United States
Environmental Protection
Agency
Office oi
Emergency and
Remedial Response
EPA/ROD/R04-93/131
March 1993
SEPA Superfund
Record of Decision:
Mathis Brothers Landfill
(South Marble Top Road), GA
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50272-101
REPORTDOCUMENTA~ON 11. REPORT NO. 2. 3. Recipient's Accession No.
PAGE EPA/ROD/R04-93/l3l
4. TItle and Subthle 5. Raport Date
SUPERFUND RECORD OF DECISION 03/24/93
Mathis Brothers Landfill (South Marble Top Road), GA 6.
First Remedial Action - Final
7. Author(s) 8. Performing Organization Rept. No.
9. Pertonnlng Organization Name and Add,.. 10 Projact Ta8klW0fk Unh No.
11. Contract(C) or Grant(G) No.
(C)
(G)
12. Sponsoring OrganIzation Name and Add- 13. Type of Report & Period Covered
U.S. Environmental Protection Agency
401 M Street, S.W. 800/800
Washington, D.C. 20460 14.
15. Supplementary Note.
PB94-964048
16. Abstract (Umh: 200 words)
The 10-acre Mathis Brothers Landfill (South Marble TOp Road) site is a landfill area
surrounded by undeveloped, forested land in Walker County, Georgia. Land use in the
area is predominantly agricultural and residential, with the nearest residence located
400 feet southwest of the site. The site borders drainage valleys to the north and
south, each containing an intermittent stream during prolonged rainfall events.
Vegetation is present over the once-cleared portions of the site and includes various
grasses and pine trees. Surface water features at the site consist of rainfall runoff,
seeps, drainage valleys, and standing water. The site also overlies two aquifers, the
Knox Surficial Aquifer and the Knox Bedrock Aquifer. From 1974 to 1980, the site
operated as a landfill and utilized three separate disposal areas. Types of drummed
waste disposed of at the site included benzonitrile, dicamba, 1,4-dichlorobenzene,
latex, and carpet wastes. In 1974, the State notified the owners to stop accepting
latex and industrial solid wastes after a milky discoloration was observed in the
ground near the northeast portion of the landfill. Shortly thereafter, the site was
allowed to accept non-hazardous waste and in 1975 was granted a solid waste handling
permit. In 1980, State studies determined that the landfill did not conform to the
(See Attached Page)
17. Document Analysis a. Deac:riptors
Record of Decision - Mathis Brothers Landfill (South Marble Top Road), GA
First Remedial Action - Final
Contaminated Media: soil, debris, gw, sw
Key Contaminants: VOCs (benzene, PCE, TCE, toluene, xylenes), other organics, metals
(chromium, lead)
b. IdentifierslOpan.End8d Terms
c. COSATI FIaIc£'Group
18. Availabllhy Statemant 19. Security CIaa8 (This Report) 21. No. of Pag..
None 60
20. Security Class (This Page) 22. Price
None
(See ANSI-Z39.18)
SMlnstrucrJons on R.v-
OPTIONAL FORM 272 (4-77)
(Formerly NTJS.35)
o.partnI8nt of Comm8lC8
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EPA/ROD/R04-93/131
Mathis Brothers Landfill (South Marble Top Road), GA
First Remedial Action - Final
Abstract (Continued)
pending federal and state statutory requirements of RCRA and the landfill was closed. In
1983, a subsequent State inspection noted that the landfill had not been closed in
accordance with federal requirements and, therefore, required that the site be brought
into compliance. Studies during the RI showed organic and inorganic contamination of soil
and ground water appeared to be the result of improper disposal practices at the landfill,
seepage of leachate, and surface water runoff. This ROD addresses the source of the
contamination, including the contaminated soil and debris, as the first and final remedial
action for the site. The primary contaminants of concern affecting the soil, debris,
ground water, and surface water are VOCs, including benzene, PCE, TCE, toluene, and
xylenes; other organics; and metals, including chromium and lead.
The selected remedial action for this site includes diverting surface water away from the
landfill; excavating approximately 4,000 yd3 of surface soil and debris, with onsite
incineration and disposal of treated soil, and onsite or offsite disposal of residuals;
treating 97,700 yd3 of contaminated subsurface soil using ex-situ biodegradation to remove
organics through bacterial and/or fungal metabolism, based on the results of a
treatability study, with onsite disposal of treated soil and onsite or offsite disposal of
residuals; placing a RCRA clay cap over the treated material; installing an interceptor
trench for collection of 1,500,000 gallons of ground water, with temporary onsite storage,
followed by offsite treatment and discharge; monitoring soil, ground water, and surface
water; and implementing institutional controls. The estimated present worth cost for this
remedial action is $12,980,000, which includes an annual O&M cost of $1,152,000 for 2.5
years.
PERFORMANCE STANDARDS OR GOALS:
50il olean-up levels were based on a direct leaching mod~l expressed as AL=(foc> (Koc)
(HBN) where AL is the soil action level, foe is the fraction organic carbon, Koc is the
organic carbon water partition coefficient, and RBN is a health-based number for the
protection of ground water, such as an MCL. When ARARs are not available for specific
compounds or exposure media, the cleanup goals are based on non-promulgated advisories or
guidance such as proposed federal MCLGs, lifetime Health Advisories (HAs), and reference
dose (RfD) based guidelines. Chemical-specific goals for surface soil and subsurface soil
include benzene 0.014 mg/kg; bis (2-ethylhexyl) phthalate 40,440 mg/kg; 1,4-
dichlorobenzene 0.43 mg/kg; and dicamba 1532 mg/kg. Chemical-specific goals for ground
water include acetone 3,500 ug/l; benzene 5 ug/l; benzoic acid 140,000 ug/l; benzonitrile
43 ug/l; benzyl alcohol 10,500 ug/l; bis (2-ethylhexyl) phthalate 6 ug/l; chlorobenzene
100 ug/l; chromium 100 ug/l; 2,4-D 70 ug/l; dicamba 1,050 ug/l; 1,4-dichlorobenzene 75
ug/l; dichlorodifluoromethane 7,000 ug/l; 1,1-dichloroethane 3,500 ug/l; 1,2-
dichloroethane 5 ug/l; di-n-butyl phthalate 3,500 ug/l; di-n-octyl phthalate 700 ug/l; 2,-
dinitrotoluene 70 ug/l; ethyl benzene 700 ug/l; lead 15 ug/l; mercury 2 ug/l; methylene
chloride 5 ug/l; nickel 100 ug/l; silver 100 ug/l; styrene 100 ug/l; PCE 5 ug/l; toluene
1,000 ug/l; 1,2,4-trichlorobenzene 70 ug/l; TCE 5 ug/l; vanadium 245 ug/l; vinyl chloride
2 ug/l; and xylenes 10,000 ug/l. Chemical-specific goals for surface water include bis
(2-ethylhexyl) phthalate 0.269 ug/l; heptachlor 0.00006 ug/l; and silver 0.13 ug/l.
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DECLARATION
of the
RECORD OF DECISION
SITE NAME AND LOCATION
Mathis Brothers - South Marble Top Road Landfill Site
Walker County, Georgia
STATEMENT OF BASIS AND PURPOSE
This decision document (Record of Decision) presents the selected
remedial action for the Mathis Brothers - South Marble Top Road
Landfill site, Walker County, Georgia, developed in accordance with
the Comprehensive Environmental Response, Compensation and
Liability Act of 1~80 (CERCLA), as amended by the Superfund
Amendments'and Reauthorization Act of 1986 (SARA) 42 U.S.C. Section
,9601 et seq., and to the extent practicable, the National
Contingency Plan (NCP) 40 CFR Part 300.
This decision is based on the administrative record for the Mathis
Brothers - South Marble Top Road Landfill site.
The State of Georgia has concurred on the ~elected remedy (Appendix
B) .
ASSESSMENT-OF THE SITE
Actual or threatened releas'es of hazardous substances from this
site, if not addressed by implementing the response action selected
in this ROD, may present an imminent and substantial endangerment
to public health, welfare or the environment.
DESCRIPTION OF SELECTED REMEDY
At this time the remedial action is proposed as both the first ,and
the final remedial action for the site. The function of this
remedy is to treat contamination and reduce it to health based
levels. Source material and contaminated soils are the principal
threat at the site.
The major components of the selected remedy include:
.
Diversion of surface water;
Excavation of waste and'soil (analysis of carpet and latex
waste for determination ,of appropriate disposal options);
On-site incineration and disposal of chemical wastes and
associated contaminated landfill soil;
Treatability,' Studies to determine the effectiveness of
biodegradation (an innovative technology with which
microorganisms, are used to break down contaminants) of
contaminated subsurface soil; if successful, implementation
of biodegradation with on-site disposal of treated soil;
.
.
.
-------
.
A RCRA Solid Waste clay cap would be placed over treated
material; ~
Installation of interceptor trench for groundwater
collection with on-site storage and off-site treatment and
disposal;
'Combined institutional control activities.
If biodegradation is unsuccessful in ,treating contaminated
subsurface soils EPA will consider other remedial
alternatives and ~end the ROD if necessary.
.
.
.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the
environment, complies with federal and state requirements that are
legally applicable or relevant and appropriate, and is
cost-effective. This remedy utilizes permanent solutions and
alternative treatment technology to the maximum extent practicable,
and satisfies the statutory preference for remedies that employ
treatment that reduces toxicity, mobility, or volume as a principal
element.
Because the remedy will not result in hazardous substances
remaining on-site above health-based levels, the five-year review
will not apply to this action.
~~
Patrick M. Tobin
Acting Regional Administrator
3--L.4 .r; oS
Date
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Record of Decision
The Decision Summary
Mathis Brothers - South Marble Top Road Landfill Site
Walker County, Georgia
U.S.
Prepared by:
Environmental Protection
Region IV
Atlanta, Georgia.
Agency
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1.0
2.0
3.0
4.0
5.0
Table of Contents
Site Name, Location,' and Description. .
. . . .
. . . .
Site History and Enforcement Activities
. . . .
. . . .
Highlights of Community Participation
Scope and Role of Remedial Action
. . . . .
. . . .
. .' . . . . .
. . . .
Summary of Site Characteristics. . . . . . . . . . . .
5 .1 Geology. . . . . . . . . . . . . . . . . . . . . .
5.2 Hydrogeology. . . . . . . . . . . . . . . . . . .
5..3 Surface Water. . . . . . . . . . . . . . . . . . .
5.4 Sampling Results. . . . . . . . . . . . . . . . .
5.4.1 Drum Sampling. . . . . . . . . . . . . . .
5.4.2 Surface Soil. . . . . . . . . . . . . . . .
5.4.3 Subsurface Soil. . . . . . . . . . . . . .
5.4.4 Groundwater. . . . . . . . . . . . . . . .
5.4.5 Surface Water and Sediment . . . . . . . . . . . . . .
5.4.6 Air . . . . . . . . . . . . . . . . . . . .
6.0 Summary of' Site Risks . . . . . . . . . . . . . . .
6.1 Identification of Contaminants of Concern . . . . .
6.3 Toxicity Assessment Summary . . . . . . . . . . . .
6.4 Risk Characterization Summary . . . . . . . . . . .
6.5 Environmental Risk Swmnary . . . . . . . . . . . .
6.6 Cleanup Levels . . . . . . . . . . . . . . . . . .
7.0
8.0
Description of Alternatives. . . . . . . . . . . . . .
7.1 Alternative 1 . . . . . . . . . . . . . . . . . . .
7 . 2 Al t erna t i ve 2 . . . . . . . . . . . . . . . . . . .
7 . 3 Al t erna t i ve 3 . . . . . . . . . . . . . . . . . . .
7.4 Alternative 4 . . . . . . . . . . . . . . . . . . .
7 . 5 Al ternati ve 5 . . . . . . . . . . . . . . . . . . .
Summary of the Comparative Analysis of Alternatives
8.1 Overall Protection of Human Health and the
Environment. . . . . . . . . . . . . . . . . . . .
Compliance with ARARs . . . . . . . . . . . . . . .
Long-Term Effectiveness and Permanence. . . . . .
Reduction of Toxicity,. Mobility 'or Volume Through
Treatment. . . . . . . . . . . . . . . . . . . . .
Short-Term Effectiveness. . . . . . . . . . . . .
Implementability '. . . . . . . . . . . . . . . . .
Cos t . . . . . . . . . . . . . . . . . . . . . . .
State Acceptance. . . . . . . . . . . . . . . . .
Community Acceptance. . . . . . . . . . . . . . .
8.2
8.3
8.4
8.5
8.6
8.7
8.8
8.9
9.0 Selected Remedy ~ . . . . .
..'....
. . . . . .
