and like I say, we'll try
to do that in about an hour and then we'll open the meeting
4
5
up for as long as it takes on questions and answers.
Then
6
we'll have a brief ten minute break, and those of you that
7
are interested in other concerns in the area, we'll have a
8
brief presentation by the State and we'll answer questions
9
that you may have about those issues.
We're just real briefly going to go over the
10
11
Superfun~ Process.
As you see the first stage is Site
12
Discovery.
There are over thirty thousand (30,000) aites
13
in EPA's inventory of potential hazardous waste sites
14
across the Country.
EPA will basically, when sites are
15
discovered, will go through this process.
They'll look at
16
sites for potential ranking and listing on the National
17
Priorities list.
The Mallory Capacitor Site went through
18
this process back in the late '80's.
We'll do what's
19
called a Remedial Investigation and Feasibility Study and
20
-
those are what we've just completed at the Mallory
Capacitor Site, and then we'll go through the Record of
21
22
Decision, which is basically a document that basically
documents the chosen alternative for EPA for the site. Then
23
24
we'll go into the Remedial Design Phase and then Remedial
25
Action Phase.
So basically we're right towards the end of
-------
Page 6
this process today with the Mallory Site.
I'll jU8t
2
briefly go over how a site can be discovered.
Basically
3
anyone, any private citizen, or any governmental body can
4
discover a site, and we have some Site Assessment Forms
5
outside, if people know of sites they want to identify to
6
the Agency, they can do so.
Most often the sites are
7
referred to either the State or EPA.
Also for those of you
8
who are familiar, there's several tracking systems that
9
were set up to discover sitee.
Senator Eckhardt in Texas,
10
back in the '70's, basically passed some legislation that
made the fifty major chemical companies in the United
11
12
States report all of their sites where they had dumped
13
anything.
Later the Hazardous Waste Program came along and
14
made all generators, treatment facilities, storage and
15
disposal facilities notify the Agency.
Then later
16
Superfund came along and required anybody that had
knowledge of any hazardous materials being disposed of to
17
18
notify the Agency, and like I said, originally just about
anybody can report a site to the Agency.
19
20
Once sites are reported, .ither the State or EPA
will conduct a Preliminary Assessment and if necessary, a
21
22
Site Investigation.
The Preliminary Assessment and Site
23
Investigation will basically just be conducted to determine
24
if the site warrants further action.
A site at that point
25
may be turned over to our removal group, to go out and pick
-------
Page 7
up a few drums or do whatever is neces8ary to eliminate an
2
immediate hazard, or it may just 90 into a safe phase,
3
which says there is not an immediate concern, but it does
4
need to be looked at further, and it could basically go to
5
the National Priority List eventually.
6
If the site does warrant further attention,
generally what's done after the Site Investigation is a
7
8
Hazardous Ranking is done.
The Hazardous Rankin; is
9
basically just a numerical system that the Agency created
so that we could compare hazardous waste sites across the
10
11
Country and rank the ones that we thought were the worst or
12
that reQuired Federal attention.
The first Hazardous
13
Ranking System that was put together was a system where you
could score up to one hundred (100) points, and anything
14
15
over twenty-eight point five (28.5) on the original HRS, or
Hazardous Ranking System, would go on the National
16
17
Priorities List.
Again, the Mallory Site went on the NPL
18
several years ago.
19
Again, the National Priorities List is just a way
to basically prioritize sites for Federal involvement.
20
21
Only a site that has been proposed and is on the NPL is
eligible for Federal money for remedial action, and we do
22
~.
update the NPL every year.
24
Again, there's several ways a site can be put on
25
the NPL.
A score under the old system, a score of 28.5,
-------
Page 8
2
would be the State's number one priority and there are
several special cases where, for example, a site would pose
3
a significant pUblic health threat but not rank in that
4
numerical system, then there is a mechanism to put it on
5
the NPL.
6
Again, the HRS was just a way, and the National
7
Priorities List, for Congress to prioritize sites for
8
Federal involvement.
9
Just for your information there are about twelve
10
hundred (1,200) NPL sites across the Nation.
There are
11
fourteen (14) total in the State of Tennessee.
There's
12
one, of course, as you're aware, in Waynesboro, the Mallory
13
Capacitor Site; two (2) in Lawrenceburg; there's four (4)
in the Memphis area; there's one (1) in Chattanooga; one
14
15
(1) in Lewisburg; one (1) in Wrigley, and of course the
16
Army Milan Facility and Oak Ridge.
Those are all on the
17
National Priorities List.
There's one in Jackson too, the
18
American Creosote Site.
Again, after a site is put on the
19
National Priorities List, the Agency will either through
its own funds or through the funds of a potential
20
21
responsible party, will do a Remedial Investigation.
That
22
is just to identify the nature and extent of cqntamination
and come up with enough information to do a Risk
23
24
The Risk Assessment that's done will evaluate
Assessment.
25
the risks posed by the site, and the risks will be
-------
Page 9
Quantified via the routes of exposure.
In other words, if
2
someone could get exposed to contaminants by drinking the
water, then that's one of the risks that would be
3
4
evaluated.
5
After the Remedial Investigation there will be a
Feasibility Study done which will determine the most
6
7
feasible alternatives for remediating the contamination
8
that was found during the Remedial Investigation.
After the Feasibility Study is done, the Remedial
9
10
Design is done, just basically like if you were going to go
out and build a house, you wouldn't build it without plans.
11
.12
Well the Remedial Design is just a way to come up with
13
plans for how you're going to clean up the site.
14
After the Remedial Design, then the actual clean
up work will be done, or the Remedial Action.
15
16
Again, just to kind of refresh you, we're here
17
tonight to discuss the Mallory Capacitor Site and the RI/FS
that's been done, the Proposed Plan that fits somewhere in
18
19
the middle, and basically the process that will continue
after tonight.
20
21
Okay, with that I'll turn it over to Patty and
she'll go basically over the Site history briefly with you.
22
23
MS. FREMONT:
Good evening.
What I'd like to do
24
now is give a brief run-down of the history, operations and
ownership, and activities occurring up until now at the
25
-------
Page 10
Mallory Capacitor Site.
2
As most of you know, the Mallory Capacitor Site
3
is l~cated in Waynesboro here, on the western bank of the
4
Green River on Belew Circle Drive.
For those of you who
5
may be unfamiliar with it though, this kind of gives it in
6
purple right there (gesturing to map of site).
The Site was originally developed in the late
7
8
1940's as a manufacturing facility for the footwear
9
industry.
In 1968 it was acquired by P. R. Mallory, Inc.,
10
a corporate predecessor to Duracel1 International. From
11
1968 to .1979 Mallory (or Durace11) pr~duced electrical
12
capacitors on the site using Polychlorinated Biphenyls or
13
PCB's.
In addition to this they used Trich10roethene, or
14
TCE, and Dich10roethene, or 1,2-DCE, as degreasers.
Emhart
15
Industries purchased the site in 1979 and also used it for
16
manufacturing electrical capacitors.
Emhart, however, did
17
not use PCB's in its process, only the TCE and 1,2-DCE as
18
degreasers.
Emhart operated from 1979 until 1984 when
19
routine still bottom testing revealed PCB's.
The plant was
20
subsequently shut down.
Emhart sued Duracel1 for PCB
21
liability on the Site.
This went on from about 1984 until
~
1988.
Currently the Site is titled Battery Properties,
23
Inc.
24
A highlight of some 01 the activities occurring
25
with the Site is as follows:
From 1976-1980, Durece11 or
-------
Page 11
Mallory conducted remedial actions to remove the following
2
materials containing PCB's:
plant equipment, an
3
und~rground storage tank, and soil around the storage tank
4
since the storage tank had been leaking.
From 1984-1988
5
Emhart conducted investigative programs as part of the suit
6
against Durace11.
These investigative programs revealed
7
PCB's in portions of the plant structure, process
8
equipment, and the site soils.
In addition .to this,
9
significant concentrations of PCB's, TCE, and 1,2-DCE.were
also found in the ground water.
10
11
EPA got formally involved in February of 1988
12
when it entered into a Consent Order with Durace11 for
13
conducting a Remedial Investigation and Feasibility Study
14
out at the Mallory Site.
Additional actions undertaken
15
from 1988 to 1989 as part of this Consent Order, in
16
compliance with it, included disposition of all equipment
and stock from the Site, removal of the plant, except for
17
18
the warehouse, and removal of all on-site soils with
19
signifi~ant PCB concentrations.
Now all of this was
20
overseen by EPA.
Soil removal came to approximately twenty
21
thousand (20,000) tons.
It was about that amount, twenty
22 .
thousand tons, for the plant and equipment and debris
23
removal also.
All materials which were removed were taken
24
to the Chemical Waste Management Facility in Emelle,
25
Alabama.
Eme11e i8 a federally approved hazardous waste
-------
Page 12
2
facility for storing and treating these kinds of wastes.
I'm going to speak a little later about the
3
Feasibility Study and the Proposed Plan for Remedial
4
Action, but right now I'd like to turn it over to Jack
5
Michels of Conestoga-Rovers & Associates.
He's been the
6
Site Manager out at the Mallory Site in conducting the
7
Remedial Investigation and Feasibility Study.
He's going
8
to tell you a little more about the Remedial Investigation,
9
which again was conducted to determine the nature, extent
10
and volume of contamination.
11
MR. MICHELS:
My name is Jack Michels and I'm
12
with Conestoga-Rovers, and I've been at the Mallory Site
13
throughout the whole process of the Remedial Investigation
14
conducted with EPA.
You heard Patty talk about certain
15
contaminants of concern at the Site, 1,2-0CE, TCE and
16
PCB's.
At the initiation of the Remedial Investigation,
17
the first thing we had to ascertain was which contaminants
18
are of a concern at the Site.
So samples were collected
19
from inside the plant, in the former impregnation room
area, where we know the PCB oils were used and .where
20
21
degreasers were used.
We collected samples from the soils
22
outside of the plant, which previous investigations had
shown to be contaminated, and we collected ground water
23
24
samples from the monitoring wells closest to the plant.
All those samples were analyzed for the complete list of
25
-------
Page 13
contaminants that EPA has, and that list of contaminants
2
includes volatile organics, base neutral acid compounds,
3
pesticides, PCB's and inorganics.
In total there's about a
4
hundred and fifty (150) compounds that were analyzed and of
those compounds it was confirmed that 1,2-0CE, and TeE were
5
6
the volatile contaminants of concern.
They're common
7
contaminants that are used in degreasers a. cleaning
8
solvents, and Polychlorinated Biphenyls, which are the
PCB's which were used in the oils to impregnate the
9
10
capacitors.
So we confirmed that the contaminants of
11
concern at the Site were limited to tho.e three compounds.
12
Having confirmed the contaminants of concern at
13
the Site, the investigation then focused on collecting
samples from all of the media at the Site, so that we could
14
15
do a complete sampling program of the entire Site.
I have
16
little figures for each of these different areas, but in
general we collected and analyzed soil samples from all
17
18
areas of the Site, the grassed areas West and South of the
Site between the Plant and the Green River, an area that'.
19
20
used as park land.
We collected sample. along sewer lines
21
from the plant.
We collected samples from beneath the'
22
plant.
We went off-site.
We collected soil samples from
23
all of the private properties adjacent to the Site.
We
24
a180 collected sediment samples from the Green River,
sediment samples from sewer systems leading away from th~
25
-------
Page 1~
Site.
We installed approximately another thirty (30)
2
ground water monitoring wells in addition to the well. that
3
wer~ already at the Site.
Those wells are located both
4
on-site and off-site.
We collected and analyzed samples of
5
ground water collected from the Green River.
We collected
6
air samples as well from around the perimeter 0' the Site
7
and we collected some samples 'rom within the warehouse,
which is the only structure that currently remains on Site.
8
9
Of the soil samples that I had mentioned, this
yellow boundary outlines the Site and we're facing North
10
11
there with Mariva Street on the South and Belew Circle
12
Drive on the North.
The ditches that flow around the Site
13
are highlighted in green.
We basically collected .oil
14
samples all along each of the ditches of the .ite.
We
15
collected samples along the sewer lines of the Site, and
then we collected soil sample. basically on a fifty (60)
16
17
foot grid throughout the whole Site, surficial soil samples
18
and then progressively deeper with depth.
This particular
19
figure does not 8how any samples co11ected in the main area
0' the Site here, because those are the areas that were
20
21
remediated in 1988-1989.
These are where the soils were
22
removed that Patty was talking about, 80 those areas were
23
all cleaned up in 1988 and 1989.
The result8 of all of
24
th08e samples showed that of the two 80lvent contaminant.,
25
1,2-OCE was not detected in any of the s011 samples.
TCE
-------
I -
Page 15
was detected in a few of the soil sample., but at very low
2
concentration., less than one (1) part per million.
PCB'.
3
were detected in both the surficial soil samples and the
4
soils deeper with depth.
The average concentration was
5
less than two (2) parts per million for all the surficial
6
soil samples that were collected and the average
concentration for all the soil samples collected, including
7
8
the ones at depth, was in the order of three (3) to four
9
(.) part8 per million.
The sample8 collected along the
10
ditches and the swales all showed similar concentration. as
11
we 11 .
~o all those concentrations are very much less than
12
the clean-up levels that were required to remediate the
main area of the Site.
13
14
The soil sampling program a180 included a
collection of soil samples from all of the yards that were
15
16
adjacent to the 8ite boundary.
We basically collected
17
three (3) 80il samples from each of the yards.
All those
18
8amp1e8 were analyzed and the average concentration in
those 80il 8ample8 off-8ite were approximately one order of
19
20
magnitude le88 than the average concentration of. the soil
21
8ample8 on-site.
They averaged about point two (.2) part8
22
per million, instead of the average of two (2) part8 per
million for the soil. on-.ite.. Again,the average
23
24
concentration i. le.8 than one (1) part per million, very
low concentration..
25
-------
Page 1e
2
We talked about collecting sediment sample..
collected sediment samples from locations in the Green
we
3
River.
These red dots represent the sediment sample..
We
4
collected up stream from the Site and basically collected
right along the bank of the Site where the storm sewer.
5
6
used to discharge to the Green River from the Site, and
then we collected samples a hundred, two hundred, and three
7
8
hundred feet down stream from the Site in the Green River.
9
We also collected sediment 8amples from the manholes on the
10
sanitary sewer system, the storm sewer system, coming from
11
Of those samples that were collected, the
the Site.
12
solvents were not detected in any of the samples.
We
13
detected PCB's at less than a part per million in one
14
manhole on the sanitary sewer system, but it was not
15
detected in the next manhole down stream.
We detected
16
PCB's in one of the eight sediment samples collected from
the Green River, and that was the sample right adjacent to
17
18
where the storm sewer used to discharge to the Green River.
19
That storm sewer has since been removed and PCB's were not
20
detected in any of the other sediment samples.
The largest part of the investigation then
21
22
focused on the ground-water issues at the Site, since 1988
and 1989 primarily concentrated on removing all of the
23
24
contaminated soil. and removing the plant from the Site.
25
Again, the Site i. highlighted ;n yellow.
Tony Able will
-------
Page 17
2
talk a little bit later more about the hydrogeology, but
these green dots represent wells that are put in at the.
3
Site, and they monitor ground water to a depth of about
twenty (20) to forty (40) feet below ground surface. The
4
5
red wells, they go up to sixty (eO) to ninety (90) feet
6
below ground surface, and so we've got a serie. of wells in
that's relatively what we call shallow, and then the red
7
8
wells are wells that are in deeper.
