United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R04-91/089
June 1991
EPA Superfund
Record of Decision:
Hercules 009 Landfill, GA
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~.101
. REPORT DOCUMENTATION 1" IIEPORTNO. ~ 1 2. a. Aldpl8nt8 Aemulon No.
PAGE EPA/ROD/R04-91/089;
: ~ - -'_IIId"'" I L AIpart Date
PERFUND RECORD OF DECISION 06/27/91
rtercules 009 Landfill, GA ~ I.
First Remedial Action
7. Aullar(a) I. I'I8rfotmIn8 OrganIzatIon AIpL No.
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401 M Street, S.W.
Washington, D.C. 20460 14.
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18. AII8hcI (Unt: 2Il1O worda) i
The 16.5-acre Hercules 009 Landfill site is in Brunswick, Glynn County, Georgia. Land
use in the area is predominantly commercial and residential. Onsite features in the
northern 7 acres of the site are a landfill area with 6 disposal cells containing
approximately 33,000 cubic .yards of 1 percent toxaphene sludge, a drainage ditch, and a
~rainage culvert. Most of the estimated 1,400 residents within 3 miles of the site are
1nected to a public water supply, except for 6 homes and a church that use private
~~lls as their drinking water supply. Fro! 1948 to 1980, Hercules Inc., manufactured
the agricultural pesticide toxaphene. Was~e from the manufacturing process was
accumulated by storing toxaphene contamina~ed wastewater in the offsite settling ponds.
In 1975, the State permitted the site to accept and dispose of pesticide waste,
including toxaphene, in the 009 landfill site. Also disposed of in the landfill area
were empty toxaphene product drums, process sludges, glass, rubble, and trash. In
1979, a State inspection detected elevated levels of toxaphene in sediment and surface
water in the adjacent drainage ditch, and in 1980, the State revoked Hercules'
operating permit. In 1983, the State required Hercules to install a ground water
I monitoring system to assess site contamination. In 1984, because toxaphene was found
I
(See Attached Page)
17. DocI8r8nt....,. .. OM ....... .
Record of Decision - Hercules 009 Landfil1~ GA
First Remedial Action
Contaminated Medium: qw .
Key Contaminants: organics (pesticides) .
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EP~tROD/R04-9l/089
Hercules 009 Landfill, GA
First Remedial Action
~ -ract (Continued)
in a deep/shallow well cluster in the aquifer beneath the site, additional qround water
monitorinq wells were installed. Hercules closed, covered, and seeded all landfill
c~lls in accordance with State solid waste permits. This Record of Decision (ROD)
addresses Operable Unit 2 (OU2), the contaminated qround water, as an interim action.
Future RODs will tully address the principal threat posed by the site. The primary
contaminants of concern affectinq the qround water are orqanics includinq pesticides.
The selected remedial action tor this interim remedy includes extendinq municipal water
lines and connectinq all residences with private wells and the church to the municipal
water supply: and implementinq institutional controls, incluCfnq qround water use
restrictions. The estimated capital cost for this remedial action is $106,000. There
are DO O&M costs associated with this remedial action.
PERFORMANCE STANDARDS OR GOALS:
the final remedy.
Cleanup levels for qround water will be addressed in
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INTERIM ACTION RECORD OF DECISION
SITE NAME AND LOCATION
Hercules 009 Landfill Site
Operable Unit #1
Brunswick, Glynn County, Georgia
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected interim remedial action
for the Hercules 009 Landfill Site, Brunswick, Georgia. The interim
. remedy was chosen in accordance with the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980 (CERCLA), as
amended by the Superfund Amendments and Reauthorization Act (SARA),
and to the extent practicable, the National Contingency Plan (NCP).
This decision is based upon the Administrative Record (Appendix A)
for the Site. .
The State of Georgia concurs with this interim action.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this Site,
if not addressed by implementing the respo~se action selected in this
Interim Action Record of Decision, may present a current or potential
threat to public health, welfare, or the environment.
DESCRIPTION OF SELECTED REMEDY
This Hercules 009 Landfill interim action (IA) is the first remedial
action to be taken at the Site by the Environmental Protection Agency
(EPA). This IA is being proposed for the Hercules site to protect
people from exposure to toxaphene and other possible contamination in
the surficial aquifer. This proposed LA addresses the threat posed
by the aquifer but is not the final action planned for the site.
Subsequent actions are planned to fully address the principal threat
posed by the conditions at the site. These conditions and feasible
alternatives will be presented in the final Remedial
Investigation/Feasibility Study (RI/FS) Report and in the final
proposed plan for this site, respectively. This IA is intended to
prevent the human consumption of contaminated groundwater. Upon
completion of the RI/FS, this interim remedy will be incorporated
into the design of the final remedy specified in the final Record of
Decision (ROD).