. . .
paae
1
1
4
5
6
6
6
9
9
10
10
10
20
20
20
26
26
28
28
32
33
33
33
35
35
36
37
37
39
39
39
40
40
40
41
41
41
41
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10.0 Statutory Determination. . . . . . . . . . . . . . . .
10.1 Protection of Human Health and the Environment. .
10. i Attainment of the Applicable or Relevant and
Appropriate Requirements (ARARs) .........
10.3 Cost Effectiveness. . . . . . . . . . . . . . . .
10.4 Utilization of Permanent Solutions to the Maximum
Extent Practicable. . . . . . . . . . . . . . . .
10.5 Preference for Treatment as a Principal Element
10.6 Documentation of Significant Changes. . . . . . .
43
43
43
47
47
48
48
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List of Fiaures
Figure 1.- Site Location Map . . . . . . . . . . . . . . . .
Figure 2 - Landfil~ Disposal Areas. . . . . . . . . . . . .
Figure 3 - Regional Geological Cross-Section. . . . . . .
. Figure 4 Conceptual Model. of Seep. . . . . . . . . . . .
Figure 5 - Designated Sampling Areas. . . . . . . . . . . .
Figure 6 - Area of Surface Soil Exceeding Background. . . .
Figure 7 Area .of Deep Subsurface Soils Exceeding
Background. . . . . . . . . . . . . . . . . . . . . . .
Figure 8 Area of Shallow Subsurface Soils Exceeding
Background. . . . . . . . . . . . . . . . . . . . . . .
Figure 9 - Area of Groundwater Exceeding Background Values.
2
3
7
8
11
14
16
17
21
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Table 1
Table 2
Table 3
. Table 4
Table 5
Table 6
Table 7
List of Tables
Drum Sampling Summary. . . . . . . . . . . . . . .
Surface Soil Sampling Summary. . . . . . . . . . .
Subsurface Soil Sampling Summary. . . . . . . . . .
Groundwater Sampling Summary. . . . . . . . . . . .
Surface Water And Sediment Sampling Summary. . . .
Summary Of Site Chemicals Of Concern. . . . . . . .
Cancer Potency Factors For Inhalation And Oral
Exposure. . . . . . . . . . . . . . . . . . . . .
Table 8 Reference Doses For Inhalation And Oral Exposure. .
Table 9 Comparison of Ambient Water Quality Criteria With
Maximum
Concentrations of The Chemicals That
Water. . . . . . . . . . .
Table 10 Proposed Cleanup Levels
Table 11 Proposed Soil Action
Groundwater. . . . . . . . . . . . . . . . . . . . . .
B!E.
12-
15
18
22
24
27
29
30
Exceed AWQC in Surface
. . . . . . . . . . . 32
For Shallow Groundwater. . 34
Levels For Protection of
34
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RECORD OF DE~ISION
The Decision Summary
Mathis Brothers - South Marble Top Road Landfill Site
. 1.0
Site Name, Location, and Description
The Mathis Brothers - South Marble Top.Road Landfill Superfund Site
(.Site.) is located approximately 0.6 mile south of Highway 136 and
0.2 mile east of South Marble Top Road in Walker County, Georgia.
The Site consists of 10 acres of undeveloped, forested land.
Approximately 1.25 acres of this land had been cleared for the past
landfill operation. General land use surrounding the Site is
agricultural and residential. The nearest residence is located
approximately 400 feet southwest of the Site (Figures 1 and 2).
Drainage valleys are present to the north and south of the site,
each containing an intermittent stream during prolonged rainfall
events. Vegetation is present over the once-cleared portions of
the site and includes various grasses and pine trees.
2.0
Site History and Enforcement Activities
The Site was operated by Messrs. Sidney and Mose Mathis as a
landfill from approximately January 1974 to January 1980. The
landfill configuration includes three disposal areas (Areas A, B,
and C on Figure 2) which are estimated to be fifteen feet deep.
Wastes disposed of at the Site include benzonitrile, dicamba,
1,4-dichlorobenzene, latex and carpet.wastes.
In February 1974, a milky discoloration was observed on the ground
near the northeast portion of the landfill. On February 26, 1974,
the State of Georgia's Environmental Protection Division (EPD)
notified the Mathis Brothers to stop accepting latex wastes and
industrial solid wastes, including benzonitrile and dicamba.
Following further site assessment by EPD in March. .1974, the
landfill was allowed to accept non-hazardous waste. A solid wast~
handling permit was granted to the Mathis Brothers by EPD in
September 1975.
During an EPD inspection in January 1980, an area of distressed
vegetation was observed near the northwest portion of the landfill.
In early February 1980, the EPD made a determination that the
landfill did not conform to the pending statutory requirements of
the Resource Conservation and Recovery Act of 1976 (RCRA) and
Georgia's Hazardous Waste Management Act and closed the landfill.
On March 11, 1980, EPD officials met with Mr. Mose Mathis to
discuss the. closure requirements for the landfill.
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STUDY AREA BOUNDARY
APPROXIMATE lANOFll BOUNDARY
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SOUTII MARBLE TOP ROAD LANDFILL
W'U'I COUNtY. 01010"
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-------
During an EPD inspection of the landfill on April 6, 1983, it was
noted that although the operations had ceased, the landfill was not
properly closed in accordance with RCRA requirements. Landfill
wastes were observed without the required soil cover. .On April 7,
1983,.EPD notified Mr. Mose Mathis that closure improvements must
be made to the landfill to bring the Site into compliance with the
permit. In December 1983, EPD conducted an inspection of the Site
and noted that the main landfill areas had been covered with a one
to two foot layer of soil. A thirty foot diameter disposal pit
(area C) was left uncovered by the Mathis Brothers.
In January 1984, the EPD requested that the Site be included on the
Georgia. State Superfund Program listing. In June 1984, the
Environmental Protection Agency (EPA) conducted a preliminary
assessment of the landfill site for possible inclusion on the
National Priority List (NPL). The NPL comprises hazardous waste
sites which appear to present a significant threat to human health
or the environment. . Sites are placed on the NPL if they have a
ranking score of 28.50 or greater. The Marble Top Road Site was
proposed for the NPL in January 1987 and was listed on the NPL in
1989.
In December 1987, the EPA contacted several companies and/or
individuals with potential responsibility for the waste disposal at..
the site to provide the companies and/or individuals the
opportunity to conduct, with EPA's oversight, the Remedial
Investigation (RI) and Feasibility Study (FS). Of the companies
and/or inaividuals notified, one company, Velsicol Chemical
Company, entered into an Administrative Order on Consent (AOC) for
the performance of the RI/FS. The effective date of the AOC was
November 2, 1988.
The investigation of the Site was conducted in two phases. Phase
I of the RI was initiated in May 1990. Phase II of the RI was
completed in July 1991. The final RI Report was accepted by EPA in
July 1992. Velsicol submitted a draft FS report in February 1992;
EPA.revised and finalized it by July 1992. .
EPA will continue its enforcement activities and will send a
Special Notice Letter to those identified as potentially
responsible for the contamination at the Site. This will provide
the potentially responsible parties (PRPs) an opportunity to design
and implement the selected remedy. Should the PRPs decline to
conduct future remedial activities, EPAwill either take additional
enforcement actions or provide funding for these activities while
seeking cost recovery for all EPA-funded response actions at the
Marble Top Road Site.
3.0
Highlights of Community Participation
A.Community Relations Plan was prepared by EPA in March 1991 as
4
-------
required by CERCLA Sl13 (k) (2) (B) (i-v) and Sl17. During that same
month EPA met with representatives from a local environmental group
and county officials to discuss the status of the investigation at .
the Site. EPA also printed and distributed a fact sheet describing.
the activities to be conducted during the RI and FS. On November
17, 1991,EPA met with a second environmental group to address
concerns they had regarding the Site. The community has ramained
interested and active.throughout the study.
The RI Report was made available to the public in February, 1992.
The FS Report and the Proposed Plan for the South Marble Top Road
Site w~re. released to the public on July 30, 1992. The
administrative record, which contains documents relating to the
remedy selection at the site, including the RIfFS Reports 'and the
Proposed Plan, was made available to the public at the Region IV
EPA Office in Atlanta, Georgia and the Lafayette-Walker Public
Library. The notice -of availability of the administrative record
was published in the Walker County Messenger and the Chattanooga
News Free Press on July 29 and August 4, 1992. A public comment
period was held from July 30, 1992 to August 29, 1992 and was
extended to September 28, 1992 pursuant to a request by Velsicol
Chemical Company. In addition, a public meeting was held on August
6, 1992 at the Cassandra Baptist Church, West Cove Road,
Kensington, Georgia. At this meeting, representatives from EPA and'
EPD answered questions about the Site and the proposed plan "for
cleanup. A response to the comments received during the meeting as
well as those received during the comment period is included in the
Responsiveness Summary, which is part of this Record of Decision
(ROD) (Appendix A). This decision document presents the selected
remedy for the South Marble Top Road Site in Walker County,
Georgia, chosen in accordance with CERCLA, as amended by SARA, and
in accordance with the NCP. The decision for the Site is based on
the administrative record.
4.0
Scope and Role of Remedial Action
This is the first and final planned remedial action for the South
Marble Top Road Site. This ROD addresses the source of
contamination including landfill wastes from the small, industrial,
four acre landfill, as well as site media contaminated by the
landfill material. The drummed waste present in the landfill and
the soil contaminated with numerous organic and inorganic compounds
pose the principal threat to human health and the environment
because of the risks associated with possible ingestion or dermal
contact. Also, the shallow groundwater present beneath the Site
has been determined to contain hazardous substances similar to
those present in the drummed landfill waste and contaminated soil.
Although this water bearing zone is not a current source of
drinking water, local residents have relied on this unit for water
in the past; therefore, under future use scenarios, the
contaminants in the groundwater are a principal threat to human
5
-------
health. The purpose of this response is to prevent current or
future exposure to the landfill waste, including the associated
contaminated soil and the contaminated groundwater, through
treatment and reduction of the migration of contaminants.
. 5.0
5.1
Summary of Site Characteristics
Geology
The South Marble Top Road Site is located in the Valley and Ridge
Province of the southeastern United States. The Valley and Ridge
Province is underlain by folded consolidated sedimentary rocks
ranging in age from Cambrian through Pennsylvanian. The underlying
rocks include shale, dolomite, limestone, sandstone, and chert. As
shown on Figure 3, several geologic formations outcrop between
Lookout Mountain and Pigeon Mountain. Within the McLemore
Anticline, weathered clays of the Knox Formation outcrop on the
surface. The South Marble Top Road Site is situated on the
residual clay cover of the Knox Formation.
The residual cover beneath the site consists of cherty clays from
the decomposition of limestone and dolomite. Based on drilling
activities during the investigation of the Site, the cherty clays
are comprised of approximately 200 feet of clay with beds of
intermixed fractured chert. The permeability of the residual cover
ranges from 6.63 x 10-5 to 5.73 x 10-9 em/sec.
5.2
Hydrogeology
Two water bearing zones are present beneath the Site: The
surficial aquifer which occurs throughout the residual cherty clay
and the Knox bedrock aquifer. The upper water bearing zone
consists of groundwater within the fractured chert layers and clay
layers and is a lower yielding zone than the Knox bedrock aquifer.
These chert layers are surrounded by the clay residuum. The
surficial aquifer is a Class lIB groundwater system as defined in
the 8Guidelines for Groundwater Classification8 under the EPA
GI0undwater Protection Strategy, Office of Groundwater Protection,
December, 1986, final draft document. The second and more
predominant aquifer sy~tem, known as the Knox bedrock aquifer, is
present in the Knox Dolomite Formation which is located
approximately 200 feet beneath the surface of the Site.
The fractured chert layers, found in the residuum, vary in
thickness from a few inches to. several feet and are laterally
discontinuous across the Site. As shown in Figure 4, these chert
layers receive water from percolation of soil. Chert layers which
outcrop at the ground surface and produce seeps, provide for
lateral groundwater migration.
Vertical migration of groundwater occurs through fractures in the
6
-------
A A'
~ lOClKOIJI CH,U rANOOQA -- Mr. LEMOnE___- __C-..c:K"''''.UGA -~I 'OOO
.000 - MQUNIIAN- VAllEY ANllClNF. VALLEY MQlJrfflAN
1000 IlOO
1100 1800
"00 "
'100 t800
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lEGEND,
Pu "ENN$YlVAMAN ROCKS, UND.FfEnENTlAT£O
M... MI$SlSSII'PIAN ROCKS. UNO"'£RENrIAJED
M'r ron r rAYN! CHER r
5,m f((D MOUNr..." fORMAttON
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REGIONAL GEOLOGICAL CROSS-SECTIO" 3
.
