PB94-964005
                                 EPA/ROD/R04-94/171
                                 July 1994
EPA  Superfund
       Record of Decision:
       Woolfolk Chemical Work Site,
       Fort Valley, GA

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                           \
                           UJ
                           O
              RECORD OF  DECISION




 SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
         WOOLFOLK CHEMICAL WORK SITE




     FORT VALLEY,  PEACH  COUNTY, GEORGIA




OPERABLE UNIT #1:  GROUNDWATER CONTAMINATION
                   PREPARED BY




       U. S.  ENVIRONMENTAL PROTECTION AGENCY




                   REGION IV




                ATIANTA, GEORGIA

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                              DECLARATION
                                Of the
                          RECORD OF DECISION
                     WOOLFOLK CHEMICAL WORKS SITE
             Operable Unit  One:   Ground water Contamination
SITE NAME AND LOCATION

Woolfolk Chemical Works Superfund Site
Fort Valley,  Peach County,  Georgia


STATEMENT OF BASIS AND PURPOSE

This decision document (Record of Decision)  presents the selected
remedial action for the Woolfolk Chemical Works Site, Fort Valley,
Georgia, developed in accordance with the Comprehensive Environmental
Response) Compensation and Liability Act of 1980 (CERCLA),  as amended
by the Superfund Amendments and Reauthorization Act of 1986  (SARA) 42
U.S.C. 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 Woolfolk
Chemical Works Superfund Site  ("the Site").

The State of Georgia, as represented by the Georgia Environmental
Protection Division  (GaEPD),  has been the support agency during the
Remedial Investigation and Feasibility Study process for the Site.  In
accordance with 40 CFR 300.430, as the support agency, GaEPD has
provided input during this process.  The State of Georgia has
concurred with the selected remedy.


ASSESSMENT OF THE SITE

Actual or threatened releases of hazardous 'substances from the
Woolfolk Site, if not addressed by implementing the response action
selected in this Record of Decision  (ROD),  may present an imminent and
substantial endangerment to public health,  welfare and/or the
environment.


DESCRIPTION OF SELECTED REMEDY

This operable unit  (OU) is the first of two planned units at the
Woolfolk Site.  OU #1 will address contamination of the groundwater
while OU #2 will address contamination of soils, surface/storm water,
structures, sediment, and air.

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The major componencs of che selected remedy for this operable unit
include:

•   Further delineation of the extent and extraction of contaminated
    groundwater from the surficial, Upper Cretaceous (UC)  water table,
    and UC confined aquifers.

    Treatment of the groundwater using iron co-precipitation and sand
    filtration with activated carbon adsorption as polishing steps, if
    needed.

    Discharge to a Publicly-Owned Water Treatment Works (POTW)  with a
    contingency plan to include a National Pollutant Discharge
    Elimination System (NPDES) permit for surface water discharge or
    possibly an infiltration gallery should an NPDES permit be
    unattainable.

    Institutional  Controls, such as deed restrictions limiting the use
    of groundwater at the site until performance goals are met.

    Groundwater monitoring of specific wells,  including the city
    wells,  to be further defined during Remedial Design/ Remedial
    Action (RD/RA)  and abandonment of all others monitoring wells used
    during the RI/FS.

    Operation and  Maintenance of the full system to be defined by an
    O&M Plan developed during the Remedial Design.


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 satisfies the preference for treatment that reduces
toxicity, mobility, or volume as a principal element.  Finally,  it is
determined that this remedy utilizes a permanent solution and
alternative treatment technology to the maximum extent practicable.

Because this remedy will result in hazardous substances remaining at
the Site above the health-based levels until the performance goals are
met, a--review will be conducted within five years after commencement
of the remedial action to ensure that the remedy continues to provide
adequate protection of human health and the environment.
	
JOHN H. HANKINSON, JRJ                                   DATE
REGIONAL ADMINISTRATOR

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                               Record of Decision
                          Woolfolk Chemical Works Site

                                Table of Contents


i . 0      SITE LOCATION AND DESCRIPTION	,.	    I

2 . 0      SITE HISTORY AND ENFORCEMENT ACTIVITIES	    3

3.0      HIGHLIGHTS OF COMMUNITY PARTICIPATION 	    4

4.0      SCOPE AND ROLE OF OPERABLE UNITS	    4

5 . 0      SUMMARY OF SITE CHARACTERISTICS .  .-	    4
         5.1  GEOLOGY/PHYSIOGRAPHY 	    5
         5.2  HYDROGEOLOGY 	    6
         5.3  MEDIA CONTAMINATION  	    8
          5.3.1 GROUNDWATER CONTAMINATION  	    8
          5.3.2 SOIL CONTAMINATION	    9
          5.3.4 SURFACE WATER AND SEDIMENT CONTAMINATION 	   10
          5.3.5 STRUCTURE CONTAMINATION  	   10
          5.3'. 6 AIR CONTAMINATION  •	   11

6.0      SUMMARY OF SITE RISKS	   11
         6.1  CHEMICALS OF CONCERN	   11
         6.2  EXPOSURE ASSESSMENT  	   12
         6.3  TOXICITY ASSESSMENT  	   14
         6.4  RISK CHARACTERIZATION	   14
         6.5  ECOLOGICAL RISK/ HISTORICAL SITES  •.	   16
         6.6  PERFORMANCE STANDARDS   	   22
                                      \
7.0      DESCRIPTION OF ALTERNATIVES	'	   23
         7.1  ALTERNATIVE 1:  No-action	   23
         7.2  ALTERNATIVE 2:  Groundwater Extraction, Treatment, and
              Discharge to POTW	   24

8.0      SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES  	   25
         8.1  OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT  .   26
         8.2  COMPLIANCE WITH ARARs	.'.  .  .   26
         8.3  LONG-TERM EFFECTIVENESS   	   26
         8.4  REDUCTION OF TOXICITY, MOBILITY, OR VOLUME	   27
         8.5  SHORT-TERM EFFECTIVENESS  	   27
         8.6  IMPLEMENTABILITY  	   27
         8.7  COST	   27
         8.8  STATE ACCEPTANCE  	   27
         8.9  COMMUNITY ACCEPTANCE  	   28

9.0      SUMMARY OF SELECTED REMEDY   	   28

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                        Record of Decision
                   Woolfolk Chemical Works Site

                   Table of Contents  (Continued)
10.0 STATUTORY DETERMINATION
     10.1 PROTECTION OF HUMAN HEALTH AND  THE  ENVIRONMENT  .  .
     10.2 ATTAINMENT  Or  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 PRINCIPLE  ELEMENT .  .
33
33
11.0 DOCUMENTATION OF SIGNIFICANT CHANGES  .  .  .

APPENDIX A:  Responsiveness Summary

APPENDIX B:  Identified ARARs

APPENDIX C:  State of Georgia Concurrence  Letter
                        Record of Decision
                   Woolfolk Chemical Works Site

                         List of Figures
Figure 1-1:  Area Map  	

Figure 1-2:  Site Map  	

Figure 5-1:  Hydrogeologic Cross Section

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                               Record of Decision
                          Woolfolk Chemical Works Site

                                 List of Tables


Table 5-1 Historical and Current Hydrogeologic Nomenclature Woolfolk
          Facility 	    5

Table 5-2 Geologic and Hydrogeologic Units Woolfolk Facility 	    7

Table 6-1 Chemicals of Concern for Groundwater	   13

Table 6-2 Critical Toxicity Values, Slope Factors and Reference Doses    15

Table 6-3 Noncancer Risks and Lifetime Cancer Risks,  Future On site
          Exposure to Groundwater from the UC Water Table Aquifer,
          Adult Resident- Reasonable Maximum Exposure  	   17

Table 6-4 Noncancer Risks and Lifetime Cancer Risks,  Future On site
          Exposure to Groundwater from the UC Water Table Aquifer,
          Child Resident- Reasonable Maximum Exposure  	   18

Table 6-5 Noncancer Risks and Lifetime Cancer Risks,  Future On site
          Exposure to Groundwater from the UC Confined Aquifer,  Adult
          Resident- Reasonable Maximum Exposure  	   19

Table 6-6 Noncancer Risks and Lifetime Cancer Risks,  Future On site
          Exposure to Groundwater from the UC Confined Aquifer,  Child
          Resident-Reasonable Maximum Exposure 	   20

Table 6-7 Risk Characterization Summary for the Hypothetical Future
          Land Use Scenario, Groundwater	   21

Table 6-8 Summary of Uncertainties Associated with  Risk Assessment  .  .   21

Table 6-9 Groundwater Performance Standards   	 :   	   22

Table 7-1 Operable Unit  §1 Alternatives	   23

Table 8-1 Breakdown of Evaluation Criteria	•..  .  .   25

Table 9-1 Groundwater Performance  Standards   	   31

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                                        Record of Decision

                                  Woolfolk Chemical Works Site
                                       Fort Valley, Georgia
1.0  SITE LOCATION AND DESCRIPTION

The Woolfolk Chemical Works Site is located in Fort Valley, Peach County, Georgia, and includes 18 acres
of the former Woolfolk Chemical Works facility.  Businesses operating on the property of the former
Woolfolk facility include SurePack, Inc., Georgia Ag Chem, Inc., and the Marion Allen Insurance and
Realty Company.  Canadyne-Georgia Corporation (CGC) also owns a one acre parcel of Site property but
does not maintain an active business at the Site.  SurePack, Inc. continues to formulate, package, and
warehouse various organic pesticides that are used primarily in the lawn and garden market but also by
peach growers.

The Woolfolk Site is located in an  area with mixed commercial and residential uses.  Residences are
located west, south, and east of the facility, with homes to the southeast adjoining a pecan orchard.
Several businesses and light industries are located along the north, northwest, and east ends of the
facility, including The Norfolk Southern Railroad tracks and station.

For an area  Location map and general Site map, see Figures 1.1 and  1.2, respectively.
                                                                             •OOLTOLK CHCWICU. XII
                                                                          ran VAUJX IIACM oootor. CCOKU.
                                                                              STTI U9CATON
                                          Figure 1.1: Area Map

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FORMERLY WOOLFOLK. FAC/LfTV-
O/ftfiEVT OMNEFt PFIOP€FrrY
  Figure 1.2:    Sice Map

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2.0  SITE HISTORY AND ENFORCEMENT ACTIVITIES

Throughout its history, the Woolfolk facility has been used for the production and packaging of organic
and inorganic insecticides (including arsenic and lead-based products), pesticides, and herbicides.  During
World War II an inorganic intermediate (arsenic trichloride) was reportedly produced at the facility for the
War Production Board. Production was expanded during the 1950's to include the formulation of various
organic pesticides, including DDT, lindarve, toxaphene, and other chlorinated pesticides. These organic
pesticides and other insecticides and herbicides were formulated, packaged, or warehoused at the facility.

The J. W. Woolfolk Company owned and operated the Woolfolk Facility from 1926 until 1941, when it
dissolved and conveyed its assets to Woolfolk Chemical Works, Ltd.  Woolfolk Chemical Works, Ltd.,
reorganized into the corporation Woolfolk Chemical Works, Inc., in 1972.  In 1977, Reichold, Limited
acquired  all of the stock of Woolfolk Chemical Works, Inc.  pursuant to a stock purchase agreement. The
stock purchase agreement was assigned to Canadyne Corporation a wholly owned subsidiary of Reichold,
Limited.  In 1984, Woolfolk Chemical Works, Inc., changed its name to Canadyne-Georgia Corporation
(CGC). Also in  1984, the facility was sold to Peach County Properties, Inc. (PCPI).  PCPI is the current
owner of most of the former Woolfolk property, and has leased most of the property to its affiliate,
SurePack, Inc., which has formulated and packaged pesticides at the facility since 1984. Another portion
of the property is leased to Georgia Ag. Chemicals, which operates a warehouse and distribution facility.
CGC currently retains the title to a one acre parcel of the facility used as a  landfill.  Marion Allen
Insurance and Realty Company also owns one parcel located northwest of the operating facility (See
Figure 1.2).

In September 1986, CGC completed an interim, voluntary  soil remediation at the Woolfolk facility,  with
Applied Engineering Sciences  (AES) serving as construction manager.  The major remediation activities,
which were funded by CGC, consisted of demolishing several buildings and excavating approximately
3,700 cubic yards of soil contaminated with a combined lead and arsenic concentration above  10,000
mg/kg. All  soil with contamination levels above this concentration was disposed of at a permitted
hazardous waste landfill in Emelle, Alabama. Other soils  and debris were disposed of underneath  an on
site cap currently owned by CGC.  CGC informed the Georgia Environmental Protection Division (EPD) of
the investigations and cleanup activities. In August 1987, AES submitted a document to EPD entitled
"Cleanup Report for the Former Woolfolk Chemical Works Plant Facility" which summarized  remedial
activities conducted at the facility.

In 1986, the Environmental Protection Agency (EPA) began investigations of the release or potential
release of hazardous substances at the facility and requested  all analytical data pertaining to the facility.
This investigation led to the proposal to add the Site to the National Priorities List (NPL) in June  1988.
In April 1989, EPA notified potentially responsible parties (PRPs), including CGC, SureCo,  Inc., Peach
County Properties, Inc., Marion Allen Corporation, and Boots Hercules/Nor-Am Corporation of their
potential liability under CERCLA for response costs incurred at the Site.  In April 1990, EPA and CGC
completed negotiations on an Administrative Order on Consent (AOC) for Remedial
Investigation/Feasibility Study (RI/FS).  The AOC was signed on April 24, 1990. In August 1990, the
Woolfolk  facility was placed on the NPL.

The Remedial Investigation was submitted to EPA by Canadyne-Georgia  in November 1992.  The RI was
performed to document the nature and extent of contamination for affected  media, including soils,
groundwater, surface/storm water, sediment and air.  The  objective of the RI was to gather sufficient
information to develop risk management options and remedial alternatives that are appropriate for the
site.  The risk management options are presented in the Baseline Risk Assessment which was submitted
to EPA in November  1992. The remedial alternatives are  presented in the Feasibility Study  which was
submitted to EPA in December 1993. In conjunction with the RI/FS a bench scale treatability test was
performed for the soils and groundwater at the site.  The results of these tests were used to support the
findings of the Feasibility Study.

During the RI/FS, high levels of arsenic contamination were found in soils in residential yards near the
Woolfolk facility.  The removal of residential soil contamination together with demolition of a dioxin
contaminated on-facility building, is being completed pursuant to an Unilateral Administrative Order for

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Removal Response activities issued by EPA to CGC,  Reichold. Limited, and Canadyne Corporation on
December 1, 1993.


3.0  HIGHLIGHTS OF COMMUNITY PARTICIPATION

EPA has made significant efforts to insure that interested parties have been kept informed and given an
opportunity to provide input on activities at the Woolfolk Chemical Works site.  EPA has been working
with the community surrounding the Woolfolk Chemical Works since 1990. In September 1990, press
releases informing the community about the NPL listing of the site were released.  Subsequent interviews
were held that Fall to develop a Community Relations Plan fCRP). The information repository was
established in  October 1990, at the Thomas Public library, 213 Persons Street, Fort Valley, Georgia.  The
CRP, which was finalized in November 1990, has been placed in the information repository. In January
1991, EPA held a public meeting to discuss the start of the RI/FS.

Most recently, in July 1993, EPA issued a press release  and fact sheet on the findings of the RI study
regarding soil  contamination and health precautions recommended by the Agency for Toxic Substances
and Disease Registry (ATSDR). On August 2-3, 1993, EPA conducted door-to door visits to the potentially
affected residents to further distribute the fact sheet and extend our invitation to an availability session.
The availability session, held on August 3, 1993 discussed the results of the RI study and ATSDR's
recommendations for health precautions.  Fifty people attended the session which was hosted by EPA,
GaEPD, and ATSDR.  Representatives of CGC were also present

EPA's Emergency Response and Removal Branch is currently working to define the extent of off site
contamination, excavating contaminated soils from residential properties, and supervising the  destruction
of a site dioxin contaminated building (Building E). Two sampling events of soils in resident's yards have
occurred to date with results subsequently explained in meetings with the mayor and the public.  CGC is
complying with an Unilateral Administrative Order (UAO) requiring the disassociation of the affected
residents from contaminated soils and destruction/removal of Building E.

The Feasibility Study, the Proposed Plan, and the Administrative Record  (AR) for OU #1 were released to
the public on January 18,  1993. These two documents were made available in both the AR, maintained in
the EPA Region IV Docket Room, and the information repository at the site. The notice of availability of
these documents and the AR was published on January  18, 1994 in various local publications.  A public
comment period was held from January  18, 1993 to..February 17, 1994. In addition a public meeting was
held on  February 1, 1994.   At this meeting representatives from EPA, ATSDR, and the State of Georgia
answered questions about  problems at the site and the remedial alternatives under consideration.
Responses to the comments received during this comment period are presented in the responsiveness
summary in Appendix A of this document.