Initially the wells
9
focused on-site.
Contaminants were detected in the ground
10
water and therefore additional wells were installed off-
11
site, and again, this shows the limits of the wells that we
12
have placed off-site, basically going, you know, half a
13
block or so away from the Site.
With all those monitoring
14
wells installed, we're able to determine which way the
15
actual ground water is flowing.
Just like the surface
16
water body, ground water also will have its own flow
direction as to where it's heading, and it's important to
17
18
know that so that you can interpret your contaminant
distribution and see where your contaminants are migrating
19
20
to.
So from all the wells that were insta11ed.in a very
21
basic sense, ground water generally flow. to the Northeast
22
from the Site towards the Green River.
This 1s a very
23
simplistic view, but for purposes of understanding here
what the ground water is doing, that would be sufficient.
24
25
Given that direction of the ground water flow, we
-------
Page 18
collected a number 0' rounds of ground water sampl.. from
2
each of the monitoring wells.
I've got two different
3
figures here that portray the extent of ground-water
4
contamination.
This one here shows the extent of ground-
5
water contamination in the shallow ground water, which is
6
like twenty (20) to forty (40) feet below the surface.
7.
Again we have the site here (gesturing).
The shaded area
8
illustrates basically the boundary of the ground water
9
contamination from the Site.
You can see that we have the
10
green dots here outside the zone that's shown contaminated.
11
These wells are clean~
Contaminants are not at those
12
wells.
Basically to the North here (gesturing) in this
13
shallow aquifer, we haven't fully defined that extent, but
the concentrations here are significantly les8 than what
14
15
they are on-site.
In the deeper aquifer, which goes to
16
ninety feet below the surface, the zone of contamination i$
17
smaller than what you saw. at the shallow depth, so you can
kind of picture the contamination as a bowl sitting off
18
19
beneath the Site.
Again, we've got these red wells that
20
are outside this boundary that's the limit of
21
contamination.
We also installed two deeper wells right
22
along the North boundary of the Site, which is the area of
23
the highest ground water contamination.
80th of those two
24
deeper well. show clean ground water.
So you've got the
25
depth of contamination defined as well.
-------
.25
Page 19
2
and it's
Given that we do have contaminated ground water
migrating in a Northeasterly direction toward the
3
Gree~ River, we also collected surface water samples from
4
the Green River.
These red dots here show where we
5
collected surface water samples.
The ground-water flow
6
direction is kind of in this direction (gesturing).
There's also a spring on this side of the Site that flows
7
8
water constantly.
There's some springs up in the hills as
9
well.
Those springs were also sampled during the program
10
and there were no contaminants detected in any of the
11
surface water samples or the stream samples.
not a release to the surface environment.
So there's
12
13
The air sampling that I had mentioned, during the
14
Site investigation program we put up some air monitoring
15
stations and we collected air samples from South of the
warehouse, and then on the East and West sides of the Site
16
.17
as we 11 .
There's two stations on the North of the
18
Site.
Again, those samples were analyzed and there were no
19
contaminants detected in the air samples.
So what this all boil. down to, I mean, there
20
21
were literally hundreds of samples that were collected.
One. we collect all the data for the air, the surface water
22
23
and the ground water, etc., the soils, then we can do a
24
Risk Assessment for the Site which allows us to Quantify
what the potential risk is to the Site.
When we Quantify
-------
Page 20
2
what the potential risk i. to the Site, you're looking at
existing conditions, you know, as it sits now with the
3
exi~ting residential neighborhood, or what could
4
conceivably happen in the future.
When we went through
5
that process and what we looked at under present
6
conditions, we had the different scenario of if the Site
7
was used as park land, what would be the exposure to the
8
people using the Site as it is today as a park land.
With
9
the off-site soils, if it'sa residential area, what is the
10
risk to the people off-site in the residential area?
We
11
have ground water migration to the Green River, which
12
discharges the surface water.
People fish in the river and
13
they can eat the fish.
People can wade. in the river, so
14
you can have physical contact with the water.
So what is
15
the risk to those people?
Under future conditions we looked at if the
16
17
warehouse becomes reoccupied and you have potential workers
in there, you know, what the residual levels in the
warehouse is and what. is the exposure to the workers? On-
18
19
20
site, it's conceivable that they could be building another
21
building on-site.
If they do that, they dig up the soils
22
that are left on-site' today, and what's the risk to those
23
soils1
The surficial soils of. the Site,. it's also
24
conceivable that the Site some day could be developed into
a residential area, and if that turns into a residential
25
-------
Page 21
area then we have the same exposure as W8 do with abutting
2
residents, and what's the exposure to people in a
3
residential scenario?
4
Then we have the ground water.
Right now there
5
are no ground water users in the vicinity of the Site.
What if somebody put a well in and wanted to use that
6
7
ground water in the future?
8
So out of all of the different scenario. that
9
were looked at, and they were all conducted in accordance
10
with EPA's procedure for doing Risk Assessments, and what
it all comes down to is that for the air exposure, there
11
12
were no contaminants detected there, so air does not pose
any risks under present or future conditions.
13
14
The on-site soils, the residual level, the
15
average concentration of less than two (2) parts per
16
million in the on-site soils, does not pose an unacceptable
17
risk.
So those on-site soils the way they are today, the
18
site literally could be used for any use, whether it's park
19
land, residential, what-have-you.
It's fine the way it is.
20
The off-.ite 8011s, again the average
concentration there was about .2 parts per million, much
21
22
1es8 than one (1) part per million.
That does not pose an
23
unacceptable risk.
80 there again the off-site 80i1s as
24
they are today are an acceptable situation.
The surface water, we analyzed the surface water
25
-------
Page 22
2
and no contaminants were detected in the surface water.
did modeling of the ground-water flow, and even with the
We
3
contaminant concentrations that were detected in the ground
4
water, because of their rate of migration which is very
5
slow, they would not discharge to surface water in
6
concentrations that would be of a concern.
So even if
7
nothing was done at the Site with respect to the ground
water, it would not pose an unacceptable surface water
8
9
condition.
10
All the sediment samples that were collected were
11
clean, therefore they're not of a concern.
12
The ground water is where the contamination now
13
is present.
There is basically two routes that the ground
14
water can take.
One is the discharge to the Green River,
15
and as I've just stated, that route presents an acceptable
16
scenario.
The concentrations would not cayse an
17
unacceptable level in the river.
The other scenario is if
18
somebody puts in a well and wanta to use that water for
drinking or for bathing. or what-have-you, that ground water
19
20
would not be acceptable.
The ground water is contaminated
21
and it would require treatment.
So the Site as it exists
22
today, the only concern remaining there is that if somebody
put a well in and wanted to use .the ground water.
23
24
Now Tony Able wants to talk a little bit more
about the ground water, and I'll turn it over to him.
2S
-------
Page 23
MR. ABLE:
This 1. the same shot or the same
2
picture that Jack showed you a while ago of the
3
contamination in the ground water, the aerial extent of it.
4
Of course this is the Site, the Green
River, and this is
5
the area of contamination.
We can see how it looks from
6
the surface here.
What I want to show yaw'll is how things
7
operate down in the rock itself, down in the aQuifer
8
itself.
So what I'm going to do is go to the chalk board
9
and show you a cross section, just like we took a knife and,
sliced the Site down the middle where we could look down
10
11
into the earth and see it.
The line across the Sit. that
12
the chalk board shows is running right straight acrOS8 the
Site like that (gesturing).
13
14
Of course I've got the soil drawn in.
Th; s is
15
supposed to be where the Site area would be across through
16
here and the Green River.
Can everybody hear?
I've got
17
the soil drawn in, and then we get into the bedrock.
The
18
bedrock is' dolomite or limestone and they probably do some
Quarrying around here, so I think yaw'll understand what
19
20
limestone is or lime rock, as many of you call it.
This
21
rock is pretty solid stuff, and the way the ground water
moves through this rock is through fractures in the rocks,
22
23
cracks, small cracks that develop in there, and these
horizontal layers are called bedding plains, where the rock
24
25
was laid down in the ocean a few years ago.
That's another
-------
Page 24
story.
Anyway, we've got all these fractures in the rock,
2
and the PCB's and the TCE solvents and the DCE near the
3
Site operation leached down into the rock and got into
4
these fractures, and started working its way into these
5
fractures like this (gesturing), filling up these fractures
6
with contaminated ground water.
What they did as far as
7
the Site Investigation or the Remedial Investigation that
Jack talked about, was coming and put monitoring wells down
8
9
into this rock to sample that ground water and try to
10
determine exactly how deep it went, and of course how far
11
So they came in and they put
it went out laterally.
12
monitoring wells in, some of them at shallow depths like
13
this (gesturing) and they could extract ground water out
from this location right here (gesturing) and determine if
14
15
it had contamination, and then they would go in with a
16
deeper well, something like this (gesturing), and tell if
17
there was contamination in those fractures in the rock.
We
18
got a pretty good idea of how deep or shallow it was, but
19
we were still concerned that there may be even deeper
contamination, and so again, Jack commented that they went
20
21
in with much deeper wells down into zones like this
(gesturing), and it turned out those wells didn't have any
22
23
contaminat~on.
$0 we got an idea of how deep the
24
contamination was and also how far out laterally it was.
These three types of contaminants, they move differently in
25
-------
. -
Page 25
the environment.
You have the solvents we keep talking
2
about, DCE and TCE, those are solvents kind of like you'd
thtnk of something like finger nail polish dissolved in the
3
4
water, and the PCB oils, we call it, they're also dissolved
5
in water, but both of these contaminants move at different
6
.rates when you get them down into the rock.
The PCB's move
7
more slowly, because they adhere to the rock surfaces more
8
so than the solvents do.
So the solvents may migrate, you
9
know, far out in this direction (gesturing), when the PCB's
10
only make it that far (gesturing).
That's good that the
11
PCB's are kept local to the Site, but the bad par~ is that
they're hard to pump back out because they adhere to the
12
13
rock surfaces so wet1.
So what we're running into here is
14
we think we'll be able to pump these solvents back out of
15
the aquifer, but we're just going to have to wait and see
16
what happens to the PCB's.
One thing we're hoping is that
17
maybe these solvents and PCB's dissolve in the water
strongly enough that they'll be extracted at the same time
18
19
as the solvents.
Of course we'll have to cross our fingers
20
on that one.
21
I think I'll turn it over to Patty now.
She's
22
going to discuss a little more about the actual ground
water extraction system that's supposed to get these
23
24
contaminants out of the aquifers.
25
MS. FREMONT:
Jack and Tony have just explained
-------
Page 28
the extent of contamination and the nature of it to you and
2
the geological situation beneath the Site.
Based on the
3
results of the Remedial Investigation, ten Remedial
4
Alternatives, or five alternatives with A and 8 parts, were
5
evaluated for consideration in cleaning up the ground water
6
beneath the Site.
7
As previously discussed, contaminated so;l was
8
excavated and replaced with clean soil and the RI also
9
revealed no concerns for air, surface water or sediment..
Now let's show the Alternatives that were
10
11
Alternative 1A involves no
developed for the ground water.
12
action.
The National Contingency Plan, or set of rules
13
governing Superfund, requires that this Alternative be
14
developed as the basis for comparing other Alternatives.
Alternative 18 involves no action with monitoring and
15
16
confirmatory sampling.
Both these Alternatives were
17
eliminated from further consideration since they weren't
18
protective of human health and the environment through
engineering controls.
19
20
Alternatives .2 through .6 are similar in a way
21
and I want to discuss their similarities here.
They all
22
involve pumping wells to extract contaminated ground water.
Monitoring and confirmatory sampling to insure that .the
23
24
plume is being contained and the concentrations are being
25
reduced ..
It also involves treatment of the extracted
-------
Page 27
ground water on the Mallory Site.
There'll be . treatment
2
system placed on the old Site where the ground water will
3
be. treated.
Also Alternatives '2 through .5 involve
4
additional investigations to better delineate the northern
5
extent of the contaminated ground-water plume and see if
anything is in Cold Water Creek that we may not have seen
6
7
before.
Since we do know the the ground water is moving in
8
a North, Northeasterly direction like Jack sh~wed you,
we're going to investigate that a little further also.
9
10
The difference between the A and 8 parts for
Alternatives .2 through .5 is the method of treatment.
11
12
Treatment for Alternatives '2A, '3A, '.A and .5A involves
Ultraviolet Chemical Oxidation, wherein the contaminants in
13
14
the ground water are converted to carbon dioxide and water
using ultraviolet light and a chemical like hydrogen
15
16
peroxide.
Treatment for Alternatives '28, '38, .48 and .58
17
involves air stripping, bag filtration and carbon
18
adsorption.
Air stripping is accomplished by passing a
19
high speed air stream through the water and evaporating the
20
volatiles off.
8ag filtration removes any solids before
21
the carbon adsorption step so it doesn't get plugged up.
The carbon adsorption step involves adhering the remaining
22
23
contaminants and sort of pOlishing the water on the porous
surfaces in the carbon.
24
25
Now I'll show you the extraction well layouts for
-------
Page 28
Alternatives .2 through '6.
As you can kind of S88,
2
Alternative '2A and .28 have six (6) ground water
3
extraction wells.
There are five (5) on-site and one (1)
4
off-site.
5
This is Alternatives '3A and '38.
They have
6
seven (7) ground water extraction wells all on-site and
they're placed around the Northern and Eastern borders of
7
8
"the Site to intercept the contamination because it is
9
moving in that direction again.
10
This is Alternatives .4A and '48.
They have
11
thirteen (13) extraction wells with seven (7) like in
12
Alternative '3, around the Northern and Eastern borders of
13
the Site, with an additional six (6) off-site, to intercept
14
any off-site contamination.
15
And Alternatives .5A and '58, these have twenty-
two (22) extraction wells, with thirteen (13) on-site and
16
17
nine (9) off-site.
So that's all the Alternatives.
18
Now Superfund laws set forth nine criteria which
19
EPA uses to evaluate and compare these Alternative..
These
20
criteria are as follows:
The first thing we consider when
21
evaluating any Alternative and the most important thing is,
is it protective of human health and the environment?
22
23
Secondly, does it comply with ARAR'S, or. Applicable and
24
Relevant and Appropriate Requirements.
That simply means
25
Federal and State laws for protecting the environment and
-------
Page 29
local one8.
The next criterion for considering an
2
Alternative i8, does it provide long term effectiveness?
3
Is .it permanent?
The next criteria i8, does it provide
4
short term effectiveness?
This remedy that i8 under
5
consideration a8 implemented, is it going to harm the
6
public or the construction workers?
The next criteria,
7
does it reduce toxicity, mobility and volume of the
8
contamination?
The sixth one, can it be implemented?
Is
9
it a technology that is well known that it works and not
too exotic that a lot of people don't know how to U8e it
10
11
and know that it works?
Has it received the State of
12
Tennessee's acceptance and does it receive your acceptance
13
as a Convnunity?
The last criteria for evaluating
14
Alternatives, i8 it cost effective?
15
EPA looked at all the criteria and chose the one
16
that gave the best balance between all of them.
Alternative that did this was Alternative '48.
We
The
17
18
preferred it for the following reasons:
Again most
19
importantly, Alternative .48 i8 protective of human health
20
and the environment.
It halts movement of contamination
21
from the Site.
It keeps that ground water from going
22
farther with the contamination in it.