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TEMPORARY SATURATED SOILS
l
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SEEPAGE POINT
GROUND SURFACE
/"
..-/
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HARD RESIDUAL SOILS
FRACTURED CHERT LAYER
CONCEPTUAL MODEL OF SEEP GENERATION
AT CHERT LAYER DISCHARGE
-- - - ----
-------
clay residuum and along the surfaces of the chert fragments.
Tritium age dating of groundwater throughout the surficial water
bearing zone indicates groundwater recharge has occurred in the
residuum since the 1950's and is approaching the underlying Knox
bedrock aquif~r.
The Knox bedrock aquifer is a cavernous dolomite and limestone that
is highly fractured. Wells were completed in the Knox formation at
the site in June of 1992. The results. of sampling these wells
indicate that the contamination has not migrated beyond the site
boundaries nor has the contamination impacted the deeper underlying
Knox Bedrock Aquifer. If future groundwater monitoring indicates
contamination in the Knox Aquifer, EPA will address this in a
future decision document. Water wells within a one mile radius of
the Site are completed in the bedrock aquifer. The average yield
for wells in this aquifer is 200 - 300 gallons per minute. (gpm) .
Beneath the Site, the McLemore Anticline forms a groundwat.er divide
within the Knox bedrock aquifer, thus depending on the side of the
anticline, groundwater movement is in a southeast or southwest
direction. .
5.3
Surface Water
The topography of the Site is characteri.zed by elevated knolls,
with. moderate slopes that yield surface water during rainfall
events. Drainage valleys are present to the south and north of the
Site. These valleys allow surface runoff to drain into. an
intermittent tributary of Mill Creek. Mill Creek eventually
discharges into West Chickamauga Creek.
During periods of high precipitation, seeps have been identified
north and east of the Site. The seeps are present where beds of
fractured chert outcrop, thus allowing shallow groundwater to exit
onto the surface.
5.4 Sampling Results
The primary emphasis for analytical testing during the RI was
placed on determining the impact that the three disposal areas
within the South Marble Top. Road Site may have had on the
environment at the Site, including the effect on soil, surface
water, sediment, air and groundwater. In addition to sampling the
environmental media at the Site, samples were collected from the
drummed material within the landfill. Based on all media sampled
and analyzed, a total of twenty six (26) volatile organic
compounds, twenty five (25), semi-volatile organic compounds,
eleven (11) pesticides, four (4) herbicides, and twenty one (21)
inorganic compounds have been identified at least once throughout
the analytical process at the Site.
9
-------
5.4.1
Drum Sampling
The contents'of four drums from Disposal Area A, two drums from
Disposal Area B, and one drum from Disposal Area C were sampled
(see Figure 5). The drums had been placed in a random orientation
during disposal and showed signs of structural damage and
corrosion. A total of nine (9) volatile organic compounds, sixteen
. (16) semi-volatile organic compounds and two (2) herbicides were
detected in the drums at levels which exceed background soil
concentrations. The main constituents present in the drums are
dicamba, benzonitrile and 1,4-dichlorobenzene. A summary of the
sampling results is provided on Table 1.
A total of 12,000 drums (3,100 yds3) are estimated to have been
disposed of in the landfill. In addition to the drummed material,
carpet scraps and latex wastes were observed in the landfill.
Based on historic records, the depth of the disposal area is
estimated to be 10-15 feet and the total volume of the landfill is
estimated at 25,000 yds3. These wastes comprise the principal
threat at the site.
5.4.2
Surface Soil
Thirty-seven surficial soil samples were collected from the site
during th~RI. Surface soil samples were collected from 0 to 2 ft
below the ground surface. The results of. this sampling effort
indicate contaminants are generally present north of the landfill
(Figure 6). Surface soil samples which exhibit the highest number
of compounds and concentrations are located within the drainage
paths of seeps north of the landfill. A total of eight (8)
volatile organic compounds, five (5) semi-volatile organic
compounds, one (1) herbicide, one (1) pesticide, and fifteen (15)
inorganic compounds were detected in the surface soil at levels
which exceed background surface soil conditions. A summary of the
surface soil sampling is provided on Table 2.
5.4.3
Subsurface Soil
Seventy-eight (78) subsurface soil samples were collected to depths
of forty (40) feet and a total of fifteen (15) subsurface soil
samples were collected from a depth between forty (40) and 92 feet.
Based on the analytical results, subsurface soil contamination was
identified in soil primarily around the landfill at depths less
than 100 feet .(Figures 7 and 8). A total of eleven (11) volatile
organic compounds, nine (9) semi-volatile organic compounds, two
(2) herbicides, five (5) pesticides, and nineteen (19) inorganic
compounds were detected in subsurface soil at levels which exceed
background levels. A summary of the subsurface soil sampling is
provided on. Table 3. The total estimated volume of subsurface soil
10
-------
--
LEGEND:
._----
BOUNDARY
STUDY AREA
l BOUNDARY
APPROXIMATE lANDFL
U'.M1.:!.!.-0
:--.~
OAD lANDFill
UlE TOP R
SOUTH MAR n.o.o.....
..LK'R COWl
MENTAL CENTER, INC.
S ENVIRON
MEMPHI "'''''''. "-ISII
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MCBride-Rat~~MccnSWna
.., GeoI HouIICt\ rr... .....
.., - ,."." 10.0'"
..... no .... JoWl-" ......
;". -OIl AMPlING AREAS. 5
DESIGNATED S
-------
Table 1
Drum Sampling Summary
Maximum Concentration
(mg/kg)
Chemical Detected
Area A
Area B
Area C
Benzene
167
ND
ND
ND
ND
62,000
2-Butanone (Methyl ethyl ketone)
Ethyl Benzene
16.0
21.1
2.55
19.8
ND
ND
Methylene Chloride
Styrene
Tetrachloroethane
Toluene
ND
28.4
3.42
ND
ND
ND
l,l,l-Trichloroethane
Xylenes
671
4.6
322
16.1
24.6
ND
ND
ND
Anthracene
Benzoic Acid
8.81
ND
ND
ND
Bis (2-ethy!hexyl) Phthalate
4-Chlorophenyl Phenyl Ether
Chrysene
73 .5
18.7
344
ND
. ND
ND
ND
Benzonitrile
16.7
42.7
ND
ND
ND
ND
1,4-Dichlorobenzene
2,4-Dinitrotoluene
106
5.98
452
ND
ND
ND
ND
Di-n-butyl Phthalate
Dibenzofuran
ND
ND
ND
557,000
Hexachlorobenzene
N-Nitrosodtmethylamine
93.6
31.2
12.7
ND
ND
ND
ND
Naphthalene
Phenanthrene
4.36
22.4
ND
ND
ND
ND
Pyrene
1,2, 3, 5-Tetrachlorobenzene
4.28
17.4
ND
ND
ND
ND
2,4-D
Dicamba
ND
3920
ND
2670
ND
ND
Aluminum
5030
4.4
3.6
58,400
507
ND
ND
ND
Arsenic
Cadmium
ND
ND
ND
-----------------------------------------------------------------------------------------------
12
-------
Table 1
Drum Sampling Summary
MaxLmum Concentration
(mg/kg)
Chemical Detected
Area A Area B Area C
700 ND ND
34.0 6.0 ND
14.0 ND ND
21,600 1810 803
7.0 ND ND
42.3 2.2 ND
6.0 ND ND
181 ND ND
2.7. ND ND
26.0 ND ND
23.3 4.3 ND
Calcium
Chromium
Cobalt
Iron
Lead
Manganese
Nickel
Potassium
Selenium
Vanadium
Zinc
ND - Not De~ected
13
-------
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LEGEND,
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SOOFACE sOt. SAMPLE
ORONG SAMPLES O.~
CORE 0
OUNDARY
STUOY AREA 0
ANDFU BOUNDARY
APPROXIMATE l
BACKGI10UN0
ACE SOt. EXCEEDING
~~ENTRATIONS
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AREA OF S~:CKGROUND
EXCEEDING
8
-------
Table 2
Surface Soil Sampling Summary
Concentration
(mg/kg)
Chemical Detected Maximum Backaround Frequency
Acetone 16.9 ND 1/11
Benzene 0.464 ND. 1/15
Dibromomethane 0.625 ND 3/15
Dichlorodifluoromethane 0.228 ND 2/15
Ethyl Benzene 0.240 ND 1/15
Methylene Chloride 1.17 ND 4/15
Toluene 1.59 ND 4/15
Xylenes 0.830 ND 2115
Anthracene 0 . 630 ND 1/11
Benzoic Acid 57.0 ND 2122
Bis(2-ethylhexyl)phthalate 26.0 3.11 10/33
Di-n-butyl phthalate 0.379 ND 2115
Di-n-octyl Phthalate 1.18 0.94 4/33
Phenol 0.540 ND 1/15
Dicamba 0.169 ND 2/15
Heptachlor Epoxide 0.018 ND 1/15
Aluminum 16,300 12,400 23/36
Arsenic 9.7 8.15 (J) 33/33
Barium 50.0 65.6 20/33
Cadmium 3.1 1.9 9/18
Calcium 870 ND 1/15
Chromium 34.6 18.8 33/33
Coba.l t 140 17.0 7126
Iron 28,200 16,800 33/33
Lead 41.0 56.0 23/33
Magnesium 650 ND 2126
Manganese 730 4,000 33/33
Mercury 0.16 ND 6126
Nickel 12.0 ND 8/33
Potassium 402 165 14/33
Silver 3.6 1.7 7/26
Vanadium 56.0 34.0 33/33
Zinc 68.0 23.2 33/33
J - Estimated Value
ND - Not Detected
15
-------
),:::'. ~C~11 :. ,,".
I
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"
LEGEND:
$
.
OEEP SO... BORING LOCATION
SHALLOW SOl.. BORING LOCATION
--- STWY AREA BOUNOARY
APPROXIMATE LANOFI.l BOUNDARY
~. INQICATES SOt. BORtlG CONVERTEO
TO MONITORING WELL
IIIB:~:=:~~~~~:~~~G
.
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1M
SOUTH MARBLE'TOP ROAD LANDFILL
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7
-------
. .
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LEGEND:
$
.
DEEP SOL BORIfO lOCATIOH
SHALLOW SOl. BORIHG lOCATION
.--- STUDY AREA BOUNDAIIY
$
APPIIOXIMATE LANOFLl BOUNOAIIY
'tOCATES SOL BORtIO CONVEIITEO
TO MONlTOIIING WELL
SHALLOW SUBSWACE SOL EXCEEDING
BACKMOUNO CONCENTIIATIONS
Ican'"
...
SOUTH MAR8LE'TO' ROAD LANDFILL
..~.u COWIn. 01"011
MEMPHIS ENVIRONMENTAL CENTER. INC.
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EJaEDttG BM:IUJIOlNI II FT 10 co FT) '. ft
8
-------
Table 3
Subsurface Soil Sampling Summary
Concentration
(mg/kg)
Chemical Detected Maximum Backaround Frequency
Acetone 21.1 21.1 2/15
Benzene 6.54 ND 4/85
Chlorobenzene 5.25 ND 4/85
Dichlorodifluoromethane 3.19 ND 5/85
1,1-Dichloroethene 2.47 ND 2170
Ethyl Benzene 0.361 ND 3170
Methylene Chloride 0.659 0.609 2/83
Tetrachloroethene 3.70 ND 6170
Toluene 5.96 ND 8/85
Trichloroethene 6.17 ND 6/70
Xylenes 0.892 ND 3/69
Benzoic Acid 260.0 ND 6/51
Benzyl Alcohol 1.03 ND 3/51
Bis (2-ethylhexyl) Phthalate 12.9 ND 31/51
Di-n-butyl Phthalate 3.16 ND 9/49
Di-n-octyl Phthalate 2.3 ND 4/49
Dibenzofuran 0.364 ND 1/36
2,6-Dinitrotoluene 0.853 ND 1/36
Fluorene 0.614 ND 1/36
1,2,4-Trichlorobenzene 0.737 ND 1/36
Aldrin 0.036 ND 1/42
Lindane 0.039 ND 1/42
4,4'-DDD 0..011 ND 1/42
4,4'-DDT 0.461 ND 1/42
Heptachlor 0.201 ND 1/42
2,4-D 4.6.1 ND 3/39
Dicamba 0.407 ND 3/39
Aluminum 27,400 6430 57/58
Arsenic 21.1 15.4 52/58
Barium 58.8 37.5 7158
---------------------------------------------------------------------------------------------
18
-------
Iron
Table 3
Subsurface Soil Sampling Summary
Concentration
(mg /kg)
Maximum BackQ'round Frequencv
1.4 .ND 10/58
4.2 ND 3/58
3,800 ND 3/58
91.6 31.3 57/58
92.0 ND 14/58
108,000 40,000 58/58
23.0 ND 30/58
617 ND 1/44
4,380 281 SE;/58
0.26 ND 27/88
118 ND 32158
1,080 .249 54/58
1.4 ND 3/58
4.1 ND 11/58
145 39.0 57/58
84.9 26.1 57/57
Chemical Detected
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Vanadium
Zinc
ND - Not" Detected
19
J.