4.0   SCOPE AND ROLE OF OPERABLE UNITS

EPA has organized the work at this Superfund Site into two operable units (OUs).  The operable units are:

      •  OU #1: Contamination of the aquifers at the Site
      •  OU #2: Contamination of soils, surface/storm water, sediments,  structures, and air at the Site

OU #1 addresses contamination of groundwater from past practices at the Site.  The purpose of the
remedy  for this OU is to initiate groundwater restoration, collect data on  aquifer response to remediation,
and prevent possible future exposure to contaminated groundwater. The  planned OU #2 will address the
sources  of contamination at the Site which shall include soils, surface/storm water, sediments, structures
and air.

5.0   SUMMARY OF SITE CHARACTERISTICS

The-major Site characteristics presented in the RI/FS Study are summarized below.

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5.1   GEOLOGY/PHYSIOGRAPHY
      The Site is located in downtown Fort Valley, which has a population of approximately 9,000 people.
      Land use surrounding the Facility is classified as industrial, commercial, and residential.  The
      majority of the Facility consists of buildings, storage  tanks, and stockpiles of equipment.  A pecan
      orchard located on the southern portion of the facility is fenced.  Residential properties border this
      fence to the south and east.

      The Woolfolk Facility is located in what is physiographically known as the Fort Valley Plateau
      District.  This district lies •.vithin  the Coastal Plain Providence of Georgia just south of the "fall
      line," which marks the boundary between the Piedmont and Coastal Plain Provinces.  This district
      is characterized by broad, flat to very gently rolling surfaces, sloping gently to the southeast.
      Surface soils are  moderately drained and generally consist of sandy and silty clays to clayey and
      silty sands.

      Several southeast flowing creeks dissect the Fort Valley  Plateau District. It is bounded to the west
      by the Flint River and on the east by the Ocmulgee Riyer. Although the Flint River borders this
      district along its western boundary, almost the entire district lies within the drainage basin of the
      Ocmulgee River.  Surface runoff leaving the Facility is collected by the City's storm sewer  system.
      The storm water flows generally to the east, southeast and south discharging to a series of local
      creeks within 1 mile from the facility. These creeks discharge to Mosy Creek approximately 7.5
      miles to the east and into Big Indian Creek approximately 4 miles  to the southeast.

      Topography at the Facility has land surface elevations which varies from 516 feet above mean sea
      level (MSL)  at the northern end of the facility to 510 feet above MSL to the south.  The slope  at the
      facility is generally around  1 percent. A man-made mound installed during a voluntary clean-up by
      CGC, approximately 170 feet by 300 feet, with a maximum elevation of 520 feet above MSL, has
      been constructed  at the north central portion of the Facility. The mound consists of, from  top to
      bottom, grass. 24-inches topsoil, a filtering geotextile, 12-inches of granular drainage  material, a 30-
      mil High Density Polyethylene (HDPE) flexible membrane liner (FML), 24-inches of compacted clay,
      and geotextile fabric on the subbase to the compacted clay.
Table 5-1: HISTORICAL AND CURRENT HYDROGEOLOGIC NOMENCLATURE
WOOLFOLK FACILITY
Previous Hydrogeologic Unit Name*
Clayton Aquifer
Kaolin Confining Unit
Providence Aquifer
Providence-Ripley Confining Unit
Ripley-Bluf f town Unit
Not Specified
Tuscaloosa Aquifer
Hydrogeologic Unit Name"
Surficial Aquifer
Surficial Perching Unit
Upper Cretaceous (UC)
Water Table Aquifer (UC
Horizons 1 and 2)
UC Confined Aquifer
(UC Horizon 3}
Tuscaloosa Confining Unit
Tuscaloosa Aquifer
* Terminology used throughout the Woolfolk Facility history
until Phase II of the RI
•*•* Terminology assigned by CH2M Hill, 1991 in the development
of the RI.

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         •      The Coastal Plain stratigraphy of the Fort Valley area is being reclassified by the Georgia
                Geological Society.  Table 5-1 presents the former sequence of lithologies beneath  the facility
                along with the hydrogeologic unit name used throughout this ROD.  The units are described
                in the following section.

         5.2    HYDROGEOLOGY .

         •      The Facility is underlain by several hundred feet of unconsolidated sediments consisting of
                interbedded layers of sand, silt, and clay (See Figure 5-1). Soil from the surface to a depth of
                about 35 feet is silty and sandy clay (immediately underlying the surface)  and  sand. The
                lower, sandy parts of this interval contain groundwater in a unit designated in this ROD  as
                the surficial aquifer (See Table 5-2).

         «      In the interval between depths of about 35 to 75 feet is a thick unit of clay consisting
                primarily of kaolin.  The top surface of the clay unit is irregular in its topography. The
                kaolin unit appears to be continuous under most of the facility except to the north. Because
                of the dense, clayey nature of the kaolin, the layer serves as a perching layer for the surficial
                aquifer.  The kaolin is designated as the surficial perching unit.

         •      Beneath the kaolin  unit are three horizons of Upper Cretaceous soils.  Horizon 1 consists of
                interbedded  sands and clayey and silty sands to a depth of about 105 feet. To  a depth of
                about 100 feet, the Upper Cretaceous sediments are unsaturated. Horizon 2 is located in the
                interval between 105 and 125 feet, consisting of greater amounts of silty and clayey
                materials. The thickness and vertical  distribution  of this horizon is variable, and  apparently
                silty clay material is not present northeast of the facility which may mean that Horizon 1
                and 3 soils are joined.  The geologic materials in which the water table occurs are designated
                as the Upper Cretaceous water table aquifer and include the clayey and silty materials of
                the underlying unit.
 ito-
 sn-
                                                                                                          !  !
!«-
 3X-

 XK-
 XTO-

 **>-
             ?   ««,
                    L£V«L IN **cu o*
                                   Fjgure 5-1:  Hydrogeologic Cross Section

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Table 5-2
Geologic and Hydrogeologic Units
Woolfolk Facility
Geologic Character
Clayey and Silty Residuum
Sand
Kaolin
Interbedded sand, silt, and clay
Silty and sandy clay
Sand
Clay layers with interbedded sand
Sand
Hydrogeologic Formation Name
Surficial Aquifer
Surficial Perching Unit
UC Horizon 1
UC Horizon 2

Upper Cretaceous
Water Table Aquifer
Upper Cretaceous Confined Aquifer
(UC Horizon 3)
Tuscaloosa Confining Unit
Tuscaloosa Aquifer
CH2M Hill, 1992
From depths of about 125 feet to 280 feet there is an alternating sequence of sands, clays,
an'd clayey sands. At the top of the sequence is a layer of sand about 20 feet thick.  This
sand is considered Horizon 3 and is part of the Upper Cretaceous Confined Aquifer. The
individual alternating layers of sands, clays, and clayey sands beneath this sand are
typically less than 10 feet thick; their combined thickness is about 70 feet.  These
alternating layers are considered to be the Tuscaloosa confining unit.

At a depth of about 275 feet, hydraulic head measurements and the appearance of the
sediments in the sandy formation indicate that wells are screened in the Tuscaloosa aquifer.

Under the EPA ground water classification system, groundwater in the surficial aquifer and
the Upper Cretaceous aquifers is considered Class lib groundwater (a potential drinking
water source), while ground water in the Tuscaloosa aquifer is considered Class Ha
groundwater (a current source of drinking water).

The direction of the groundwater flow in the surficial aquifer is  generally toward the
southeast.  Leakage occurs through the surficial perching unit from the surficial aquifer into
the Upper Cretaceous sediments below.

The water table in the Upp'er Cretaceous aquifer indicates that  groundwater flows generally
to the north and northeast beneath most of the facility and to the east in the southeast
portion of the facility.

The hydraulic head contours in the Upper Cretaceous confined aquifer generally conform to
those of the Upper Cretaceous water table aquifer, indicating that groundwater flows
primarily to the northeast and east. There is also a component of the flow towards the
northwest in the Upper Cretaceous confined aquifer, along the northwest side of the facility.
Hydraulic heads in the Upper Cretaceous confined aquifer are typically below those of the
water table, indicating vertical groundwater flow from the Upper Cretaceous water table
aquifer  into the Upper Cretaceous confined aquifer.

Hydraulic head measurements in the Tuscaloosa aquifer beneath most of the facility indicate
groundwater flow toward the southeast. These measurements also show a reversal in
groundwater flow direction in and beyond the northwestern part of the facility. The'

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           direction of flow toward the northwest is consistent with the expected effects of pumping
           groundwater from the Tuscaloosa aquifer by the City of Fort Valley's wells.

    •       Hydraulic and lithological data indicate the potential for groundwater flow vertically-
           downward beneath the facility. The general nature of the perched surficial unit makes it
           likely for the groundwater to leak downward through this unit.  Downward flow is also
           indicated by a comparison of the hydraulic-head gradients of the Upper Cretaceous Aquifers
           and the Tuscaloosa Aquifer  presented in Figure 5-1.

    5.3     MEDIA CONTAMINATION

    There were 48 chemicals of potential concern selected  for analysis in the baseline risk assessment
    which are presented below.  This section summarizes the extent of these chemicals in the
    groundwater, soils, surface water/sediments, structures, and air.

                                             Volatiles
                 1.2-dichloroethane                                     chloroform
                 1,2-dichloropropane                     -                   xylene
                 acetone                                          carbon  disulfide
                 chlorobenzene                                   tetrachloroethane
                 trichloroethylene

                                          Semi-volatiles
                 1,4-dichlorobenzene                          2-methylnaphthalene
                 benzo(a)anthracene                                benzo(a)pyrene
                 benzo(b)floranthene                            benzo(g,h,i)perylene
                 benzofklfluoranthene                                 benzoic acid
                 bis(2-ethylhexyl)phthalate                                chrysene
                 di-n-butylphthalate                             di-n-octylphthalate
                 fluoranthene                               indeno( l,2,3-cd)pyrene
                 naphthalene                                   pentechlorophenol
                 phenanthrene                                             pyrene


                                            Pesticides
                 alpha-BHC                                             beta-BHC
                 delta-BHC                                          gamma-BHC
                 heptachlor                                         endrin ketone
                 4',4'-DDE                                              4',4'-DDD
                 4',4'-DDT                                             toxaphene
                 dieldrin                                             endosulfan I
                 endosulfan sulphate                                endosulphan II
                 alpha-chlordane                                gamma-chlordane

                                            Inorganics
                 antimony                                                arsenic
                 cadmium                                                     lead
                 selenium

5.3.1      GROUNDWATER CONTAMINATION

•  The groundwater contamination levels for each of the aquifers at this Site are presented in Table 6-1.
   The highest levels detected are presented in italic boldface.  The performance standards (levels
   required to attain  groundwater remediation) are set forth in Table 6-9.  A comparison of these two
   tables gives a view of the contamination at  the site. This section gives a general review of the
   findings from the RI.

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•  The levels of contamination exceeded the performance standards in the surficial, Upper Cretaceous
   (UC) water table, and UC confined aquifers. Trace contaminants have been detected directly beneath
   the site in the Tuscaloosa aquifer although  recently sampling has indicated no detection of chemicals.
   The City of Fort Valley water wells, which draw water from the Tuscaloosa aquifer, have never shown
   any levels of contamination.

Surficial Aquifer and Surficial  Perching Unit

•  Groundwater samples were taken from 11 monitoring wells in the surficial aquifer and surficial
   perching unit.  The presence of pesticides was detected in 7 of the 11 wells with lindane being
   detected most frequently. No pesticides were detected in up-gradient wells. Trace metals were
   detected in 8 of the 11 wells sampled. Arsenic, chromium and lead were found to  have the highest
   levels. The most common volatile organic compound fVOC) was  1,2-dichloroethane (1,2-DCA), which
   was detected in 5 of the 11 wells sampled.

Upper Cretaceous Water Table Aquifer

•  The groundwater samples from  the monitoring wells in the Upper Cretaceous water  table aquifer
   indicated that pesticides were present in 8 of 18 wells. Pesticides detected were the  same as in the
   surficial  aquifer sampling, but in a smaller  percentage of wells. The highest concentrations  of metal
   values were arsenic, chromium, cadmium and lead.  The contaminant 1,2-DCA also  was detected in
   the Upper Cretaceous water table aquifer.

Upper Cretaceous Confined Aquifer

•  The groundwater samples from  the monitoring wells in the Upper Cretaceous confined aquifer showed
   pesticides in five of the seven wells. No arsenic was detected; however chromium, and lead  were
   discovered. 1,2-DCA was detected in all wells sampled. Tetrachloroethene was detected in MW-3R.

Tuscaloosa Aquifer

•  Pesticides, arsenic, and chromium were not detected in the groundwater samples collected from the
   Tuscaloosa aquifer wells.  No contaminants were detected in the'City of Fort Valley Municipal Water
   Supply wells. Lead was detected in three of the five Tuscaloosa  wells and 1,2-DCA was detected in
   two of the Tuscaloosa wells.

5.3.2      SOIL CONTAMINATION

•  At the Woolfolk facility, two series of soils are identified:  The Greenville series and  the Grady Series.
   The Greenville Series soil commonly has a 4- to 8-inch surface layer of dark reddish-brown or dark
   brown fine sandy loam and a subsoil of dark red, friable  sandy clay.  The Grady Series soil has a dark
   gray to black fine sandy loam or sandy clay loam surface layer (5 to 10 feet)  and  a subsoil of firm
   gray clay that is sometimes mottled.

•  Several pesticides (toxaphene, DDD, DDE, DDT, dieldrin, BHCs), arsenic, and lead were detected in
   both surface (0 to 1 foot) and subsurface (generally 1 to 8 feet) soil samples collected from locations  on
   and off the facility. Areas with elevated concentration of one or more of these constituents include the
   tank farm, Area A cap, Building W, Building S, west boundary of Marion Allen Insurance and Realty
   company property, and the area northeast of the limehouse.  As mentioned in Chapter 2, the
   definition and removal of residential soil contamination is being completed pursuant to a UAO issued
   by EPA to CGC.

•  In general, volatile and semivolatile organic compounds were  not detected as frequently as arsenic,
   lead, or pesticides in either the surface or subsurface soil samples.  In addition, the  concentrations  of
   volatile and semivolatile organic compounds were lower than the other constituents.

•  The remediation for soils will be addressed in OU #2.

-------
5.3.4      SURFACE WATER AND SEDIMENT CONTAMINATION

•  The sampling results indicated that surface/storm water leaving the site contained only trace levels of
   DDT, benzoic acid,  and pentachlorophenol.

•  The results of sediment sampling indicated that pesticide concentrations, with the exception of
   toxaphene, are generally higher on the facility than downstream (intersection of Preston and Spruce
   streets). Toxaphene concentrations were detected at levels up to  12 mg/kg downstream and were
   detected in three out of four samples throughout the stormwater conveyance system. The inorganic
   constituent results  of the sediment samples indicated that arsenic levels were generally higher on the
   facility than upstream or downstream. No consistent pattern was observed with the lead results.

•  The remediation of surface/storm water and sediment contamination will be addressed  in OU #2.

5.3.5      STRUCTURE CONTAMINATION

•  The buildings are constructed primarily of wood and sheet metal and have wood flooring.  Chemicals
   have been  absorbed within the wood floors and  have migrated through the floors to the underlying
   soils. Also, the wood rafters in Building W have pesticide dust on them as a result of using this
   building to make pesticides in powder form. Building W is located on the Georgia Ag Chem property
   to the west of the facility.  Organic pesticides were formulated and packaged in the building.
   Elevated levels of arsenic, lead, pentachlorophenol, and dioxin were found in soil samples taken from
   the area beneath and adjacent to Building W during the Remedial Investigation.

•  On the facility is a  small garage-size building called "Building E".  Several 30- and 55-gallon drums of
   silvex were brought into Building E and repackaged in pint and quart containers.  Some of the silvex,
   which contained 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD) as a contaminant, was inadvertently
   spilled on the wood floors, resulting in localized contamination of the floors and underlying soil with
   silvex, TCDD, 2,4-dichlorophenoxyacetic acid and 2,4,5-trichlorophenoxyacetic acid.

•  Building E is being demolished by CGC under EPA oversight pursuant to a Unilateral  Administrative
   Order issued by EPA to CGC, Reichold, Limited, and Canadyne Corporation. Building W will be
   addressed  in OU #2.