Utilizes a permanent
23
solution for TCE and 1,2-OCE contamination.
We're
24
estimating that these volatiles would be removed by
approximately a hundred percent (100.) in thirty (30)
25
-------
t"'age ,JU
year..
The next reason we prefer this Alternative i. that
2
it provides the largest protection for the volatile. over
time with minimal risk during construction and
3
4
-
implementation.
This Alternative also insures that
5
possible chemical and biological impact to the Cold Water
6
Creek will be assessed.
I think I touched on that before.
7
A real big reason we liked this Alternative is the air
8
stripping, bag filtration and carbon adsorption are proven
9
technologies.
They've been tested on a small scale out at
10
the Site and found to work very well.
UV/Chemica1
11
Oxidation's efficiency' is Questionable under the conditions
12
at the Site.
The next reason we like it is Alternatives .2
13
and .3 are estimated to only partially reduce the volatiles
14
or TCE and 1,2-DCE.
For those of you who got a chance to
15
read the Feasibility Study Report in the library, you may
remember seeing that the Potentially Responsibly Party, or
16
17
Duracel1, expressed a preference for Alternative '28.
problem with that one was that it didn't fully remove
The
18
19
volatile contamination, therefore we didn't choose it.
EPA
20
didn't prefer it.
Alternative '1, of course, does not
21
protect human health and the environment.
And No.9 is
22
that Alternative .48 is cost effective.
Alternative '58,
23
which has twenty-two (22) extraction well., is estimated to
get you exactly the same results, which again is reduction
24
25
of the volatiles by approximately a hundred percent in
-------
Page 31
2
thirt"y years, and Alternative .48 is juat mor. cost
effective.
3
Alternative .48 again involves the following:
Installing thirteen (13) ground water extraction wells on
4
5
the Site, which I showed you the scenario; seven (7) on-
6
site to sort of cover the Northern and Eastern borders and
7
then the six (6) off-site; treating the TCE and 1,2-OCE in
ground water with air stripping, bag filtration and carbon
8
9
adsorption; monitoring and confirmatory sampling to insure
that the contamination is reduced and contained, it's not
10
11
going any farther laterally or out, or vertically, down;
and additional investigations to better determine the
12 "
13
northern extent of off-site ground-water contamination in
14
the Cold Water Creek area.
15
Now all the well numbers and locations that we've
16
estimated at this time are approximate, and monitoring
after the system is in place and sampling may show the need
17
18
to add wells or move them to get a more effective clean-up.
If you'll excuse my art work here, I wanted to
19
20
sort 01 show you how this "works and I thought this might
21
convey it.
The Proposed Remedy again is thirteen (13)
22
we lls .
How it works is these wells are under ground and
23
all you see on top of the ground is just like a little
24
manhole looking cover, smaller than a manhole.
Everything
25
i 8 under "ground.
How it works is there's an under ground
,
-------
Page 32
pumping system that goes to the Sit..
On the Site there'.
2
an air stripper first in line.
What happen. is the water
3
comes in this air stripper from the top and a high speed
air stream goes against that water and evaporates the
4
5
volatiles.
These air strippers are estimated to be about
6
ninety-nine point nine (99.9~) percent effective.
They're
7
very good at removing these volatiles.
Now some very small
8
concentrations of volatiles will exit the stack, but I've
9
got to emphasize too that they're very small.
This stack
10
will be monitored as part of the Record of Decision.
11
Should the concentrations exceed EPA's allowable levels,
12
we'll install a carbon bed on top of that stack to capture
13
those volatiles.
The next step once the water goes through
14
there and gets the volatiles evaporated off, it goes
15
through a bag filter.
The bag filter removes solids and
16
any mud or anything that would come up from the ground that
17
could clog the following step.
The following step is a
18
carbon adsorption unit, again, where the remaining
19
contaminants are adsorbed to the porous carbon.
The system is in many stages to insure the purity
20
21
of effluent.
Right now our options for the discharge are
22
discharging it to the Green River or discharging it to the
Waynesboro City Treatment Plant.
23
24
It's just important to note about the PCB's.
Tony did a good jOb of explaining a few minutes a90 about
25
-------
Page 33
them and I just want to make mention to you about them.
It
2
may be technically infeasible because of their properties,
th. way they stick in the rock, to remove them from the
3
4
aQuifer at least to the levels we want to remove them to. .
However monitoring associated with all these Alternatives
5
6
is going to insure that they're not going to go anywhere.
They're going to stay contained and we'll see how their
7
8
concentrations are being reduced.
9
Removing the volatiles or the TCE and l,2-DCE
will help to immobilize the PCB's, because they won't be
10
11
dissolved in them any more, so that will help~
And since
12
we know this is the case, at least every five (5) years EPA
13
will conduct a formal review to insure that the PCB's are
14
being contained and they're not migrating anywhere.
15
If any future innovative technologies come along
for getting these PCB's out of the aQuifer, EPA will assess
16
17
them and maybe utilize them at that time if they'll work.
Again, this is a case for PCB's, but the preferred
18
19
Alternative does remove the volatiles to close to a hundred
20
percent in thirty years.
Right now what I'd like to do is introduce
21
22
Suzanne Durham, who is our Community Relations Coordinator
at EPA, Region IV, and she'll explain a little bit more
23
24
about the community relations process in the Superfund to
25
you.
-------
Page 34
MS. DURHAM:
Thank you, Patty.
My
Good Evening.
2
name is Suzanne Durham and I'm the Community Relation.
3
Coordjnator for the Mallory Capacitor Site.
Choosing the
4
Final Response Action is perhaps the most important
5
decision ever made at a Superfund site, because you people
here in the Community with the Superfund site are the most
6
7
affected by the hazardous waste problems and the clean-up
8
EPA strongly encourages local citizens to get
processes.
9
involved in that decision making process.
Publ ic
10
involvement and comment does influence EPA clean-up plans
by your providing valuable information about site
11
12
conditions, community concerns and your preferences.
13
We recently issued a Proposed Plan Fact Sheet,
14
which I hope you all received in the mail, which summarizes
15
what we've found during the Remedial Investigation and the
16
Feasibility Study.
We also sent an Administrative Record
17
to your local library, the Wayne County Public library.
That Administrative Record contains all the documents that
18
19
EPA used in developing our Proposed Plan. .
I hope you've
20
all .had the opportunity to go by the library and review
21
those documents.
If you haven't done so yet, please do,
22
ask us questions tonight, and submit your comments to the
23
Agency.
We are soliciting comments on all the Alternatives
24
under consideration, not just the one that EPA prefers.
Our comment period began June 14th and runs
25.
-------
Page 35
through July 15th, 1991.
If, however, you fe.l that you
2
need additional time to review what's in the library to
3
proyide comments to us, we can allow additional time.
would need you to submit a letter of request for an
We
4
S
extension within two (2) weeks of today's meeting.
After
6
the comment period ends, EPA prepares a document called the
7
Responsiveness Summary.
Now that summaries all of your
8
comments and concerns and our response to those comments
9
and concerns.
10
A Record of Decision, which is the document which
11
will outline in detail what EPA will do as far as clean-up
of the Site, will be signed only after careful
12
13
consideration of State and pUblic comments.
When that
14
Record of Decision is signed by the Regional Administrator
in Atlanta, a notice will .be published in your local
15
16
newspaper.
Then the Record of Decision and Responsiveness
17
Summary become available to the pUblic as a part of the
Administrative Record.
18
19
An excellent opportunity for community
involvement is through our Technical Assistance Grant or
20
21
TAG Program.
Congress has recognized that our documents
22
are Quite lengthy and highly technical and we can now offer
one grant to a community group in the amount of Fifty
23
24
thousand ($50,000) dollars for you to hire your own
technical advisor to interpret the documents that we
2S
-------
Page 3e
produce.
2
In summary, the goa1 of the Community Relations
3
Program is to keep you informed and involved about complex
4
decisions which will affect your Community.
Patty and I
5
are your two contacts at EPA.
We want you to feel free to
6
contact either one of us at any time.
Now Alvin lenoir, our attorney, will briefly
7
8
discuss the enforcement process with you.
9
MR. LENOIR:
Thank you.
Having reached the stage
10
of adopting the Proposed Plan, it is very important that
the public have an opportunity to comment on the Plan and
11
.12
it's my intention to relay to you that the Agency will
respond to all the comments and give them due consideration
13
14
before a Final Plan is adopted.
Once the Regional
15
Administrator has signed the Record of Decision, or the ROD
16
as we call it, choosing the necessary remedy to clean up
the Site over the long term, this is when EPA's enforcement
17
18
process really begins.
In the discussion that follows I will explain to
19
20
you how EPA accomplishes the implementation of the remedy.
As a basic proposition of enforcement, our major goal is to
21
22
achieve clean-ups by identifying persons or entities who
are responsible under the law for the contamination of the
23
24
Site.
These persons generally fall into four categories:
25
They are generally the current owners and operators of the
-------
1- -
Page 37
2
.ite, or they're the past owners or operators; they are
either transporters, meaning truckers or shippers; or
3
they're generators, ,the compan i es that made the chem; ca 1 s
that were used at the site and the manufacturers of the
4
5
contaminant materials.
6
We group these parties into what W8 call
"Potentially Responsible Parties" or "PRP's" for short.
7
8
This means that they are potentially liable for the costs
of the clean-up, and EPA attempts at a very early stage to
9
10
try to identify as many PRP's as possible.
Some PRP's may
11
no longer be in existence through either failure of their
businesses or the insufficiency of evidence to track them
12
13
to whatever businesses they have evolved to over a period
14
of years.
Other PRP's may not be financially able to help
15
with the clean-up.
In some instances environmental harm is
16
caused by small Mom and Pop operations that are barely
making a profit themselves and couldn't contribute to any
17
18
sort of clean-up costs to the Agency.
Others who we
19
identify as PRP's may. have valid defenses to EPA's
20
allegations of 'liability.
However in each of these
21
circum$tances EPA conducts a thorough investigation,
checking Federal, State and County tax records, property
22
23
logs, Chamber of Commerce listings, and in many instances
interviewing former employees or officers of companies and
24
25
corporations in order to determine the level of liability.
-------
Page 38
2
When PRP's are identified early, EPA notifies
each of them of their potential liability and at that time
3
off~rs them an opportunity to participate in the clean-up
4
If PRP's have not been identified early or if
process.
5
they've been offered the chance to participate and have
declined the offer, EPA notifies them again by letter after
6
7
the ROD has been signed.
This notification is called a
8
Special Notice Letter.
The Special Notice Letter does
9
three things.
First of all it gives the PRP'. information
10
about the site, and secondly; offers the PRP's the
11
opportunity to perform the work themselves or to pay for
someone else to do the work as required by the ROD.
12
13
Thirdly, it places a moratorium on EPA's activities for a
14
sixty (60) day period.
The moratorium period means that
15
EPA will not do anything to incur costs at the site unless
16
there is an emergency.
The moratorium is designed to make
17
it possible for EPA and the PRP's to negotiate a settlement
18
The PRP's at that point have
for clean-up of the site.
19
sixty (60) days to demonstrate to EPA two things.
They
20
must first of all demonstrate to the Agency that they have
a good fa.ith intent to either perform the work to clean up
21
22
the site or pay for the work to be done.
Secondly, they
23
must show that they are capable of financing a clean-up
that they'll do themselves or that they intend to pay for.
24
25
This process is called making a good faith offer.
It is at
-------
Page 39
this point in the process also that EPA invitee the State
2
and the Natural Resources Trustees to participate if they
3
want to.
If a good faith offer is received within the
4
sixty day period, EPA will automatically extend the
moratorium for another sixty (60) days, which then makes
5
6
the process a four (4) month process in order to work out
the details of the settlement agreement.
7
8
If an agreement is reached, the terms and
conditions of that agreement are spelled out in a document
9
10
called a Consent Decree.
A Consent Decree does. not
11
renegotiate the work required by the ROO.
The required
12
work stays the same.
The Consent Decree merely assesses a
13
penalty and sets out time schedules and deadlines for the
completion of the clean-up work.
14
15
The Consent Decree must be approved by the
Department of Justice and after the Justice Department has
16
17
approved it, it is lodged with the appropriate Federal
Court within forty-five (45) days from the terms of the
18
19
settlement.
The public will then at that point have an
20
opportunity to comment on the terms of the settlement.
EPA receives comments from the public which are deemed
If
21
22
appropriate to change the terms of the settlement, the
Consent Decree will be amended to reflect those changes
23
24
before it becomes final.
If no amendments are necessary,
25
the Consent Decree will become final as ;s, and this
-------
. 21
Page 40
2
process usually takes an additional thirty (30) to forty-
five (45) days, but at times can take longer.
3
If EPA and the PRP's cannot agree on a
4
settlement, EPA has two options:
(1) EPA can order the
5
PRP's to perform the clean-up under what is called a
6
Unilateral Administrative Order, which is enforceable in
7
Federal Court.
Generally it does not take long for the
8
Agency to issue such an order, but if the PRP's choose not
9
to cooperate or if they mount a legal challenge, the
10
resultant trial or the litigation to resolve that dispute
11
could take Quite a long time.
It could be an extensive
12
amount of time.
EPA has another option.
If EPA feels that
13
something like that could happen and it could take a long
14
time, EPA could perform the clean-up itself uSing monies
15
from the Superfund.
EPA would then most likely choose to
16
sue the PRP's for reimbursement of its costs with. the help
17
of the Justice Department.
As a practical matter this
18
action which is called a Cost Recovery Action can also take
19
a long time, but EPA feels that this is time well spent
20
because it's important to attempt to make those parties who
are responsible pay for the damage that they've done to the
22
environment.
The other advantage of this is that the site
23
is then already cleaned up and you don't have to wait for
the PRP's to demonstrate their good faith to clean up the
24
25
We would clean the site up and then go after the
site.
-------
I -
. 16
Page ..1
money.
It's important also to EPA because rather than look
2
for the PRP's to spend their resources to clean up the
site---it would be better to have the PRP's do it rather
3
4
than spend money out of the Superfund which could be used
at other sites where PRP's aren't available to clean up the
5
6
sites.
So therefore at every site where it's deemed that
7
there are PRP's who could use their dollars to clean up
sites, EPA is very assertive in going after that money to
8
9
either get the PRP's to clean up the site themselves or
clean it up and then have the PRP's reimburse the
10
11
Superfund.
12
Lastly, EPA will always oversee any work that is
13
done by PRP's at a site in order to insure that the clean-
up is done correctly and in accordance with the ROD and the
14
15
National Contingency Plan.
If EPA ever determines that a
remedy is not being implemented as required, or if new
17
information is discovered which leads EPA to determine that
18
a change in the remedy is necessary, as perhaps in this
case, new information might become available as to how the
19
20
PCB's could be cleaned up, then it's at that point where
EPA could change the remedy and make the PRP's use the new
21
22
technology to go after the PCB clean-up, or at that point
EPA may decide that it wants to implement the remedy
23
24
itself, and it has the authority to take the site back and
thus implement the remedy itself.
25
-------
Page ~2
That's my comments.
At this point. I believe
2
Harold will field the Questions.
3
MR. TAYLOR:
If I could just sort of summarize
4
where we are as far as the Superfund process real Quickly.
5
You know. I put that chart up that showed Site Discovery
and Listing and Remedial Investigation and Feasibility
6
7
Study.
We've done those things.
We've issued a Proposed
8
Plan and we're here to answer any Questions you might have.