-------
contamination is 97,700 yds3.
5.4.4
Groundwater
A total of twenty-one (21) monitoring wells were installed for the
collection of shallow groundwater. Five (5) wells were ~nstalled
adjacent to the landfill boundary during the initial phase of the
RIo An additional sixteen (16) wells were installed during
subsequent RI field activity to define the extent of contamination.
The wells were installed with well screens set between 25 and 90
feet below the surface of the ground. Concentrations of
groundwater contamination are greatest surrounding the landfill.
The highest concentrations of groundwater contamination were found
in the northeast portion of the Site (Figure 9). A total of
fourteen (14) volatile organic compounds, eleven (11) semi-volatile
organic compounds, nine (9) pesticides, two (2) herbicides, and
seventeen (17) inorganic compounds were identified in the
groundwater. Table 4 provides a summary of the groundwater
sampling conducted during both phases of the RI. Approximately
1,500,000 gallons of shallow groundwater are contaminated at the
Site.
5.4.5
Surface Water and Sediment
Surface water and sediment samples were collected to assess
contaminat~on and potential contribution of contaminants into the
surface water system. Surface water features at the Site consist
of rainfall runoff, seeps, drainage valleys, and standing water.
Thirteen surface water samples and sixteen (16) sediment samples
were collected at the Site. The data from this sampling indicate
that contaminants are being released north of the landfill from
seepage of leachate and surface runoff. In addition, surface water
contamination is present in the remnant pit located in Disposal
Area C and sediment contamination has been observed in the drainage
valley north of the Site. Six (6) volatile organic compounds, six
(6) semi-volatile organic compounds, three (3) pesticides, two (2)
herbicides, and ten (10) inorganic compounds were present in the
surface water at the site. Eight (8) volatile organic compounds,
three (3) semi-volatile organic compounds, one (1) herbicide, and
sixteen (16) inorganic compounds were detected in the sediment at
the site. A summary of the samplin9 data is available in Table 5.
5.4..6
Air
Air samples were collected as part of the RI to assess the
potential airborne migration of contamination at the Site. Samples
were collected upwind and downwind of the Site as well as on-site
during excavation of landfill material. The results of air
sampling do not indicate that air transport of contaminants is
occurring. .
20
-------
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9
-------
Table 4
Groundwater Sampling Summary
Concentration
(mg/l)
Chemical Detected Maximum Backqround Frequencv
Acetone 1.47 0.610 8/20
Benzene 0.45 ND 6/10
Chlorobenzene 0.0138 ND 1/10
Dichlorodifluoromethane 0.0117 ND 1/10
1,1-Dichloroethane 0.0586 ND 2/10
1,2-Dichloroethane 0.003 ND 1/10
Ethyl Benzene 0.16 ND 2110
Methylene Chloride 0.0176 ND 1/10
Styrene 0.0176 ND 1/10
Tetrachloroethene 0.0086 ND 2/10
Toluene 12.1 . ND 4/20
1, 1, 1-Trichloroethane 0.0054 ND 1/10
Trichloroethene 0.015 ND 2110
Xylenes 0.26 ND 5/20
Benzoic Acid 326 ND 218
Benzonitrile 1.56 ND 3/8
Benzyl Alcohol 0.85 ND 218
Bis(2-ethylhexyl)Phthalate 0.83 ND 11/15
Dibenzofuran 0.0413 ND 1/8
1,4-Dichlorobenzene 0 .112 ND 3/8
2,6-Dinitrotoluene 0.052 ND 1/8
Fluorene 0.047 ND 1/8
Naphthalene 0.011 ND 1/8
Phenol 0.21 ND 1/8
1,2,4-Trichlorobenzene 0.062 ND 218
Aldrin 0.00007 ND 4/10
BHC, Beta 0 .0017 ND 6/10
Lindane 0.00008 ND 1/10
4,4'-DDD 0.00012 ND 2110
22
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Table 4
Groundwater Sampling Summary
Concentration
(mg/l)
Chemical Detected Maximum BackCJround Frequencv
Dieldrin 0.00008 ND 2/10
Endosulfan, Alpha 0.00005 ND 1/10
Endosulfan, Beta 0.00027 ND 1/10
Endrin 0.00004 ND 1/10
Heptachlor 0.00004 ND 1/10
2,4-D 1.26 ND 3/9
Dicamba 0.0284 ND 4/9
Aluminum 244 20.4 17/20
Arsenic 0.02 ND 3/11
Barium 0 .314 ND 1/10
Calcium 63.0 9.8 14/20
Chromium 0.410 0.099 16/20
Cobalt 0.66 ND 2/10
Iron 524 85.7 20/20
Lead 0.120 ND 3/20
Magnesium 11.9 ND 2/20
Manganese 12.1 1.13 20/20
Mercury 0.004 ND 6/20
Nfckel 0.13 0.06 9/20
Potassium 19.4 2.85 17/20
Silver 0.161 ND 7/20
Sodium 88.0 ND 14/20
Vanadium 0.490 0.09 S/20
Zinc 0.830 0.467 17118
ND - Not Detected
23
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Table 5
Surface Water And Sediment Sampling Summary
Concentration
(mg/l)
Chemical Detected Maximum Backaround Frequency
StJRlPACB WATER.
Acetone 0.140 ND 1/12
Benzene 0.0068 ND 1/12
Ethyl Benzene 0.020 ND 2112
Styrene 0.0095 ND 1/12
Toluene 0.0663 ND 4/12
Xylenes 0.152 ND 2112
Benzoic Acid 2.32 ND 3/12
Benzonitrile 0.602 ND 2112
Benzyl Alcohol 0.042 ND 2112
Bis (2-ethylhexy1) Phthalate 0.269 0.355 5/12
Di-n-octy1 Phthalate 0.010 ND 1/12
Phenol 0.014 ND 1/12
Heptachlor - 0.00006 ND 1/12
2,4-D 0.00052 ND 1/12
2,4,5-T 0.00129 ND 1/12
Dicamba 0.300 ND 4/12
2,4,5-TP 0.0003 ND 1/12
Aluminum 6.67 0.35 6/12
Arsenic 0.01 ND 1/12
Calcium 46.4 ND 4/12
Iron 19.7 ND 8/12
Magnesium 9.1 0.121 1/12
Manganese 2.99 ND 9/12
Potassium 127 1.32 2112
Silver 0.13 ND 2112
Sodium 9.7 ND 1/12
Zin~ 67.0 ND 5/12
---------------------------------------------------------------------------------------------
24
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Table 5
Surface Water And Sediment Sampling S\.UIIJDarY
Concentration
(lng/l)
Chemical Detected Maximum Backqround Frequency
Sediment Sampling Summary
Carbon Tetrachloride 0.186 ND 1/11
Dichlorodifluoromethane 0.323 ND 1/11
Trans-1,2-dichloroethene 0.170 ND 1/11
Ethyl Benzene 0.211 ND 1/11
Methyl Chloride 0.889 ND 1/11
Tetrachloroethene 0.304 ND 1/11
Toluene 0.234 ND 1/11
Vinyl Chloride 0.494 ND 1/11
Benzoic Acid 36.0 ND 1/13
Bis (2-ethylhexyl) Phthalate 31.0 0.355 5/13
Di-n-octyl Phthalate 0.810 ND 1/13
Dicamba 0.17 ND 1/12
Aluminum 13,500 3,570 11/13
Arsenic 9.0 3.1 11/13
Barium 111 44.1 8/13
Cadmium 3.4 ND 3/13
Calcium 1,600 618 3/13
Chromium 23.0 5.0 11/13
Cobalt 62.0 ND 4/13
Iron 24,000 4,480 11/13
Lead 34.0 13.0 10/13
Magnesium 660 ND 1/13
Manganese 1,470 251 11/13
Mercury 0.16 ND 3/13
Potassium 335 147 3/13
Silver 2.0 ND 3/13
Vanadium 38.0 8.0 11/13
Zinc 39.0 6.4 11/13
ND - Not Detected
25
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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. The assessment of risk posed by the
South Marble Top Road Site was evaluated in a site specific risk
assessment dated January 1992.
6.1
Identification of Contaminants of Concern
The South Marble Top Road Landfill Site is a threat to human health
and the environment due to the presence of hazardous substances in
the landfill. The criteria for selection of contaminants of
concern include the frequency of detection, the number of media
affected, the concentration of a contaminant, the toxicity of the
contaminant, and whether the contaminant is known to be associated
with past disposal practices. The contaminants of concern for the
Site are listed in Table 6.
6.2
Exposure Assessment Summary
Exposure assessment is the estimation of the magnitude, frequency,
duration, and routes of exposure to humans. Exposure to "the
contaminants of concern at the Site was evaluated based on current
and future use scenarios. The principal potential pathways of
exposure for the Site are direct contact with the contaminated
landfill material, soils or sediment and/or consumption of
contaminated groundwater.
The Site is currently closed to the publici therefore, the current
land use for the Site would be limited to occasional trespassers.
The average and maximum exposure frequency for a trespasser was
estimated at 25 and 50 visits per year, respectively. For the
trespasser scenario, the exposure pathways are ingestion and dermal
contact with contaminants in the soil and dermal contact with
surface water. Since the population surrounding the Site are
s~r~ed by a municipal water system, ingestion of the contaminated
groundwater was not evaluated as a potential pathway of cu~rent
exposure.
To address future use scenarios, it was assumed that residential
development would occur at the Site. Daily exposure was estimated
at an average duration of nine (9) years for adults and seven (7)
years for children and a maximum duration of 30 years for adults.
In conducting the exposure assessment for the residential use
scenario, focus was on the health effects that could result from
inhalation of particulate phase contaminants, ingestion and dermal
contact with contaminated soil, dermal contact with surface water
and seeps, and ingestion and dermal contact with contaminated
groundwater.
26
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Table 6 Summary Of Site Chemicals Of Concern
MAXIMUM CHEMICAL CONCENTRATION
£..andf11l Wastes So11 Sediment Ground Water Surface Water Air
Chemicals of Concern (mq/kq) (mq/kq) (mqll) (uq/l) (mq/l) (mq/kq)
VOLAcrILE COMPOUNDS
Acetone NO 21.1 ND 1470 0.140 NO
Benzene 167 6.54 ND 450 0.0068 NO
Chlorobenzene ND 5.25 ND 13.8 NO NO
Dichlorodifluoromethane NO 3.19 0.323 11.7 ND NO
l,l-Dichloroethane NO NO ND 58.6 ND ND
l,2-Dichloroethane ND NO ND 3 NO NO
Ethyl Benzene 16 36 0.211 160 0.020 NO
Methylene Chloride 21.1 17.3 0.889 17.6 ND NO
Styrene 3.42 NO NO 17.6 0.0095 NO
Tetrachloroethene NO 3.7 0.304 8.6 ND ND
Toluene 671 48.6 0.234 12,100 0.0~63 ND
Trichloroethene NO 6.17 ND 15 NO ND
Vinyl Chloride NO 0.509 0.494 ND NO NO
Xylenes 322 409 NO 260 0.152 ND
SEMI-VOLATILE COMPOUNDS
Benzoic Acid 73.5 7690 36 326,000 2.32 NO
Benzonitrile 18.7 7.95 NO 1560 0.602 NO
Benzyl Alcohol NO 6.00 ND 850 0.042 NO
Bis(2-ethylhexylj Phthalate 344 26 31 830 0.269 NO
Di-n-butyl Phthalate 106 3.16 ND ND NO NO
Di-n-octyl Phthalate NO 2.3 0.810 NO 0.010 NO
-Dibenzofuran 5.98 0.364 NO 41.3 ND NO
l,4-Dichlorobenzene 557,000 11 NO 112 ND NO
2,6-Dinitrotoluene ND 0.853 ND 52 ND ND
l,2,4-Trichlorobenzene ND 82.1 ND 62 ND NO
HERBICIDES
2,4-D 2670 4.61 ND 1260 0.00052 NO
Dicamba 58,400 2770 0.17 28.4 0.300 NO
METALS
Chromium 34 91.6 23 410 ND NO
Cobalt 14 140 62 660 ND - NO
Lead 7 1660 34 120 ND ND
Mercury ND 0.35 0.16 4 NO ND
Nickel 6 118 NO 130 NO NO
Silver ND 4.1 2.0 161 0.13 ND
Vanadium 26 145 38 490 ND NO
ND = Not Detected in Site Medium
27
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6.3
Toxicity Assessment Summary
Toxicity values are. used in conjunction with the results of the
exposure assessment to characterize site risk. Cancer potency
factors (CPFs) have been developed by EPA for estimating excess
lifetime cancer risks associated with exposure to carcinogenic
chemicals. Reference doses (RfDs) have been developed for
indicating the potential for adverse health effects due to exposure
to noncarcinogenic chemicals. .