   Wood Samples of Building E

•  Sampling of the wood in Building E was conducted during the RI to assess the extent of dioxin
   contamination in the flooring.  Five pesticides were detected in the two wood samples collected.
   Concentrations ranged from 9.5 mg/kg for alpha-BHC to 2,000 mg/kg for toxaphene. Several
   inorganic constituents were detected in the wood samples, including arsenic (11,100 to  72,400 mg/kg)
   and lead (320 to 968 mg/kg). Dioxin and some of its isomers were detected in the wood samples from
   Building E.  Concentrations ranged from 0.012  mg/kg to 37.4 mg/kg for the various isomers.

   Soil Samples of Building E

•  Soil samples were taken from the floor of Building E. DDT was the only pesticide found in all 10
   samples, and was detected at concentrations from 0.36 to 49 mg/kg. Arsenic was detected in all
   samples at concentrations ranging from 63 mg/kg to 2,790 mg/kg.  Lead was also identified in each  of
   the samples from this building, at concentrations ranging from 40.1 mg/kg to 1,550 mg/kg.  The data
   indicate that the concentrations of both arsenic and lead decrease with depth in most instances.

•  The 10 Building E soil samples also were analyzed for dioxin and  its isomers.  Nineteen dioxin
   isomers were detected and were distributed evenly with depth. In most cases, concentrations
   decreased  with depth. The highest concentration of any dioxin isomer detected was total-
   octachlorodibenzo-p-dioxin, which was found at a concentration of 18.5 mg/kg in a shallow (0- to  1-foot
   depth) soil sample.  This mixture of dioxin isomers is much less toxic than the more commonly known
   dioxin isomef TCDD.                                                  •


                                                10

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•  Structure contamination  will be addressed in OU#2.

5.3.6      AIR CONTAMINATION

•  A total of 24 chemicals were detected in air samples taken during RI sampling consisting of 6 volitile
   organics, 4 semi-volitile organics, 12 pesticides/herbicides, and 2 inorganic (lead and arsenic).

•  Air contamination will be addressed in OU #2.


6.0       SUMMARY OF SITE RISKS

CERCLA directs EPA to conduct a baseline risk assessment to determine whether a Superfund Site
poses a current or potential  future threat to human health and the environment in the absence of any
remedial action. The baseline risk assessment provides the basis for determining whether or not
remedial action is necessary and the justification for performing remedial action.  The Final  Baseline
Risk Assessment of the Site was submitted in November 1992.

The Remedial Investigation  and Baseline Risk Assessment have determined the media contaminated by
the chemicals of concern.  OU #1, addressed in this ROD, will manage contamination of the groundwater
while OU #2, will address the remaining contaminated media.

Measurable concentrations of many of the chemicals of concern were found in the groundwater samples
from the facility. For those  receptor populations identified in the baseline risk  assessment (i.e. on site
workers, off-site residents), ingestion and exposure to groundwater are not complete exposure pathways
under a current domestic use scenario. However, these pathways represent a health threat should
groundwater usage result under a future land use scenario.

Actual or threatened releases (i.e. potential city well contamination) 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.

6.1       CHEMICALS OF CONCERN

The chemicals which were carried through the risk assessment process are referred to as chemicals of
potential concern (COPC). COPCs were selected on the basis of the following criteria:  (1) their potential
to unfavorably affect human health; (2) their persistence and/or mobility in the environment; (3) their
presence in groundwater at  levels above federal maximum contaminant levels (MCLs); (4) their presence
in environmental media exceeding background levels; (5) the number of environmental media affected;
and  (6) the frequency of their detection in soil, air, groundwater, surface water, or sediment.

Chemicals are included in this Summary of Site Risk Section if the results of the risk assessment
indicate that a  contaminant might pose a significant current or'future risk. These chemicals are referred
to as contaminants of concern (COC). The criteria for determining the contaminants of concern are those
contaminants that contribute to a pathway that exceeds a 1E-4 risk or Hazard Index (HI) of 1; chemicals
contributing to  these pathways need not be included if their individual carcinogenic risk contribution is
less than 1E-6 or their noncarcinogenic Hazard Quotient (HQ) is less than 0.1.  COCs for the
groundwater and the exposure point concentrations for each of those chemicals are presented in Table 6-
1. The exposure point concentrations represent the 95% upper confidence level (UCL) on the arithmetic
mean or the maximum concentration if the UCL exceeds the maximum.

Current land use on and around the facility consists of industrial, commercial, and residential areas.
The groundwater beneath the site has been divided into four layers. The first (the surficial perched
aquifer), the second (Upper Cretaceous (UC) Water Table), and third (UC Confined Aquifers) layers are
not in use currently. The fourth, the Tuscaloosa Aquifer, is the source for the  City of Fort Valley's water
supply.   The closest City well is located within 500 ft of the Site,  north of the railroad. Monitoring of the
City Wells since 1985 has shown no contamination concern.


                                                11

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6.2       EXPOSURE ASSESSMENT

Whether a chemical is actually a concern to human health and the environment depends not only on the
innate toxicity but also upon the likelihood of exposure, i.e. whether the exposure pathway is currently
complete or could be complete  in the future.  A complete exposure pathway (a sequence of events leading
to contact with a chemical) is defined by the following four elements:

   •      A source and mechanism of release from the  source,

   •      A transport medium (e.g. surface water,) and mechanisms of migration through  the medium,

   •      The presence or potential presence of a receptor at the exposure point, and

   •      A route of exposure (ingestion, inhalation, dermal  absorption).

If all four elements are present, the pathway is considered complete.

An evaluation was undertaken of all potential exposure pathways which could connect chemical  sources
at the Site with potential receptors. All possible pathways were first hypothesized and evaluated for
completeness using EPA's criteria.  No current potentially complete exposure pathways for groundwater
remained after screening but three future exposure pathways exist.  The current pathways are
considered to be incomplete for reasons that the population near the site is served by the municipal
water system. A well survey indicated  that no well exists in  the areas of concern other than the
municipal wells, which are screened in  the Tuscaloosa Aquifer. The Tuscaloosa aquifer is an aquifer
which has never been found to contain  chemicals above  drinking water standards.

The future pathways represent exposure pathways which could exist, in the future, if the current
exposure conditions change.  Exposure by each of these  pathways was mathematically  modeled using
generally conservative assumptions.

The future pathways are:

   •      potential dermal exposure by potential on site residents to groundwater,

   •      ingestion of contaminated groundwater by potential on site residents and,

   •      inhalation exposure of potential on site residents.

The exposure point concentrations  for each of the chemicals of concern and the exposure assumptions for
each pathway were used to estimate the chronic daily intakes for the potentially complete pathways.
The chronic daily intakes were then used in conjunction with cancer potency factors and noncarcinogenic
reference doses to evaluate risk.
                                                12

-------
Table 6-1: Chemicals of Concern for Groundwater
Exposure Point Concentrations in mg/L'
Chemical
Surficial
Perched
Aqu.
Upper Cret.
Water
Table
uc
Confined
Aquifer
Tuscaloosa
City
Wells
Inorganics
Arsenic
Cadmium
Chromium
Lead
Manganese
5.92*
0.0043
0.102
0.0235
20.5
0.853
0.0161
0.1049 .
0.04
3.99
0.005
0.0025
0.35713
0.03
0.134
0.005
0.0025
0.005
0.0045
0.0503
0
0
0
0
0
Pesticides
Alpha-BHC
Beta-BHC
Delta-BHC
Gamma-BHC
Dieldrin
0.015
0.029
0.01
0.0083
0.00005
0.017
0.0007
0.0051
0.016
0.0001
0.001
0.0006
0.0007
0.002
0.00005
0
0
0
0
0.00005
0
0
0
0
0
Semi-Volatile Organics
bis(2-ethylhexyl)
ph thai ate
0.0388
p.0272
0.0145
0.005
0
Votatile Organics
Acetone
Chloroform
Carbon Bisulfide
1,2, Dichloroethane
1,2, Dichloropropane
Tetrachloroethene
0.0054
0.0059
0.005
0.0701
0.0319
0.0072
0.0073
0.0067
0.0254
0.0161
0.0145
0.005
0.058
0.005
0.011
0.021
0.0165
0.0071
0.005
0.005
0.005
0.005
0.005
0.005
0
0
0
0
0
0
Footnotes:
1) Lognormal distribution assumed. The exposure point concentrations represent the
upper 95% confidence level (UCL) on the arithmetic mean or the maximum
concentration if the UCL exceeds the maximum.
2) Results in italic boldface represent the maximum concentration rather than the
UCL.
13

-------
The major assumptions defining exposure frequency and duration that were considered in the exposure
assessment were:

   •       The body weights for adult residents is assumed to be 70 kilograms for adults and 15 kgs for
          children.

   •       Ingestion rates per day are estimated as 2 liters per day for adults and 1 liter per day for
          children.

   •       The exposure frequency is 350 days per year for adults and children.

   •       The duration of exposure was assumed to be 6 years for children and 30 years for adults.

   •       The showering time for dermal and inhalation exposure was assumed to be 12 minutes.

6.3       TOXICITY ASSESSMENT

Toxicity values are used in conjunction with the results of the exposure assessment to characterize site
risk.  EPA has developed critical toxicity values for carcinogens and noncarcmogens.  These critical
toxicity values are listed in Table 6-2.  Cancer slope factors (CSFs) have  been developed for estimating
excess  lifetime cancer nsks associated with exposure to potentially carcinogenic chemicals.  CSFs, 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 a high end estimate of the excess lifetime cancer risk associated with exposure
at that intake level.  The term "high end" reflects the conservative estimate of the nsks calculated from
the CSF. Cancer slope factors are derived from the results of human epidemiological studies or chronic
animal bioassays to which animal-to-human extrapolation and uncertainty factors have been applied.

Reference doses (RfDs) have been developed by EPA for indicating the potential for adverse health effects
from exposure to  chemicals exhibiting noncarcinogenic effects.  RfDs, which are expressed in units of
mg/kg/day, are estimates of lifetime daily exposure levels for humans, including sensitive individuals.
Estimated intakes of chemicals from environmental media can be compared to the RfD. RfDs are derived
from human epidemiological studies or animal studies to which uncertainty factors have been applied
(e.g., to account for the use of animal data to predict effects on humans).  These uncertainty factors help
ensure that the RfDs will  not underestimate the potential for adverse noncarcinogenic effects to occur.

6.4       RISK CHARACTERIZATION

Human health risks are characterized for potential carcinogenic and noncarcinogenic effects by
combining exposure and toxicity information.  Excessive lifetime cancer risks are determined by
multiplying the estimated daily intake level with the cancer slope factor.  These risks are probabilities
that are generally expressed in scientific notation (e.g., IxlO'6).  An excess lifetime  cancer risk of IxlO6
indicates that, as a plausible upper limit, an individual has a one in one million additional (above their
normal risk) chance of developing cancer as a result of site-related exposure to a carcinogen over a
70-year lifetime under the assumed specific  exposure conditions at a site.

EPA considers individual excess cancer risks in the range of IxlO4 to Ixl0fc as protective; however the
1x10 6  risk level is generally used as the point of departure for setting cleanup levels at Super-fund sites.
The point of departure risk level of IxlO6 expresses EPA's preference for remedial  actions  that result in
risks at the more protective end  of the risk range.  The health-based risk levels for OU #1  are shown in
Tables 6-3, 6-4, 6-5, and 6-6.

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 contaminants' reference dose). A HQ which exceeds one (1)
indicates that the daily intake from a scenario exceeds the chemical's reference dose.  By adding the HQs
for all  contaminants within  a medium  or across all media and appropriate pathways to which a given
population may reasonably be exposed, the Hazard Index (HI) can be generated.  The HI


                                                14

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provides a useful reference point for gauging the potential significance of multiple contaminant exposures
within a single medium or across media.  An HI which exceeds unity indicates that there may be a
concern for potential health effects resulting from the cumulative exposure to multiple contaminants
within a single medium or across media.  The His for OU #1 are also shown in Tables 6-3 through 6-6.

Risks associated with the  surficial aquifer were in a qualitative manner by comparing the concentration
of chemicals in the surficial aquifer with the Upper Cretaceous (UC) confined aquifer. Accordingly, if the
surficial aquifer was used  as a drinking water source or for showering, it would present cancer and non-
cancer risks to hypothetical future residents greater than those calculated for the Upper Cretaceous
water table aquifer under  the same exposure conditions due to the higher concentration of chemicals of
concern in the surficial aquifer.
Table 6-2
CRITICAL TOXICITY VALUES1
SLOPE FACTORS (SFs) AND REFERENCE DOSES (RfDs)
Contaminants

Arsenic
Cadmium
Chromium
Lead
Manganese
a-BHC
P-BHC
8-BHC
Y-BHC
Dieldrin
bis(2-ethylhexyl)phthalate
Acetone
Chloroform
Carbon Bisulfide
1,2-Dichloroethane
1,2-Dichloropropane
Tetrachloroethene
Notes:
Slope Factor
(SFs)
Oral2
1.8
ND

ND

6.3
1.8
6.3
1.3
16
1.40E-"
ND
6.10E'3
ND
9.1QE'2
6.80E'2
5.10E'2
Inhal.





6.3
1.8 .
6.3
1.3
16
-
-
S.lxlO'2
-
9.10E-2
-
2.00E-3
Reference Dose
(RFD)
Oral2
3.00E"1
5.00E"1
5.00E3
ND
5.00E'3
ND
ND
ND
3.00E'4
5.00E'5
2.00E'2
l.OOE'1
LODE'2
l.OOE'1
ND
ND
l.OOE-'
Inhal.





-
-
-
-
-
-
-
-
2.85E-3
-
1.14E-3
-

1 Critical toxicity values obtained from Integrated Risk
Information System (IRIS) or Health Effects
Assessment Summary Tables (HEAST) (USEPA, Fiscal
Year 1991).
2 Also basis for deriving dermal toxicity value.
ND No data. USEPA has not derived a RfD or slope factor
                                                 15

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 Ingestion of arsenic in the UC Water Table aquifer groundwater accounts for over 90% of the calculated
 hazard indices and lifetime cancer risks calculated for the future on  site resident.  The calculated hazard
 indices for the on site adult and child resident were 83.2 and 202,  respectively.  Lifetime cancer risks
 calculated for the future on site adult and child resident also exceed the upper bound target risk level
 fix 10'';. A summary of the risk characterization is provided in Table 6-7.

 Hazard indices calculated for the  future on site adult and child resident exposed to groundwater from the
 UC Confined aquifer were less than one for the adult resident but greater than  one for the child resident.
 Lifetime cancer risks for future on site adult  and child were 2x10" and  IxlO4, respectively.  Lifetime
 cancer risks resulting from exposure to groundwater from the UC Confined aquifer resulted primarily
 from  arsenic and to a lesser extent, the presence of low  concentrations of beta-BHC, bis(2-
 ethylhexyljphthalate, 1,2-dichloroethane, and tetrachloroethene.

 Throughout the risk assessment process, uncertainties associated with evaluation  of chemical toxicity
 and potential  exposures arise.  For example uncertainties arise in derivation of toxicity values for
 reference doses (RfDs) and carcinogenic slope factors (CSFs), estimation of exposure point concentrations,
 fate and transport modeling, exposure assumptions and  ecological toxicity data.  Because of the
 conservative nature of the nsk assessment process, risk  estimated in this  assessment may overestimate
 the true risk associated with potential exposure at OU #1 of the Woolfolk  Chemical Site.   Uncertainties
 for the OU #1 at the Woolfolk Chemical  Site are enumerated in Table 6-8.

 6.5       ECOLOGICAL RISK/ HISTORICAL SITES

 An ecological assessment evaluates potential hazardous  effects on non-human  species at Superfund sites.
 It may be a qualitative or quantitative appraisal of the actual and  potential effects on the environment of
 a Superfund. site.  Not all sites provide a  suitable ecological habitat.  Many sites in industrial areas have
 little  or no wildlife.  The appropriate level of effort for assessing ecological risk is determined on a site-
 by-site basis.

 The Woolfolk facility is located adjacent to the central business district of Fort Valley, Georgia, and the
 surrounding community consists of residential homes and small businesses.  A qualitative assessment of
 the potential ecological effects of the Woolfolk Chemical  Works facility determined that the site poses no
 significant ecological impacts.  It is unlikely that the Woolfolk facility effects any designated wetlands
 due to the fact that the closest wetland is more than three miles from the Facility  and is not
 hydraulically connected. The Woolfolk facility is not located within either the  100-year or 500-year
 floodplain.

 It is unlikely that the facility affects either of the three  identified endangered  species  (i.e., the Red-
 Cockaded Woodpecker,  Kirtland's  Warbler, or the Bald Eagle) that reside in  the  geographical area for the
 following reasons: 1) There are no records or reported sightings of any of these species in Peach  County,
 and 2) the Facility and surrounding area do not provide  the  critical types of habitat needed for these
 endangered or  threatened species.