If you've been to the library. you know that there'. a
9
10
shelf about this thick (gesturing) with documents that the
11
Agency,re1ied upon to come to the decision.
So we realize
12
that in an hour presentation and a couple of pages of
discussion that you don't have all the answers on what you
13
14
need to know.
We're here tonight to try and answer those
15
as best we can.
Where we go from here, as Suzanne Durham
16
said, the public comment period is open.
We'd like to have
17
comments from you.
There's a page in the back of the
18
Proposed Plan where you can write your comments in and send
19
We will address your concerns in the
them to the Agency.
20
Responsiveness Summary before there's a decision made. and
21
we'll take those to the Regional Administrator.
There wi 11
22
be a Record of Decision issued.
We anticipate issuing a
23
. Record of Decision in September of this year.
As Alvin.
24
the attorney. just got through describing. there'. a
process we'll go through to determine if the Potentially
25
-------
Page .3
Responsible Parties want to do this work or whether this
2
work will be done by the Superfund.
That process, as Alvin
3
des~ribed, takes at least four (4) months.
Practical
4
experience has shown me just from Records of Decision that
5
we issued last September, it took approximately until
February or March to actually get a signed agreement where
6
7
the Potentially Responsible Parties did desire to do the
8
work.
So if we had a Record of Decision in .September, that
9
would put us into March of '92.
When we have a signed
10
Consent Decree, that Decree is then lodged or entered in
11
the Federal District Court and there's a thirty (30) day
12
public comment period on that Decree itself.
As Alvin
13
said, that takes somewhere around forty-five (45) days.
After the Decree is entered and lodged, the Potentially
14
15
Responsible Parties will begin. the design.
Just as I told
16
you, before you'd build anything like you'd build a house,
17
you'd want a design for how to do it.
Designs, just
18
historically, have been taking---well if you go through the
time line in our statements of work, Consent Decrees have
19
20
been taking about fifteen (15) months to complete on a
21
typical site.
So I guess
Some go faster.
Some go slower.
22
what I'm here to tell you is that once the Record of
Decision is signed, once we go through the negotiations and
23
24
actually come up with a design, it would probably be about
two (2) years before the remedial action itself, actually
25
-------
Page 44
installing the extraction wells, pumping, and building the
2
treatment facility at the Site would actually begin.
So
3
that just puts it in a little time perspective for you.
What I'd like to do with the Questions and
4
5
if I could, is again as I went over the Agenda
answers,
6
what I'd like to do is answer any Questions you have on
7
that Mallory Capacitor Site.
I'd like you to get up, if
8
possible, come up and use the microphone.
If you think you
9
can project, go ahead and stand up and state your full name
10
so we'll know who you are.
If you have a name that is
11
difficult to spell, since we do have a Court Reporter here
who's keeping a record of the meeting, I'd appreciate it if
12
13
you'd spell your last name so we'll have it right.
Direct
14
your Questions to me.
If I can, I'll try to answer them.
15
If it's an answer that I need help on or is more
16
appropriate for someone else, I'll direct it to them.
Once
17
we've finished answering any Questions that you may have on
18
the Mallory Capacitor Site, like I said befor., we'll take
19
about a ten minute break.
If any of you have concerns,
20
which I think some of you do, about other environmental
issues in the area, we have the State of Tennessee and EPA
21
22
people will stay and we'll answer any questions that you
may have or take any concerns that you may have about sites
23
24
other than the Mallory Capacitor Site at that time.
So again if I could, I'll open it up to questions
.25
-------
Page ~5
and answers, and I'd like, if possible, for you to stand up
2
and state your name and the Question that you have.
I'm
3
no~ taking them in any order, so anybody that wants to ask
4
the first Question.
Yes, Sir.
5
HARVEY BAKER:
My name i8 Harvey Baker, and I'm
6
wondering how you determine the boundary, the Northeast
boundary, of the contaminated area since all the wells are
7
8
inside it.
It seems like you'd need a well outside the
9
area as well.
I know you're talking about checking up on
10
that, but I was wondering is there any way you actually
11
determine that boundary?
12
MR. TAYLOR:
I guess I'll refer the first
13
Question over to our able geologist, Tony Able.
14
MR. ABLE.:
Well you said it yourself.
We'll have
15
to put wells on the outer boundary of that thing, and we'll
16
keep putting them out there until we come up with a clean
17
one that says we have got the furthest extent of it.
To go
18
a little further, the reason we haven't gone ahead and done
that now, is we figured it's the best idea to go ahead and
19
20
get something positive started and get this pumping system
in, and at the same time the pumping system i8 going in
21
22
then we'll put those extra,characterization wells in at
23
that time.
24
MR. BAKER: So at the moment it's kind of a guess
25
where that boundary is?
I mean, you can tell a little bit
-------
Page 46
by the decreased concentrations.
2
MR. ABLE:
Yeah, we're getting a good idea where
3
it js, but we don't have it narrowed down yet.
4
MR. TAYLOR:
We have it narrowed down, I think,
5
but we don't know it exactly.
6
MR. ABLE:
We can't pinpoint it.
I ' 11 put; t
7
that way.
8
BOB POWELL:
Was there any modeling done on this?
9
Did you model the ground water?
10
MR. TAYLOR:
MR. POWELL:
Your name, Sir?
Bob Powe 11 ;
11
I mean, that might help
12
explain it further.
13
MR. TAYLOR:
I don't believe---wel1, there was
14
modeling done for the Feasibility Study.
15
MR. MICHELS:
There was modeling done to project
16
the contaminant concentrations to the Green River with time
17
and with clean-up times as well.
So there was ground water
18
modeling done to a certain extent, ye8.
19
If I could again, I think your
MR. TAYLOR:
20
question i. one that I get every day.
What we have to do
21
i8 balance what we need to know to select the remedy
without going out and doing the studies for extensive
22
23
periods of time, because as I think I've described to you,
the Superfund process in itself ;s somewhat cumbersome in
24
25
that it takes a long time to get through.
What I, as
-------
1- -
Page ~7
2
basically a supervisor of the remedial work that goe8 on
have to balance is, do we know enough about a particular
3
si~e to go ahead and make a decision on what needs to be
4
done, or do we need to delay doing something in order to
5
get more characterizations.
I think in this case we made
6
the decision that we knew enough that we needed to go ahead
and start pumping and treating the ground water, and we
7
8
knew enough about the extent of it to be able to at least
cost out what we thought it would take to do that, and
9
10
that's the decision that was made.
Typically our decision
11
is to ~o ahead and do additional investigatory work at the
same time we're doing the remedial action.
12
13
JEWELL POAG:
I'm Ms. Poag.
Did I understand you
14
to say that it would be two years,even if things went
15
according to schedule, before you would get started with
the actual clean-up?
16
17
MR. TAYLOR:
That is, I guess, the scenario which
18
I think will occurl
It could be
It could be two years.
19
less.
20
MS. POAG:
Well my Question is, won't. this
21
picture of the contaminants change a lot within two years?
22
MR. TAYLOR:
Not a lot; the contamination that's
23
been goin9 on started probably when TCE, DCE, PCB's were
24
started to be used at the facility.
Ground water doesn't
2S
migrate fast.
It does migrate.
I think it's migrated
-------
Page 48
three hundred (300) yards or so over the plant property
2
over time.
The longer we take to either
So you're right.
3
further investigate or to negotiate or to do the design,
the contamination would probably move, but it won't be
4
5
significant if it's done within two years.
If it were a
6
faster moving aQuifer, it would change more drastically.
In some iites we're deciding to go ahead before we even do
7
8
investigations, and start the pump and treat~
9
CARL MOORE:
I'm Carl Moore.
10
Excuse me, Carl.
What's your last
MR. TAYLOR:
11
name again?
12
MR. MOORE:
Moore; in the thirty years that it's
t
13
going to take to pump this stuff out, won't it have spread
Quite a bit?
14
15
MR. TAYLOR:
Well again, I'll ask Tony, but to
16
add to it, what was envisioned with the pump and treatment
17
system that we're putting in is that it would be a
hydraulic barrier basically to keep the ground water from
18
19
90in9 further.
In other words, we'd be pumping and at the
20
same time we're treating.
Even if we don't reduce the PCB
21
contamination, we should have contained it within the
22
areas.
23
Yea, Ma'am, your name?
24
BILLIE JEAN HOLLIS:
I'm Billie Jean Hollis, and
25
I want to ask you a question that I don't know whether it
-------
1-
Page 49
has a definite answer or not.
You've talked about three
2
contaminants.
I think at a public meeting that I attended
3
tha~ you held to discuss the health risks that I only
4
recall two contaminants you discussed, PCB's and TCE's. I
5
wonder what you can tell me---I read what you had in your
blue book about 1,2-DCE, where it was a compound that would
6
7
irritate your skin.
What is the s~gnificant health risk?
8
MR. TAYLOR:
Kevin, perhaps you can---
9
KEVIN KOPOREC:
Well I'm not sure why DeE wasn't
10
addressed previously, but I anticipate it could be because
11
the other two contaminants, the PCB's and the TCE are both
12
probable carcinogens, whereas the DCE is not thought to be
13
a carcinogen at all.
So that may be the reason for
14
separating those out from each other.
15
MS. HOLLIS:
Is it a deadly chemical where you
16
have to be careful?
17
MR. KOPOREC:
The primary problem with it is
No~
18
that it does irritate the skin as identified in the
19
proposed plan.
Also if you happen to ingest it, especially
20
a little bit over long periods of time, then it can cause
liver problems.
21
22
MS. HOLLIS:
Do you mean something like
23
cirrhosis?
24
MR. KOPOREC:
Well I suppose if you ingested
25
enough of it for long enough it could cause some problems
-------
Page 50
2
like that, but it would take a lot of it to cause much
problems.
3
MR. TAYLOR:
I was probably---was that meeting as
4
far back as '86 or '87?
5
MS. HOLLIS:
I wonder had you not found it at
6
that time?
7
MR. TAYLOR:
well again, I need to let somebody
8
else expand upon it, but 1,2-0CE, typically we find it in
9
places where we have TCE, because typically, I think, it's
10
a contaminant of the TCE.
It's also used as a degreaser.
11
So as Jack went over earlier, the first thing we d1d as
part of the RI was to sample some of the nastier places
12
13
like in the facility itself, to see what the contaminants
14
of concern would be, and that's where we came up with the
15
1,2-0CE and the TCE and PCB's.
I think to answer your
16
question, there probably just wasn't adequate sampling back
in '86 or '87.
17
18
Yes, Sir, your name, please?
19
My name i8 Billy Pulley.
I was
BILLY PULLEY:
20
. just wondering how soon it would be before you think this
property would be productive or could be used for
21
22
something?
23
MR. TAYLOR:
Well I was talking to the City
24
earlier about that.
Of course, EPA doesn't own the
25
property, so all we can say is whether we would agree that
-------
J
Page 51
2
the property could be used for a particular thing or not.
The actual, physical property itself, we're really not
3
putting any restrictions on the property, other than aSking
for people not to'drill any wells through it and ingest the
4
5
water that's under the Site.
So the warehouse and the area
6
behind the warehouse and on the side, we're really not
saying that those areas need to be restricted for any kind
7
8
of use.
We're not dictating that it be used for any
9
particular thing, because that's the property owner that
10
determines that.
We're no~ saying that that property needs
If somebody wants to use the warehouse,
11
to be restricted.
12
we're saying that it's okay.
If somebody wants to use that
13
property, we're saying that's okay.
Obviously there's some
14
liability concerns since that is a National Priority list
15
Site.
If future activities were to contaminate the Site
16
again, not only would the guy or person that was operating
17
the facility there be liable to the Agency, but probably
also all the past owners would be liable for the
18
19 .
contamination.
So that's a concern at the Site about
20
future us..
21
MR. PULLEY:
I was thinking in terms of using it
22
for a park or something like that.
23
MR. TAYLOR:
Well again, that was one of .the
24
scenarios that was looked at as far as whether that would
25
be a problem or not, and in our opinion it wouldn't be a
-------
Page 52
problem.
2
Yes, Sir, your name, please?
3
ROBERT T A Y'LOR :
My name is Robert Taylor, and I'm
4
a concerned property owner that has adjacent property
5
around this, as 1 think the majority of people in this room
6
In other words, you say your study says that the only
are.
7
real liability at this point is the ground water itself,
8
and you told Mr. Pulley there that there could be some
liability concerns if somebody wanted to buy that property
9
10
,or put up a business.
What about the liability concerns
11
for us if we wanted to sell our property or anything?
Do
12
you have any comment on that?
Would there be any problem
13
with that?
You know, we're innocent of what the conditions
14
around us are like.
15
MR. TAYLOR:
I'll ask Alvin Lenoir to jump in if
16
he has anything to add, but really what we've concluded is
that there's no problem with the property surrounding the
17
18
Site.
19
Well that's what your study says.
ROBERT TAYLOR:
20
MR. TAYLOR:
The problem with the ,properties, if
21
there is a problem, is that we don't want anybody to drill
wells on those properties and start drinking the water,
22
23
'because that would be a potential exposure at that point.
So the Agency itself, as far as liability, we're concerned
24
25
with the people that owned and operated the facility where
-------
Page 53
the discharge was.
Alvin can jump in here and h. might
2
want to add, but we're really not concerned with people
that may have been innocent people, which may have had
3
4
contamination enter their property through no fault of
their own.
5
6
ROBERT TAYLOR:
In other words, you're not
7
concerned with me and my problems from it, or my problems
8
that might come up?
9
MR. .TAYLOR:
We're concerned with public health
10
problems or environmental problems that may result from
11
that Plant.
You're probably as a property owner concerned
12
about your property value.
13
ROBERT TAYLOR:
I'm concerned about the
No.
14
health of myself and the people around me.
15
MR. TAYLOR:
From what?
16
ROBERT TAYLOR:
The property that I have happens
17
to-have been in our family for a hundred and fifty years
18
and I'd like for it to still stay there.
So I'm not
19
concerned with the value of my property.
dollar on it.
You can't put a
20
21
MR. TAYLOR:
Well I guess from what you've heard
22
tonight, what concerns you from a health aspect about your
property, I guess is my Question?
23
24
ROBERT TAYLOR:
Are there going to be any risks?
25
I mean, the only thing you're saying i8 at this point it's
-------
Page 54
in the ground water itself only?
2
MR. TAYLOR:
Well I think we're saying more than
3
that.
I think what we've said tonight is that from the
4
data that we've reviewed, and I reviewed the past data, the
5
data that was generated through the last few years, and
we're not saying that there's a health risk to people or to
6
7
the environment from the soils, the. sediments or the air.
8
We're saying the only unacceptable health risks that we see
is if you would drill a well and drink the water.
9
10
Yes, Ma'am, your name, please?
11
How can you document that so that
JEWELL POAG:
12
potential buyers would know about these problems?
I mean,
13
if someone bought it and didn't know about it and drilled a
14
well, and then later on down the line, you know, the PCB's
15
are going to be there a long time, probably longer than
thirty years.
16
17
MR. TAYLOR:
Yes, Ma'am.
One of the things and
18
it's in the Proposed Plan and one of the things that we
were including in the Alternative is that there be what we
19
20
term Institutional Controls, and those controls, I talked
21
with the City today a little bit about them.
I haven't
22
defined other than to say Institutional Controls, what
those need to be, but there needs to be a restriction
23
24
against any drilling going on in that area where we've
.25
shown there ;s contamination.