CPFs are derived from the results of human epidemiological studies
or chronic animal bioassays to which animal-to-human extrapolation
and uncertainty factors have been applied. The CPFs, which are
expressed in units of (mg/kg-day) -1, are multiplied by the estimated
intake of a potential carcinogen, in mg/kg-day, to provide an
upper-bound estimate of the cancer risk. The term .upper~bound"
reflects the conservative estimate of the risks calculated from the
CPF. Use of this conservative approach makes underestimation of
the actual cancer risk highly unlikely. The.CPFs for inhalation
and oral exposure to the contaminants of concern at the Site are
contained in Table 7.
RfDs are also based on the results of human epidemiological studies
or animal studies to which uncertainty factors have been applied to
account for the use of animal studies to. predict noncarcinogenic
effects on humans. RfDs, expressed in units of mg/kg-day, are
estimates _of chronic daily human exposure levels which are not
expected to cause adverse effects. Estimated intakes of chemicals
from environmental media can be compared to the RfD. Uncertainty
factors are applied to the RfDs to insure an underestimation of the
potential for adverse noncarcinogenic effects does not occur. The
RfDs for this Site are provided in Table 8.
6.4
Risk Characterization Summary
A characterization of risk was performed in the risk assessment to
estimate the carcinogenic risk and the noncarcinogenic health
effects posed by the South Marble Top Road Landfill Site. The risk
characterization was based on identifying potential chemicals of
concern and developing exposure scenarios for current and future
exposure pathways.
Excess lifetime cancer risks are determined by combining the
results of the exposure and toxicity assessments. Carcinogenic
risk is a probability that is generally expressed in scientific
notation (e. g., lxlO-6). An excess cancer risk of lxlO-6 indicates
that dn individual has a one in one million additional chance of
developing cancer as a result of site-related exposure to a
specific carcinogen over a. 70-year lifetime under the specific
exposure conditions at the Site. EPA has established an acceptable
range of lxlO-6 to lxlO-4 for individual lifetime excess cancer risk.
28
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Table 7
Cancer Potency Factors For Inhalation And Oral Exposure
Chemical Inhalation Exposure Oral Exposure
Cancer CPF Cancer CPF
Classifica- mg/kg/day-l Classifica- mg/kg/day-l
tion tion
Benzene A 2. 90xl0-z' A 2. 90x10-z
1,1-Dichloroethane C Not Deter C Not Deter
1,2-Dichloroethane 82 9.10xl0-z B2 9.10x10-z
MethYlene chloride 82 1. 6Sx10-3 B2 7 :SOx10-3
Styrene B2 2 .OOxl0-3 B2 3.00x10-z
Tetrachloroethene 82 1.82xl0-3 B2 S.10x10-z
Trichloroethene 82 1. 70xl0-z B2 1.10x10-z
Vinyl chloride A 2. 9Sxl0-1 A 1.90xl0o
Bis(2-ethylhexyl)phthalate 82 Not Deter B2 1 .40x10-z
1,4-Dichlorobenzene C No!; Deter C 2.40x10-z
2,6-Dinitrotoluene B2 Not Deter B2 6. 80xlO-1
Chromium VI A 4.10xl01 Not Deter Not Deter
Lead - B2 Not Deter B2 Not Deter
Nickel A 1.70x10o Not Deter Not Deter
Not Deter = Not determined: - = USEPA has not derived a CPP or cancer classification
29
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Table 8
Reference Doses For Inhalation And Oral Exposure
Chemi<.;al Inhalation Oral Exposure
Effect of Chronic Effect of Chronic.
Concern RFD Concern RFD
mg/kg/day mg/kg/day
Acetone Not Deter Not Deter liver / 1 .OOxlO.1
kidney
Chlorobenzene li ver 5. OOxlO'] li ver 2 .OOxlO'z
Dichlorodifluoromethane lung/liver 5. OOxlO'z decreased 2.00xlO-1
body wt.
l.l-Dichloroethane kidney 1 .OOxlO.1 kidney 1 .OOxlO-1
Ethyl benzene develop- 2.86xlO'1 liver/ 1 .OOxlO.1
mental kidney
Methylene chloride liver 8. 57xlO.1 1 i ver 6.00xlO'z
Styrene Not Det.er Not Deter blood/ 2. OOxlO-1
liver
Tetrachloroethene Not Deter Not Deter liver l.OOxlO-z
Toluene nervous 5. 71xlO.1 li ver / 2. OOxlO.1
system kidney
Xylenes nervous 8. 57xlO'z decreased 2. OOxlOo
system body wt.
Benzoic acid Not Deter Not Deter decreased 4. OOxlOo
body wt.
Benzyl alcohol Not Deter Not Deter stomach 3. OOxlO.1
Bis(2-ethylhexyl)phthalate Not Deter Not Deter liver 2. OOxlO'z
Di-n-butyl Phthalate Not Deter Not Deter increased 1 .OOxlO-1
mortality
Di-n-octyl Phthalate Not Deter Not Deter kidney / 2.00xlO-z
liver
l.4-Dichlorobenzene kidney / 2.00xlO'1 Not Deter Not Deter
li ver
l,2,4-Trichlorobenzene porphyria 3. OOxlO'] porphyria 1. 31xlO-]
2,4-D Not Deter Not Deter blood/ 1 .OOxlO-z
li ver
kidney
Chromium II I nasal 6. OOxlO'? liver 1. OOxl0o
mucosa
Chromium VI nasal 6. OOxlO'? liver 5. OOxlO']
mucosa
Mercury nervous 8. 57xlO.5 kidney 3. OOxlO-.
system
Nickel Not Deter Not Deter decreased 2. OOxlO'z
body wt.
Sil ver Not. Deter Not Deter argyria 3. OOxlO-]
-
Vanadium Not Deter Not Deter skin 7. OOxlO-]
Not Deter = Not determi, tled - = USEE'A has tlot derived atl RfD
. Chronic RfD supplied by USEE'A Region IV
30
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Potential concern for noncarcinogenic effects of a single
contaminant in a single medium is expressed as the hazard quotient
(HQ) (or the ratio of the estimated intake derived from the
contaminant concentration in a given medium to the contaminant's
reference dose). By adding the HQs for all contaminants within a
medium or across all media to which a given population may
reasonably be exposed, the Hazard Index (HI) can be generated. The.
HI provides a useful reference point for gauging the potential
significance of multiple contaminant exposures within a single
medium or across media. An HI which exceeds unity indicates that
there may be concern for potential health effects resulting from
exposure to the contaminant.
The risk assessment process contains inherent uncertainties.
Exposure parameters such as frequency and duration of exposure and
ingestion rate of contaminated media can vary between individuals.
Therefore, upperbound values were used to estimate exposure, in
order to be more protective of human health. Slope factors and
Reference Doses each involve extrapolation to which conservative
uncertainty factors are added in order to be protective of
sensitive humans. Thus, the risk characterization process strives
to minimize the probability that uncertainties may result in an
underestimation of the actual health risks that could result from
human exposure to the site.
For the current use scenario (trespasser), the total lifetime
cancer risks associated with exposure to the Site is 4x10-8 under
mean exposure conditions and 2x10-7 under the reasonable maximum
exposure scenario (RME). The total HI for exposure to
noncarcinogens was calculated to be 1.82x10-3 (mean) and 1.47x10-2
(RME) . Since the carcinogenic risks are less than the EPA's
established risk range (lx10-4 to 1x10-6) and the hazard indices are
less than one, the current exposure pathways are not producing
unacceptable risks or health effects.
For the future use scenario (residential), the total lifetime
cancer risks for adults is 2x10-s (mean) and 3x10-4 (RME). The
chemicals that primarily contributed to this risk are benzene, bis
(2-ethylhexyl) phthalate, 2,6 dinitrotoluene and 1,4-
dichlorobenzene. For a child resident, the mean risk is 3x10-s and
the RME is 2x10-4 with the primary contributors be~ng benzene, bis
(2 ethylhexyl) phthalate and 2,6 dinitrotoluene. The total HI for
adult residents was calculated to be 0.753 (mean) and 7.12 (RME).
The chemicals that primarily contributed to the risk associated
with dermal contact with groundwater include ethyl benzene, toluene
and vanadium. For groundwater ingestion the primary contributors
were toluene, benzoic acid, benzonitrile, bis (2-ethylhexyl)
phthalate, l,2,.4-trichlorobenzene, 2,4-D, chromium VI, silver and
vanadium. The total HI for children which would reside at the site
under the future use scenario is 1.72 (mean) and 14.1 (RME). The
chemicals that primarily contributed to risk associated with dermal
contact with groundwater include toluene and vanadium. For
31
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groundwater ingestion the primary contributors were toluene,
benzoic acid, benzonitrile, bis (2-ethylhexyl) phthalate, 1,2,4
trichlorobenzene, 2,4-D, chromium VI, silver, and vanadium. As
indicated by the carcinogenic risks and noncarcinogenic hazard
indices, the future use residential scenario exceeds the' EPA's risk
range and hazard index.
6.5
Environmental Risk S~ry
During the RI, no endangered or threatened species were observed at
the Site. Although the Site is fenced, it is still accessible to
terrestrial species such as mice, rabbits, birds, etc.; therefore,
a potential exists that wildlife may have direct contact with
contaminants at the Site. The maximum exposure condition was
assumed to be associated with burrowing activities of rodents
living on the Site. The results of the ecological risk assessment
. indicate a hazard index of 494 (mean) and 1612 (RME). Since these
hazard indices exceed EPA's accepted level of 10 for environmental
risk, burrowing species may suffer adverse effects from the
contaminants present at the Site.
Minnows and tadpoles have been observed in the remnant pit on the
Site. Surface water present in this pit exceeds Ambient Water
Quality Criteria as well as Region IV Water Screening Criteria for
several contaminants (Table 9); therefore, the water in the pit
poses potential risk to aquatic life.
Table 9 Comparison of Ambient Water Quality Criteria With Maximum
Concentrations of The Chemicals That Exceed AWQC in Surface Water
Chemicals of Concern AWQC" Region IV WQC Maximum
Concentrations
in On-Site
Surface Water
Acute Chronic
mg/L mg/L . mg/L mg/L
Bis(2- 0.003" 1.11 <.0.0003 0.269
ethylhexyl) phthalate
Heptachlor 3. 60x10-6 5. 20x10-4 3. 80x10-6 6. OOx10-s
Silver 1.20x10-4 1.23x10-3 1.20xlO-s 1. 30x10-1
Phthalate esters
.. Fresh chronic criteria
32
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6.6
Cleanup Levels
Cleanup levels, designed to protect human health .and the
environment from threats posed by the hazardous substances present
at the Site, were developed for soil, sediment, surface water and
groundwater. See Table 10 and Table 11. The modei that was used
. to calculate the soil clean-up levels is a direct leaching model.
. The direct leaching model is expressed as AL = (foc) (Koc) (HBN)
where AL is soil action l~vel, foc is the fraction organic carbon,'
Koc is the organic carbon water partition coefficient and HBN is a
health based number for the protection of groundwater such as an
MCL. This model was used because the contaminated soils are near
the water table and there is little chance for attenuation plus'
much of the ground water transport is through fractured chert which
again affords little opportunity for attenuation.
The proposed plan did not contain soil cleanup levels for metals.
.It stated that soil cleanup values for metals would be included in
the ROD as soon as they were determined. Since the time that the
proposed plan was issued EPA determined that there is no
statistical difference between the metals levels found in
background soil and those found in site soil samples. Therefore,
there is no need for soil cleanup levels for metals in soils.
Actual or threatened release.s of hazardous substances from this
site, if not addressed by implementing the response action selected
in this ROP, may present an imminent and substantial endangerment
to public health, welfare, or the environment.
7.0
Description of Alternatives
Five alternatives were considered for remediation of the
contaminated soil and groundwater at the South Marble Top Road
Site. The alternatives are evaluated in detail in the Feasibility
Study Report. All of the alternatives, except the .No Actiona
alternative, address contamination in excess of the cleanup levels
established for the Site.
7.1
Alternative 1 - No Action'
The Superfund program requires the aNo Action. alternative be
considered at every site [Section 300.430 (e) of the National
.Contingency Plan]. The no action alternative serves as a baseline
with which the other alternatives can be compared. Under the no
action alternative, EPA would take no action at the Site to
33
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Table 10
Proposed Cleanup Levels For Shallow Groundwater
. .