 There are two historical sites listed in Peach County, Georgia. These sites include the Peach County
 Courthouse located on West Church Street, and Strothers Farm located near the Peach/Macon  County
 line.  It is unlikely that the Facility adversely affects the use of these historical sites nor their cultural
 value because they are located at least 1/2 mile from the Facility.

There are no wild and scenic rivers nor designated wilderness areas in Peach County. The Facility does
 not affect any coastal zones or coastal barriers.
                                                 16

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                                              Table 6-3
                           Noncancer Risks and Lifetime Cancer Risks
          Future On site Exposure to Groundwater from the UC Water Table Aquifer
                        Adult Resident- Reasonable Maximum Exposure

Qicmical

inorganics
Arsenic
Cadmium
Lead
Pesticides
4,4'-DDT
alpha-BHC
bota-BHC
dclta-BHC
jamma-BHC (lindane)
Dieldrin
Endosulfan II
Endosulfan Sulf.itc
Endrin Ketone
Semivolatilc organic chemicals
Bis(2-ethy lhcxyl)phtha late
Di-n-octyl phthalate
Volatile organic chemicals
1,2-Dichloroethane
1,2-Dichloropropane
Acetone
Carbon disulfide
Chloroform
Teixachlorothene
Trichloroethene
Xylenes (total)
Pathway Risk
Sum of Pathway


Ingcstion

7.79E+Q1
8.82E-01
-

3.84E-03
l.SSEiOO
6.39E-02
4.66E-01
1.46E+00
5.48E-02
3.12E-02
2.74E-02
6.85E-03

3.73E-02
8.08E-03

-
-
2.00E-03
6.96E-03
1.84E-02
1.37E-02
2.28E-02
726E-05
8.26E+01

Qironic
Haurd Quotient
Dermal Inhalation

1.57E-01
3.20E-02
'

3.21E-03
3.94E-02
1.62E-03
1.18E-02
3.71E-02
2.S3E-03
6.30E-05
5.53E-05
2.49E-04

2.48E-03
1.47E-05

-
6.43E-02
3.63E-06''
6.32E-03 2.40E-01
4.33E-03
9.20E-03
9.53E-03
1.17E-05
3.17E-01 3.04E-01
832E+01


Ingcstion

1.80E-02
na
IK

2.79E-07
1.26E-03
1.48E-05
3.77E-ai
2.44E-W
1.88E-05
na
n.T
n.i

4.47E-06
na

1.72E-05
1.16E-OS
na
na
4.80E-07
3.05E-06
6.46E-07
na
2E-02

Lifetime
Cancer Risk
Dcnnal

3.64E-05
nj
nc

2.34E-07
3.20E-OS
3.76E-07
9.59E-06
6.21 E-06
8.66E-07
ixn
113
n.i

2.98E-07
na

1.65E-07
2.10E-07
na
na
1.13E-07
2.0SE-06
2.70E-07
na
9E-05
2E-02


Inhalation

•
«
*

6.88E-09
5.90E-07
5.32E-10
6.24E-09
1.53E-07
6.87E-10
na
n.i
na

na
na

1.34E-06
na
na
na
1.46E-O6
1.42E-07
2.56E-07
na
4E-06

(.):        Hazard quotient could not be calculated due to lack of a reference dose.
na:        Not applicable
*:         Inhalation exposure to metals in groundwater is not assumed to occur.
nc:             Lead is considered by the EPA to be a potential weak human carcinogen.  Lifetime cancer risk estimates were
               not calculated due to lack of a slope factor.
                                                   17

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                                               Table 6-4
                            Noncancer Risks and Lifetime Cancer Risks
           Future On site Exposure to Groundwater from the UC Water Table Aquifer
                          Child Resident- Reasonable Maximum Exposure
1
Oi emicji

11
li\c;estion
inorganics
Arsenic l.S2Et02
Cadmium 2.06E-iOO
Uad
Pesticides
4,4'-DDT
alpha-BHC

1.28E-02
3.62E4-00
beta-BHC i 1 49E-01

delta-BHC 1.09E+OO
jamma-BHC (ILndane)
3.41Et-00
Dieidrin 1.28E-O1
EndosuLfan II 7.29E-02
EndosulfanSulfato 6 39E-02
Endrin Ketonc
Sernivolalile organic chemicals
Bis(2-ethylhexy I)phtha la te
Di-n-octylphthalate
Volatile organic chemicals
1,2-Dichloroetha ne
1,2-DichJoropropanc
Acetone
Carbon disulfide
Chloroform
TetrachJorothene
Tric±Uoroethene
Xylenes (total)
Pathway Risk
Sum of Pathway
1 .60H -02

8.69E-02
1.89E-02

1 .28E-02
3.62E-fOO
1.49E-01
1.09E-MDO
3.41E+00
1.28E-01
7.29E-02
6.39E-02
2.01 E+02

Oironic
azjrJ Quotient
Dermal Inhalation

291E-01
5 93E-02.
-

9.90E-03
7.30E-02
3.01E-03 ' -

2.19E-02
6.87E-02
4.68E-03
1.171I-O-5
1 02E-CM
4 MEXM

4.59E-03
2.72E-05

9.90E-03
7.30E-02
3.01E-03
2.19E-02
6.87E-02
4.68E-03
1.17E-04
1.02E-04
7.1&E-Q1 O.OOE+00
2.02E+02


Incestion

7.34E-03
na
tic

1.86E-07
5.87E-CM
6.90E-06

1 .76E-ai
1.14E-04
8.77E-06
na
na
na

1.49E-OS
7.HE-09

8.03E-06
5.40E-06
na
na
2.24E-07
1.42E-06
3.01 E-07
na
8E-03
•
Li 1 ctimc
Oncer Risk
Dermal

1.82E-05
na
nc

1.44E-07
1.18E-05
1.39E-07

3.SSE-06
2.30E-06
3.21E-07
na
na
na

7.87E-10
na

6.13E-08
7.78E-08
na
na
4.19E-08
7J59E-07
9.98E-08
na
4E-05
8E-03


Inhalation

•
-


1.S3E-08
5.50E-07
4.96E-10

5.82E-09
1.43E-07
6.42E-10
iia
na
na

na
na

1.2SE-06
na
na
na
136E-06
1J3E-07
239E-07
na
4E-06

(-):        Hazard quotient could not be calculated due to lack of a reference dose.
na:        Not applicable
*;         Inhalation exposure to metals in groundwater is not assumed to occur.
no        Lead is considered by the EPA to be a potential weak human carcinogen.  Lifetime cancer risk estimates were not
          calculated due to lack of a slope factor.
                                                  18

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                                             Table 6-5
                          Noncancer Risks and Lifetime Cancer Risks
           Future On site Exposure to Groundwater from the UC Confined Aquifer
                        Adult Resident- Reasonable Maximum Exposure

Ci\emicil

norgantca
Arsenic
./ad
Pesticides
alpha-BHC
bcta-BHC
dclta-BHC
;amma-BHC (Lindanc)
Dicldrin
Semivolatilc organic compounds
Bovioic Add
Bis(2-cthyllicxyl)phtKalatc
Di-n-butyl phthalatc
Di-n-octyl phthalatc
Volatile organic compounds
1,2-Dichlorocthanc
1 ,2-Dichlorop ropanc
Acetone
Carbon disulfidc
Chloroform
Tctrachlorothene
Pathway Risk
Sum of Pathway Risks


Ingcslion
4.S7E-01
-

l.OOE-01
S.48E-02
6.67E-02
1.37E-01
2.74E-02
1.7HL-04
1.99E-02
1.37E-03
6.85E-03

1.S9E-02
3.01E-03
1.37E-02
1.9SE-02
4.67E-01

Chronic
Hizird Quotient
Dermal InluUcion
9.21E-O4
"
-
2.S5E-03
1.39E-03
1.69E-03
3.4SE-03
1.26E-03
2.27E-(X,
1.32E-03
8.20E-OS
1.24E-05

7.32E-02
2.88E-05 •.
2.73E-03 1.04E-01
3.23E-03
1.31E-02
3.09&02 1.77E-01
6.7SE-01


Ingestion
1.06E-04
nc

8.14E-05
1.27E-OS
S.40E-OS
2.29E-05
9.39E-06
na
2.3SE-06
na
na

2;24E-05
1.32E-OS
na
na
3.58E-07
4.34E-06
2E-04

Lifetime
Cancer Risk
Dermal
2.13E-07
nc

2.07E-06
3.22E-07
1.37E-06
5.82 E-07
4.33E-07
i\a
1.S9E-07
rta
na

2.16E-07
2.39E-07
na
na
8.45E-08
2.91 E-06
8E-06
2E-04


Inhalation
.
•

3.82H-08
456E-10
8.93E-10
1.44E-08
3.44E-10
na
na
na
na

1.75E-06
na
na
na
1.09E-06
2.02E-07
3E-06

(.):        Hazard quotient could not be calculated due to lack of a reference dose.
na:       . not applicable
V        ."Inhalation exposure to metals in grouudwater is not assumed to occur.
nc:       ' Lead is considered by the EPA to be a potential weak human carcinogen. Lifetime cancer risk estimates were not
          calculated due to lack of a slope factor.
                                                   19

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                                               Table 6-6
                            Noncancer Risks and Lifetime Cancer Risks
             Future On site Exposure to Groundwater from the UC Confined Aquifer
                          Child Resident- Reasonable Maximum Exposure

O i cm i ca 1

Inrorganics
Arsenic
Lead
Pesticides
alpha BHC
bota-BHC
delta-BHC
gamma BHC (Lindar^
Dioldrin
Semi volatile organic chemicals
Benzoic Acid
Bis(2-ethy Lhexy l)phthj la to
Di-n-butyl phthalate
Di-n-octyl phthalate
Volatile organic chemicals
1 ,2-Didtloroetha ne
1,2-Dichloropropane
Acetone
Carbon disulfide
Chloroform
Tetrachlorothene
Pathway Risk
Sum of Pathway Risks


In^cstion

l.OTE-t-00


2.34E-01
1.2SE-01
1.56E-01
3.20E-01

2.S2E-05
6.44E-03 - VOTE -Ob
2.34E-03 - ; 4 38n^>'»

4.20E-06 - n.i
2.45E-03 - U1E-06
1.S2E-04 - i m
2.30E-05

-
3.42E-01
5.34E-05
5.06E-03 4.85E-01
5.98E-03
2.42E-02
5.71 E-02 8.27E-01
1.97E+00
na

1.05E-05
6.15E-O6
no
na
1 .67E-07
2.02E-06
1E-04

Lifetime
Oncer Risk
Dermal

7.89E-OS
nc

7.66E-07
1.19E-07
5.08E-07
215E-07
1 60E-07

ru
5.87E-08
na
na

7.99E-O8
8.85E-08
aa
na
3.13E-08
1.08E-06
3E-06
1E-04


Inhalation

•
•

2.71E-09
4.26E-10
8.34E-10
1.34E-08
3.21E-10

ru
na
na
na

1.64E-O6
na
na
na
1.02E-06
1.89E-07
3E-06

(-):        Hazard quotient could not be calculated due to lack of a reference dose.
na:        Not applicable
*:         Inhalation exposure to metals in groundwater is not assumed to occur
nc:        Lead is considered by the EPA to be a potential weak human carcinogen  Lifetime cancer risk estimates were not
          calculated due to lack of a slope factor.
                                                   20

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Table 6-7
Risk Characterization Summary for the Hypothetical Future Land Use Scenario
Groundwater
Exposure Source
Upper Cretaceous
(UC) Water Table
Aquifer
UC Confined Aquifer
Tuscaloosa
Receptor
Adult
Child
Adult
Child
Adult and child
Hazard Index
RME Case
83.2
202
<1
1.97
None
Additional
Lifetime Cancer
Risk'
RME Case
2E-02
8E-03
2E-04
1E-04
None
' Current lifetime cancer risk without exposure to Facility chemicals is approximately 1 in 4, or
0.25. Risk with adult RME exposure to chemicals in the UC Water Table Aquifer is 0.27.
                                  TABLE 6-8
                 SUMMARY OF UNCERTAINTIES ASSOCIATED
                           WITH RISK ASSESSMENT
              Assumption
  Estimated
Magnitude of
Effect on Risk
 Direction of Effect
  on Risk Estimate
Environmental Sampling and Analysis

Errors in chemical analysis
                                     V

The majority of sampling wells are installed
in the region of the suspected contaminant
plume
     Low


 Low-Moderate
Over or underestimate
risk

Overestimate risk
 Fate and Transport Modeling

 Chemical concentrations reported as "below
 method detection limit" are used at one-half
'detection limit when calculating mean
 chemical concentrations
     Low
Over or underestimate
risk
 Toxicological Data

 Hazard indices (His) were developed
 assuming all toxic effects were additive
 Low-Moderate
Overestimate risk
 Exposure Parameters.

 Conservative values were used for exposure
 duration, frequency, and intake levels.
 Low-Moderate
Overestimate risk
                                       21

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6.6
PERFORMANCE STANDARDS
The establishment of health-based performance standards serves as an important means of guiding
remedial activities.  A health-based approach is warranted when performance standards promulgated by
state or federal agencies are not available for contaminants in soil, as well as for certain groundwater
contaminants. The approach to developing health-based standards is derived from the risk assessment
process.  The risk assessment is essentially a process by which the magnitude of potential cancer risks
and other health effects at a site can  be evaluated quantitatively. A performance standard is established
by back-calculating a health protective  contaminant concentration, given a target cancer risk or hazard
index which is deemed acceptable and realistic. The concept of the performance standard inherently
incorporates the concept of exposure reduction  which allows remedial alternatives to be flexible.

The groundwater at the Woolfolk Chemical site currently contains concentrations of Site-related
contaminants at levels which would pose an  unacceptable nsk (cumulative risk  in excess of IxlO6) to
human health if the water was being used for human consumption. Actual or threatened  releases of
hazardous substances from this Site,  if not addressed by implementing the response action selected in
this ROD, may present an imminent and substantial endangerment to public health, welfare, or  the
environment.
TABLE 6-9: GROUNDWATER PERFORMANCE STANDARDS
Micrograms per liter (uglli or part* per billion Ippb)
Chemical
Standard1
Inorganic
Arsenic
Cadmium
Chromium
Lead'
Manganese'
50
5
100
152
2003
Pesticides
alpha-BHC'
beta-BHC'
delta-BHC'
gamma-BHC
Dieldrin*
0.01
0.05
0.014
0/2.
0.005
Chemical
Standard'
Semi-Volatile Organic Compounds
bis(2-ethylhexyl)phthalate'
6
Volatile Organic Compounds
Acetone'
Chloroform'
Carbon Disulfide'
1,2-Dichloroethane
1,2-Dichloropropane'
Tetrachloroethene"
40003
3
3003
5
5
5

NOTES:
1 The COCs in this column are cancer-causing substances unless otherwise noted. The risk-
based concentrations represent a 106 risk level (or an increased chance of one additional
case of cancer in one million people). Exception: The risk level for arsenic at the MCL
level is 2.5 x 103.
2 EPA standard from Lead and Copper Rule, 56 FR, June 7, 1991.
This chemical is a non-cancer causing substance. The performance standard is based on a
concentration which is not likely to produce harmful health effects (HQ=1).
4 The health/risk -ba.sed number is based on the toxicity of alpha-BHC.
Performance standard is risk-based in absence of MCLs.
                                                22

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The performance standards for groundwater are contained in Table 6-9.  The groundwater performance
standards have been generated to ensure localized isolation and treatment of contaminated groundwater
which exceeds the health-based groundwater performance standards established at the lxlO'e risk level.
The IxlO"6 risk level is protective but can only be achieved in light of the current surface off-site soils
removal, the future OU #2 which will address on site soils and other media, the limited potential of
groundwater use currently and in the future, continued local resident's municipal water use in the area,
and the deed  restrictions that are planned for this operable unit.

Health based performance standards for groundwater protection are based on a IxlO"6 risk level for
carcinogens and a hazard quotient of 1 for noncarcinogens.  Setting the performance standards for the
groundwater contamination at the IxlO'6 risk level is consistent with the NCFs requirement for
establishing performance standards  within the 1x10'* to IxlO'6 range.  The performance standards for
groundwater are listed in Table 6-9.