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The major component 6f the selected remedy for this interim remedial
action is:
Connection of seven (7) institutional and residential locations
to the city of Brunswick Dublic water supply system. This IA
will' be taken in cooperation with the City of Brunswick Water and
Wastewater Department. The work includes excavation, .
backfilling, grading, landscaping, mechanical work, and the
installation of metering points at each node on the system.
Institutional controls will be implemented to prevent the
consumption of contaminated groundwater.
STATUTORY DETERMINATION
This interim action remedy is protective of human health and the
environment, complies with (or waives) Federal and State applicable
or relevant and appropriate requirements for this limited-scope
action, and is cost-effective. This action is interim and is not
intended to utilize permanent solutions and alternative treatment (or
resource recovery) technologies to the maximum extent practicable for
this interim action. Because this action does not constitute the
final remedy for the site, the statutory preference for remedies that
employ treatment that reduces toxicity, mobility, or volume as a
principal element will be addressed by the final response action.
Subsequent actions are planned to address fully the threats posed by
the conditions at this site. Because this remedy wi~l result in
hazardous substances remaining on site above health-based levels, a
review will be conducted within five years after commencement of the
remedial action as EPA continues to develop final remedial
alternatives for the site. The review will be conducted to ensure
that the remedy continues to provide adequate protection of human
health and the environment. Because this is an interim action ROD,
review of this site and of this remedy will be continuing as part of.
the development of the final remedy for the site.
~rrl71;,,~
-k1Greer C. Tidwell
~- Regional Administrator
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2.0
3.0
4.0
5.0
6.0
7.0
8.0
9.0
10.0
11.0
TABLE OF CONTENTS
SITE LOCATION AND DESCRIPTION
. . . . . . . . . . . . . . . . . . . . . . . . . . page 1
SITE HI STORY. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . page 1
HIGHLIGHTS OF COMMUNITY PARTICIPATION.................... page 4
SCOPE AND ROLE OF THE OPERABLE UNIT ....................page 5
SITE CHARACTERISTICS................................... page 5
5.1
5.2
.Area Geology.................... ~ . . . . . . . . . . . . . . . . page 5
.Area Hydrogeology................................ page 5
SUMMARY OF
SITE RISKS.................................. page 6
DESCRIPTION OF ALTERNATIVES ............................page.7
7.1
ALTERNATIVE
1 - No Action ~........................ page 7
7.2
ALTERNATIVE 2 - Extending Municipal Water Lines ..page 7
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
. e.. . . . . . page 8
SELECTED RE.MEDY ......................................... page 10
STATUTORY DETERMINATIONS ...............................page 10.
RESPONSIVENESS SUHMARY ..... ~.................. ........ ...page 11
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LIST OF FIGURES
,
A.
Figure 1 - Geographic Location Map
B.
Figure 2 - Site Map
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RECORD OF DECISION
DECISION SUMMARY
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1.0
SITE NAME. LOCATION. AND DESCRIPTION
The Hercules 009 Landfill (hereinafter, "the Site")is located in
Glynn County, Georgia approximately three miles north of the City of
Brunswick and one mila west of u.S. Highway 17 (Figure 1). The 16.5
acre property is bordered by Georgia State Highway 25 (GA Spur 25) on
the west; an automobile dealership on the north; a young slash pine
forest on the east; and several homes, a church, an elementary school
and a shopping center at the south-southeastern point of the
. property. Land use surrounding the Site includes mixed commercial
and residential. Located approximately 1,000 feet from the site are
a large shopping mall, a bank, and a family restaurant.
Approximately ninety-nine percent of the estimated 1,400 residences
within a three-mile radius of the Site are connected to the public
water supply. Homes west of the spur depend on wells for drinking
water, although at least two of these have deep artesian wells. The
wells nearest the site belong to a church and five residential
properties. The nearest home is situated 500 feet from the landfill
area of the site, and this home does have a private well.
On the northern seven acres of the property are six disposal cells
which contain approximately 33,000 cubic yards of one percent
toxaphene sludge (Figure 2). A drainage ditch runs along the eastern
. edge of the Site then curves toward a tidal marsh. A pond lies at
the southern end of the property and was originally excavated as a
borrow pit. A drainage culvert constructed of 48-inch diameter
corrugated pipe is located semi-parallel to the southern boundary of
the landfill cells. The landfill property is fenced and has one
entrance through a locked gate.