Chemical
Action Level (ug/L)
Acetone
Benzene
Benzoic Acid
. Benzonitrile
Benzyl Alcohol
Bis(2-ethylhexyl)Phthalate
Chlorobenzene
Chromium
2,4-D
Dicamba
1,4-Dichlorobenzene
Dichlorodifluoromethane
1,1-Dichloroethane
1,2-Dichloroethane
Di-n-buty1 Phthalate
Di-n-octy1 Phthalate
2,6-Dinitrotoluene
Ethyl Benzene
Lead
Mercury
Methylene Chloride
Nickel
Silver
Styrene
Tetrachloroethene
Toluene.
1,2,4-Trichlorobenzene
Trichloroethene
Vanadium
Vinyl Chloride
Xylenes
3500
5
140,000
43
10,500
6
100
100
70
1,050
75
7000
3,500
5
3,500
700
70
700
15
2
5
100
100
100
5
1000
70
5
245
2
10,000
ug/L = micrograms of chemical allowed per liter of water
Proposed Soil Action Levels For Protection of Groundwater
Table 11
Chemical
Soil Concentration (mg/kg)
Benzene
Bis(2-ethylhexyl)Phthalate
1,4-Dichlorobenzene
Dicamba
0.014
. 40,440
0.430
1532
(mg/kg = milligrams per kilogram or parts per million)
34
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control or minimize the migration of the contaminants in either the soil
or groundwater. There is no cost associated with this alternative since
no additional activities would be conducted.
Capital Cost: -0-
. Annual Operation and Maintenance
Present Worth (PW): -0-
Months to Implement: -0-
(O&M) Costs: -0-
7.2
Alternative 2 - Institutional Controls
Combined institutional controls on the site would include physical
limitations' to on-site access (fencing and signing) and deed restrictions
on land use and bans on use of shallow groundwater on site and nearby.
Surface and groundwater would be monitored for at least 30 years,
biannually for the first five years and annually thereafter. EPA would
conduct five-year reviews. This option also includes four new monitoring
wells and surface water controls.
Capital Cost: $221,400
Annual O&M Costs: $358,500
PW: $580,000
Months to Implement: 24 months
7.3 Alternati ve 3 - Resource Conservation and Recovery Act (RCRA
Subtitle C) Multilayer Cap and Interceptor Trench/Off-Site
Treatment/Disposal
Alternative 3 proposes that a RCRA multilayer cap and an interceptor
trench be constructed over and around the existing landfill,
respectively, to impede the infiltration of precipitation and to provide
a collection system for contaminated groundwater. The cap would cover
an area of about four (4) acres. The trench would extend to a depth of
approximately 40 feet below grade, encircling the landfill along a
perimeter of about 1,680 linear feet. Initial construction would consist
of clearing the land and grading the site .to facilitate building. the
interceptor trench.' .
Groundwater would be pumped from the trench to an on-site steel tank and
transported off site to a regulated facility for treatment and disposal.
Each batch will be tested to determine whether it meets cleanup levels.
If, when tested, each batch could meet cleanup levels and Federal and
State requirements (ARARs), it would be discharged on site.
This also includes all of the activities contained in the previou.s
alternative.
Capital Cost: $2,100,000
Annual O&M Costs: $1,300,000
PW: $3,400,000
Months to Implement: 24 months
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7.4 Alternative 4 - on-Site Incineration/Disposal, RCRA Multilayer Cap
and Interceptor Trench/Off-Site Treatment/Disposal
The basic components. of Alternative 4 include collection, off-site
treatment and disposal of groundwater, remediation of landfill waste and
. associated soil, and capping.
This alternative includes the interceptor trench for collection and
containment of groundwater discussed in Alternative 3. As in Alternative
3, the ground and surface water will be stored on-site in a steel storage
tank and will be sent off-site for treatment and disposal. This
management and disposal will continue until the water on-site meets
cleanup levels and ARARs. .
Alternative 4 requires excavating and testing the various landfill wastes
to determine the appropriate disposal or treatment options of the
landfill waste and associated soils and to determine whether it contains
a hazardous substance or has the potential to release hazardous
substances. Any of the landfill waste which contains hazardous
substances or has the potential to release hazardous substances will be
removed and incinerated on-site. Associated soils, i.e. soils which
cannot be separated from these wastes, will also be incinerated.
However, if "the only hazardous substances found in the carpet wastes are
metals, those wastes will be disposed of properly in a RCRA Subtitle C
landfill off-site, instead of incinerated. All other site soils and any
landfill wastes that either do not contain hazardous substances or do not
have the potential to releas"e hazardous" substances, will remain
undisturbed and will be covered by the cap discussed below.
The wastes found thus far at the site are considered characteristic
hazardous waste. . When this material is incinerated and no longer
exhibits the characteristic that caused it to be a hazardous waste then
it is no longer a hazardous waste. Treated waste which is no longer a
hazardous waste will be placed back in the ground on-site. If, however,
the treated waste still contains metals and fails TCLP then it is a
hazardous waste and must be disposed of in a Subtitle C landfill. All
waste and associated soils that are excavated from the landfill must meet
applicable RCRA Land Disposal Restriction treatment standards before the
treated waste (e.g. incinerator ash) can be placed back on the ground or
sent off-site for landfill disposal.
T:t-e NCP establishes a presumption that treatment to the legislated
standards based on the Best Demonstrated Available Technology is
generally inappropriate for CERCLA contaminated soil "and debris (55 FR
8758-62, (March 8, 1990». Therefore, compliance with the land disposal
treatment standards would be achieved pursuant to a treatability variance
for CERCLA contaminated soil and debris which would be granted upon ROD
signature. .
Finally, this alternative requires a RCRA multilayer cap to contain
treated landfill waste (such as ash and incinerator waste), other
nonhazardous landfill wastes and remaining subsurface soils [contaminated
at levels above soil action (cleanup) levels (SALs)]. However, any
incinerator ash that will contain elevated levels of metals will be
properly disposed of off-site.
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Removal and treatment alternatives may require temporary relocation of
residents adjacent to the site. EPA can relocate households temporarily
with a minimum of inconvenience and has done so at other sites around the
country. An estimated cost for temporary relocation has been included
in the total estimated cost, should relocation be necessary. Alternative
4 also includes activities and institutional controls contained in
.Alternative 2.
Capital Cost: -$8,377,000
Annual O&M Costs: $1,298,000
.PW: $9,675,000
Months to Implement: 24 months
7.5 Alternative 5 - On-Site Incineration/Disposal, On-Site Biotreatment
with Disposal and Interceptor Trench With Off-site Treatment/Disposal
This alternative proposes a multi-step plan for the remediation process:
-Diversion of surface water;
- Excavation of waste and soil (analysis of carpet and latex
waste for determination of appropriate disposal options);
-On-site incineration and disposal of chemical wastes and
associated contaminated landfill soil; .
-Treatability Studies to determine the effectiveness of
biodegradation (an innovative technology with which
microorganisms are used to break down contaminants) of
contaminated subsurface soil; if successful, implementation of
biodegradation with on-site disposal of treated soil;
-A- RCRA Solid Waste clay cap would be placed over treated
material;
-Installation of interceptor trench for groundwater collection
with on-site storage and off-site treatment and disposal; .
-Combined institutional control activities.
- If biodegradation is unsuccessful in treating contaminated
subsurface soils EPA will consider other remedial alternatives
and amend the ROD if necessary.
The components are similar to 14 except this alternative provides for
treatment of subsurface soils and use of a RCRA solid waste clay cap in
lieu of a multilayer cap use. Remediation will begin with collecting run-
off waters and excavating the landfill wastes and soils. An interceptor
tr~nch system will be installed to collect and remove contaminated
groundwater. Waste suspected to be hazardous would be stored in a RCRA-
approved storage area before treatment. Approximately 4,000 yd3 o[ soil
excavated during drum and waste removal would be incinerated on-site.
About 97,700 yd3 of subsurface soils underneath the. landfill would be
treated on-site by biodegradation if biodegradation is proven effective
in treatability studies. An engineered bio-cell design would be used for
biodegradation to reduce the organic contaminants through bacterial
and/or fungal metabolism. With respect to the wastes and soils at this
site, bioremediation has not yet been proven to be an effective
technology. Contaminated site waters will be collected and stored on-
site prior to treatment and discharge. If biodegradation is unsuccessful
in treating contaminated subsurface soils EPA will consider other
remedial alternatives and amend the ROD if necessary. Once soil action
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levels are achieved, the treated soils will be used to backfill the
excavation. Incinerator ash will also be backfilled on-site. If the ash
or treated' soils still contain elevated levels of metals this material
will be disposed of properly off-site. Implementation of removal and
treatment alternatives may require temporary relocation of residents
, adjacent to the, site. An estimated cost for temporary relocation has
been included in the total estimated cost of this alterative also, in
case relocation is necessary.
The NCP establishes a presumption that treatment to the legislated
standards based on the "Best Demonstrated 'Available Technology is
generally inappropriate for CERCLA contaminated soil and debris (55 FR
8758-62, (March 8, 1990». Therefore, compliance with the land disposal
treatment standards would be achieved pursuant to a treatability variance
for CERCLA contaminated soil and debris which would be granted upon ROD
signature.
Capital Cost: $11,830,000
Annual O&M Costs: $1,152,000
PW: $12,980,000
Months to Implement: 36 months
8.0
Summary of the Comparative Analysis of Alternatives
This section of the ROD provides the basis for determining which
alternative provides the best balance with respect to "the statutory
balancing criteria in Section 121 of CERCLA and in Section 300.430 of the
NCP. The major objective of the FS was to develop, screen, and evaluate
alternatives for the remediation at the Mathis Brothers South Marble TOp
Road Landfill Site. The remedial alternatives selected from the
screening process were evaluated using the fOllowing nine evaluation
criteria:
-OVerall protection of human health and the environment.
-Compliance with applicable and/or relevant Federal or State
'public health or environmental standards.
-Long-term effectiveness and permanence.
-Reduction of toxicity, mobility, or volume of hazardous
substances or contaminants.
-Short-term effectiveness, or the impacts a remedy might have
on the community, workers, or the environment during the course
of ~lementing it.
-Implementability, that is, the administrative or technical
capacity to carry out the alternative.
-Cost-effectiveness considering costs for construction,
operation, and maintenance of the alternative over the life of
the project, including additional costs should it fail.
-Acceptance by the State.
-Acceptance by the Community.
The NCP categorizes the nine criteria into three groups:
(1)Threshold Criteri~ - overall protection of human health and
the environment and compliance with ARARs (or invoking a
waiver) are threshold criteria that must by satisfied in order
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,
for an alternative to be eligible for selection;
. (2) Primary Balancing Criteria - long-term effectiveness and
permanence; reduction of toxicity, mobility, or volume; short-
term effectiveness; iIIPlementability, and cost are primary
balancing factors used to weigh major trade-offs among
alternative hazardous waste management strategies; and
(3)Modifying Criteria - state and community acceptance are
modifying criteria that are formally taken into account after
public comment is received on the proposed plan and
incorporated in the ROD.
The selected alternative must meet the threshold criteria and comply with
all ARARs or be granted a waiver for cOIIPliance with ARARs. Any
alternative that does not satisfy both of these requirements is not
eligible for selection. The Primary Balancing Criteria are the technical
criteria upon which the detailed analysis is primarily based. The final
two criteria, known as Modifying Criteria, assess the publicis and the
state agency's acceptance of the alternative. Based on these final two
criteria, EPA may modify the remedial action. .
The following analysis is a summary of the evaluation of alternatives for
remediating the ~this Superfund Site under each of the criteria. A
comparison is made between each of the alternatives for achievement of
a specific criterion.
Threshold Criteria
8.1 OVerall_Protection of Human Health and the Environment
Alternative 1 (No Action) is not protective of human health and the
environment. Alternative 2 is protective of human health, but it is not
protective of the environment. Alternative 3 is protective of human
health and the environment. Alternative 3 reduces the risk by limiting
potential exposure with a RCRA cap and reducing infiltration of surface
water iato the landfill and by collecting contaminated shallow
groundwater for treatment and disposal and eliminating off-site migration
discharge of groundwater via seeps. Alternative 3 addresses protection
of the environment by control of contaminated groundwater migration,
however the source material (drums) remains on-site. Alternative 4
includes the components of Alternatives 2 and 3 and adds a greater degree
of protection of both human health and the environment. Alternative 5,
both the incineration and bioremediation, provides the greatest overall
protection of human health and the environment because it provides for
remediation of contaminated subsurface soils in addition to elements
included in Alternative 4; the site is essentially restored to a
protective condition and risks to human health and the environment are
eliminated with Alternative 5.
8.2
COIIPliance with ARARs
Alternatives 1 and 2 do not comply with RCRA, Clean Water Act (CWA), Safe
Drinking Water Act (SDWA), and/or Georgia's Solid Waste Management Act.