The groundwater performance standards will be applied at the Site to  ensure that any future
groundwater consumers will not be exposed to unacceptable concentrations of Site-related chemicals in
the groundwater.  The concentrations presented represent either the regulated  Maximum Contaminant
Level (MCL) or the health-based performance standards which was developed for those chemicals of
concern which do not have MCLs.
7.0
DESCRIPTION OF ALTERNATIVES
The following is a description of remedial alternatives evaluated to provide a range of cleanup options for
the Woolfolk Site. All actions presented below would be conducted in a manner that minimizes impact in
accordance with regulations. The alternatives for the remediation of contaminated groundwater in OU
#1 at the Woolfolk Chemical Works Site were evaluated in the Feasibility Study Report and presented in
the Proposed Plan for the Site.
Table 7-1: Operable Unit #1 Alternatives
Alterna-
tive
Number
1
2
Medium


Groundwater
Groundwater
v Remedial Action


No Action
Pump Surficial and Upper Cretaceous Aquifers, On
site treatment, Discharge to POTW and Institutional
controls.
Present
Cost
(millions)
$0
$2.3
The assembled site-specific alternatives represent a range of distinct waste-management strategies
addressing the human health and environmental concerns posed by Operable Unit #1.  Although the
selected remedial alternative will be further refined during the predesign and design phases, the analysis
presented below reflects the fundamental components of the various alternatives considered feasible for
this Site.
7.1
ALTERNATIVE 1: No-action
The no action alternative is carried through the screening process as required by the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP). This alternative is used as a baseline for
comparison with other alternatives that are developed. Under this alternative, EEA would take no
further action to minimize the impact the contamination  of groundwater has oh the area.  Groundwater
                                               23

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contamination would remain and possibly migrate.  There is no cost associated with this alternative
since no additional activities would be conducted.

7.2      ALTERNATIVE 2: Groundwater Extraction, Treatment, and Discharge to POTW

This alternative requires the design, construction, and  maintenance of an extraction and treatment
system that includes extraction wells, iron co-precipitation and sand filtration with activated-granular
carbon units as a polishing unit, if necessary, discharge to a publicly-owned treatment works (POTW),
and institutional controls.  If a POTW permit can not be obtained a National Pollutant Discharge
Elimination System (NPDES) permit or an on  site infiltration gallery will be pursued.  Installation of
extraction wells into the surficial aquifer, the UC Water Table aquifer, and the UC Confined aquifers
will control groundwater flow and prevent contaminant migration. Pumping the surficial aquifer will
intercept contamination that would otherwise migrate downward into the Upper Cretaceous aquifers.
Meanwhile pumping the Upper Cretaceous Water Table and Confined aquifers will reduce the
contaminant mass limiting further degradation of that  zone and limit downward migration of
contaminants to the Tuscaloosa Aquifer.  The extraction and treatment system will be operated until
performance standards, as identified in Table 6-9, are met.

Groundwater migrating from the facility  in both the surficial, the  UC Water Table, and the UC Confined
aquifer will be intercepted and extracted.  The number  of wells and their location will be optimized to
capture all  water migrating laterally and vertically in the surficial, water table, and the confined
aquifers.

Groundwater extracted from the surficial aquifer and UC Water Table aquifer will be treated to remove
arsenic using iron co-precipitation and sand filtration.  After treatment it would be discharged  to the
City of Fort Valley POTW along  with the groundwater from the Upper Cretaceous confined aquifer.
Arsenic in the surficial and UC Water Table aquifers is possibly the only contaminant of sufficient
concentration to merit treatment prior to discharge. Verification of the contaminant levels throughout
the remediation for all  of the aquifers will be required.  Preliminary discussion with both the Georgia
EPD and the City of Fort Valley have indicated support with limiting on site treatment of groundwater
of sufficient concentration.  Formal  approval must be obtained prior to discharge from both parties.  If
needed, an  activated carbon unit will be added as a polishing unit but is not part of the current cost
estimates.  The system will be housed in  an adequately sized treatment building and have the  proper
controls to allow it to function with  minimal operator attention.

If approval from the  EPD or the  City of Fort Valley with respect to the discharge of wastewater to the
POTW is unattainable, an NPDES permit for surface water discharge must be sought.  If a NPDES
permit is not attainable on site an infiltration gallery will be investigated for the discharge of treated
water.  Should either of these be required, changes will be implemented  to the treatment process of
groundwater from all the aquifers in order to comply with discharge requirements.

During the remedial  design  for this project, field scale treatability studies will be conducted to
determine the effectiveness of the treatment system. The treatment process of the remedy will be used if
proven effective by these treatability studies in reducing the contamination in the extracted water.
Other  treatment technologies for groundwater may be  found to be effective and may be implemented if
the timeframe for remediation may  be retained, however, a ROD amendment or an Explanation of
Significant Differences (ESD) may be required. Final methods will be determined during the remedial
design of the remedy.

Institutional controls of this alternative includes limiting access to contaminated groundwater, -
monitoring groundwater quality, and abandoning selected monitoring wells.  Although these controls
help reduce risks associated with contact with  contaminated groundwater, they do not reduce the
contamination or achieve the remedial action objectives. This alternative will limit access to
contaminated water by future users. On the basis of the groundwater-use survey performed during the
RI, there are no known  current users of the surficial aquifer, Upper Cretaceous water table, nor the
confined aquifers within one-half mile of the Woolfolk Facility.
                                                24

-------
Groundwater, including extraction from the city wells, will be monitored quarterly as a part of the
implementation of this alternative to determine the effectiveness of the remedy. Abandoning existing
contaminated wells which will no longer be of use will limit access to contaminated groundwater.  Some
wells at the facility may be allowing contaminants to migrate downward into deeper parts of the
hydrogeological system, thereby causing the contamination to spread.  These wells will be abandoned in
a manner that would prevent the contamination and will comply with  State regulations applying to
closure of abandoned wells.

Operation and maintenance of the systems will also be required. This shall include development and
implementation of an Operation and Maintenance Plan. The plan will address all aspects of the system's
operation and the laws governing O&M activities at Superfund sites. It shall also define  responsibilities,
timeframes, procedures, and schedules for these activities. It is estimated that the extraction and
treatment system for groundwater may potentially operate for 68 years to achieve all performance
standards. The source removal activities under OU #2 may reduce the timeframe for groundwater
remediation under this OU.
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 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 remediation of the site.

EPA evaluated each alternative by the standard criteria shown in Table 8-1 to determine which would
best reduce risks posed by the Site. To be considered as a remedy, the alternative must protect human
health and the environment, and comply with applicable or relevant and appropriate requirements
(ARARs}.  Section 121(d) of CERCLA, as amended by SARA, states that any remedial action selected for
a site must attain, at a minimum, a degree of remediation that ensures protection of human health and
the environment. In addition, levels or standards of control under federal or state environmental laws
(ARARs) must be attained with respect to any hazardous substance, contaminant or pollutant remaining
on-site at the completion of remedial actions.  Potential ARARs for the Site are listed in Section 8.2.

The selected alternative must meet the threshold criteria of overall protection of human health and the
environment and compliance  with all ARARs (or be granted a waiver for compliance with ARARs).  Any
alternative that does not satisfy both of these requirements is not eligible for selection. The Primary
Balancing Criteria are the technical criteria upon which the  detailed analysis is primarily based. The
final two criteria, known as Modifying Criteria, assess the public's and the state agency's acceptance of
the alternative. Based on these final two criteria, EPA may  modify aspects of a specific alternative.
                            Table 8-1: Breakdown of Evaluation Criteria
    THRESHOLD CRITERIA
                            PRIMARY BALANCING
                                  CRITERIA
   MODIFYING CRITERIA
  -Overall protection of human
  health and the environment
                         -Long-term effectiveness
-State acceptance
  -Compliance with ARARs (or
  invoking a waiver)
                         -Reduction of toxicity, mobility,
                         or volume
-Community acceptance
                                  -Short-term effectiveness
                                  -Implementability

                                  -Cost
                                               25

-------
The following analysis is a summary of the evaluation of alternatives for remediating the groundwater
contamination at the Woolfolk 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 would provide no protection from  the present contamination  levels. Taking no action at
the site in regards to groundwater will allow contamination to continue to migrate both laterally and
vertically. Either of these migration  pathways has the potential to contaminate the city water system.
Taking no action  would also not lessen the potential on site residents from coming in  contact with the
groundwater contamination.  Alternative #2 would provide adequate protection of human health if the
alternative components are designed, constructed, operated, and maintained properly by extracting,
treating, and restricting use of contaminated groundwater until performance standards are met.

8.2      COMPLIANCE WITH ARARs

The evaluation of the ability of the alternatives to comply with ARARs includes a review of chemical-
specific, action-specific, and location-specific ARARs.  The requirements of federal and state laws are
identified and applied to remedial actions as ARARs using the approach outlined in the EPA's CERCLA
Compliance with Other Laws Manual (EPA/540/G-89/006, August 1988).

Applicable requirements are those cleanup standards, standards of control, and other substantive
environmental protection requirements, criteria,  or limitations promulgated under federal or state law
that specifically address a hazardous substance, pollutant or contaminant, location, or other
circumstances at a CERCLA site.  Relevant and appropriate requirements are those cleanup standards,
standards of control, and other substantive environmental protection requirements, criteria, or
limitations promulgated under federal or state law that are not  directly applicable to a hazardous
substance, pollutant or contaminant,  location, or other circumstances at a CERCLA site but address
problems or situations  sufficiently similar to those encountered  at the CERCLA site, and whose use is
well suited to the particular site. The judgement of the relevance and appropriateness of a requirement
to a remedial action depends on the substances in question, the  physical nature of the site, or other
circumstances at the site.

In order  to comply  with CERCLA  requirements, selected remedial actions must attain ARARs unless a
waiver is invoked. Performance standards for a remedial action will generally be based on chemical-specific
and location-specific ARARs or health-based levels.

In the event that  an ARAR does not exist,  other pertinent guidelines and standards should be considered.
These are commonly referred to as To-Be-Considered (TBC).  Risk-specific  doses (RSDs), reference doses
(RFDs), health advisories (HAs) and state and federal guidelines and criteria,  etc. are example TBCs.

Alternative #1 d,oes  not meet ARARs.  For example, Maximum Contaminant Levels (MCL)  are not met by
Alternative #1'.  The performance standards (Chemical-specific  ARARs), presented in Table 6-9, lindane
(gamma-BHC) is  the MCL of 0.2 parts per billion (ppb).  The  observed concentration of lindane in the
surficial aquifer, presented in Table 6-1, is 8.3 ppb.  Alternative #2 will meet all identified ARARs. In the
above example, pumping the defined aquifer until the performance  standards have been met will meet the
identified ARAR.  All identified ARARs, including those for the  State, for Alternative #2 are presented in
Appendix B.

Primary Balancing Criteria

8.3      LONG-TERM EFFECTIVENESS

Under Alternative #1, contamination would remain at its current  levels-of effectiveness or would worsen with
time.  As shown above, migration of the contamination cannot be prevented in the long term should no action


                                                26

-------
be taken. Alternative #2 would permanently reduce contamination of ground water to safe levels and would,
therefore, be an effective long-term and permanent remedy if the alternative components are designed,
constructed, operated, and maintained properly.

8.4      REDUCTION OF TOXICITY. MOBILITY. OR VOLUME

Alternative #1 would not reduce toxicity, mobility or volume. The levels of contamination will remain toxic
should no action be taken to remove them from the aquifers. The potential for migration and the overall
volume will remain the same or increase should no action be taken. Alternative #2 would pump, collect and
treat the groundwater beneath the facility in the surficial and Upper Cretaceous aquifers. The extraction
scheme will intercept contamination migrating off the facility and create an upward gradient  from  the
underlying Tuscaloosa aquifer preventing contamination of this zone, therefore, reducing mobility.  Toxicity
and volume will be reduced by treatment of extracted groundwater using iron co-precipitation, sand
filtration, and possibly activated carbon as a polishing unit.

8.5      SHORT-TERM EFFECTIVENESS

Alternative #1 would not require construction  or excavation that would cause a health risk to  workers,
therefore, Alternative #1 is effective in the short-term. However, Alternative #1 would be less effective in
achieving the overall groundwater performance standards in the shortest time period.  Alternative #2 will
induce a temporary increase in short-term risk by potentially causing a temporary increase in fugitive dust
generation during normal remedial construction activities. However, dust control measures will be instituted
in order to lessen the effect of any dust. Alternative #2 also increases the possibility of a construction related
accident. Safety practices adequately followed during construction  will limit the number of accidents which
may occur during the implementation of Alternative #2.

8.6      IMPLEMENTABILITY

Alternative #1 would require no action to implement. Technological expertise, services, equipment and
materials are adequately available for the implementation of Alternative #2.  Iron co-precipitation, sand
filtration, and activated carbon systems are available or easily designed for implementation at the  site. The
pump and treat technology has been extensively used in remediation activities in the past. Drilling and
installing wells at the facility has been difficult due to drilling conditions but wells have been installed in
all aquifers in the past. The treatment plant and extraction system piping would also need to be  placed so
as not to effect activities related to OU #2.

8.7      COST

Alternative #1 would not require any additional cost.  The present cost of Alternative #2 is estimated to be
$2,390,000.  These  costs include groundwater extraction, institutional controls, groundwater treatment,
operation and maintenance during the implementation of the alternative  as well as post remediation
monitoring.  While Alternative #2 is more costly, the added effectiveness justifies the additional  cost.


Modifying Criteria

8.8      STATE ACCEPTANCE

The State of Georgia, as represented by the Georgia Environmental Protection Division (GaEPD), has been
the support agency during  the Remedial Investigation and Feasibility  Study process  for the Woolfolk
Chemical Works site. In accordance with 40 CFR 300.430, as the support agency, GaEPD has provided-input
during this process. The State of Georgia concurred with the selected remedy on March 23,  1994. The letter
of concurrence is in Appendix C.
                                                27

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 8.9       COMMUNITY ACCEPTANCE

 EPA has determined community acceptance of the preferred alternative after considering comments received
 during the public comment process associated with the Proposed Plan. EPA has included a Responsiveness
 Summary in Appendix A of this ROD, which addresses those comments. The community seems generally
 supportive of EPA's selected remedy.

 9.0       SUMMARY OF SELECTED REMEDY

 Based upon consideration of the requirements of CERCLA, ^he NCP, the detailed analysis of alternatives
 and public and state comments, EPA has selected a remedy for OU #1 at the Site. The selected remedy is
 Alternative #2.  The area of concern at this Site for OU #1 is defined as the area where the level of
 contamination is above the performance standards set forth in Section 6.6  of this ROD. The extent of the
 contamination will be further defined during the Remedial Design/Remedial Action phases. The selected
 remedy provides for the following:

   1) Further delineation of the extent and extraction of contaminated ground water from the surficial, Upper
   Cretaceous (UC) water table, and UC confined aquifers.

   2) Treatment of the groundwater using iron co-precipitation and sand filtration with activated  carbon
   adsorption as polishing steps, if needed.

   3) Discharge to a Publicly-Owned Water Treatment Works (POTW) with  a contingency plan to include a
   National Pollutant Discharge Elimination System (NPDES) permit for surface water discharge or possibly
   an  infiltration gallery should an NPDES permit be unattainable.

   4)  Institutional Controls,  such  as  deed restrictions  limiting the  use  of groundwater at the site until
   performance goals are met.

   5)  Groundwater monitoring of specific wells, including the city wells, to be  further defined  during
   Remedial Design/ Remedial Action  (RD/RA) and abandonment of all others monitoring wells used during
   the RI/FS.

   6) Operation and Maintenance  of the full  system to  be defined by an  O&M Plan developed during the
   Remedial Design.

At the completion of this remedy,  the risk associated with this Site  has  been calculated at 106 for cancer
risks and a Hazard quotient of 1, which is determined to be protective of human health and the environment.
The total present cost of the selected remedy, Alternative #2, is estimated  at $ 2,300,000 for capital costs
and $90,000 for O&M costs over the next thirty years.  O&M costs assume an O&M period which  will be
further defined during the RD/RA.

A- GROUNDWATER REMEDIATION  .                                            '   .

Groundwater remediation will address the contaminated groundwater in the Surficial aquifer and the Upper
Cretaceous aquifers at the  Site.   Groundwater  remediation will include extraction of contaminated
groundwater, treatment, and discharge  to a Publicly-Owned Treatment Works (POTW).

A-l. The major components of groundwater remediation to" be implemented include:

 •  Fencing of the Site and treatment facility;
 •  Extraction and on site treatment of groundwater by iron co-precipitation and sand filtration treatment
   with granulated carbon adsorption as a polishing step if needed;
 •  Drainage controls to divert runoff from Site;


                                             •  28'

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• Institutional controls, such as deed and land-use restrictions;
• Operation and Maintenance Plan;
• Groundwater monitoring, including City of Fort Valley Water Wells.

Air emissions during the cleanup will be monitored to ensure safety of workers and residents near the Site.