2.0
SITE HISTORY AND ENFORCEMENT ACTIVITIES
The 009 Landfill is owned by Hercules, Incorporated, who is the
Potentially Responsible Party (PRP) for this Site. Hercules is a
large, diversified company whose services include the manufacture of
chemicals for industry, as well as rocket .propulsion projects for the
U. S. Department of Defense. Hercules purchased the four-year old
Brunswick Plant in 1920 from the Yaryan Rosin. and Turpentine
Company. The company began manufacturing the agricultural pesticide
toxaphene in 1948 and continued production through 1980. Toxaphene
was used as a pesticide to control. boll weevils as well as mites and
ticks on cattle. The EPA banned the use of toxaphene in 1982.
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POINT
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DRAINAGE ..
DITCH
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SCALE 1: 24,000
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Figure I
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JDOU:T ROAD
EN'TRANCE
Figure 2
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Hercules began negotiations with the Georgia Environmental Protection
Division (GaEPD) in January 1974 for a permit to dispose of pesticide
waste. This waste was accumulated by storing contaminated wastewater
from the toxaphene manufacturing process in settling ponds. The
procedure allowed water to evaporate, thus leaving a sludge residue
in the drying basin. The 009 Landfill was permitted by the GaEPD in
1975 to accept toxaphene and began operation that year.
, .
The landfill was constructed in a borrow pit formed during the
construction of Spur 25. Reportedly, the cell bottoms and sides were
lined by a one foot bentonite clay and soil mixture. The landfill
was primarily filled with wastewater sludge generated during .
production of toxaphene at the Hercules plant~ however, contaminated
soil, empty toxaphene product drums, process sludges, glass, rubble,.
and trash are also believed to be contained in the landfill. In
1979, as a result of a routine GaEPD inspection, elevated levels of
toxaphene were detected in sediment and surface water samples
collected in the adjacent drainage ditch. Hercules' operating permit
was revoked in July 1980. .
In 1983, the GaEPD requested a groundwater monitoring system. One
deep well and five shallow wells were installed to assess groundwater
contamination originating at the landfill and to determine the
direction and rate of groundwater flow in the surficial aquifer.
Because of toxaphene found in the deep well, four additional deep
wells were installed in 1984 to further characterize groundwater
contamination at the Site. Toxaphene concentrations in excess of the
drinking water standard were identified in one deep/shallow well
cluster in the aquifer beneath the Site. As a result of the Hazard
Ranking System (HRS) Package completed by EPA, Hercules was proposed
for inclusion on the National Priorities List (NPL) in September
1983.. Hercules 009 Landfill was finalized for inclusion on the NPL
in September 1984. Initial remedial activities were performed by
GaEPD, and EPA assumed the role of lead agency in 1987. In an
agreement signed ~n July 15, 1988, Hercules consented to conduct the
. RI/FS under the oversight of EPA.
All cells were closed in accordance with a Solid Waste Permit
the GaEPD. The closed cells were covered with Hercules stump
and seeded with grass. Stump dirt originates at the Hercules
and is removed from the wood purchased for extraction of pine
with
dirt
plant
resins.
3.0
HIGHLIGHTS OF COMMUNITY PARTICIPATION
The Interim Action Proposed Plan for the Hercules 009 Landfill was
released to the public on Hay 13, 1991. This document was made
available to the public in both the administrative record and an
information repository maintained at the EPA Record Center in Region
IV and at the Brunswick-Glynn County Regional Library. Also, all
addressees on the Site mailing list were sent a copy of the Proposed
Plan. The notice of availability of these two documents was
published in the Brunswick News on May 10,1991. A public comment
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period was held from May 13, 1991 to June 12, 1991. In addition, a
public meeting was held.on May 15, 1991. At this meeting,
representatives from-EPA discussed the Interim Action alternatives
currently under consideration and addressed community concerns.
Response ~o the comments received during the comment period is
included in Responsiveness Summary section of the ROD. This decision
document presents the selected interim remedial action for the
Hercule~009 Landfill, Brunswi~k, Glynn County, Georgia, chosen in
accordance with CERCLA, as amended by SARA and, to the extent
practicable, the NCP. The decision for this site is based on the
Administrative Record.
4.0
SCOPE AND ROLE OF THE INTERIM ACTION
Due to the length of time required to complete the RI/FS and the
immediate nature of the threat at this site, EPA has decided to
initiate an interLm action. This IA is being proposed for the
Hercules site to protect human health from exposure to toxaphene and
other possible contamination in the surficial aquifer. This proposed
Interim Action addresses the threat posed by the aquifer but is not
the final action planned for the site. Subsequent actions are
planned to fully address the principal threat posed by the conditions
at the site. These conditions and EPA's proposed solution will be
presented in the final RI/FS Report and final proposed plan for this
site. This proposed action of providing an alternate water supply is
intended to prevent the human consumption of contaminated
groundwater.