Some communities, for
-------
Page 55
example Memphis, they have a program where all well
2
drillers are permitted and have to receive a permit before
3
th~y drill in any particular location.
So in Memphis, at
4
the North Hollywood Site for example, there will be an
s
ordinance placed that you can't drill.
They can't issue a
6
permit to drill a well in the area of the North Hollywood
7
Dump Site.
We're going to have to come up with something
8
similar here, whether it's a notice on the deeds; whether
it's a County Ordinance.
9
10
MS. POAG:
You know, in twenty or thirty years,
11
everybody will forget about all of this and somebody might
go in there drill a well and be drinking out of it.
12
13
MR. TAYLOR:
Well I hope not.
Alvin, do you have
14
anything to add on Institutional Controls?
1S
MR. LENOIR:
Well the method that many
16
communities have used in other instances is placing
17
restrictions on the deeds.
A deed restriction is entered
18
into the County records, and anybody who potentially
conveys the property has to present this deed to the
19
20
potential buyer, and it should be a red flag to anybody
buying the property that they couldn't drill wells on that
21
22
site.
It may not be something that will sweeten the
23
bargain as far as they're concerned.
They may not want the
24
property if they can't drill wells on it, but at least that
protection would be there.
25
-------
12
MR. TAYLOR:
2
DOROTHY HUCKABA:
3
scraped the top soil.
feet like they did the wells and check?
We live right
4
Page 56
Your name, please?
They came to our yard and just
Why didn't they dig down in 80 many
5
across from the storage place over there.
Can I have your name, please?
6
MR. TAYLOR:
MS. HUCKABA:
7
8
MR. TAYLOR:
MS. HUCKABA:
9
Dorothy Huckaba.
Where do you live, Dorothy?
Right acrOS8 from the storage
10
building that's standing right now.
And your Question is why---
11
MR. TAYLOR:
MS.
HUCKABA:
We've got windows up above the
13
garage and I can smell that stinking sme11---
---when the Plant was operating?
14
MR. TAYLOR:
MS. HUCKABA:
15
16
working over there.
17
MR. TAYLOR:
---every morning.
The Plant was
Again, I'll ask for help from
18
anybody that wants to jump in here, but the thing that was
The reason we
19.
looked at with the yards was surficial soil.
looked at surficial soi1 was that's what you're going to
come in contact with, if a child goe8 out and plaY8 in the
20
21
22
yard.
They're mo8t likely not going to dig down 8ix or---
Well we dig down to put flowers in
23
MS. HUCKABA:
24
and tree8 and things.
25
MR. TAYLOR:
That's why we took sample8---I think
-------
Page 57
I heard you earlier, that's why we took samples from
2
gardens in particular, because that's an area---
MS. HUCKABA: You didn't get any from our garden.
MR. TAYLOR: Jack, do you know anything about the
samples that were taken in her yard?
MR. MICHELS: Well the samples from the off-site
3
4
S
6
7
properties, I'd have to know exactly which yard was taken
and I was showing the figure that had the locations in the
8
9
property, those are in prospective to the actual area at
10
the Site.
I don't know where your actual garden is located
11
or whatnot, but generally they took three (3) samples from
each of the properties adjacent to the Site.
12
13
MS. HUCKABA:
They dug down about that far
14
(gesturing) in the dirt.
1S
MR. MICHELS:
They collected surficial soil
Yes.
16
samples.
The reason, the rationale behind that, is that if
17
your property became contaminated with PCB's, then how did
18
the PCB's get to your property, and---
19
MS. HUCKABA:"' Well we built before they put that
20
storage building there.
See, that storage building would
21
block part of it.
We lived there before the storage
22
building was ever put up.
23
MR. MICHELS:
So if PCB's migrated onto your
24
property, it would have probably been from the air
2S
dispersion.
If anything particular comes up in the
Okay.
-------
Page 58
air, the air comes over and settles back down, and so any
2
contamination would be on the 8urface of your property.
3
There isn't a mechanism where you could have introduced
4
contamination three feet below the surface of your
5
It would have had to have been deposited on the
property.
6
surface, and PCB's stick to the soil and they basically
7
don't migrate unless they have some solvent that will carry
8
them down.
So we collected surface soil sam~les, and if we
9
detected PCB's there, then we went further down.
If we
10
didn't detect PCB's in the surface soil samples, we didn't
11
collect any additional samples, but there were three
12
samples collected from all of the properties in the
locations that we felt you were most likely to be exposed
13
14
to.
Now the flower bed, or gardens, or play areas, or
15
what-have-you, we didn't---
16
MS. HUCKABA:
Well they come around and took a
17
second soil sample, and what they did, we had put top soil
18
in our flower bed, and they took the soil sample out of our
19
flower bed.
I tried to tell the man that that was 8011
20
dirt that we had put in there after the Plant had closed
21
over there.
22
MR. MICHELS:
We received several comments after
23
we collected the soil samples to that nature.
Wherever we
24
received a comment of somebody saying, .Well that's not
25
really representative of what's on my property," we went
-------
Page 59
back and collected additional samples.
2
MS. HUCKABA:
They didn't come back any more.
They took it off the top soil and
3
after I told them that.
4
that was it, out of the flower bed, because I witnessed it.
5
MR. MICHELS:
I'd have to check the specific
6
records to that property, but I know for certain that there
were three samples collected initially from the property.
7
8
MR. TAYLOR:
Yes, Ma'am?
9
BILLIE JEAN HOLLIS:
You have a cost figure for
10
your Preferred Plan in the blue book and I'm wondering how
much has this cost, I mean, from its inception, to do it?
11
12
Who did pay for that?
Did Duracell pay for it?
13
MR. TAYLOR:
Well again, the Remedial
14
Investigation and the Feasibility Study that was done was
15
done under a Consent Order with the Agency, so the
16
Potentially Responsible Parties incurred the costs for
17
doing the work.
In other
We had oversighted that work.
18
words, when they were there we had personally our
19
contractor there.
They're required to pay us those costs
20
via the terms of the Consent Agreement.
We probably had
21
some historical costs that were associated with ranking the
Site and those kinds of things, and we'll attempt to settle
22
23.
those costs when we do the settlement for the Remedial
24
Design and the Remedial Action.
Not only will we attempt
.25
to settle this cost, but part of the agreement to do the
-------
1- - --
Page 60
work will require the Potentially Responsible Parties to
3
MS. HOLLIS:
pay the costs of overseeing the future work.
00 you have any idea what the total
2
cost has been to cover the private interests?
4
00 you know
6
MR. TAYLOR:
just what it will cost in all?
Well I know in the removal alone, I
5
7
think, over Five million dollars was spent hauling
material, debris, etc. away from the Site.
8
9
MS. HOLLIS:
What about the work Conestoga-Rovers
10
has done?
That's been paid for, I'm sure.
Are yaw'll
12
MR. MICHELS:
going to try to collect for that as well?
All those costs have been paid for
11
14
investigative costs.
by Duraeell, the remediation costs to date, the
13
15
MS. HOLLIS:
Are you including that in the Five
million dollar removal figure?
16
17
MR. TAYLOR:
MS. HOLLIS:
18
Of this investigation, yes.
So the Five million dollars and then
19
another what, Two or three million?
Yes, Ma'am.
20
MR. TAYLOR:
MS. HOLLIS:
21
22
there other costs?
23
MR. TAYLOR:
About Eight million total or are'
The Three million dollars that's in
the Proposed Plan 1S an estimated cost.
24
Anybody that
25
negotiates the settlement will have to do the work,
-------
. 12
Page 61
1
regardless of whether it costs Three million or Eight
million.
2
3
MS. HOLLIS:
Are you saying then that possibly
4
the total thing will be contained below Ten million from
the very beginning to its completion thirty years from now?
5
6
MR. TAYLOR:
That's our estimate.
The Three
7
million dollars is the term, the money, that it will take
up front to fund the whole, entire operation.
8
9
MS. HOLLIS:
So it should be somewhere between
10
Eight to Ten million dollars?
11
MR. TAYLOR:
Again, the figure that's in the
Proposed Plan is an estimate of what it will take, and we
13
won't really know wh~t it actually costs until you get out
there and design it and someone bids it out and builds it
14
15
and implements it, but that is the estimated cost as best
16
we can project.
17
Yes, Sir, your name, please?
18
JOE JERNIGAN: My name is Joe Jernigan, and I'd
19
like to ask a couple ~f things.
One is to our geologist
20
here.
When you went to the black board, Sir, did I
21
understand you correctly to say that in the deeper wells,
the ninety foot wells, you detected no contaminants?
22
23
MR. ABLE:
There were two (2) deep ones put in
24
and there were no contaminants.
25
MR. JERNIGAN:
Another thing that I was wondering
-------
Page 62
about i. about this air evaporator and .what we'll be
2
breathing and why you chose it over whatever the
3
'4A-or whatever it was.
I was a little fuzzy on all those
4
letters.
5
MR. TAYLOR:
There were A and B Alternatives on
6
each of the .2 through .5 Alternatives that were
7
considered.
The A Alterative was the ultraviolet
8
detoxification theory.
Basically that technology is good
9
if you know---it's good if you have a high volume of water
10
to treat, and it's good if you have a consistent so~rce,
11
such as. if you have" X" water that c9mes in; n high vo 1 urnes
and you're fairly confident of what the contaminants would
12
13
be, then UV is a good technology.
Based upon the low
14
volume that we're going to get at this Site, and based upon
the fact that we're going to get levels which vary from
15
16
time to time, we're going to get basically where there's
fractures, we're going to get a relatively hot source
17
18
coming through the waste water treatment plant, and we're
19
going to get fractures that are uncontaminated.
We're
20
going to get material that's not been contaminated.
We
21
jU8t don't think the UV is really all that desirable for
22
this particular situation.
The carbon filtration, the air
23
.stripping, and bag filtration,. we think i8 a more
24
appropriate technology.
We have gone out and done a
2S
treatability study and it works well at the Site.
The air
-------
1-
Page 63
stripping that you mentioned when you mentioned breathing
2
contaminants, you know, in addition to what we've described
3
here, i6 that there will be monitoring and if there are any
4
contaminants that are a concern to the Agency because of
5
any other statute, that air stream will be run through
carbon so that it won't release contaminants to the air in
6
7
levels that would be unacceptable.
Too, I'd like to stress
8
that we're talking about contaminants in the part per
9
billion range in the water, and those contaminants are. if
10
an adult consumes or drinks or ingests that water over a
11
seventy year life time.
That's really what the risk is at
12
the Site.
It's not that you're going to be acutely
13
poisoned if you were go out and drink some of that water.
It's not that the water is fifty (50~) percent
14
15
contaminants.
It's just that it's in the part per billion
16
and part per million range.
You're going to have an air
17
stripper and it's going to be run in 9allons per minute
18
through the air stripper, part per million or part per
19
billion contamination.
80 you're going to have gallons
20
running through.
You're 90in9 to have basically very, very
21
low levels of contaminants released through the air.
As
22
10n9 as those contaminants are within acceptable guidelines
for breathing, just as we allow people to have cars that
23
24
operate off of combustion, just as we allow people that
have dry cleaners, just as we allow people to operate
25
-------
Page 64
industry, as long as thoS8 levels are acceptable with the
2
standards in effect, we'll allow that to go on, and I can
. assure you that if those levels are unacceptable and would
3
4
be something that we think is a risk on a long term basis,
5
then we'll deal with it.
6
MS. POAG:
How often will that be checked?
7
MR. TAYLOR:
How often will the air stripper be
8
checked?
9
MS. POAG:
Yes.
10
MR. TAYLOR:
The actual frequency will have to be
11
determined during the design, but typically what's done is
12
you check it real frequent up front to make sure that the
13
levels are acceptable, and then you come up with a
14
monitoring plan to make sure the levels stay acceptable.
Until we actually have the design to tell you what kind of
1S
16
treatment plant, what size it's going to be, and how much
17
water it's going to pump, we really can't tell, you know,
18
whether it's going to be weekly, daily, monthly.
19
MS. POAG:
Well someone mentioned that EPA would
20
check every five (5) years.
21
MR. TAYLOR:
The five year, we put that in all of
22
our meetings, because that's what the National Contingency
Plan says, but it's somewhat misleading when we say "Check
23
24
every five years".
What it really means is that we review
25
all the data as a whole every five years.
The Consent
-------
Page 65
Decree that we enter into will reQuire the PRP's to send in
2
the monitoring results on a routine basis to the Agency,
and-at any time if those monitoring results show that there
3
4
is an unacceptable release either to the air or to the
5
water or whatever, then that practice will have to be
6
stopped immediately.
What we're saying in the five year
7
review is Congress said, "EPA, you've got a bunch of
8
National Priority List Sites that are going to take thirty,
9
forty, a hundred years to remediate.
What we want you to
10
do is if you're not 90in9 to be able to just go out there
and remove everything overnight to acceptable health
11
12
levels, then we want you to review the Site every five
13
years," because as you're aware, in the last twenty years
14
the information we've gathered on the chemicals has changed
15
Quite a bit.
If after five years we determine that the
16
levels that we set in 1991 are not acceptable from a human
health or environmental concern, then the Agency has said,
17
18
"You need to at a minimum review those every five years to
19
make sure they're still protective of public health and
20
environment and until every contaminant has been removed
21
from that Site to an acceptable level."
So that's what "the
22
five year review is about.
It's really not that we sign a
23
Decree and then we let the work go on for five years and
then we look at it to see if it's .11 right.
24
25
Yes, Sir, your name, please?
-------
Page 66
HARRY CORN:
I'm Harry Corn and I'm a property
2
owner around the property.
Has there been any of these
3
contaminants found on any of the citizens' property around
4
this Site?
5
MR. TAYLOR:
Well when you say "Has there been
6
any contaminants found," I'd have to answer that there has
been, like there has been basically allover the Country.
7
8
There's contaminants of some sort found.
9
MR. CORN:
Well I'm talking about the three
10
contaminants that you're speaking of?
11
MR. TAYLOR:
We have found PCB's on sites
12
outside the Plant property.
13
MR. CORN:
Why does the EPA spend all the money
14
cleaning this site up if it has contaminants outside of
15
this property?
Why isn't it forcing this company to buy
16
these people's property and get them somewhere where it's
17
safe?
You're a very powerful organization, because I deal
18
with you some through my work, and I know that you have the
power to do these things.
19
20
MR. TAYLOR:
If those levels of contaminants were
21
at a concentration that we felt was detrimental to your
health or your livelihood, then we would require action be
22
23
done.
The levels of contamination that have been found are
24
extremely low, and we don't feel are unacceptable.
25
Well they must be pretty high to spend
MR. CORN:
-------
Page 67
2
a8 much money as you have down there, and you're fixing to
spend some more money to put in wells and drainage systems
3
to take this out.
4
MR. TAYLOR:
Well the money that's being spent in
5
the future is to make sure that the ground water is safe
6
for human consumption.
The money that was spent in the
7
past on demolishing the Plant was done so that the
unacceptable levels of PCB's in the soil would be removed
8
9
and you wouldn't be exposed to them any more.
10
MR. CORN:
So the EPA is not intending to do
11
anything for the people around this Site; just for this
12
Site?
Is that the way I understand it?
13
MR. TAYLOR:
Well it's not the way I evaluate it.
14
What I evaluate is that EPA has looked at the data that's
15
been generated and has said that the soils that are off-
16
site and the soils that are remaining on-site, there's no
17
cause for alarm, so therefore there's no need to do
18
anything additional.