A.2. Extraction, Treatment, and Discharge of Contaminated Groundwater

This remedy requires the construction and maintenance of an extraction and treatment system that includes
extraction wells, iron co-precipitation and sand filtration with activated-granular carbon units as a polishing
unit, if necessary, discharge to a publicly-owned treatment works (POTW), and institutional controls.  If a
POTW permit can not be obtained a National Pollutant Discharge Elimination System (NPDES) permit or
an on site infiltration gallery will be pursued. Installation of extraction wells into the surficial aquifer, the
UC Water Table aquifer, and the UC  Confined aquifers will control  groundwater flow  and prevent
contaminant migration. Pumping the surficial  aquifer will intercept contamination that would otherwise
migrate downward into the Upper Cretaceous aquifers. Meanwhile pumping the Upper Cretaceous Water
Table and Confined aquifers will reduce the contaminant mass limiting further degradation of that zone and
limit downward migration of contaminants to the Tuscaloosa Aquifer. The extraction and treatment system
will be operated until performance standards, as identified in Table 9-1, are met.

Groundwater migrating from  the facility in both the surficial, the UC Water Table, and the UC Confined
aquifer will be intercepted and extracted.   The number of wells and their location will  be optimized to
capture all water migrating laterally and vertically in the surficial, water table, and the confined aquifers.

Groundwater extracted from the surficial aquifer and  UC Water Table aquifer will be treated to  remove
arsenic using iron co-precipitation and sand filtration.  After treatment it would be discharged to the City
of Fort Valley  POTW along with the groundwater from the  Upper Cretaceous confined aquifer. Quarterly
verification of the contaminant levels throughout the remediation for  all of the aquifers will be required.
Preliminary discussion with both the State of Georgia and the City of Fort Valley have indicated no problems
with limiting treatment to groundwater which does not meet the performance standards.  Formal approval
must be obtained prior to discharge from both parties.  If needed, an activated carbon unit will be added as
a polishing unit but is not part of the current cost estimates. The system will be housed in  an adequately
sized treatment building and have the proper controls to allow it to function with minimal operator attention.


If approval from the State or the City of Fort  Valley with respect to  the  discharge of wastewater to the
POTW is unattainable, an NPDES permit for surface discharge must be sought. If a NPDES permit is not
attainable on site an infiltration gallery will be investigated for the discharge of treated water. Should either
of these be required, changes will be implemented to  the treatment process of groundwater from all the
aquifers in order to comply with discharge  requirements.

During the remedial  design for this project, field scale  treatability studies will be conducted to determine
the effectiveness of the treatment  system.  The treatment process outlined above will be used if proven
effective by these treatability  studies  in  reducing the contamination in the extracted water.   Other
treatment technologies for groundwater may  be found to be effective and may be implemented if the
timeframe for remediation may be retained, however, a ROD amendment or an Explanation of Significant
Differences (BSD) may be required. Final methods will be determined during the remedial design of the
remedy.

Institutional controls of this alternative includes limiting access to contaminated groundwater, monitoring
groundwater quality, and abandoning selected monitoring wells. Although these controls help reduce risks
associated with contact with contaminated groundwater, they do not reduce the contamination or achieve
the remedial action objectives. This alternative will limit access to contaminated water by future users. On


                                                29                                               '

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the basis of the groundwater-use survey performed during the RI, there are no known current users of the
surficial  aquifer, Upper Cretaceous water table, nor the confined aquifers  within one-half mile  of the
Woolfolk Facility.

Groundwater,  including extraction  from  the city wells,  will be monitored  quarterly as a part  of the
implementation of this alternative.  Abandoning existing contaminated wells which will no longer be of use
will limit access to contaminated groundwater.  Some wells at the facility may be allowing contaminants to
migrate downward into deeper parts of the hydrogeological system, thereby causing the contamination to
spread.  These wells will be abandoned in a manner that would prevent the contamination and will comply
with State regulations applying to closure of abandoned wells.

Operation and maintenance of the  systems  will  also be required.  This shall include development and
implementation of an Operation and Maintenance Plan. The plan will address all aspects of the system's
operation and the laws governing O&M activities at Superfund sites.  It shall also define responsibilities,
timeframes, procedures, and schedules for these activities. It is estimated that the extraction and treatment
system for groundwater have to operate for 68 years to achieve all performance standards.
The source removal activities under OU #2 may reduce the timeframe required for groundwater remediation
under this operable unit.

A-3.  Performance Standards

a. Treatment Standards

Groundwater shall be treated until the performance standards  set forth in Table 9-1 are attained at the wells
designated by EPA.

b. Discharge Standards

Discharges from the groundwater treatment system shall comply with all ARARs, including, but not limited
to, substantive requirements of the NPDES permitting program under the Clean Water Act, 33 U.S.C. {1251
et seq., and all effluent limits established by EPA).  All identified ARARs are presented in Appendix B of
this ROD.

c. Design Standards

The  design, construction  and operation  of  the  groundwater treatment  system shall  be conducted in
accordance with all ARARs, including but not limited to the RCRA requirements set forth in 40 C.F.R. Part
264 (Subpart F-Groundwater monitoring requirements). All identified ARARs are presented in  Appendix
B of this ROD.

d. Other Standards

In addition, the selected remedy shall comply with those ARARs identified  in Section 10.2 (Attainment of
ARARs) and in Appendix B of this ROD.


B. Compliance Monitoring

Groundwater monitoring shall  be conducted on- and  off-site.   After demonstration of compliance with
Performance Standards, the groundwater shall be monitored for five years.  If monitoring indicates that the
Performance Standards set forth in Paragraph A3(a) are being exceeded at any time after pumping has been
discontinued, extraction and treatment of the groundwater will  recommence until the Performance Standards
are once again achieved.
                                               30

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TABLE 9-1: GROUNDWATER PERFORMANCE STANDARDS
Micrograms per liter lug Hi or parjs per billion Ippbl
Chemical
Standard1
Inorganic
Arsenic
Cadmium
Chromium
Lead*
Manganese"
50
5
100
15!
2003
Pesticides
alpha-BHC'
beta-BHC*
delta-BHC'
gamma-BHC
Dieldrin'
0.01
0.05
0.01"
0.2
0.005
Chemical
Standard1
Semi-Volatile Organic Compounds
bis(2-ethylhexyl)phthalate'
6
Volatile Organic Compounds
Acetone*
Chloroform'
Carbon Disulfide"
1,2-Dichloroethane
1,2-Dichloropropane*
Tetrach loroethen e
40003
3
3003
5
5
5

NOTES:
1 The COCs in this column are cancer-causing substances unless otherwise noted. The risk-
based concentrations represent a 10"6 risk level (or an increased chance of one additional
case of cancer in one million people). Exception: The risk level for arsenic at the MCL
level is 2.5 x 10'3.
'J EPA standard from Lead and Copper Rule, 56 FR, June 7, 1991.
3 This chemical is a non-cancer causing substance. The performance standard is based on a
concentration which is not likely to produce harmful health effects (HQ=1).
4 The health/risk -based number is based on the toxicity of alpha-BHC.
Performance standard is risk-based in absence of MCLs.
This remedy will achieve substantial risk reduction through treatment of the principal threat at OU #1 of
the Woolfolk Chemical Superfund Site. The principal threat is the groundwater contamination for this OU.
Soils, structures, surface/storm water,  sediment, and air will be addressed in OU #2.

Air emissions from the Site will be monitored to ensure compliance with the Clean Air Act.  Air monitoring
will be conducted to ensure that contaminant concentrations do not exceed levels considered to be safe for
human health. If levels are exceeded, mitigative procedures such as vapor capture will be employed to
prevent harmful levels of air emissions from  leaving the Site.

The  selected alternative for OU #1  of the Woolfolk Chemical site is consistent with the requirements of
Section 121 of CERCLA and the NCP. The selected alternative will reduce the mobility, toxicity, and volume
of contaminated groundwater at the Site. In addition, the selected alternative is protective of human health
and the environment, will.attain all Federal and State applicable or relevant and appropriate requirements,
                                                31

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is cost-effective, and utilizes  permanent solutions to the maximum  extent  practicable.   The selected
alternative for OU #1 is consistent with previous and projected remedial actions at the Site.

Based on the information available at this time, the selected remedy represents the best among the criteria
used to evaluate remedies, especially in light of the ongoing removal action  The remedy is believed to be
protective of human  health and the environment, will attain ARARs, will be cost effective, and  will utilize
permanent  solutions and  alternative treatment technologies or resource  recovery technologies  to the
maximum extent practicable.

The goal of this remedial action is to restore the groundwater in the surficial and Upper Cretaceous aquifers
to beneficial use fas  drinking water) at this Site.  The performance standards for this remedial action are
listed in Table 9-1.   Based on information obtained during the remedial investigation, and the  analysis of
all remedial alternatives, the selected remedy will be able to achieve this goal. Groundwater contamination
may be especially persistent in the immediate vicinity of the contaminant's source, where concentrations are
relatively  high.   The  ability  to achieve performance  standards at all  points throughout the area of
attainment, or plume, cannot be determined until the extraction system has been implemented, modified as
necessary,  and  plume  response monitored over time.   If the  selected remedy cannot meet the specified
remediation goals, at any or all of the monitoring points during implementation, contingency measures and
goals  will  be defined and implemented to replace the selected remedy and goals for these portions of the
plume. Such contingency measures will, at a minimum, prevent further migration of the plume and include
a combination of containment technologies,  treatment, and institutional controls.  These measures are
considered to be protective of human  health and the environment, and are technically practicable under the
corresponding circumstances.

The selected1 remedy will  include groundwater extraction and  monitoring,  during which the system's
performance will be carefully monitored on a regular basis and adjusted as warranted by the performance
data collected during operation.  Modifications may include any or all of the following:

• at individual wells where performance standards have been attained, pumping may be discontinued;
• alternating pumping at wells to eliminate stagnation  points;
• pulse pumping to allow aquifer equilibration and  encourage adsorbed contaminants to partition into
  groundwater; and
• installation of additional extraction wells to facilitate or accelerate cleanup  of the contaminant plume.

To ensure that performance standards continue to be maintained, the aquifer will be monitored at least
annually for five years following discontinuation of groundwater extraction for those wells where pumping
has ceased.

The decision to  invoke  any or all of these measures may be made during a periodic review of the remedial
action, which will occur at least every five years in accordance with CERCLA section 121(c) and the NCP.


10.0     STATUTORY DETERMINATION

Under its legal authority, EPA's primary responsibility at Superfund Sites is to undertake remedial actions
that achieve adequate protection of human health and the environment and attain all ARARs. In addition,
Section  121 of CERCLA establishes  several other statutory requirements and preferences.  These specify
that, when complete, the selected remedy must also be cost effective and utilize permanent solutions and
alternative treatment technologies or resource recovery technologies to the maximum extent practicable.
Finally, the statute  includes  a  preference for remedies that employ  treatment that  permanently and
significantly reduce the volume, toxicity, or mobility of hazardous substances as their principal element: The
following sections discuss how the selected remedy meets  these statutory requirements.
                                                 32

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10.1     PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT

The selected remedy protects human health and the environment through isolation and treating a principal
threat remaining at OU #1 of the Site, the contaminated groundwater.  The selected remedy, extraction of
groundwater, provides protection of human health and the environment by reducing, and controlling risk
through treatment, engineering controls and/or institutional controls. The surface and subsurface soils at
OU #1 of the Site are not addressed with this ROD but will be fully remediated through removal actions and
OU #2 activities which  will mitigate these sources of contamination to groundwater.

10.2     ATTAINMENT OF THE APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
         (ARARs)

Remedial actions performed under CERCLA must comply with all applicable or relevant and appropriate
requirements (ARARs) unless a waiver is invoked. All alternatives considered for the Site were evaluated
on the basis of the degree to which they complied with these requirements. The selected remedy  was found
to meet or exceed all ARARs  that have been identified in Appendix B attached to this ROD.

10.3     COST EFFECTIVENESS

The estimated cost of EPA's selected remedy is $2,390,000. 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 increased effectiveness  of the remedy. The selected remedy does cost more than the no
action alternative; however, effectiveness achieved by the remedy justifies the higher cost.  The remedy is
considered cost effective.

10.4     UTILIZATION OF PERMANENT SOLUTIONS TO THE MAXIMUM EXTENT PRACTICABLE

EPA believes the selected remedy is the most appropriate cleanup solution for the Woolfolk Chemical Works
Site and provides the best balance among the evaluation criteria for the remedial alternatives  evaluated.
This remedy provides effective protection in  both the short-term and long-term to  potential human and
environmental  receptors, is implementable, and is cost-effective. The  selected remedy, by pumping and
treating contaminated groundwater until performance standards are met, meets the statutory requirement
to utilize permanent solutions to the maximum extent practicable.

10.5     PREFERENCE FOR TREATMENT AS A PRINCIPLE ELEMENT

The statutory preference for  treatment will be met because the selected remedy treats the contaminated
groundwater which is a principal threat posed by the Site.


11.0     DOCUMENTATION OF SIGNIFICANT CHANGES

There are  no significant changes from the proposed plan.
                                              33

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                APPENDIX A:








          RESPONSIVENESS SUMMARY



       WOOLFOLK CHEMICAL WORKS SITE



OPERABLE UNIT #1: GROUNDWATER CONTAMINATION



     FORT VALLEY, PEACH COUNTY, GEORGIA

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                              RESPONSIVENESS SUMMARY
                          WOOLFOLK CHEMICAL WORKS SITE
                 OPERABLE UNIT #1: GROUNDWATER CONTAMINATION
                        FORT VALLEY, PEACH COUNTY, GEORGIA


The U.S. Environmental Protection Agency (EPA) held a public comment period from January 18,
1994 through February 17, 1994 for interested parties to give input on EPA's Proposed Plan for
Remedial Action at the Woolfolk Chemical Superfund Site in Fort Valley, Peach County, Georgia.
A public meeting was conducted by EPA on February 1, 1994, at the Hunt School Complex in Fort
Valley.  At the meeting EPA presented the Proposed Plan  for the Woolfolk Chemical Works Site,
Operable Unit #1, which was based on the results of the Remedial Investigation and Feasibility
Study (RI/FS).

A responsiveness summary is required to document how EPA addressed citizen comments and
concerns about the Site, as raised during the public comment period.  All comments summarized in
this document have been factored into the final decision of the remedial action for the  Woolfolk
Site.

This responsiveness summary for the Woolfolk Site is divided into the following sections.

       I.      Overview - This section discusses the recommended alternative for remedial action
              and the public reaction to this alternative.

       II.     Background on  Community Involvement and Concerns: This section provides a
              brief history of community interest and concerns regarding the Woolfolk Site.

       III.    Summary of Major Questions and Comments Received During the Public Comment
              Period and EPA's Responses:  This section presents comments submitted during the
              public comment period, and provides the responses to these comments.

       IV.     Concerns to be Addressed in the Future:  This section discusses community
              concerns of which EPA should be aware during remedial design.
I.      Overview

The preferred remedial alternative was presented to the public in a Proposed Plan released on
January 18, 1994. A public meeting was held February 1, 1994 with about 70 people attending.
The selected alternative consists of:

•      Further delineation of the extent and extraction of contaminated groundwater from the
       surficial, Upper Cretaceous (UC) water table, and UC confined aquifers.

•      Treatment of the groundwater using iron co-precipitation and sand filtration with activated
       carbon adsorption as polishing steps, if needed.

•      Discharge to a Publicly-Owned Water Treatment Works (POTW) with a contingency plan to
       include a National Pollutant Discharge Elimination System (NPDES) permit for surface
       water discharge or possibly an infiltration gallery should an NPDES permit be
    ,.   unattainable.

•      Institutional Controls, such as deed restrictions limiting the use of groundwater at the site
       until performance goals are met.
                                           A-l

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 •      Groundwater monitoring of specific wells, including the city wells, to be further defined
       dunng Remedial Design/ Remedial Action (RD/RA) and abandonment of all others
       monitoring wells used during the RI/FS.

 •      Operation and Maintenance of the full  system to be defined by an O&M Plan developed
       dunng the Remedial Design.

 In general, the public was in agreement with EPA on the proposed remedial actions to be taken at
 the Site.
II     Background on Community Involvement and Concerns

EPA has made significant efforts to insure that interested parties have been kept informed and
given an opportunity to provide input on activities at the Woolfolk Chemical Works site.  EPA has
been working with the community surrounding the Woolfolk Chemical Works since 1990.  In
September 1990, press releases informing the community about the NPL listing of the site were
released.  Subsequent interviews were held that Fall to develop a Community Relations Plan
(CRPi. The information repository was established in  October 1990, at the Thomas Public library.
213 Persons Street, Fort Valley, Georgia.  The CRP, which was finalized in November 1990, has
been placed in the information repository.  In January 1991. EPA held a public meeting to discuss
the start of the RI/FS.