5.0
SITE CHARACTERISTICS
Geo1oqy
The landfill is located within the area commonly known as the
Atlantic Coastal Ridge. The unconsolidated sed~ents encountered at
the landfill are fine to medium grained sand with varying amounts of
silt and clay. This stratigraphy extends to a depth of 80 feet.
Below depths of 80 feet, coarse sands and shell/gravel are found to a
depth of 100 feet.
Hvdroloav
Two distinct aquifer components underlie the Site. These components
are separated by a semi-confining layer, although the extent of
continuity of this layer is uncertain. The shallow zone of the
surficial aquifer extends from the water table (about eight feet) to
a semi-confining layer. . This semi-confining layer begins at
approximately 30-35 feet below the land surface and extends to
approximately 60 feet below the land surface. The shallow zone is
monitored by nine wells in the surficial aquifer table at a depth of
25-35 feet. Underlying the shallow zone is a slightly sandy clay
layer from 35-60 feet which acts as a semi-confining layer between
. the shallow zone and the deeper aquifer zone. Below the
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semi-confining layer is a layer of mediUm to coarse sands containing
shell and gravel. This layer begins at about 60 feet and continues
to 90-100 feet. This zone is monitored by five wells screened at
various intervals from 78-90 feet.
Water level data collected during the Remedial Investigation sampling
event in April and June of 1990 show groundwater flows in the shallow
zone toward the southeast. Results of the Remedial Investigation
sampling efforts of March/April, 1990 revealed concentrations of
toxaphene in the groundwater ranging from 5.6 to 76 parts per billion
(ppb) in the surficial aquifer. One sample from the deep aquifer
showed 30 ppb toxaphene.. .
6.0
SUMMARY OF SITE RISKS
CERCLA directs that the EPA must protect human health and the
environment from current and potential exposure to hazardous
. substances at Superfund sites. In order to assess the current and
potential risks for the Hercules site, a risk assessment will be
coriducted as part of the RIfFS. This risk assessment will include an
ecological assessment that will address any ~pacts the site may have
on the tidal marsh. The major goal of this IA is to prevent the
consumption of contaminated groundwater. This action will achieve
significant risk reduction early in the Superfund process.
The major risk that is currently associated with the Hercules site
concerns toxaphene contamination in the groundwater. Toxaphene is a
class B2 carcinogen. A B2 carcinogen is defined as a probable human
carcinogen, which indicates that sufficient. evidence exists as to the
compound's carcinogenicity in animals and inadequate or no evidence
exists as to the compound's carcinogenicity in humans. Toxaphene has
. been detected a levels ranging up to 76 ppb in shallow groundwater to
30 ppb in deeper groundwater. Toxaphene has been found in drainage
ditch sediments ranging up to 65.6 parts per million (ppm).
Three private wells located in the residential area adjacent to and
southeast of the Site have been sampled annually since 1985 by
Hercules. At least two of the wells are screened in the deep
aquifer. Toxaphene was not detected in any of the samples at or
above concentrations of 2 ppb, which is the detection limit for the
instrumentation. Toxaphene contamination of a private well off-site
has been documented at 1 ppb; however, it is ~portant to note that 1
ppb is an estimated value and is below the practical quantification
limit for toxaphene.
Other constituents identified in groundwater included carbon
tetrachloride, acetone, alpha BHC, heptachlor, dieldrin, DDE, DDD,
endrin ketone, DDT, endrin, 4 methyl-2pentanone, and TCDF.
Potential routes of human exposure to groundwater include the private
wells located downgradient (southeast) of the site, discharge to the
drainage ditch adjacent to the site, and groundwater flow to Belle
Creek and the. tidal marsh located a mile downstream. A school is
located adjacent to the drainage ditch. Potential routes of .
environmental exposure include both groundwater and surface water
flow into the drainage ditch and the tidal marsh.
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The drinking water standard for toxaphene is 3.0 ppb. Levels found
in private wells are 1 ppb, which does not exceed the drinking water
standard. However, the direction of groundwater flow from the Site
is toward these private wells. Therefore, the immediate threat at
the site is the migration of a toxaphene plume towards the residences
located southeast of the site, not the possible presence of toxaphene
in the wells. Since the contamination in the aquifer exceeds the
safe drinking water standards on the site, a potential risk to human
health and the environment definitely exists. Actual or threatened
releases of hazardous substances from this Site, if not addressed by
implementing the response action selected in this IA present a
current or potential threat to the public health and welfare.