Alternatives 1 and 2 are not protective and do not meet ARARs therefore
they will not be discussed further. Alternative 3 does not cOIIPly with
39
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management requirements for non-hazardous wastes, specifically, those
applicable design and construction requirements requiring a composite
basal liner. Alternative 3 also does not meet RCRA landfill requirements
regarding the source a.t the site because although the source material is
not a hazardous waste, it is similar in nature so that standards .for
managing RCRA hazardous waste are relevant and appropriate. Alternative
3 attains a much greater degree of compliance with ARARs than.
Alternatives 1 and 2, but less than Alternatives 4 and 5. While
protective, Alternative 3 does not meet ARARs and will not be discussed
further. Alternative 4. fully complies with ARARs associated with the
.various components of the alternative (removal, storage, treatment, and
disposal). RCRA Land Disposal Restrictions (LDR) restricted wastes would
be treated by the Best Demonstrated Available Technology (BDAT) and
disposed of on-site in compliance with RC~ requirements. Alternative
4 attains a greater degree of compliance with ARARs than Alternative 3
because the landfill wastes will be removed and treated, and then
disposed of on-site according to RCRA nonhazardous landfill requirements.
Alternative 5, which includes bioremediation also. complies with all
ARARs. If it is discovered that subsurface soils are contaminated with
LDR restricted wastes, bioremediation to treat these soils will require
a treatability variance for soil and debris (before treated soils can be
disposed of on-site). Until treatability studies have been conducted,
EPA will not know whether bioremediation can achieve cleanup goals. All
of the alt~rnatives would comply with Clean Air Act (CAA) ARARs.
Primary Balancing Criteria
8.3
Long-Term Effectiveness and Permanence
Alternative- 4 and. 5 would achieve greater long term effectiveness and
permanence through removal of the source areas." Treatment will render
the wastes nonhazardous as defined by RCRA. For Alternative 5,
bioremediation of subsurface soils would permanently reduce the
concentration of contaminants to cleanup levels. Therefore, Alternative
5 achieves the greatest degree of long term effectiveness and permanence.
Off-site treatment/disposal at a permitted RCRA treatment, storage, and
disposal (TSD) facility would effectively and permanently reduce the
volume of contaminated groundwater on-site.
8.4
Reduction of Toxicity, Mobility or Volume Through Treatment
The alternatives including containment (4, 5) would reduce the potential
for increased waste volume and migration of contaminated soil and
groundwater by minimizing the generation of leachate. Incineration
(Alternatives 4 and 5) would result in a reduction of mobility, toxicity,
and volume. Biological treatment (5) ,would result in short-term waste
volume increases; however, this process would be expected to achieve
ultimate waste destruction over a period of time, thus decreasing
toxicity and volume to a higher decree than containment alternatives.
Off-site treatment and disposal of groundwater (4 and 5) would remove the
waste from the site for processing at a RCRA" facility. Alternatives 4
and 5 would all reduce contaminant mobility, toxicity, and volume,
although Alternative 5 would result in the greatest reduction.
8.5
Short-Term Effectiveness
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The alternatives including containment (Alternative 4) would achieve
almost immediate reduction on the potential for waste generation and
migration. Alternatives 4 and 5 would require source area excavation and
storage for processing. Consequently, the volume and/or mObility of .the
waste streams could increase while the excavation is open and vulnerable
to weather disturbances and from air emissions. Additionally, off-site.
disposal could result in a temporary increase in the potential for public
exposure during waste transport. Implementation of Alternatives 4 and
5 includes some form of' short-term exposure of Site workers. However,
. properly managed, these short-term concerns can be diminished
significantly.
8.6
Implementability
All alternatives are implementable. Containment (Alt. 4 and 5) is a
proven technology which could be easily implemented. Materials and
equipment are the only requirements and are available locally. Many of
the materials are synthetic and would have to be specially ordered, but
are commercially available. Although interceptor trench construction (4
and 5) requires special equipment, it is readily available. Containment
technologies would require clearing of the land to permit safe and proper
equipment operation and construction of the cap, interceptor trench, and
fence. Abandonment of existing monitor wells and reinstallation of new
ones could easily be accomplished.
Appropriate removal, treatment, and disposal alternatives could also be
implemented at the site. Additional clearing of land would be necessary
for constru.9tion. of bio-cells (5) and equipment installation of
bioremediation. with respect to the waste and soils at this site
bioremediation is not yet a proven technology. It will be necessary to
test the various landfill waste to determine the appropriate disposal or
treatment options necessary for these types of material. Treatment
methods would be designed to detoxify (make less harmful) the waste and
soils to required cleanup levels. The process of remediation under these
alternati ves could take from one to three years to complete. Electricity
and public water supply lines are available for connection at or near the
Site. Although temporary relocation of a few residences may be necessary
to implement alternatives 4 and 5, EPA can relocate households
temporarily with a minimum of inconvenience and has done so at other
sites around the country.
8.7
Cost
All of the costs 'are for construction and operation and maintenance (O&M)
of each alternative. The lowest cost alternative is il at $0, but it is
the least effective. The other alternatives have present worth costs of
$580,000, $3,400,000, $9,675,000 and $12,980,000, with i5 being the most
expensive.
Modifying Criter~a
8.8
State Acceptance
The State of Georgia has concurred with the selection of Alternative #5
to remediate the Mathis Site.
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8.9
Community Acceptance
~
The public was concerned about incineration and the possibility of
spreading the contami~ation through the air. They were also concerned
about the potential for contamination of the Knox aquifer, a drinking
water source. Based on the comments received at the public meeting as
well as during the public comment period, some of the community members"
support the selected remedy and some do not. The community was generally
in agreement that some remediation was needed to provide protection of
health and the environment. The Responsiveness summary in Appendix A
"documents how EPA has tried to address community concerns about the
proposed plan and the preferred alternative the selected remedy, however,
provides the best balance of the remedy selection criteria, and available
cleanup options for remediating site wastes are limited. See Section
10.6 for changes in selected remedy made to address public comment.
9.0 Selected Remedy
Based upon" consideration of the requirements of CERCLA, the NCP, the
detailed analysis of alternatives and public and state comments, EPA has
selected a remedy for this site. The selected cleanup alternative to
reduce risks posed by contamination found at the Mathis Brothers Site is
Alternative 5, On-Site Incineration/Disposal, On-Site
Biotreatment/Disposal and Interceptor Trench/Off-Site Treatment Disposal.
This alternative consists of surface water diversion, waste and soil
excavation, on-site incineration and biorem.ediation, clay cap,
installation of interceptor trenches, and institutional controls. Based-
on current information, this alternative would provide the best balance
of trade-offs with respect to the nine evaluation criteria EPA uses to
compare cleanup alternatives. The total cost of this alternative is
estimated at $12,980,000. EPA believes this" remedy will be fully
protective of human health and the environment, will attain Federal and
state standards or meet requirements for variances from them, and will
utilize permanent solutions and alternative treatment technologies to the
maximum extent practicable.
A.
Source Control
Source control remediation will address the waste material, contaminated
soils and contaminated sediments at the site. The major components of
source control to be implemented include:
.
Diversion of surface water;
Excavation of waste and soil (analysis of carpet" and latex
waste for determination of appropriate disposal options);
On-site incineration and disposal of chemical wastes and
associated contaminated landfill soil;
Treatability Studies to determine the effectiveness of
biodegradation (an innovative technology with which
microorganisms are used to break down contaminants) of
contaminated subsurface soil; if successful, implementation of
biodegradation with on-site disposal of treated soil;
A RCRA Solid Waste clay cap would be placed over treated
material; .
Installation of interceptor trench for groundwater collection
with on-site storage and off-site treatment and disposal;
.
.
.
.
.
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Combined institutional control activities.
If biodegradation is unsuccessful in treating
subsurface soils EPA will consider other remedial
and amend the ROD if necessary~
A portable incinerator will be us"ed on- site to treat the excavated waste
material and associated soils. A pilot study will be conducted on the
subsurface soils to see if, in EPA' s judgement, bioremediation is
feasible. If the bioremediation is successf~ then it will be used to
treat the subsurface soils.to appropriate established levels.
.
.
contaminated
alternatives
Performance Standards
Certain performance standards will not be determined until the Remedial
Design' Phase. The' performance standards for this component of the
selected remedy include, but are not limited to, the following standards:
Excavation Standards
Excavation shall continue until. the remaining soil and material
achieve the levels outlined in Table 11 of this document. All
excavation shall comply with ARARs, and state standards.
Testing methods approved by EPA shall be used to determine if
the cleanup levels have been achieved.
Treatment Standards
All treatment and disposal shall comply with applicable or
relevant and appropriate requirement$ (ARARs), including, but
not limited to RCRA. RCRA requires that incineration destroy
99.99 % of the contaminants.
B.
Groundwater remediation
Groundwater remediation will address the contaminated groundwater at the
site. Groundwater remediation will include installation of interceptor
trenches for groundwater collection with on-site storage and off-site
treatment and disposal.
Treatment Standards
Groundwater shall be treated until the concentration levels listed on
Table 10 are attained at the wells designated by EPA as compliance
points.
C.
Compliance Monitoring
Groundwater, treated soils and surface water monitoring shall be
conducted at this site. After demonstration of compliance with
Performance and Treatment Standards, the Site including soil and
groundwater, shall be monitored for five years. If monitoring of
groundwater indicates that the" Performance Standards are being exceeded
at any time after pumping has been discontinued, extraction and off-site
treatment and disposal of the groundwater will recommence until the
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-
I
Standards are once again achieved. If monitoring of the treated soil
indicates Performance Standards have been exceeded, the effectiveness of
the source control component will be re-evaluated.
10.0 Statutory Determination
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 remedy must meet appropriate
environmental standards established under Federal and State environmental
laws unless a statutory waiver is justified. The selected remedy also
must 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.
10.1
Protection of Human Health and the Environment
The selected remedy protects human health and the environment through
. treatment and disposal of the contaminated media at the site. 'The-
selected remedy provides protection of human health and the environment
by eliminating, reducing, and controlling' risk through treatment,
engineering controls 'and/or institutional controls.
10.2 Attainment of
Requirements (ARARs)
Remedial actions performed under CERCLA, as amended by SARA, must comply
with all applicable or relevant and appropriate requirements (ARARS)
unless a waiver is justified. All alternatives considered for the site
were evaluated on the basis of the degree to which they complied with
these requirements. The selected alternative was found to attain ARARs.
the
Applicable
or
Relevant
and
Appropriate
When ARARs are not available for specific compounds or exposure media
(such as groundwater), the cleanup goals are based on non-promulgated
advisories. or guidance such as proposed federal MCLGs, lifetime Health
Advisories (HAs), and reference dose (RfD) based guidelines.
Federal chemical-specific ARARs for the Mathis Brothers site include the
following:
Resource Conservation and Recovery Act (RCRA) Identification
and Listing of Hazardous Waste requirements - Defines those
solid wastes that are sUbject to and regulated as hazardous
waste. 40 CFR 261, Subparts C and D
RCRA Maximum Concentration Limits requirements - Standards for
14 hazardous constituents as a part of RCRA groundwater
protection standards. 40 CFR 264.94
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RCRA Treatment Standards - Treatment standards for hazardous
wasteR or hazardous waste extracts before land disposal is
allowed. 40 CFR 268, Subpart D
Safe Drinking Water Act (SDWA) Maximum Contaminant Limits
(MCLs) - Standards for select organic compounds, minerals, or
metals that are enforceable standards for public drinking water.
systems. 40 CFR 141 and 143
Clean Water. Act (CWA) Ambient Water Quality Criteria
requirements - Suggested ambient standards for the protection
of human health and aquatic life. Presented in CERCLA
Compliance Manual, 33 USC 300
CWA Toxic Pollutant Effluent Standards - Establishes effluent
standards or prohibitions for certain toxic pollutants:
aldrin/dieldrin, DDT, endrin, toxaphene, benzidine, PCBs. 40
CFR 129
Clean Air Act (CAA) National Emission Standards for Hazardous
Air Pollutants - Standards for specific constituents from
specific point sources. 40 CFR 61
State chemical-specific ARARs for the Mathis Brothers Site include the
following:
Georgia Water Quality Control Act Rules and Regulations for
Water Quality Control - State-mandated ambient water-quality
standards with respect to state-wide surface waters and
effluent discharge standards. Act No. 870, Chapter 391-3-6
Georgia Safe Drinking Water Act of 1977 Rules for Safe Drinking
Water State standards that set contaminant levels and
treatment techniques to satisfy the requirements of 42 USC 300
for public water systems. Act No. 231, Chapter 391-3-5
Georgia Hazardous Waste Management Act Hazardous Waste
Management - Establishes standards for generators of hazardous
waste. Act No. 231, Chapter 391-3-5
Georgia Air Quality Control Act Rules for Air Quality Control -
Establishes ambient air quality standards and point source
emission standards. Act No. 794, Chapter 391-3-1 .