Most recently, in July 1993, EPA issued a press release and fact sheet on the findings of the RI
study regarding soil contamination and health precautions recommended by the Agency for Toxic
Substances and Disease Registry (ATSDR).  On August 2-3, 1993, EPA conducted door-to door
visits to the potentially affected residents to further distribute the fact sheet and extend our
invitation to an availability session.  The availability session, held on August 3, 1993 discussed the
results of the RI study and ATSDR's recommendations for health precautions. Fifty people
attended the session which was hosted by EPA, GaEPD, and ATSDR. Representatives of CGC
were also present.

EPA's Emergency Response and Removal Branch  is currently working to define the extent of off
site contamination, excavating contaminated soils from residential properties, and  supervising the
destruction of a site dioxin  contaminated building (Building E). Two sampling events of soils in
resident's yards have occurred to date with  results subsequently explained  in meetings with the
mayor and the public.  CGC is complying with an  Unilateral Administrative Order (UAO)
requiring the disassociation of the affected residents from contaminated soils and
destruction/removal of Building E.

The Feasibility Study, the Proposed Plan, and the Administrative Record (AR> for OU#1 were
released to the public  on January 18, 1993.  These two documents were made available in both the
AR, maintained in the EPA Region IV Docket Room, and the information repository at the site.
The notice of availability of these documents and'the AR was published on  January 18, 1994  in
various local publications.  A public comment period was held from January 18, 1993 to February
17, 1994.  In addition  a public meeting was held on February 1, 1994.  At this meeting
representatives from EPA, ATSDR, and the State  of Georgia answered questions about problems at
the site  and the remedial alternatives under consideration. Responses to the comments received
dunng this comment period are presented in the responsiveness summary in Appendix A of this
document.
                                             A-2

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III.    Summary of Major Questions and Comments Received During the Public Comment Period
       and EPA's responses
Comment 1:   Concern was raised about the data submitted by the PRPs regarding the testing of
              the City Wells. There was also a concern that the City Wells had been
              contaminated at one time.

EPA Response:

       Canadyne-Georgia Corporation (CGC) has sampled the City Wells and wells screened in
the Tuscaloosa aquifer located on-site since  1984. The results of the sampling from those wells has
never shown there to be contamination above action levels in any of the City Wells. In December
1985, reports from an October sampling event showed levels of lead in the City Well #1. These
levels were 14 parts per billion (ppb) and 3 ppb of lead which are below current action levels of 15
ppb.  It should be noted that this action level has been revised from 50 ppb to 15 ppb in the Lead
and Copper Rule, 56 FR, June 7, 1991.

       Regardless of the fact that the levels were below the action level, the wells were re-sampled
in  December, 1985 the results of which were published in a report dated February, 1986 which
showed no levels of lead in this well. The explanation given for the lead levels shown in the
December results was that there was a possible Quality Assurance problem. This means that
there may have been another source of lead (i.e. well casing, leaching from the soils, ..) that was
not sufficiently taken into consideration during the sampling event. When these errors occur,
sampling'results are questionable and the best possible action is to re-sample.  Re-sampling of the
City  Wells since 1985 has  not shown levels of any contaminant in the City wells.

       In order for EPA to be certain that the data provided from CGC is accurate?  EPA has  a
number of techniques for assuring that the company is not falsifying its results. One is to sample
along with the company. This technique is called split sampling. An EPA representative is
present at the time of the  sampling event.  In the case of groundwater, when the sample of water
is taken from the well, EPA takes some of it and analyzes it at an independent laboratory.  The
results must be comparable  or EPA requires the company to re-sample.  These techniques have
been used to assure quality  sampling results from the City Wells.  Acceptance between EPA's
sampling and the Company's data has been good.


Concern #2:   Why was the City  of Fort Valley Well #1 capped.

EPA Response:

       The Superfund program does not involve itself with the day to day operation of a municipal
water system unless it has been shown that this "system is being affected by a Superfund site.  The
City of Fort Valley Water Wells have shown no contamination and hence no action is required by
the water treatment plant.  In discussions with the Fort Valley Utility Commission regarding the
closure of City Well #1, it has been  indicated that the well was closed due to structural problems
and not contamination from the Woolfolk Superfund site.


Concern #3:   Concerns were raised about  significant time requirements for remediation of the
              groundwater.

EPA Response:

       Remediation of groundwater has been known to take significant amounts of time.  The
pump and treat technology is limited in  the rates arid amounts of water that can be pumped and


                                            A-3

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extracted.  Extraction levels can be very slow due to the nature of the soils and the amount of
water flowing through the area. What is of most concern to EPA is that the groundwater
contamination is not allowed to spread further which would result should  nothing be done.

       The time estimates for remediation of the  groundwater are as follows: Surficial Aquifer is
18 years; Upper Cretaceous Water Table is 68 years; and the UC Confined Aquifer is 30 years.
These are estimated times for remediation which will be revised during the design phase after we
gather more information about  the system. These timeframes may also be reduced by the source
control measures implemented under OU #2.  As alluded to above, the system will prevent further
spread of contamination by drawing the contamination  back toward the wells. This will also
prevent downward migration to the Tuscaloosa aquifer  preventing contamination of the City Water
system. Source removal activities under Operable Unit (OU) #2 will reduce the time required to
remediate the groundwater further protecting the City Water system.


Concern #4:   What are the contamination levels9

EPA Response:

       Results of testing of the groundwater are summarized in Table 6-1 of the  Record of
Decision.  Levels in this table indicated in italic boldface are actual maxjmum concentrations
detected during the testing.  Other levels presented are estimates derived  from mathematical
calculations completed for the Baseline Risk Assessment. As an example the level of Aresenic
found in the surficial aquifer is  5,920 parts per billion (ppb).  The performance standard (Table 6-
9) which the treatment is required to meet is 50 ppb.


Concern #5:   Will EPA allow comments on the design of the groundwater remediation.

EPA Response:

       EPA made  available $50,000 through its TAG grant process for the Community action
group to hire an independent consultant to review the files related to the Site. The remedial
design will be included as part of these files.  Although  EPA is not required to have a formal public
meeting, EPA will  continue to consider all requests for meetings on an individual basis. EPA
regards public comments as an  important part of the process for remediation  of the Site.

Concern #6:   Concern was raised about the former remjection wells at the site.

EPA Response:

       The reinjection  wells used by the plant prior to the removal.actions taken by CGC in 1986
have been, abandoned and meet standards established by the State of Georgia, Water Well
Standards Act of 1985, Section 12-5-134 Standards of Wells and Boreholes, Paragraph 6(1). The
paragraph  states that "abandoned individual, non-public, public, irrigation and industrial wells
shall be filled, sealed, and plugged by a water well contractor licensed by the council."  The wells
were closed by Greene's Water Wells, Inc., under direction of Jarrell  Greene-Georgia State License
#29.
Concern #7:   A comment was raised about the groundwater beneath the drainage ditch.

EPA Response:

       Groundwater beneath the drainage ditch has not been sampled though is not believed to be
of concern.' Groundwater contamination is caused by levels of concentration deposited ic a large


                                            A-4

-------
volume of soil.  Though the levels of the contamination in the ditch are elevated, the volumes are
considered to be small and hence not of concern for the groundwater.  The levels are of concern to
the children who may be exposed while playing in the ditch and also the environmental receptors
(aquatic biota) in and around the ditch. It is for these reasons that the ditch is being investigated
through the removal action as part of the Unilateral Order for off-site soils issued by EPA to CGC
on December 1, 1993.


Concern #8:   A concern was raised that soil remediation will protect the underlying groundwater,
              and thus groundwater remediation to MCLs or health-based concentrations in the
              surficial (perched water table) aquifer is unnecessary.

EPA Response

       The remediation of groundwater contaminant source areas is designed to minimize the
time required for groundwater remediation in all aquifers beneath the site, including the surficial
aquifer. The site (source area) remediation under OU #2 .will ultimately protect the deeper
aquifers.  However, using the logic expressed by this comment, one can make the argument that
because the source area is being remediated under OU#2 to levels which should cause no further
groundwater degradation, it is unnecessary to conduct any groundwater remediation at all.  This is
counter to EPA's position, namely, that:

       •       Current levels of groundwater contamination exceed health  based and MCL
              concentrations and are therefore unacceptable.

       •       The groundwater remedial action at this site should include active remedial
              measures in all aquifers containing a current or potential source of drinking water,
              to attain MCLs.  This approach is in accordance with EPA regulations which
              specify that MCLs are the  relevant and appropriate standards to be attained by the
              groundwater remedial action for all current or potential sources  of drinking water,
              and reflects EPA's position that absence of such active remedial  measures  will
              likely not result in attainment of the MCLs within an acceptable time frame.

                                           \
Concern #9:   The Point of Compliance should be at the Site Boundary.

EPA Response:

       The commenter believes that a "point of compliance" for groundwater should be established
at the Woolfolk property boundary. EPA defines an "Area of Attainment" for groundwater
remedial  actions as any points outside the area of waste remaining in place, and up to the
boundary of the contaminant plume (EPA/540/G-88/003, OSWER Directive  9283.1-2, December,
1988, Guidance on Remedial Actions for Contaminated Groundwater at Superfund Sites.  EPA's
goal is  to reach applicable or relevant and appropriate (ARARs) for groundwater -within this "Area
of Attainment" as rapidly as possible, consistent with engineering constraints and with site specific
conditions. While the groundwater within the site boundary is not expected to be utilized as a
drinking  water source for the foreseeable future, EPA believes that in the absence of active
groundwater remediation throughout the area where groundwater is now contaminated, it will
require an excessively long period of time for groundwater remedial action  objectives to be
attained.  Regardless of the point of compliance, active groundwater remedial action across the
area of groundwater contamination would reduce the time for the groundwater  remedial action to
attain the groundwater remedial action objectives.  CGC cited a review of Region  IV Records of
Decisions that indicates "...at two-thirds of the sites discussed, the point of compliance was
designated to be the site or property boundary or the edge of a waste management unit...".
Designating the edge of a waste management unit or waste management area as a groundwater
point of compliance  would be consistent with the referenced EPA guidance  document, and with the


                                            A-5

-------
 concept of a groundwater compliance point in the uppermost aquifer beneath a site, as it is
 established by RCRA regulations (40 CFR Part 264 §264.95). Designating the site property
 boundary as the point of compliance is not consistent with the referenced EPA guidance, nor with
 the concept of a compliance point as it is used in the RCRA program, nor with EPA's intent to
 restore groundwater quality within a time frame that is reasonable.  Defining the entire site as a
 "waste management area" is inappropriate; however, for wastes which are left in place at the site
 (i.e. landfilled).  EPA would not require groundwater compliance monitoring beneath the wastes.


 Concern #10:   There is insufficient yield in the Surficial Aquifer to qualify as a Usable Dnnking-
               Water supply.

 EPA Response:

        The commenter contends that groundwater in the surficial  aquifer is not a potential source
 of drinking water because of the probable low yield  of this aquifer.  EPA has made an evaluation of
 the potential yield in the surficial aquifer and has determined that for at least some parts of the
 surficial aquifer beneath the facility, it is probable that a sustained yield  of 150 gallons per day is
 attainable.  This yield  is the cutoff point for a minimum yield of a Class II groundwater  under
 EPA's groundwater classification system (in Guidelines for Groundwater Classification under the
 EPA Groundwater Protection Strategy, USEPA 1986).  The preamble to the National Oil and
 Hazardous Substances Pollution Contingency Plan (40 CFR Part 300) states on  page 8732 (Federal
 Register Volume 55, Number 46, March 8, 1990, page 8732) "EPA's Superfund program uses EPA's
 Groundwater  Protection Strategy as guidance when determining the appropriate remediation for
 contaminated groundwater at CERCLA sites." Based upon this citation and the minimum yield
 criterion,'EPA considers that some of the groundwater in the surficial aquifer is a potential source
 of drinking water where MCLs are ARARs. Because all groundwater in the surficial aquifer is in
 the same "groundwater unit", as this term is defined in the referenced EPA groundwater
 classification document, an equivalent level of protection is necessary for the entire volume of
 surficial aquifer groundwater.   EPA does acknowledge  that the modeling analysis of the  potential
 yield from  the surficial aquifer  is not absolutely conclusive with regard  to the potential yield  of the
 aquifer. If, during the groundwater remedial action, long term groundwater withdrawal from the
 surficial aquifer demonstrates that EPA should not  consider the surficial  aquifer groundwater as a
 potential source of drinking water, or if impracticability of attaining MCLs in the surficial aquifer
 groundwater is demonstrated, then  remediation of the  surficial aquifer  groundwater to drinking
 water standards may not ultimately be required.  However, for purposes of specifying  in the
 Operable Unit #1 Record of Decision the remediation goals that the EPA's selected groundwater
 remedy expects  to achieve (i.e. attainment of AJRARs for groundwater in all current or potential
 sources of drinking water), the  groundwater in the surficial aquifer must be included,  based upon
 the best evidence available to EPA at this time.  It is also important to note that due to  the
 hydraulic connection between the surficial aquifer and underlying aquifers, surficial aquifer
 groundwater remediation would be required by  EPA, regardless of  the groundwater classification
 for the aquifer.  Thus, the issue of the surficial aquifer groundwater classification  is irrelevant to
 ERA's selected remedial technology.


 Concern #11:   EPA's Position on the Shallow Aquifer is inconsistent.

 EPA Response:

        EPA's position  has changed, but it was based on the evaluation of the data received during
 the RI/FS,  not on inconsistent or arbitrary judgement.  The commenter also states that EPA's
 position on the shallow aquifer is inconsistent.  Initially, EPA Region IV had verbally
 communicated to CGC, in advance of any actual analysis to support CGC's speculation, that
 groundwater in  the surficial aquifer at the Woolfolk site might not  be considered by the  EPA as a
.potential source of drinking water.  CGC was also informed that if EPA did not consider the

-------
surficial aquifer groundwater to be a potential source of drinking water, then drinking water MCLs
would not apply as ARARs for that groundwater.  In that case, remedial objectives for the
groundwater in the surficial aquifer would be structured so that both further groundwater
contamination in lower aquifers, and the time required for groundwater remediation for those
lower aquifers would be minimized.

       Subsequent to this preliminary assessment of the surficial aquifer groundwater by EPA
Region IV, actual data analysis by EPA Region IV led to the conclusion that groundwater in the
surficial aquifer was a potential source of drinking water. EPA Region IV has never stated that
groundwater flow from up-gradient of the Woolfolk site (i.e. "dilution", for purposes of evaluating
the effects of contaminant introduction into the aquifer through contaminant leaching from soils) is
nonexistent. Rather, to provide a "worst-case" estimate of the effects of contaminant migration
through those soils, the dilution was assumed to be nonexistent by EPA Region IV in a modeling
analysis to evaluate soil remediation levels for groundwater protection.  EPA has in fact  made an
estimate of the surficial aquifer groundwater flow from up-gradient under very low flow conditions
fless than what has been observed at the site) and has concluded that some groundwater flow from
up-gradient should occur under those exceptionally low flow conditions.


Concern #12:   Manganese is included in the chemicals of concern for this ROD though eliminated
              from the Baseline Risk Assessment (BRA).

EPA Response:

       Manganese was detected in on-site groundwater at levels well above the 200 ppb
health-based value. The only justification  for not including it as a COC would be if legitimate
ground water background levels equalled or exceeded this level.  No background samples were
taken at the site, therefore, manganese has not been deleted.


Concern #13:  Concern was raised over the level to which  lead will be remediated.

EPA Response:

       The 15 ppb action level for lead is  a value applied at the tap per the drinking water
standards set forth in the Lead and Copper Rule, 56 FR, June 7, 1991.  Superfund has adopted
this value as the remedial goal for groundwater.


Concern #14:  Concern was raised over the performance standard for chloroform.

EPA Response:

        The chloroform performance level  is an example of a  situation where the MCL for treated
drinking water is not appropriate as a remedial level. The MCL of 100 ppb for four (4)
trihalomethanes (one of which is chloroform) is a compromised MCL in recognition of its chlorine
source, a chemical intentionally added to drinking water as a microbicidal agent to purify water.
Three (3) ppb is a more appropriate health-based number for chloroform in groundwater at this
site that originates from an undesirable contaminant source.


Concern #15:  The State of Georgia Environmental Protection Division (EPD) has a policy
               regarding the remediation of groundwater which states that "EPD requires that all
               chemical contaminants in  all groundwater  be remediated to the maximum
               contaminant levels (MCL) or (when  an MCL does not exist), to a background value
                                             A-7

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EPA Response:

       Since Georgia's policy of remediating to a background level in the absence of an MCL is not
based on any promulgated regulatory standard or enacted statutory standard of general
applicability, it can not be considered an applicable requirement nor relevant and appropriate
requirement (ARARi. EPA will, therefore, in accordance with its normal approach, remediate the
groundwater based on the MCLs and. when  there is no MCL for a contaminant, based on
health/nsk-based calculations, whichever is lower,  for all aquifers.
Concern #16:  Many concerns were raised by the public regarding their health from their exposure
              to the contaminants.