7.0 DESCRIPTION OF ALTERNATIVES
Alternative 1
No Action Alternative - The Superfund program requires the "No
Action" alternative to be evaluated at every site to serve as a
baseline for comparison with the other alternatives. Under this
alternative, EPA would take no further action at the site to minimize
the impact from the contaminated groundwater until the completion of
the RI/FS. The "No Action" alternative would not eliminate any
exposure pathways or reduce the level of risk at the site.
Construction Cost: $0
Annual Operation and Maintenance Costs (O&M): $23,000
Months to Implement 0
Alternative 2
Extending Municipal Water Lines - In order to minimize exposure to
contaminated groundwater, municipal water lines from the Brunswick
Water System would be extended along Benedict Road and Nix Lane.
With the owner's permission, all the residences and the Beverly
Shores Baptist Church would be connected to the municipal water
system. Under this alternative, private wells immediately
downgradient of the landfill would be replaced by the municipal water
system. This action would be taken in cooperation with the City of
Brunswick Water and Wastewater Department. Institutional controls
will be implemented to prevent the consumption of contaminated
groundwater. Extension of the city's water supply to the impacted
area would achieve significant risk reduction early in the Superfund
Process.
Construction Cost: $106,000
Annual Operation and Maintenance Costs (O&M): $0
Months to Implement 6
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8.0
SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
The proposed Interim-Action for the site is to extend municipal water
lines along Benedict Road and Nix Lane. As discussed earlier, the Interim
Action for the groundwater is being proposed to prevent the consumption of
contaminated groundwater. Subsequent actions are planned to address fully
the principal threats posed by the conditions at the site. The "No
Action" alternative would not eliminate any exposure pathways or reduce
the level of risk; however, this alternative is carried through the
comparative analysis as a baseline for comparison with the remaining
alternative. .
The evaluation of the proposed Interim Action is based on the limited role
and scope of this. action. .The evaluation profi~es the performance of the
Interim Action with respect to the nine criteria that EPA uses to evaluate
alternatives. The evaluation criteria are noted below.
EVALUATION CRITERIA
Overall Protection of Human Health and Environment - addresses
whether or not a remedy provides adequate protection and describes how
risks posed through each pathway are eliminated, reduced, or .
controlled through treatment engineering controls or institutional
controls.
Compliance with ARARs - addresses whether or not a remedy will meet
all of the applicable or relevant and appropriate requirements (ARARs)
of other Federal and State environmental statutes and/or provide
grounds for invoking a waiver.
Lona~Term Effectiveness and PeJ:DlAl1ence - refers to the magnitude of
residual risk and the ability of a remedy to maintain reliable
protection of human health and the environment over time once cleanup
goals have been met.
Reduction of Torlcity. JIobility. or Volume Throuah Treatment - is
the anticipated performance of the treatment technologies that may be
employed in a remedy.
Short-Term Effectiveness - refers to the speed with which the remedy
achieves protection, as well as the remedy's potential to create
adverse impacts on human health and the environment that may result
during the construction and implementation period.
T~lementabilitv - is the technical and administrative feasibility
of a remedy, including the availability of materials and.services
needed to implement the chosen solution
Cost - includes capital as well as operation and maintenance costs.
State Acceotance - indicates whether, based on its review of the
RI/FS and Proposed Plan, the State concurs with, opposes, or has no
comment on the preferred alternative.
Community Acce~tance - will be assessed in the Record of Decision
following a review of the public comments received on the RI/FS report
and the Proposed Plan.
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Analysis
Overall Protection of Human Health and the Environment The" no
action" alternative is not protective of human health and the environment
because it allows the continued consumption of the contaminated
groundwater. The "no action" alternative also defeats the purpose for
conducting th~s Interim Action." The proposed municipal water hook-up will
provide protection of human health and the environment by eliminating or
reducing the risk through preventing the consumption of contaminated
groundwater. "
Compliance with ARABs CERCLA provides that if an interim measure is
conducted, ARARs can be waived; however, any"ARARs directly associated
with this action will be met. "
Long-TeDD Effectiveness and PeDDanence The goal of this interim
" action is to prevent the consumption of contaminated groundwater. Within
the scope of this interim action, the placing of the nearby residents on a
municipal water system will achieve a long term solution of alleviating
the ~ediate water quality threat to human health in the ~ediate area
of the Site. However, long-term effectiveness and permanence for a remedy
for the source of the contamination will be evaluated prior to
~plementing the final remedy for the site when the RI/FS is completed.
The "no action" alternative will not provide long-term effectiveness and
permanence with respect to the contaminated aquifer at this Site.