19
Yes, Si r.
20
DAVID.BAKER:
My name is David Baker. .1 think it
21
might help this discussion if you would go into defining
22
what you mean by acceptable risks, because you've been
23
~sing that word a lot and I haven't heard it defined yet.
24
MR. TAYLOR:
I'll have to ask Kevin to help me
25
here a little bit.
As we've described, a remedial
-------
Page 68
investigation is done to collect data basically.
Say the
2
levels of con"tamination in the soi 1 are "X", the levels of
3
con~amination of the ground water is "y", and the levels of
4
contamination in the air is "Z",
That information is used
S
by our Risk Assessment people to calculate the risks to the
6
people in the area under certain scenarios.
Basically for
7
example, David, if that soil sample was collected from a
8
residential yard, we would evaluate the risks to a child
going out and playing in that yard over their lifetime.
9
10
I'll let Kevin jump in here, but depending on the
11
contaminant and whether it's a carcinogen or a
12
noncarcinogen, we would evaluate whether it's an
13
unacceptable risk.
The National Contingency Plan defines
14
an unacceptable risk as being one for eveiy ten to the
1S
minus four, or one in ten thousand, to one in one million,
16
or ten to the minus six.
17
If I could, I'd like to get Kevin to maybe
explain a little bit more about what acceptable risk means.
18
19
MR. KOPOREC:
Well basically for the PCB's and
20
for the TCE, the two probable carcinogens, both of those
contaminants have been shown to cause cancer in laboratory
21
22
animals.
They haven't been shown conclusively to cause
23
cancer in people, so that's why the probable human
24
carcinogens are not known human carcinogens.
What we hope
25
to do is take the animal data and put some safety factors
-------
Page 69
2
into that, because you're 901ng from animals to try and
figure out what's going to happen in people, and estimate
3
what might be---how many additional cancers you might have
4
from a given exposure, or decide, like Harold was talking
5
about, how many additional cancers is acceptable, which
6
we're talking about one in a million to one in ten thousand
7
being acceptable, and then extrapolate bac~ and say, "Well
8
what conc~ntrations, what levels of exposure, can you have
9
and stay within that acceptable 'risk'?"
I will have to
10
emphasize that these are all upper bound estimates.
11
There's a lot of safety factors put in, since we don't know
12
what's going to happen in a person compared to an animal.
13
Of course we can't do testing in a human.
It wouldn't be
14
ethical and so we have to estimate.
In doing that
15
estimating, we'd always be more protective rather than less
16
protective.
So it's an upper bound estimate of how many
17
additional cancers may occur, and we're really pretty sure
18
that the actual occurrence would be lower and it's most
19
likely not going to be higher than our .estimates.
Does
20
that answer your question?
21
MR. BAKER:
I understand the material.
I just
22
thought it would be he1pful---
23
MR. KOPOREC:
Well if anybody else needs
Okay.
24
clarification, I'll be glad to go further on it.
25
CARL MOORE:
I would like to know what exactly is
-------
Page 70
the number of additional cancers that is acceptable?
2
MR. KOPOREC:
Well it's kind of hard to explain.
3
Wha~ we're saying is that the risk to an individual be
4
between one in ten thousand, one in a million.
Now it's
5
kind of confusing, because a lot of people interpret that
6
to say, "Well does it mean that you're saying for every
million people, you're going to have one additional cancer
7
8
and so for an area like this where you don't have anywhere
9
close to a million people, do we need to worry?"
That'~
10
not what we're saying.
What we're saying is for each,
11
individual person the additional risk over the risk you
have from all the rest of the contaminants that you're
12
13
exposed to in the environment, in your food or whatever,
14
that it's going to be one in a million or one in ten
15
thousand.
We're trying to get the exposure media down to
16
where your risk is less than one in ten thousand for sure,
17
and hopefully less than one in a million in cases where we
18
can.
19
MR. TAYLOR:
Yes, Sir?
20
HARVEY BAKER:
My name is Harvey Baker.
So the
21
risk assessment for the Plant Site would be at a different
22
factor, difference usage factor, than the risk. . assessment
23
for somebodY's yard.
In the scenario
Is that correct?
24
that you're using, you're using the possible use of the
25
Site, factoring that in.
Is that correct?
-------
Page 71
MR. KOPOREC:
That's partly true, but what they
2
actually do in the Risk Assessment for the Site, the
3
contractors did the Risk Assessment that I reviewed, and
4
for the current day, present day scenario, they looked at
5
the Site being used as a park land, I think, and then in
the future scenario, what specifically could happen in the
6
7
future, they looked at well, what if we go in there and did
8
allow a resident to build a house on the present day site,
into the ground water level, then what would the risks be
9
10
then?
That's where they came up with saying that as far as
11
the soil goes, that there's not an unacceptable risk, but
12
if a person put a well in there and would drink that water
13
for a normal time span, like they lived there for thirty
14
(30) years or whatever, then it would be unacceptable.
So
15
they really did look at a residential scenario even on the
16
Site.
17
MR. TAYLOR:
One thing that might have been
18
confusing that I think Mr~ Koporec mentioned a lot were the
19
current zoning laws.
When we did the Risk Assessment, we
20
basically disregarded the current zoning.
21
BILLIE JEAN HOLLIS:
Are there not PCB's, or were
22
there not, or are there not still PCB's in motor oil and
23
other oils that you'd find in service stations that are
24
spilled all over the service station floors?
25
MR. KOPOREC:
I'm not sure.
Do you know about
-------
Page 72
that, Harold?
2
MR. TAYLOR:
PCB's and TCE's have been found and
3
we continue to find them in waste oils a lot, where there's
4
been contamination.
5
MS. HOLLIS:
But there are not PCB's in motor
6
oil?
7
MR. TAYLOR:
Not today and not ever intentionally
Now a lot of times, like I say,
8
in normal motor oil.
9
you've have a waste hauler years ago that might have picked
10
up wastes from Company X that had pce wastes, or had picked
up from service stations that didn't have any PCB's, but
11
12
carried them in the same truck and it contaminated
13
everything that was there.
14
MR. HOLLIS:
Well I had heard that there were
15
PCB's in the oil in service stations, but that's not
16
correct?
17
MR. TAYLOR:
Not to my knowledge, but that's
18
where we get back to what's acceptable or unacceptable
19
risks.
One of the things that the Agency, EPA, had to come
20
to some terms with is that there's been contamination of
21
PCB's allover the Country really, because PCB's are in
22
transformers, they're in a lot of paints, they were
23
basically widely used back before they were banned, and
those PCB's were basically dispersed to some extent to
24
25
where the majority of people today have some trace, you
-------
Page 73
know, some level of PCB's in their bOdy.
You know, usually
2
it's at real extreme low levels and it doesn't do any harm,
but -if you go down with the analytical procedures we have
3
5
MS. HOLLIS:
today, you'll find PCB's pretty much dispersed widely.
I've heard it's in asphalt too.
Is
4
6
it in asphalt?
7
MR. TAYLOR:
Not to my knowledge, unless once
again there's some sort of contamination going on with the
8
9
asphalt.
PCB's may be on the roads a lot of places,
because of the wide use of transformers that have PCB's.
10
11
MS. HOLLIS:
12
except in the oil?
13
MR. TAYLOR:
Have PCB's been found anywhere else
Well they were used in inks.
PCB
14
was used in certain inks years and years and years ago.
I
guess the classical, typical, ninety-nine percent use would
15
They're used in
be transformers as a dielectrical fluid.
16
17
ballasts for lights.
They're used in transformers on the
18
poles. and they're used in transformers in ~uildings.
And in capacitors?
19
MS. HOLLIS:
MR. TAYLOR:
20
21
MS. HOLLIS:
MR. TAYLOR:
22
Excuse me?
In capacitors?
In capacitors, yes, Ma'am.
Capac i tors,. you know, are put in cars. They're put in
23
24
homes.
They're put everywhere and when people are through
They go to landfills and
with them, they throw them away.
25
-------
Page 74
the landfills become contaminated.
We find trace amounts
2
of PCB's, if you analyze, pretty much all over th~ Country.
4
DOROTHY HUCKABA:
Yes, Ma'am, your name again, please?
I'm Dorothy Huckaba, and we had
3
5
our house appraised and we would have had to take a loss.
7
sell it?
Who would we come back on, Mallory's or EPA, if we were to
6
8
MR. HUCKABA:
9
MS. HUCKABA:
MR. TAYLOR:
10
You can't sell it.
You wouldn't get anything for it.
You know, I'll ask Alvin if he has
anything to add, but really EPA, I don't think, has any
liability to citizens for contamination.
11
12
13
MS. HUCKABA:
14
Mallory then?
15
MR. TAYLOR:
So we'd have to come back on
You know, anybody, if they've been
16
damaged, can file a civil lawsuit against anybody to seek
damages, if those damages were legitimately incurred.
17
18
MS. HUCKABA:
Well she said on account of the
Plant being tore down over there, that we would have to
take a 1088 on our property if we were to put it up for
19
20
21
sale.
22
MR. TAYLOR:
MS. HUCKABA:
23
24
MR. TAYLOR:
That was the real estate agent?
Yes.
25
you.
I understand and am fully aware that across the
Well, you know, I sympathize with
-------
. 10
Page 75
nation where there are National Priority List Sites, people
2
complain of property devaluation.
As the Environmental
3
Protection Agency, the authority that Congress gave us, was
4
to go out and reQuire the people that contaminated the
5
property, to reQuire them to clean up the property, and
6
that's really what we're here tonight to talk about, is the
7
contamination that was there, we would basically reQuire
8
that contamination of the soil to be removed and disposed
9
of properly.
Now we're here to talk about the ground
water~ which we think needs to meet State and Federal
11
requirements for drinking water.
Any harm that's come to
12
you as a result of that Plant being there is between you
and the people that run the Plant.
13
14
MS. HUCKABA:
So in other words, we'd have to
15
file a lawsuit against Mallory's?
16
MR. TAYLOR:
Alvin, do you have anything to add?
17
MR. LENOIR:
I believe you've covered it
18
adequately.
You know, I'll say that as a practical matter,
19
if you feel that you've been harmed, your right of recourse
20
is against the party that you feel harmed you.
21
MS. POAG:
Well with the report that you're
22
giving about the average contamination on top of the
ground, wouldn't this go against any suit that she'd have?
23
24
It seems to me that the value of the property is going to
be lower, even though EPA claims it's okay.
25
-------
Page 76
MR. LENOIR:
The value of the property is a
2
sUbjective thing.
You're talking about public perception
3
and-EPA can give the .property a clean bill of health, but
if the public still perceives that property as being
4
5
contaminated---
6
MS. POAG:
Well can you give her some kind of
7
statement or paper showing as you say "a clean bill of
8
health" for her property?
9
That basically is what the document
MR. LENOIR:
10
would be in terms of the ROD, you know, the successful
11
cleaning up of the property, after the Consent Decree has
12
been implemented.
There is such a document that states in
13
effect that this Site has been cleaned up to EPA standards,
14
but EPA doesn't issue declaratory jUdgments about
particular properties.
15
16
MS. POAG:
You couldn't do that until the ground
17
water is cleaned up.
Right?
18
That's correct.
MR. LENOIR:
I mean, as an
19
Agency---
20
MR. POAG:
After thirty more years?
21
MR. HUCKABA:
MS. HUCKABA:
We'll be gone before that.
We'll be dead and gone and buried
22
23
by that time.
24
ROBERT TAYLOR:
If a property owner or any of us
25
got together and say we fe.l t that we've been harmed,
-------
Page 77
whether you say that the health standards are fine, but if
2
we felt like what the public's perception is, he's saying
3
y-ou -know, what they perce i ve out of it, if we fee 1 1 i ke
4
that our property has been devaluated and if we wanted to
5
file a class action suit, a liability suit, it would be
6
against who; P. R. Mallory, or how would we go about that?
7
I would also like to ask this.
Is there a time period from
8
the time that they closed down that operation or is there a
Statute of Limitations for any property liability and would
9
10
that be out in the State of Tennessee?
Can you tell us
11
anything, Sir?
12
MR. LENOIR:
We're getting into the area of free
13
legal advice here.
14
ROBERT TAYLOR:
Well aren't you getting paid for
15
being here tonight?
16
MR. LENOIR:
Yes, but I'm being paid as counsel
17
for EPA.
In terms of the Statute of
I can tell you this.
18
Limitations, you would have no Statute of Limitations. on a
19
matter like that.
20
ROBERT TAYLOR:
For property liability?
21
MR. LENOIR:
For property liability.
22
ROBERT TAYLOR:
In any state?
23
MR. LENOIR:
I beg your pardon?
24
ROBERT TAYLOR:
That's all states?
25
MR. LENOIR:
That's in any state.
The Statute of
-------
Page 78
Limitations would run in terms of when you discovered that
2
you were harmed, and your discovery of when you were harmed
;s w.hen you got enough information to actually bring an
3
4
action in court.
5
ROBERT TAYLOR:
That's true.
We didn't realize
6
how much damage was there until you people came in and
7
started cleaning up this Site.
8
MR. LENOIR:
You can't be penalized for what you
9
don't know, in other words.
10
That's right.
But you say, in
ROBERT TAYLOR:
11
other words, to your knowledge there's no Statute of
12
Limitations?
13
MR. LENOIR:
That's correct.
14
ROBERT TAYLOR:
That'll answer my question.
15
Thank you.
16
MR. TAYLOR:
Yes, Sir, your name again, please?
17
HARVEY BAKER:
My name is Harvey Baker.
What
18
source of assistance does EPA provide the people who are in
this situation, who want to pursue a legal action?
19
20
MR. TAYLOR:
I don't know,just to be. quite
21
honest, if the Agency offers anything other than the
22
documentation and what's been discovered through our
23
investigation.
There's no formal requirement of the NCP or
24
no formal policy of the Agency to try and assist property
owners about litigation against owners or operators of
25
i
t
i
j
!
,
-------
Page 79
other pieces of property.
We get into this and there are
2
reasons for that.
You know, now with Superfund and
3
litigation and whatnot, just every piece of property that's
sold now in the United States on any large scale, there's
4
5
usually some sort of environmental assessment that's done
6
before that property is even sold.
As you can imagine,
7
there are actually millions of transactions every year that
go on between private parties, and everyone of those
8
9
transactions, if that were the law then EPA would be
involved in those transactions and in resolving any
10
11
disputes with those transactions.
I think Congress decided
12
that that really wasn't the role of the Environmental
13
Protection Agency.
The role was to make sure that human
14
health and the environment was protected and not to get
15
into legal battles between the property owners.
I'd 1 i ke
16
to tell you something that we could offer, but to the best
17
of my knowledge we have no assistance.
18
MR. BAKER:
Just the actual results of your
19
testing?
20
MR. TAYLOR:
Right, and that's in the library and
21
that's available to you upon request.
Yes, Sir, David Baker.
22
23
DAVID BAKER:
Yes, David Baker, just a few
24
things; I read in the FS I believe it was, that the release
into the air was just an estimated four (4) plus pounds per
25
-------
Page 80
day of VOC's, Volatile organic Compounds, and that this was
below the limits that you would consider requiring further
2
3
treatment.
Would that amount create an odor in the air at
4
all?
5
MR. TAYLOR:
6
your question.
Perhaps someone else can.
From what?
7
MR. KOPOREC:
MR. TAYLOR:
8
9
MR. BAKER:
To be Quite honest, I can't answer
DCE and TCE.