Federal action-specific ARARs for the Mathis Brothers Site include the
following: .
Guidelines for the Thermal Processing of Solid Wastes
Establishes guidelines applicable to thermal processing
(incinerators) facilities designed to process 50 tons or more
of municipal solid wastes. 40 CFR 240
. .
Guidelines for the Land Disposal of Solid Wastes - Establishes
minimum guidelines applicable to land disposal facilities
receiving nonhazardous solid wastes, including siting, access,
design, and operating conditions. 40 CFR 241
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Guidelines for the Storage and Collection of Residential,
Commercial, and Institutional Solid Waste Establishes
guidelines for the collection of residential, cOmmercial, and
institutional solid wastes, including guidelines on the types
.of containers and collection frequency. 40 CFR 243
Criteria for Classification of Solid Waste Disposal Facilities
and Practices - Establishes criteria for use in determining
which solid waste disposal facilities and practices pose a
reasonable probability of adverse effects on health or the
environment. 40 CFR 257
Criteria for Municipal Solid Waste Landfills - Establishes
minimum national criteria for municipal solid waste landfills
to ensure protection for human health and the environment,
. including siting restrictions, monitoring, corrective motions,
and post-closure care. 40 CFR 258
RCRA Hazardous' Waste Management Systems General - Establishes
procedures and criteria for modification or revocation of any
provision in 40 CFR 260-265. 40 CFR 260
RCRA Standards Applicable to Generators of Hazardous Waste -
Establishes standards for generators of hazardous waste. 40
CFR 262
RCRA Standards Applicable to Transporters of Hazardous Waste -
Establishes standards which apply to persons transporting
h~zardous waste within the u.S. if the transportation requires
manifest under 40 CFR 262. 40 CFR 263
RCRA (Subparts B-O and Subpart X) Standards for Owners and
Operators of Hazardous Waste Treatment, Storage, and Disposal
Facilities - Establishes minimum national standards which
define the acceptable management of hazardous waste for owners
and operators of facilities which treat, store, or dispose of
hazardous waste. 40 CFR 264
RCRA Standards for the Management of Specific Hazardous Wast,es
and Specific Types of Hazardous Waste Management Facilities -
Establishes requirements which apply to recyclable materials
that are reclaimed to recover economically significant amounts
of precious metals, including gold and silver. 40 CFR 267
RCRA Land Disposal - Establishes a timetable for restriction of
burial of wastes and hazardous materials. 40 CFR 268
Underground Storage Tanks - Establishes regulations related to
underground storage tanks. 40 CFR 280
SDWA National Primary Drinking Water Regulations - Specifies
sampling, analytical, and monitoring requirements. 40 CFR 141
SDWA Underground Injection Control Regulations - Provides for
protection of underground sources of drinking water. 40 CFR
144-147
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CWA National Pollutant Discharge Eliminating System (NPDES) -
Requires permits for the discharge of pollutants from any point
source into waters of the United States. 40 CPR 125 .
CWA National Pretreatment Standards - Sets standards to control
pollutants which pass throl}gh or interfere with treatment
processes in publicly owned treatment works or which may
contaminate sewage sludge. 40 CFR Part 403
CAA Standards of' Performance for Incinerators Sets
performance standards and test methods for evaluation of
performance. 40 CFR 60 Subpart E
CAA National Emission Standards for Hazardous Air Pollutants -
Stipulates monitoring requirements for emissions of specific
contaminants. 40 CFR 61
Hazardous Materials Transportation Act (HMTA) Hazardous
Material Transportation Regulations - Regulates transportation
of hazardous materials. 49 CPR 107, 171-177
Comprehensive Response, Compensation and Liability Act of 1980,
As Amended (CERCLA) - Establishes funding and enforcement
authority for a comprehensive response program for past
hazardous waste activities that cause or may cause significant
negative impacts on human health and/or the environment. 4Z
USC 9601
Na~ional Contingency Plan (NCP) - Procedures for site removal
and remediations; requires that all response actions will be in
accordance with the NCP .to the greatest extent possible.. 40
CFR 300
State action-specific ARARs for the Mathis Brothers Site include the
following:
Georgia Water Quality Control Act Waste Treatment and Permit
Requirements - Establishes treatment standards and permitting
requirements. Act No. 870, Chapter 391-3-6.06
Georgia Water Quality Control Act Pretreatment and Permit
Requirements - Establishes treatment standards and permitting
requirements. Act No. 870', Chapter 391-3-6.08
Georgia Water Quality Control Act Publicly owned Treatment
Works Pretreatment Programs - Establishes treatment standards
and permitting requirements. Act No. 870, Chapter 391-3-6.09
Georgia Water Quality Control Act Land Disposal and Permit
Requirements Establishes permit requirements, hydraulic
loading rates, treatment specifications, and monitoring
requirements for land disposal of pollutants. Act No. 870,
Chapter 391-3-6.11
Georgia Water Quality Control Act Underground Injection Control
- Establishes criteria and standards for injection wells. Act
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No. 870, Chapter 391-3-6.13
Georgia SDWA Rules for
analytical testing and
evaluation of drinking
391-3-5
Safe Drinking Water - Se~s sampling,
monitoring frequency requirements for
water quality. Act No. 870, Chapter
Georgia Hazardous Waste Management Act - Establishes minimum
state standards which define the acceptable management of
hazardous wastes for owners and operators of facilities which
treat, store, dispose of hazardous wastes. Act No. 1251,
Chapter 391-3-11
Georgia Air Quality Control Act Rules for Air Quality Control -
Establishes sampling and monitoring requirements for emissions
of specific contaminants. Act No. 794, Chapter 391-3-1
Georgia Solid Waste Management Act - Establishes minimum state
standards which define the acceptable management of solid waste
for owners and operators of facilities which treat, s~ore, or
dispose of solid waste. Act No. 794, Chapter 391-3-4
"
Georgia Groundwater Use Act - Establishes procedures to be
followed to obtain a permit to withdraw, obtain, or use
groundwater and for the submission of information concerning
the amount of groundwater withdrawal, its intended use, and-
proposed aquifers. Act No. 794, Chapter 391-3-4
Georgia Hazardous Site Response Act - Requires that after July
1, 1993 all persons who own property where hazardous substances
were disposed or released include notice that the property is
contaminated in any instrument granting an interest in the
property. The owner must also file an affidavit, that will be
recorded in the deed records, indicating that the property is
contaminated and describing the contaminants with the superior
court of the county in which the property lies. .
10.3
Cost Effectiveness
The estimated cost of EPA's selected remedy is $12,980,000. Cost
effectiveness is determined by comparing the cost of all alternatives
being considered with their overall effectiveness to determine whether
the costs are proportional to the effectiveness achieved. EPA evaluates
the incremental cost of each alternative as compared' to the incrE'.:I sed
effectiveness of the remedy. The selected remedy, Alternative *5 does
cost more than the other alternatives. However, effectiveness achieved
by Alternative *5 justifies the higher cost. the remedy is considered
cost effective.
10.4 Utilization
Practicable
of
Permanent
Solutions
to
the
Maximum
Extent
EPA has determined that the selected remedy provides the best balance
among the nine evaluation criteria for the alternatives evaluated. the
selected combination provides protection of human health and the
environment, reduces the mobility of the contaminants, and is cost
48
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effective. The remedy, when complete, will provide a high degree of
permanence. The remedy represents the maximum extent to which permanent
solutions and treatment can be practicably utilized to remediate the
Mathis Brothers Site."
10.5
Preference for Treatment as a Principal Element
The statutory preference for treatment will be met because the selected
remedy treats the contaminated media through incineration. and
bioremediation.
10.6
Documentation of Significant Changes
EPA issued a Proposed Plan (preferred alternative) for remediation of the
Mathis Brothers/South Marble Top Road Landfill Superfund Site on July 30,
1992. The selected remedy differs slightly from the Proposed Plan.
The volume estimate and the cost for Alternative 4 and Alternative 5 have
changed slightly from when the proposed plan was issued in July 1992.
The volume changed from 140,000 yd3 subsurface soils to 97,700 yd3
subsurface soils and 108,800 yd3 of soils and waste combined. The cost
of Alternative 4 went from $11,900,000 to $9,675,000 and the cost of
Alternative 5 went from $17,500,000 to $12,980,000.
Also, the cleanup levels found in Table 10 and 11 changed.
for these changes are outlined in the followi~g paragraphs.
The groundwater cleanup level found on Table 10 for silver changed from
50 ug/l to 100 ug/l, styrene changed from 10 to 100 ug/l, :oluene changed
from 2000 ug/l to 1000 ug/l and 1,2,4-Trichlorobenzene changed from 9 to
70 ug/l. The National Primary Drinking Water Standard (NPDWS) value for
silver was delisted from the drinking water standards list July 17, 1992,
around the time the Proposed Plan was being completed. There is no
longer an MCLG for silver but the secondary MCL (SMCL) for silver is .1
mg/l or 100 ug/l. This is the number that will be used for the cleanup
level for silver. The values for styrene and toluene were typographical
errors and they have been corrected. The value for 1,2.,4-
Trichlorobenzene was an error. An MCLG exists for 1,2,4 -Trichlorobenzene
and should have been used. The MCLG is 70 ug/l~ .
The reasons-
The soil action level found on Table 11 for benzene changed from 0.002
to 0.014 mg/kg, Bis(2-ethylhexyl) Phthalate changed from 4200 for total
to 40,440 mg/kg for Bis(2-ethylhexyl) Phthalate, 1,4-Dichlorobenzene
changed from 3 to 0.43 ° and Dicamba changed from 10 to 1, 532 mg /kg . EPA
received comments from the public during the public comment period that
questioned EPA's soil cleanup numbers. EPA rechecked"our soil cleanup
numbers at that time and realized that they were incorrect and needed
recalculation. This recalculation was based on 3 components: (1) The
PRP commented during the public comment period that they thought the
organic matter content that was used was wrong. After analytical data
was provided to EPA to support the organic matter content found in the
Remedial Investigation (RI) Report Appendices, it was used in lieu of the
original conservative number" that EPA had used because of lack 6f
sufficient data; (2) EPA had used an outdated MCL instead of a more
recent superseding MCL; and (3) In checking these numbers as a result
49
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of receiving comments from the public, EPA rechecked all of the numbers
used to calculate cleanup levels and found that a partitioning
coefficient was incorrect and therefore had to be changed. The original
came from Shaver's Farm information but the GWTSU found a data source
. that was more reliable than the source that was originally used for a
partitioning coefficient. After changes were made to the cleanup levels
based on the above mentioned information, the volume estimate was checked
again to see if the cleanup level changes il'Cq;>acted the volume. They did
not il'Cq;>act the volume; the volume remained at 108,800 yd3. There was
therefore no significant change.
The proposed plan did not contain soil cleanup levels for metals. It
stated that soil cleanup values for metals would be included in the ROD
as soon as they were determined. Since the time that the proposed plan
was issued EPA determined that there is no statistical difference between
the metals levels found in background soil and those found in site soil
samples. Therefore, there is no need for soil cleanup levels for metals
in soils. .
In the proposed plan a contingency remedy of incineration was included, .
in Alternative 5, in the event that bioremediation failed. This has been
deleted in light of comments recei ved by EPA. In the event that
bioremediation fails incineration remains an option that may be
considered during ~ future evaluation of alternative contingencies for
subsurface soils. Future developed technologies could also be considered
in that evaluation. .
50
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r~un' UI'l~c.ru MUn U'I rlU I
IU. ~~ ..)6.t( "~IO nM~ 4:.'"t, ~:JJ...) ",-..,).jr.o. r.".::,
ueorgla uepanmenl OT l'Jatural HeSOUrCes
205 Butler Street, S.E., Suite 1252, Atlanta, Georgia 30334
Joe O. TlU\ner. Comrrissioner
Harold F. Rehoia. Director
Envil'OMlental PtOl8Clion Diviaion
March 23, 1993
Mr. Richard D. Green
Associate Director. Superfund
and Emergency Response
U.S. Environmental Protection Agency
Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
RE:
Revised Draft Record of Decision
For Mathis Brothers/South
Marble Top Road
Walker County. Georgia
Dear Mr. Green:
The Georgia Environmental Protection Division has reviewed the above referenced
document and concurs with the Record of Decision. and the Environmental Protection Agency's
selected remedia] action for the Mathis BrothersfSouth Marble Top Road LandfjJ) site.
If we can be of further assistance to you. please contact Bill Mundy at (404) 656-7802.
~~
Harold F. Rcheis
Director
HPRInwb
r;~~~1Ir
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