Reduction of 'l'orlcity, Hobility, or Volume of the Contaminants 'l'hrough
Treatment Neither of the alternat~ves provide for a reduction of
toxicity, mobility or volume of the contaminants through treatment. Such
a re~uction is beyond the scope of this interim action but will be
addressed by the final remedial action to be implemented.
Short-TeDD Bffectiveness The goal of this interim action is to
prevent the consumption of contaminated groundwater. The "no action"
alternative does not provide any short-term effectiveness with respect to
the contaminated aquifer at this Site. However," the placing of the
nearby residents on a municipal water system will achieve.an ~ediate "
solution to the ~ediate water quality threat to human health in the area
of the Site within the scope of this interim action. The short-term
effectiveness of the remedy for the source of the contamination will be
evaluated prior to implementing the final remedy for the site when the
RIfFS is completed.
Implementability Both alternatives are easily implemented for the"
Site. Implementation time is expected to be approximately six months from
the date of an approved design for the installation of the municipal water
hook-ups.
Cost The "no action" alternative will have costs of $23,000 per year"
associated with it. This cost will be necessary to sample and analyze the
existing drinking wells located along Benedict Road on an annual basis.
The estimated construction cost for the municipal water hook~ups is
$106,000 to design and construct the system.
State Acceptance The State of Georgia concurs with the selected
remedy for this site.
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community Acceptance Community acceptance of the Interim Action of
the selected remedy ~as been positive. A local environmental group, the
Glynn Environmental Coalition, concurs with the selected remedy. The
residents who live along Benedict Road and Nix Lane like the selected
remedy, but have expressed concerns about who will have to pay the monthly
water bills once the municipal water is provided to their homes.
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9.0
SELECTED REMEDY
EPA proposes that the municipal water lines from the Brunswick Water
System be extended along Benedict Road and Nix Lane. With the owner's.
permission, all the residences and the Beverly Shores Baptist Church would
be connected to the municipal water system. Under this alternative,
private wells immediately downgradient of the landfill would be replaced
by the municipal water system. In summary, the municipal water hook-ups
would achieve substantial risk reduction at a early stage in the Superfund
process. This early action is being taken to abate the immediate threat
to human health, and is being taken in response to a potential problem
that could worsen if not addressed. This action will be taken in
cooperation with the City of Brunswick Water and Wastewater Department.
10.0
STATUTORY DETERMINATIONS
Protection of Human Health and the Environment
This interim remedy is part of an overall remedy for the site which will
ult~tely protect human health and the environment. This interim remedy
is protective in the short term in that it will prevent the ingestion of
contaminated groundwater from the site until a permanent remedy is in
place. This remedy is interim in nature and as such will not be
protective in the long term. Although this interim remedy is not
protective in and of itself, it will be part of an overall remedy which
will attain the statutory requirement for protectiveness. In addition, a
five-year review will be conducted to determine whether this interim
action is serving the protective purpose for which the this remedy was
intended~ .
ARARs
CERCLA provides that if an interim measure is conducted, ARARs can be
waived, and these requirements will be achieved upon completion of the
permanent remedy. Accordingly, final cleanup levels for soil and
groundwater do not have to be achieved for this interim action, but will
be addressed in the final remedy. This interim remedy will comply with
all Federal and State requirements which are applicable or relevant and
appropriate to its implementation.
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Permanence
The selected interim-remedy does not represent a' permanent solution with
respect to the principal threats posed by the site. However, given the
interim nature of this action and the fact that further studies are needed
before a permanent remedy for the Site can be selected, the statutory
preference for use of permanent solutions and alternative treatment
technologies will be addressed at the time of selection of the final
remedy for the site.
Treatment
The selected interim remedy does not utilize treatment as a principal
element. Given the 'nature 'of this interim action, this alternative uses
treatment to the maximum extent practicable. "
Cost Effectiveness
, The selected remedy is cost effective, and is the most cost-effective when
compared to the other alternative which would not adequately protect human
health and the environment in the short term by preventing contaminant
ingestion.
EXQlanation Of Sianificant Chanaes
There have been no significant changes in the selected interim remedy from
the preferred interim remedy described in the Proposed Plan.
11.0
RESPONSIVENESS SUMMARY
-,
The purpose of this responsiveness summary is to identify the comments and'
concerns of the local community and potentially responsible parties (PRP) ,
regarding the Interim Action Proposed Plan, and to document how EPA
considered these comments and concerns during the selection of a remedial "
alternative. This responsiveness summary consists of comments received
during the public meeting and during the public comment period.
1.
Public Comment:
What is the purpose of the proposed remedial action?