They said if you were spraying paint,
10
you know, lacquer, if you're wearing a mask and if you can
I was just wondering---
11
12
MR. TAYLOR:
smell it, you're getting too much.
Well that's with a respirator that
13
you would use.
14
MR. BAKER:
MR. TAYLOR:
15
Right.
Yeah, if you can smell it, then
obviously the respirator is not working right.
I don't
16
17
know.
We can look into that and certainly would be glad
I don't know whether anybody here can answer that
18
to.
We were out at the Site today cOllecting
19
question today.
some samples of Cold Water Creek there and when you walked
by the dry cleaners there, you could smell the solvents
20
21
22
from the dry cleaners.
those were in the air, whether it was four (4) pounds per
I couldn't tell you what levels
23
24
day or what.
MS. BILLIE JEAN HOLLIS:
We can occasionally
25
-------
I~
Page 81
2
smell the paper mills, which to me is a great anomaly that
you could spend Ten million dollars to clean up this area
3
and allow these plants that pump out into the air as they
4
do where you can smell it here from Florence.
There's a
5
paper mill in Savannah and one in Florence.
You should go
6
to Columbia at night, you know at Mt. Pleasant, and see the
7
chemical plants.
(Inaudible)
8
MR. TAYLOR:
Well you know the Clean Air Act was
9
amended.
10
MS. HOLLIS:
I used to be a Social Worker in
11
Maury County and I did a lot of work for farm families that
12
lived a couple of miles from that plant.
I was talking to
13
this man and he told me about his cows teeth rotting out
and (i naud i b 1 e ) .
14
15
MR. TAYLOR:
The Air Program is the one that's
16
been revamped by Congress and the goal is to significantly
17
reduce the contaminants that are now at levels which have
18
found to be unacceptable.
I understand your concern, but
19
I'd like toni9ht, you know, we're focusing on the Mallory
20
Capacitor Site.
It's going to be somewhat like the state
21
trooper that might stop you on the road and you're going
sixty-five and he stops you in a fifty-five zone and gives
22
23
you a ticket.
As you're sitting there, somebody goes by at
24
a hundred and twenty miles an hour and you tell him to look
25
at that car, but really, you know, he's concentrating, as
-------
Page 82
we are tonight, on one site at a time.
What we've
2
determined is that the ground water at the Site is above
3
Sta~e and Federal drinking water standards and therefore it
4
needs to be cleaned up.
The costs, the only way we get
5
involved with the costs, is when we get to comparing
6
technologies that will achieve those goals.
So if it can
7
be done for Three million dollars and we think that's a
8
good technical solution, then we'll choose the Three
9
million dollar remedy.
If it'll take Thirty million
10
dollars to do it and there's no other cheaper remedy, we'll
11
do it for Thirty million dollars.
12
MS. HOLLIS:
I'm gOing to challenge you on your
13
analogy just a bit.
I think if you were a state trooper
14
and you were in the process of writing a ticket to someone
15
for driving sixty-five in a fifty-five zone, and someone
16
zipped by at a hundred and twenty, you might not be able to
17
jump back in your car and catch him.
However, I think that
18
that's--
19
MR. TAYLOR:
I know what you're saying.
He could
20'
probably call ahead and ask somebody---
21
MS. HOLLIS:
I mean, are you saying that you
22
would then just henceforth and forever more ignore anybody
23
that's speeding?
24
MR. TAYLOR:
No, Ma'am.
What I'm saying is I
25
would sit there and write you the ticket for going sixty-
-------
Page 83
five in a fifty-five zone.
2
MS. HOLLIS:
Wouldn't you hop in your vehicle and
3
go after the hundred and twenty mile an hour man?
Nobody
4
is hopping in their vehicle---
5
DAVID BAKER:
It's because of their jobs and
6
they're politically---it's all politics, in other words.
7
MS. HOLLIS:
See that's what I'm saying.
Would
8
you look at that car and say, "Hey, that was the Governor.
9
Layoff."
Or woul d you say, "Okay, I've got thi s dude.
10
that's doing sixty-five in a fifty-five and I've got to
11
radio up ahead because I know that's (inaudibl~)."
That's
12
what I'm saying.
I'm not saying, "Yes, I realize that
13
you're tied up in Mallory."
But I'm saying all this time
14
that you've been tied up in Mallory, we've been telling you
15
that a paper company is coming into Wayne County and
16
napalming our for rests and that's not a lie.
They're
17
spraying the defoliant just like they did in Viet Nam.
I
18
showed Albert Gore the pictures of the (inaudible).
is not the first time you have heard this.
This
19
20
MR. TAYLOR:
Well I work in the Superfund
21
Program.
You're right.
It's not the first time I've heard
22
problems about other programs.
What I'm saying is that
23
Congress is. the one that passes the laws and regulations
24
for the Country.
Congress has just revamped the Clean Air
25
Act to improve it and EPA will enforce the laws that
-------
Page 84
Congress has enacted.
2
DAVID BAKER:
I have some more Questions.
Future
3
reporting procedures, how are we go;ng to find out about
4
decisions made and information required ;n the future?
5
Will it be pretty much what we've had. in the past, fits and
6
starts, or will there be a kind of steady flow of
7
information that we can see?
8
MR. TAYLOR:
Well again, you say fits and starts,
9
and that's just your opinion.
My response is to try to get
10
the publ ic as much information as is warrante.d in a timely
11
manner as we get this information.
We don't want to be out
12
here every other day saying, "We've got news for you on
13
Mallory Capacitor and the news is we're going to put in
another well."
14
15
MR. BAKER:
As documents are produced, they
No.
16
should be forwarded to the depository at the library.
Is
17
that not correct?
There hasn't been a steady flow in the
18
There have been times when the flow has dried up.
past.
19
There was a period of over a year when we didn't receive
20
anything fairly recently.
21
MR. TAYLOR:
As documents are approved by the.
22
Agency, they're put in the Repository.
We don -.t put in
23
documents that we don't think are valid or have not .gone
24
through review.
25
I just want to articulate the
MR. BAKER:
-------
Page 85
principle that as documents are produced that are final
2
documents, that the public gets access to them in a timely
3
order.
4
MR. TAYLOR:
I agree a hundred percent with you.
5
We should put any documents---there's some instances where
6
we have done that and we've been lax about it and we'll try
7
to do better in the future.
8
MR. BAKER:
I mean, I don't want to belabor the
9
past, but that's been an issue.
I'm ready to let that one
10
drop.
11
MR. TAYLOR:
The idea is to put documents in the
12
Repository as soon as possible.
We as an Agency have
13
fallen behind universally at doing that and we've been
14
playing a catch-up game for the last four years.
As you
15
saw at the Repository now, we have quite lengthy documents.
16
The goal is to keep that thing up to date and not let it
17
fall behind.
The problem the Agency got into, if you saw
18
that quite lengthy document, we had to put all of that
19
together.
What we try to do is put all of that together
20
before we issue the Record of Decision to catch up and then
21
stay ahead of the game.
22
MR. BAKER:
I just have a few more.
. Somebody
I wrote
23
mentioned a while ago and I wrote this down.
24
"Natural Resources Trustees?"
Somebody mentioned that term
25
and didn't define it.
-------
Page 86
MR. TAYLOR:
I'll let somebody else answer that
2
question, but the National Contingency Plan defines what a
3
Nat~ra1 Resource Tru~tee is and it's basically people like
the Department of Interior, Fish and Wildlife, Bureau of
4
5
the,Mines, if they're impacted.
We have a list of Natural
6
Resource Trustees and it may include people like I've said,
7
the Department of the Interior.
The State of Tennessee has
8
notified about five State and County Resour~e Trustees to
9
us, and we've notified all five of those people.
Those
10
people are allowed to basically comment on any settlement
11
that we',re entering into if it is impacting any sort of
12
natural resource.
They can say~ "Well your remedy is not
13
protective of this particular resource.' , You need to beef
14
it up here or we won't give a covenant not to sue as far as
15
the Consent Decree negotiations."
What that means is---it
16
doesn't mean that the Decree can't be entered.
What it
17
means is the responsible parties may be liable to further
Federal action from another Federal agency if there's been
18
19
damage to a natural resource.
20
MR. BAKER:
The decision on whether to direct the
21
effluent from the treatment into the Green River directly
22
or through the Sewage Treatment Plant, what are the issues
tnvolved in making that decisioh?
23
24
MR. TAYLOR:
Let me back up to the other question
25
you had.
For example, a Natural Resource Trustee, we have'
-------
Page 87
the Fish and Wildlife Agency coming out and reviewing the
2
documents that we have.
3
The decision on whether the discharge goes to the
4
POTW or whether it goes to a particular stream, just to be
5
honest about it, that's pretty much the way we're
6
structuring all the Records of Decision now.
In the past
7
we've said,
"Well this discharge can go to the POTW."
8
Before we. do that we go to the POTW and say, . "Can we send
you "X" number of gallons of the water from this Superfund
9
10
Site?"
They say, "Sure, no problem."
Everything is fine
11
and we send it on, and then two years pass and maybe they
12
are hydraulically limited to the amount of water they can
. receive, or maybe they just question whe~her they should
13
14
receive water from a Superfund Site, and they say, "No.
We
15
told you two years ago you could discharge it to us and now
16
we're saying you can't."
So then our only option really is
17
to get a permit to discharge the water to a stream or a
18
river.
So during the design phase, the engineers do the
19
design and calculate hQw much water they think they'll
20
generate, what the residual contaminants would be, and
21
there will have to be a decision, and I'm sure they'll go
22
to the POTW and say, "We're going to generate so many
23
gallons per week.
Can you take. it and what will it cost?"
24
Then they'll sit down and determine how many gallons that
25
they're going to discharge to the stream.
They'll go to
-------
Page 88
the State and see what the discharge limits would be and
2
basically make an economic decision on which is the best.
3
way_to go.
4
MR. BAKER:
You know, it doesn't seem to be that much.
Going through a POTW, unless it
5
in this case?
6
MR. TAYLOR:
So it all ends up in the Green River
7
offers some additional kind of treatment, there's really no
8
real advantage unless you're discharging a bigger stream.
MR. BAKER: One more question; in the Remedial
9.
10
Investigation, in the evaluation of the ~ite geology
11
there's a misidentification of stratigraphy and that's
12
mostly at this point, I think, an aesthetic consideration,
Is there any way
13
but when I read that I go (gulp gesture).
that that can be rectified?
14
15
MR. ABLE:
Yeah.
Are you the one I talked to on
17
of the Site?
the phone when we discussed getting the geological survey
16
18
MR. BAKER:
MR. ABLE:
19
20
MR. BAKER:
Yeah.
Did you ever call those guys?
I tried.
I didn't get a .hold of the
It's not a real
22
important issue.
right guy and I didn't call back.
To me it's something that---
21
23
MR. ABLE:
24
corrected.
25
MR. BAKER:
To answer the question, yes, it can be
When I read that, I said, "Well what
-------
Page 89
else did they screw up?"
You know, that was my first
2
response.
3
MR. ABLE:
Yes, it can be corrected in upcoming
4
documents.
We can put it in the Remedial Design.
5
MR. TAYLOR:
As a part of your comment tonight,
6
we'll look into it and correct it via the Responsiveness
7
Summary.
8
Your name again for the Court Reporter?
9
CARL MOORE:
I was wondering this four pounds per
10
day coming from this purifier, this air purifier thing,
11
how much of a threat is that going to cause if it's four
12
pounds a day for thirty years?
If you're directly down
13
wind from that, there's going to be some build up.
14
MR. TAYLOR:
There won't be a build up of
15
contaminants.
They'll disperse through the atmosphere.
16
MR. MOORE:
I'm sure they will, but first some of
17
them will come to rest on the ground and on buildings and
18
plants as well as dispersing through the atmosphere.
19
MR. TAYLOR:
Well these are volatile organics and
20
our experience has been that they won't fallout of the sky
21
on plants and animals.
They will disperse.
22
MR. MOORE:
So all of this stuff goes straight up
23
and wreaks havoc in outer---in other words, straight up.
24
Right?
25
MR. TAYLOR:
Again, what we've told you and what
-------
Page 90
we'll assure you tonight i8 that we will evaluate any
2
releases from the air stripper and if those releases are
3
una~ceptable according to State and Federal laws of this
4
Country, then those releases will be controlled via carbon
5
adsorption.
If they're allowable within the laws and
6
regulations of this Country as they exist at the time that
7
they're released, then they'll be released just as we issue
8
permits to chemical companies that release "X" amount of
contaminants to the air from their plants.
9
10
Yes, Sir.
11
My name is Harvey Baker.
HARVEY BAKER:
Is there
12
any atmospheric release from the UV Oxidation treatment?
13
MR. TAYLOR:
MR. BAKER:
Or is that one unacceptable or less
Patty, do you know?
14
15
acceptable because it tends to put more out in the water?
16
MS. FREMONT:
Well it should be carbon dioxide
17
and water.
That's what the contaminants would be converted
18
to, but since the system is such that, with the conditions
at the Site, the efficiency is very, very limited.
19
20
MR. TAYLOR:
I. think what we've determined is
21
that UV lamps, as t understand it, under conditions of. low
volume, that during examination they burn out pretty
22
23
frequently.
50 at least in our evaluation you'll have a
24
more dependable system as far as the health and environment
with the carbon adsorption and air stripping than you will
25
-------
Page .91
if you've got a system.that's out running with lamps that
2
have burned out, discharging water that hasn't been
3
treated.
4
DAVID BAKER:
What sort of maintenance will there
5
be?
Well I guess you won't know that until you get the
6
design, but will there be somebody living here in
Waynesboro who has the responsibility for looking after all
7
8
of this?
9
MR. TAYLOR:
It depends on how automated the plan
10
is.
The whole idea usually behind designing pl~ns is 80
11
that there's minimal custodial care, putting in a system of
12
alarms and monitoring to make sure that you can monitor on
13
a consistent basis.
14
JEWELL POAG:
Well I hope.they don't do it like
15
they did---SOS tested the soil and did find, you know, some
PCB's and we reported it to the State and they came out and
16
17
put up signs.
They weren't supposed to be getting the
18
gravel out of there anyway, but people just go and get
19
gravel, you know, when they want it, and then it was put in
20
some of the construction.s around here.
Well we didn't know
21
just exactly what it all amounted to, because we thought
well if they found it here this much, there may be more
22
23
over here, you know.
They put up signs and someone tore
24
them down.
So I was wondering if we'll have that here.
I
25
hope not, you know.
-------
Page 92
MR. TAYLOR:
Well again, the only thing I can
2
assure is that we're going to take the steps that we think
3
are appropriate to make sure---there's no need in pumping
4
this ground wate~ and spending all the money to treat it to
5
create additional problems.
6
MS. POAG:
That's right.
7
MR. TAYLOR:
I don't think either the Agency or
8
the Potential Responsible Party is going to i.ncur further
9
liability or damage from trying to improve the environment.
10
MS. POAG:
There certainly were some people here
11
that said, "Well I'm not afraid of PCB's.
They're not
12
going to hurt you."
And they piled the gravel up and the
13
little, old kids were coming along from school playing in
14
it and you know, they didn't know.
They didn't have the
15
study that you've done or anything else, except we knew
16
that there was some there.
They just don't care,so many
17
people don't.
I hope this doesn't happen again.
18
I concur with your desires that it
MR. TAYLOR:
19
doesn't and hope to assure you that to the best of our
20
abilities that it won't.