EPA ReSDOnse: The purpose of this interim action is to alleviate' the
immediate threat posed by a contaminated groundwater plume that could
impact several residences and a church located southeast of the site
if left unchecked.
2.
Public Comment: Has toxaphene been detected in the private wells
located southeast of the site?
EPA Resoonse: Toxaphene has been tentatively detected at 1 ppb in
residential wells; however, this is a value that is estimated since it
is below the practical quantification limits of the instrUmentation
and is not fully differentiated from matrix interferences on the
chromatoqraph.
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3.
Public Comment:
How safe is the drinking water?
EPA Response: The Maximum Contaminant Level (MCL) for toxaphene is
3.0 ppb. Toxaphene is has been tentatively identified in the
residential wells at 1.0 ppb. Therefore, the drinking water is safe;
however, the threat exists that the MCL could be exceeded in the
immediate future.
4.
Public Comment: Has there ever been a release from one of the
containment cells to the drainage ditch that runs beside Altama
Elementary School?
EPA Response: It is unknown at this time whether the containment
cells are leaking or whether the contamination is from a point source
in the former sludge staging area. In 1980, the GaEPD sampled the
drainage ditch and found toxaphene contamination at levels of 65 ppm
in a sample collected 65 feet east of the landfill in the drainage
ditch. In 1990 samples in the drainage ditch were collected as part
of the RIfFS. These samples were collected at locations which
included: three areas adjacent to the site, adjacent to the school,
at Stafford Avenue, at U.S. Highway 17, and in the tidal marsh.
Toxaphene was only detected at one of these locations. This location
was adjacent to the site in the proximity of the former sludge staging
area of the landfill. During the summer of 1991, surface water and
sediment samples will be collected from the drainage ditch at the
locations listed above.
5~
Public Comment:
area removed?
Why was the large oak tree that was in the landfill
EPA Response: Trees have root systems that could cause penetration
through the landfill cap. During possible wind storms, trees could be
overturned, which would bring contaminated sediment to the surface.
Therefore, all trees must be kept from growing on the landfill cap.
6.
Public Comment:
How much sludge was put in the landfill?
EPA Response: An estimated 19,300 tons of soil which contained 1%
toxaphene sludge by weight was put into the landfill from 1975 until
.1980.
7.
Public Comment:
for at the site?
Are contaminants other than toxaphene being analyzed
EPA Response: Yes, full scan analyses for the target compound list of
chemicals which includes volatile and semi-volatile organic compounds,
pesticides, metals, and PCB's are being analyzed for at the site.
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8.
Public Comment:
Who will pay for this interim action?
EPA ReSDonse: Hercules has verbally indicated their interest in
paying for this interim action, and EPA will be pursuing a written
consent decree with Hercules on this matter. However, if an agreement
cannot be reached and Hercules does refuse to pay for the proposed
municipal water hook-ups, then money will be used from the Superfund
trus£ to fund this action. All costs associated with the hook-up
(plumbing and landscaping included) will be paid by either Hercules or
EPA. A determination has not been made as to who will be responsible
for the payment of the monthly water bills.. EPA will look into this
matter further before implementing the selected remedy.
9.
Public Comment:
Will this be the final action at the site?
EPA Response: No, EPA is currently conducting an in-depth study
contamination at the landfill and possible cleanup alternatives.
the RI/FS is complete, a remedy will be chosen to address the
contamination at the landfill itself.
of
Once
10. Public Comment:
versus off-site?
How do toxaphene levels compare in wells on-site
EPA ReSDonse: Toxaphene has been found in monitoring wells on-site at
levels up to 76 ppb. Toxaphene has been tentatively identified in the
residential wells at 1 ppb.
11. Public Comment: Is there any difference in the way the samples are
analyzed by Hercules versus how they are analyzed by EPA?
EPA ResQOnse: No, Hercules is using laboratories to conduct the
analyses that follow the same contract laboratory protocols as EPA
uses. In addition, EPA takes duplicate and split samples on a
percentage of the samples taken at the site and runs identical tests
in our own laboratories to insure that samples taken by Hercules are
properly analyzed. -
12. Public Comment: What are the health effects due to toxaphene? Can
the Toxicological Profile for Toxaphene be placed at the repository?
EPA ReSDOnse: According to the Toxicological Profile for Toxaphene
that is published by the Agency for Toxic Substances and Disease
Registry (ATSDR), toxaphene can enter your body through your lungs if
you breathe air containing it, through your stomach after eating or
drinking food or water containing it, or through the skin. Poisoning
in people from breathing eating or drinking high levels of toxaphene
for brief periods -has been reported to cause damage to the lungs,
nervous system, liver, and kidneys and can result in death. Exposure
to toxaphene for longer periods may result in damage to the liver,
kidneys, lungs, and nervous system; however, it is not known for
. -13- -
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certain whether these long-term effects will occur since there is no
good evidence in humans. For further information, the complete
Toxicological Profile for Toxaphene has been placed at the repository
in the Glynn County Library on Gloucester Street in Brunswick.
13. Public Comment:
Has air monitoring been performed at the site?
,
EPA ReSDonse: Air monitoring was performed in 1990 during soil boring
activities. No contamination was detected above the detection limit
of the instrumentation.
14. Public Comment: Has any consideration been given to moving the
drainage ditch that runs along the site?
EPA ReSDonse: Consideration of this option will be given at the time
the final remedy is chosen for the site.
15. Public Comment:
Are the marshes being tested?
EPA ReSDonse:
samples of the
the RIfFS work
samples in the
Samples of the sediment and surface water as well as
biota will be collected in the tidal marsh as part of
to be conducted during the summer of 1991. Previous
marsh have not detected toxaphene.
16. Public Comment:
Could the landfill cells be leaking?
EPA ReSDOnse: EPA does not have the data to confirm that the cells
are leaking, but the groundwater contamination at the site could be
due to one of the cells leaking or to a point source outside the cells
in the sludge staging area of the site. EPA will have further data on
this issue when the RIfFS is complete.
17. Public Comment: Can EPA accelerate the implementation of the final
site remediation?
EPA Comment: EPA will do everYthing possible to complete the current
study and to implement the final remedy in a timely manner.
18. Public Comment: Can the schoolyard of Altama Elementary School be
tested for the presence of toxaphene?
EPA Response: The drainage ditch that runs alongside the school has
been tested in the past and will be retested during the summer of
1991. No toxaphene has been detected adjacent to the school. Samples
are a1so being taken adjacent to the site and across the drainage
ditch in the area behind the school.EPA has no evidence to indicate
that the schoolyard should be tested at this time.
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19. PRP Comment: It.is unclear why the reported distance to the nearest
home has changed from 500 feet to 200 feet. Please refer to the
February 1990 fact sheet and clarify this.
EPA Response: The closest residence is 500 feet from the actual
landfill ce1ls~ however, this residence in only several hundred feet
from the site property boundary.
20. PRP Comment: The conclusion that groundwater contamination in the
deep aquifer was based on suspect data. Therefore, resampling
groundwater in the deep aquifer has been agreed to in the revised
Addendum Workplan investigation. This will definitively establish if
contamination exists in the deep aquifer.
EPA Response: A decision to throw out the suspect data has not been
made at this time. The well in question must be replaced and
resampled in order to make a better judgement on the validity of the
data from the well in question.
21. PRP Comment: It is important to note that one part per billion is an
estimated value and is below the practical quantification limit for
toxaphene.
EPA ReSDonse: This fact is so noted and included in the body of this
Record of Decision.
22. PRP Comment: The geologic description does not agree with section
3.5.1 of the August 1990 RI report. The surficial aquifer extends to
approximately 30 feet, and is followed by the semi-confining layer
extending to about 60 feet, which is then followed by the deep aquifer
extending to about 100 feet.
EPA ResDonse: The above is so noted and included in the body of this
Record of Decision.
23. PRP Comment: There appears to be a typographical error on the value
73.44 ppb. It should read 73.34 ppb. However, the highest
"groundwater value detected on-site" was 76 ppb in well number N-11.
EPA ResDOnse: The above is so noted and included in the body of this
Record of Decision.
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,
Georqia Department 01 Natural Resources
205 Butler Street, S.E.. Suite 1252. 'Atlanta. Georgia 30334
. Joe D. Tanner. Commissioner
Harold F. Reheis. Assistant Director
Environmental Protection DivIsion
r
June 27, 1991
Mr. Doug Mundrick, Chief
South Superfund Remedial Branch
U.S. Environmental Protection Agency
Region IV
345 Courtland Street, NW
Atlanta, Georgia 30365
Re:
Hercules 009 Landfill - Brunswick, Georgia
Final Draft Interim Action Record of Decision (ROD)
Dear Mr. Mundrick:
This letter will constitute the Georgia Environmental Protection Division's forma!
concurrence with the Final Draft ROD for connecting the alternate water supply to
residents in close proximity to the Hercules 009 Landfill.
If you have any questions, please contact Jim Ussery at 656-2833.
Sincerely,
~ T:IO;/~r
Land Protection Branch
JU:lbe
file: Hercules 009 Landfill (R)
"
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