People are people and mistakes
21
,happen.
22
MS. POAG:
That's why I was aSking about how
23
often someone would see about it, you know.
24
MR. TAYLOR:
Yes, Ma'am.
What we'll do, David, I
25
think, asked the question about the public keeping involved
-------
Page 93
and those kind of things.
2
MS. POAG:
Well there are some that will help and
3
are -interested in it being done right.
Others just don't
4
really care.
5
MR. TAYLOR:
The design for the facility will be
6
put in the Repository.
If there's an interest, we'll be
7
glad to come up and explain what the design calls for and
the freQuency of monitoring and how it will be monitored
8
9
and whether there will be a custodian there all the ti~e,
10
or whether the custodian will come on a weekly basis or
11
daily basis or monthly basis.
Those things, you know, we
12
want to have the comments from the pUblic as to what they
13
think is appropriate.
David asked how often it would be
14
monitored, and I would say if I were designing, I'd try to
15
design it so that I could cut down on custodial care to
16
decrease my costs.
That doesn't mean I wouldn't have to
17
implement monitoring to assure the Agency that it's being
18
done properly.
It's just a cost balancing of what kind of
19
monitoring eQuipment you put in versus what kind of human
20
attention you give at the Site.
I know as an Agency we try
21
to reduce the custodial care as much as we can with
22
technical innovations so that we don't have to have someone
23
at the pump and treat station twenty-four hours a day to
24
take care of it, but that doesn't necessarily mean there's
25
any sort of detriment to the environment or the health of
-------
Page 94
the citizens, because usually there's monitoring that takes
place.
2
4
JOE JERNIGAN:
Yes, Sir, your name, please?
I was
3
My name is Joe Jernigan.
6
contaminants.
wondering about this bag that's supposed to trap some
5
7
MR. TAYLOR:
What do you do with it?
Well I'll let Patty help me here.
9
Treatment Plant?
You're talking about the bag filtration on the Waste Water
8
10
MR. JERNIGAN:
11
MR. TAYLOR:
MS. FREMONT:
12
Yeah.
Patty, if you could answer that.
It's going to trap fines and that
14
MR. JERNIGAN:
sort of thing that could clog the carbon adsorption system.
So it's not really contaminated
13
15
substances?
16
MS. FREMONT:
It could have some PCB's, since
18
with air stripping.
they tend to adhere to solids.
Air stripping also causes some
17
The volatiles will come out
precipitates to get trapped on that bag.
19
There's two
20
'things that can be done with them.
21
or incinerated.
22
MR. TAYLOR:
They can be 1andfi11ed
If they have hazardous.substances,
23
then they'll have to be either 1andfi1led according to the
landfill regulations for those particular hazardous
24
25
substances or they can be incinerated via the requirements
-------
Page 95
for those kinds of hazardous substances.
If they are just
2
inert materials, you know---
3
MR. JERNIGAN:
So can that be monitored?
4
MR. TAYLOR:
Well it's another thing to be
5
monitored.
You're not talking about a great deal of
6
volume.
You also have the carbon that has to be disposed
7
of properly also.
So there's no free rides and there's no
8
magic box.
There's no easy solution.
The contamination
9
that's at the Site didn't get there overnight.
10
MR. JERNIGAN:
Well this whole thing is so
11
technical.
You've put so much not only money, that's just
12
one thing, but just the sheer brain power and technology
13
and the incredible time and the heart really, it takes to
14
go into something like this, and I just wanted to see that
15
that's maximized.
One of the things that I really want to
16
see is where these thirteen wells be are the most
17
strategically placed.
You know, the idea came up about the
18
plume changing and I think the selection of those wells is
pretty important.
19
20
MR. TAYLOR:
Well as Patty went over, the
21
selection of even the number of wells was done really for a
22
matter of costing it out and coming up with a basic plan.
That doesn't mean that there'll be thirteen wells placed in
23
24
thirteen locations that we can describe to you today.
25
MR. JERNIGAN:
I wouldn't want
Well I know that.
-------
Page 96
you to.
2
MR. TAYLOR:
We may be able to place twelve wells
3
and jf we can do that, and take care of the plume in a cost
4
effective way, it would be less than that.
5
MR. JERNIGAN:
I guess I'm just for one thing
6
applauding everybody on their hard work and loyalty and the
7
intensity that you've put into the project and we want to
8
see a real fruitful result.
9
MR. TAYLOR:
Well we appreciate that.
At the
10
same time we also ask again that you be cognizant---it
11
isn't an, easy problem.
12
MR. JERNIGAN:
That's true.
13
MR. TAYLOR:
I'm involved, like I say, in a
14
number of sites, in a number of pump and treats, and
15
they're not easy.
We've gone in and put wells in and
16
pumped them for a couple of years and either have had very
17
low reduction of contaminants or we've determined that the
18
wells would be better a little deeper.
They'd be better a
19
little higher.
It's very costly, expensive.
It's not
20
something that you can just stand up here today and say,
"Well we're going to have these wells and they need to have
21
22
a good stream and they're g~ing to pump exactly thirteen
23
gallons a minute."
You get out'there and put the wells in,
24
and just as you said, you're going to put some dry wells
25
in.
You're going to put some wells that produce a lot of
-------
Page 97
water.
You're going to find the contaminants.
They're
2
going to probably go down after a few years and reach some
3
sort of steady state.
It's not easy.
I might say it was
4
going to be easy and there would never be a change, but
5
that's just not the case.
What we've done is what we feel
6
is the best jOb of evaluating what the alternatives are for
7
remediating the Site.
We're going to get out there and do
8
the work and we're going to find things that may be a
9
little different.
When we do, the law and the National
10
Contingency Plan and the regs that go along with it,
11
assumin~ those are significant, we'd come back and tell you
12
what the changes are and ask for your in-put again.
At a
13
lot of the sites we have, we're having to do that, just
14
because when we get out in the field, conditions are not
15
exactly the same as we had anticipated they would be.
So
16
it's not easy.
It's
It's frustrating at times.
17
frustrating to you.
It's
It's frustrating to me.
18
frustrating to everybody up here.
It's led to a lot of
19
distrust about what's .going on, a lot of miscommunication.
20
We're really just human just like you are.
I've.been doing
21
this job for thirteen years and I've had a lot of successes
22
and I've had failures and we just try to do the best we
23
can.
24
Any other questions on the Mallory Site?
25
CARL MOORE:
I was wondering would it be a faster
-------
Page 98
process if you added extra wells?
2
MR. TAYLOR:
That was one of the alternatives in
3
.5 that we considered.
4
CARL MOORE:
Like if you added an extra three or
5
four wells, it would seem like you would pull that much
more water that much faster and it would get it out that
6
7
much more sooner.
8
MR. TAYLOR:
Tony, could you answer the question
9
about what additional wells we'd use?
10
Well they put together those two
MR. ABLE:
11
scenarios, Alternative .4 and .5 and due to the mOdeling
that they did to determine the rates that it would occur,
12
13
it ended up that the twenty-two wells would be just as fast
14
in removing the contaminants as thirteen, and what you get
15
into there is each of these wells has an area that it
16
influences.
If these areas of influence get to overlapping
17
too much, then they're interfering with each other and
18
you're not getting enough bang for the buck.
19
MR. TAYLOR:
In other words, if you have "X"
20
amount of water and you can pump it "X" fast, that's really
21
about as fast as you can pump that water without either
pumping "X" minus one from over here and you still get "X"
22
23
water up.
So in our evaluation, putting in additional
24
wells, and making that place look like Swiss cheese,
25
probably won't be of any more benefit that putting in
-------
Page 99
strategically located wells and pumping at a consistent
2
rate.
3
DAVID BAKER:
4
me.
One is that we had a discussion here a while back, I
A couple of things just occurred to
6
lives on Brewer Drive.
don't remember the folks' name, but there's a family that
Brewer Drive is across the Green
5
7
River from the Site.
abandoned well in that area, which you might be able to get
They told me that they had an unused,
8
9
a sample from to test.
10
MR. TAYLOR:
11
that well?
Jack?
12
MR. MICHELS:
Does anybody have any information on
No.
If there's an unused,
13
abandoned well there, I mean, it certainly wouldn't be with
There was a door to door survey
15
done, you know.
the records of the County.
14
16
MR. BAKER:
17
about an unused well.
18
survey.
19
MR. MICHELS:
Well they might not have asked them
It might have gotten missed on the
20
information on that, I'm sure we'll be glad to consider
Okay.
Well if you have some
21
that.
22
MR. TAYLOR:
23
appreciate receiving it.
24
MR. BAKER:
25
MR. TAYLOR:
If you have information, David, we'd
Well that's aJ1 I've got.
One thing I'll say about wells as
-------
Page 100
far as private wells being good monitoring points, you
2
know, if there's something that you can get in with low
3
cost$ and get a sample out of it, it might add some
4
information.
At the same time, if you don't know the depth
5
of that well, if you don't know where it's streamed, and if
it was put in 1 i ke a lot of private wells are and it's
pretty poorly zoned, I don't know whether the well would
6
7
8
add any information that would be valid or not, but we
9
would certainly be glad to look at it and see.
10
Well it's just something that
MR. BAKER:
11
occurred to me.
12
CARL MOORE:
One thing that just occurred to me
13
if you've got these wells pumping in water from under
ground from under the Mallory Site, but what if one of them
14
15
starts pulling in a large vein or whatever of this
hazardous stuff that will be too high a concentration for
16
17
this water treatment system to handle it?
Is it going to
18
be pumping out a fairly significant percentage of PCB's or
whatever, out into the water that's leaving or into the air
19
20
or in the water that's going to the City drinking water?
21
How much of a threat would that pose?
22
MR. TAYLOR:
Well what I'd first say is that
23
based upon what sampling results we have today, that's
24
pretty unlikely, because if you've gone out to the Site
25
you've seen a number of holes poked out there.
So far
-------
Page 101
we've not experienced what you've just discussed.
If we
2
did, obviously the system would have to have monitoring.
3
CARL MOORE:
And it would be?
4
MR. TAYLOR:
We would have monitoring to monitor
5
the discharge so you'd know if you ever had a problem at
6
the Site.
That is extremely, highly unlikely.
7
CARL MOORE:
I would hope that it would have a
8
built-in safety, you know, in case something like that, in
9
the unlikely case, did happen.
10
JEWELL POAG:
We can't hear over here.
11
CARL MOORE:
In the event that you came upon a
12
high concentration of the toxic stuff, I would hope that
13
the system would shut down before that would go into the
City drinking water.
14
15
MR. TAYLOR:
Again, the discharge goes through
16
the POTW to the Green River and not into the City drinking
17
water per se.
18
Does anybody else have anything to add on that?
19
MR. ABLE:
Well say one of those wells did hit a
20
hot vein, you know, we've got thirteen other ones that
aren't hitting---twelve other ones that aren't hitting a
21
22
hot vein and they would pretty much dilute that out.
23
MR. TAYLOR:
We're not talking about wells that
24
are going to pump a great volume of material.
Any
25
monitor1ng that's done with the system would certainly
-------
Page 102
detect that.
Again, it appears to me to be highly
2
unlikely.
3
CARL MOORE:
If the monitoring or whatever did
4
detect something like that, and there was no individual
5
that would be out there for another three or four days,
6
then it would go by unchecked?
7
MR. TAYLOR:
Well the system will be engineered
8
based upon the best available information.
All we can say
9
is fr9m what we've seen so far, the terms that you've.
10
. described, we don't believe would happen.
The design
11
engineers will take into consideration what system to put
12
in and then we'll have to consider what kind of monitoring
13
needs to be done.
Most likely that would be done under the
14
best available information.
It's hard to say without
15
really---you know, theorizing is one thing on what action
16
to take to monitor the Site.
17
Are there any more Questions on the Mallory
18
Capacitor Site?
19
(No additional Questions were asked.)
20
If we could, let's take a ten minute break
21
here, and anybody that has concerns about any of the other
~
sites, EPA and the State are going to hang around and have
23
a short presentation.
So let's take a ten minute break
24
because it's fifteen 'til ten.
25
(WHEREUPON THIS PUBLIC HEARING WAS TERMINATED.)
-------
Page 103
STATE OF TENNESSEE
COUNTY OF WAYNE
I. Merry B. Sigmon. Court Reporter and Notary
PUbl.ic-at-Large. within and for the State of Tennessee.
do hereby certify that the foregoing pages constitute a
full, true and correct transcript of a Public Meeting
that was held in the Wayne County Circuit Courtroom at the
Wayne County Courthouse in Waynesboro, Tennessee, on June
27, 1991.
I further certify tha~ the Public Meeting was
held in regard to the Mallory Capacitor Company National
Priorities List Site and was conducted by employees of the
Environmental Protection Agency, out of Atlanta, Georgia.
I further certify that this transcript contains
all of the presentations made by the employees of EPA, as
well as the comments and questions offered by the Public.
I do further certify that I am neither of kin,
counsel nor interest to any party hereto.
WITNESS my hand and seal this 11th day of July,
1991.
.
~.~ 0Y0
Si on, Court ~rter
ub ic-at-Large/Tennessee
My Commission Expires:
July 20, 1992
cM~'tf!l 13. cSigmon
COU'ft d?~pO'ft~'f & rviJ~09'fQP6~'f
406 rwQ(~1 d?OQJ
PU(Qlki. ry~nn~llu 38478
363.6200
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APPENDIX B
LETTERS FROM SUPPORT AGENCIES
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I -
STATE OF TENNESSEE
DEPARTMENT OF ENVIRONMENT AND CONSERVATION
706 Church Street, Suite 200
Nashville, TN 37243-1538
August 8, 1991
Mr. Harold Taylor
U.S. EPA - Region IV
North Superfund Remedial
345 Courtland STreet
Atlanta, GA 30365
Branch
Dear Mr. Taylor:
Division
Decision
County.
include:
of Superfund personnel have reviewed the draft Record of
for the Mallory Capacitor site in Waynesboro, TN, Wayne
The major components of the selected alternative 4b
a.
Extraction of contaminated ground water with 13
extraction wells.
On-site treatment of the extracted ground water using
an air stripper to remove volatiles.
A bag filter and carbon absorption unit will follow
stripper prior to discharge to adjacent surface waters
or the POTW.
b.
c.
Environmental monitoring will be required during the life of the
treatment process.
The Division feels that the selected remedy adequately addressed
state concerns and is appropriate for this site based on the
existing. known conditions.
Sincerely,
~~\.. \.A...
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APPENDIX C
RISK ASSESSMENT CERTIFICATION
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I: -
RISK ASSESSMENT CERTIFICATION
The Region IV risk assessment staff has reviewed the PRP-
generated risk assessment for the Mallory Capacitor NPL Site,
Waynesboro, TN for compliance with current Agency health risk
guidance-and policy. Comments were conveyed to the Potential
Responsible Parties (PRP) through the Remedial Project Manager
and appropriate changes/corrections have been incorporated into a
revised risk assessment document. In accordance with the
requirement of OSWER Directive No. 9835.15 (8/28/90), it has been
determined that the final risk assessment as summarized. in this
Record of Decision conservatively conveys the upperbound cancer
and the systemic toxicity risks posed through all reasonably
likely current and future exposure scenarios by contaminants
identified at this site. Therefore, it is acceptable to the
Agency.
~
~
01/ L
/ ate
tV
Elmer W. Akin
Health Assessment
Officer
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