EPA Response:

       EPA is not qualified to discuss health aspects. However, EPA has contacted the Agency for
Toxic Substances and Disease Registry (ATSDR) in order that these public concerns can be
addressed.  ATSDR attended the public meeting with EPA on February' 1, 1994 and the site is
currently under consideration for further action by their office.
IV. Concerns to be Addressed in the Future

EPA will continue to address community concerns about the site. The remedial design and
remedial action will be given the utmost priority in order to limit further exposure of the residents
to the contamination at the site. EPA will also work closely with City representatives including
the Fort Valley Utility Commission to ensure that the Remedial Actions meet with their approval.

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            Appendix B:




      Applicable Requirements




                or




Relevant and Appropriate Requirements,




             (ARARs)

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Table B-l
IDKNTIHCATION OF POTENTIAL ACTION-SPECIKIC ARARs R>R WOOl.FOI.K CHKMICAI. WORKS
l'uKc 1 of •>
Actions'
Container Storage
(Onsite)






.




•















Direct Discharge of
Treatment System
Effluent
Requirement
Containers of RCRA hazardous waste must be:

• Maintained in good condition

• Compatible with hazardous waste to be
stored

• Closed during storage (except (o add or
remove waste)




Inspect container storage areas weekly for
deterioration.
Place containers on a sloped, crack-free base, and
protect from contact with accumulated liquid.
Provide containment system with a capacity of
10 percent of the volume of containers of free liquids.
Remove spilled or leaked waste in a timely manner to
prevent overflow of the containment system.
Keep containers of ignitable or reactive waste at least
50 feel from Uie facility's property line.
Keep incompatible materials apart. Separate
incompatible materials stored near each other by a
dike or other barrier.
At closure, remove all hazardous waste and residues
from the containment system, and decontaminate or
remove all containers, liners.
Applicable federal water quality criteria for the
protection of aquatic life must be complied with
when environmental factors are being considered.
Prerequisites
RCRA hazardous waste (listed or
characteristic) held for a temporary |icri
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                                                                                                 Table It-1
                                               IDENTIFICATION OF I'OTKNTIAI. ACTION-SPECIFIC ARARs FOR WOOI.FOI.K CHKMICAI.  WORKS
                                                                                                                                                                                                 Page 2 of ')
       Actions"
                                             Requirement
                                                                     Prerequisites
                                                                                                                                 Cltallnn
                                                                                                                          ARAR
                                                                                                                                                                                 Comments
 Direct Discharge of
 Treatment System
 liffluenl {Continued)
Applicable federally approved stale waler quality
standards must be complied with.   Ihese standards
may be in addition to or more slnngenl than oiher
federal standards under the CWA.
Surface discharge of treated effluent
40CTR  122.4-1
and slate
regulations
approved under
40CFK  HI
Applicable
if (ieorgia stale  regulations  are more
slnngenl than federal waler  quality
standards, the (ieorgia standards will  be
applicable to direct discharge.  llie state
has aulhonty under 40 Cl R 131 lo
implement direct discharge requirements
within the slate, and should  he contacted <
a case-hy-case basis when dneit discharge
                          Use of best available technology (HAT) economically
                          achievable is required to control toxic and
                          nonconventional pollutants.  Use of best conventional
                          pollutant control technology (BCD is required to
                          contiol conventional pollutants.  I-echnology based
                          limitations may be determined on a case-by-case
                          basis.
                          'llie discharge must conform to applicable waler
                          quality requirements when the discharge affecis a
                          stale other than the certifying state.
                                                       Surtacc discharge of ire.ih-d ellHk'iil
                                                       Surface waler discharge affecting waters
                                                       outside (ieorgia.
                                             40 CTR
                                             I22.44(d)l4)
                                                                                                                                                 Not ARAR
                                               I"

                                    If treated effluent is discharged lo surface
                                    waters, lliese trealmeni requirements wdl he
                                    applicable.  Permitting anil repoiling
                                    requirements will Ix- applicable only if the
                                    effluent is  discharged at ,in otlsjte location
                                    llie pc mm ling auihoniy and should he
                                    contacted on a case-by-case basis to
                                    delennine eftluenl standards

                                    No discharge is expected lo affcu surface
                                    water outside (ieorgia.
Direct Discharge of
Treatment System
Effluent (Continued)
Discharge limitations must he established for all toxic
poUulanls that are or may be discharged al levels
greater than those thai can he achieved  by
technology-based slajidards.
                          Discharge must be monitored lo assure compliance.
                          Discharger will monitor:

                          •          'Iric mass of each pollutant

                          •          The volume of effluent

                          •          Frequency of discharge  and other
                          «          measurements as appropriate

                          Approved test methods for wasle constituents to be
                          monitored must be followed.  Detailed requirements
                          for analytical procedures and  quality controls are
                          provided.
Surface discharge of treated effluent
                                                       Surface discharge of treated effluent.
40 CI-R
12244{e)
                                             40 CI-R
                                             I22.44(i)
                   Applicable
                 F\xaci  limitations are based on review ol  the
                 proposed treatment system and receiving
                 water  characteristics, and are  usually
                 determined on a case-by-case basis   'Ihe
                 permuting authority should be contacted to
                 determine effluent limitations.

                 lliese  requirements  are generally
                 incorporated into permits, which  are  nol
                 required for onsite discharges. The
                 substantive requirements are applicable,
                 however, in thai verifiable evidence must bo
                 offered thai the discharge standards  are
                 being  met  "Pie permitting  authority should
                 be. contacted to determine monitoring and
                 opera!   maJ requirements.

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Table B-l
IDENTIFICATION OF POTENTIAL ACTION-SPECIFIC ARARs FOR WOOLFOLK CHEMICAL WORKS
Page 3 nf 9
Actions*
Direct Discharge of
Treatment System
Effluent (Continued)


',.
,



' •• (-















'








* •

Requirement
Permit application informal ion must be submitted.
including a description of activities, listing of
environmental permits, etc.
Monitor and report results as required by permit (at
least annually)
Comply with additional permit conditions such as:
• Duly to mitigate any adverse effects of
any discharge
• Proper operation and maintenance of
treatment* systems
Develop and implement a Best Management Practices
(BMP) program and incorporate in the NPDES permit
to prevent the release of toxic constituents to surface
waters.

The BMP program must:

• Establish specific procedures for the
control of toxic and hazardous pollutant
spills

• Include a prediction of direction, rate of
flow, and total quantity of loxic pollutants
where experience indicates a reasonable
potential for equipment failure
• Assure proper management of solid and
hazardous waste in accordance with
regulations promulgated under RCRA
Aproved test methods for waste constituent to be
monitoried must be followed. Detailed requirements
for analytical procedures and quality controls are
provided. Sample preservation procedures, container
materials, and maximum allowable holding limes are
prescribed.



Prerequisites










Surface water discharge.

















Surface water discharge.








Citation
40CFR 122.21


40CFR
I22.44(i)
40CFR




40CPR
125.100




40CFR
125.104










40CFR 136.1-
136.4







ARAR
Applicable









Applicable

















Applicable








Comments










These issues are determined on a case-by-
case basis by the NPDES permitting
authority for any proposed surface discharge
of treated waslcwatcr. Although a
CERCLA site remediation is not required to
obtain an NPDGS permit fur onsilc
discharges to surface waters, the substantive
requirements of the NI'DES permit. program
must be met by the remediation action if
possible. The permitting authority should
be consulted on a case-by-case basis to
determine BMP requirements,






These requirements arc generally
incorporated into permits, which are not
required for onsite discharges. The
substantive requirements are applicable.
however, in that verifiable evidence must be
offered that standards are being met. The
permitting authority should be consulted on
a case-by-case basis to determine analytical
requirements.

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Table B-l
IDENTIFICATION OK POTENTIAL ACTION-SPECIFIC ARAKs FOR WOOLFOI.K CHEMICAL WORKS
PaKc 4 of '
Acllnnv"
Discharge to I'OTW'





•.











• •









Requirement
Pollulants lhat pass through the I'()'I"W without
treatment, interfere with POTW operation,
contaminate I'OTW sludge, or endanger health/safely
of POTW workers are prohibited.



Specific prohibitions preclude the discharge of
pollutants to POTWs thai:

TOTW
« Ale corrosive (p|l<5.0)
• Obstruct How resulting in interference
• Are discharged al a flow rale and/or
concenlralion that will result in
• Increase the temperature of wastewater
entering the treatment plant that would
result in interference, but in no case raise
the POTW influent temperature above
I04°P (40°C)

Discharge musl comply with local I'O I W
pretreatmenl program, including POTW-specific
pollutants, spill prevention program requirements, ajid
reporting and monitoring requirement;
RCRA permit-by-rule requirements musl be complied
with for discharges of RCRA hamdous wastes to
POTWs by Iruck. rail, or dedicated pipe.
Prerequisites
Indirect discharge to a POTW.



























( llatlon
40 U-K 4IB.5


















40 CI-R 4f)1 5
and local
POTW
regulations


40 CFR 26-1 7 1
and 40 CFR
264.72
ARAR
Applicable



























Cuinnicnl.'i
If any liquid is discharged to a I'O |W.
these requirements are Applicable. In
accimliuiee with guidance, a discharge
|X-ninl may he required even fm aji onMle
ilischarge, since pemutling is the only
substantive control nieiliaimm available to
a I'OI W
Categiincal standards have mil been
promulgated foi CTRCI.A Mies, so
discharge standards must be determined on
charactenslics of the waste stream arid the
receiving I'OTW Some municipalities ma\
have published standards lor noil
categorical, non-domeslic discharges
Changes in (he composition of the wasie
or the addition of new waste streams may
require renegotiation of the |>ermit
conditions.











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                                   Table B-l
IDENTIFICATION OF POTENTIAL ACTION-SPECIFIC ARARs FOR WOOLFOLK CHEMICAL WORKS
                                                                                                     Page 6 of'
Actions'
Surface Waler Conlrol
;:.V '
H "
•/injection Wells
>:• i"
»/ . *
• ••
• ?* *
Requirement
Prevent tun-on, and control and collect ninoff from a
24-hour. 25-year storm (waste piles. land treatment
facilities, landfills).

Complete application for injection well permit.
Injection shall not cause contaminants to migrate into
underground sources of drinking water that will cause
adverse health effects.
Prerequisites
Land-based treatment, storage, or disposal
units.

Injection of fluids into the subsurface.

Citation
40CFR
264.25 l(c)(d)
40CFR
264.273(c)(d)
40CFR
264.301 (c)(d)
40 Cl^ 144.31
40CPR 144.32
40CTR 144.40
40CTR 144.51
40 CFR 144.52
GA Rule 391-3-
6.13
ARAR
Relevant and
Appropriate
Applicable

Applicable
Applicable
Comments
Trie requirements for control of run-on and
run-off will be relevant and appropriate to
all remediation alternatives thai manage
non-hazardous waste and include onsite
land-based treatment, storage, or disposal.
The requirements will be applicable to any
remediation measures that include land-
based treatment, storage, or disposal of
hazardous wastes.



-------
• '*•• Tahlc B-l
..•;• .'• IDKNTIl'K ATION or I'OTKNTIAI, ACTION-SPEdl'ir ARAK-, I OR W(KM.FOLK CIIKMICAI. WORKS
• ;• l';i(;o 5 (if ')
-, • Actions"
Discnar'tjc to I'OTW
(Coniinuocl)
,i
• / . •
F.xAvaljon
(Ccwinned)
Operalntm and
Maintenance (O&M)
Requlromont
Area from which materials arc excavated may require
cleanup to levels established by closure requirements.
Movement of excavated materials to a previously
uncontaminated, onsue location, a.nd placement in or
on land may trigger land disposal restrictions.
Devise fugitive dust ajid odor emission control plan
for this action if existing site plan is inadequate.
Post-closure care to ensure that site is maintained and
monitored.
Prerequisites
Disposal by disturbance of hazardous waste
and moving it outside the unit or are;i of
contamination.
Materials containing RCRA hazardous
wastes subject to land disposal restrictions.


Citation
40 CTR 26-1
Disposal and
Closure
Requirements
40 CFR 26S
(Subpan U)
CAA Section
101" and
40 CFR 52"
40 CFR 26-1.1
ARAR
Relevant anil
Appropriate
A^hcable
Relevant and
Appropriate
Applicable
Applicable
Relevant and
Appropnate
Applicable
( 'omments
If contaminated materials llial are noi
ha/ardous wastes arc excavated from the
site during remediation, ihe RCKA
requirements for dis|»sal and sue < IOMIU-
(of the excavated area) become relevant and
Capping, Clean Closure. Closure with
Waste In -Place, elc.
If the excavated materials can be classified
as ha/ardous wastes, ihe disposal and
closure requirements would be applicable.
Hie land disposal restrictions restrict
disposal of certain hazardous wastes. Some
wasi -s may be derived frcmi or may In-
sufficiently similar to restricted wastes lo
make the land disposal restrictions relevant
and appropnate.
I-or wastes thai can be classified as
restricted ha/ardous wasies, ihe n-sinctions
are applicable after Novrinix-r 8. 1988
After this date, land disposal is prohibited
for these wastes unless they are treated to
defined standards. ChemicaJ characlen/alion
of the wastes will be necessary to determine
die applicability or relevance of this
requirement.
See discussions under Construction of new
landfill.
Post closure requirements for operation and
maintenance of the Woolfolk facility are
relevant and appropriate lo new disposal
units with non-hazardous waste, or existing
units capped in-placc.
In cases where the wastes are determined to
he hazardous wastes, and new disposal units
are created, ihe post-closure requirements
will be applicable.

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•V "
4 •-.'• Table 11- 1
: •'' '.•• • IDENTIFICATION OF I'OTKNTIAI. ACTION-SI'KCIFIC ARARs FOR WOOI,FOI,K CHKMICAI. WORKS
' -• .
. . • i '
. ;••£ .. . PaRC 7 of 9
.•^Actions'
TarifcrSlorage (Onsite)
,
;;*



* •
. ' .'t '.',
/• *




.•






• : ;>: •.
. ••'



Tank Storage
(Continued)


;»_.;.' •
• .*•':'.
Requirement
Tanks must have sufficient structural strength to
ensure thai they do not collapse, rupture, or fail.

Waste must not be incompatible with Ihe lank
material unless the lank is protected by a liner or by
other means.

Tanks must be provided with secondary containment
and controls lo prevent overfilling, and sufficient
freeboard maintained in open tanks lo prevent
overtopping by wave action or preciplalion.

Impact the following: overfilling control, control
equipment, monitoring data, waste level (for
uncovered tanks), lank condition, above-ground
portions of tanks (to assess (heir structural integrity).
and the area surrounding the lank (lo identify signs ol
leakage).
Repair any corrosion, crack, and leak.


At closure, remove all hazardous waste and hazardous
waste residues from tanks, discharge control
equipment, and discharge confinement structures.
Slorc ignitable and reactive waste so as to prevent the
waste from igniting or reacting. Ignitable or reactive
wastes in covered tanks must comply with buffer
zone requirements in "Flammable and Combustible
Liquids Code." Tables 2-1 through 2-6 (National Fire
Protection Association. I976or 1981).
Prerequisites
Storage of RCRA hazardous waste (listed
or chacleristic) not meeting small quantity
generator criteria held for a temporary
period greater than 90 days before*
treatment, disposal, or storage elsewhere
(40 CFR 264.10). in a lank (i.e., any
portable device in which a material is
stored, transported, disposed of. or *
handled). A generator who accumulates or
stores hazardous waste on-site for 90 days
or less in compliance with 40 CFR
262.34(a)(l-4) is not subject lo full RCRA
storage requirements. Small quantity
generators are not subject lo the 90 day *
limit (40 CFR 262.34(c), (d), and (c)|.
,.



-.










Citation
40 CFR
264.191


40 ere
264.191



40 CI-K
264.193-194





40 CI-K
264.195

40 CFR
264.196
40 CFR
264.197

40 CFR
264.198




ARAR
Aplicable























Potentially
Applicable




Comments
These requirements would be applicable lo
the construction and use of lank storage al
Woolfolk.




























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'[,' . Table D.I
' ^ • IPKVI 11 •[< A IION <>l I'Ol 1CMIAI. AC MON-SI'Kl 1HC AKAKs FOR Wool, KOI, K CHKM1CA1. \\OKKS
; :. ' 1'anf H «f
' Acllimv"
''VpJlk Storage
(C'oiumuetJl
V
''./ ' .
.'/>'-
«* ' I
'•*1>calincnl
>' -s.
' ' / "' ' '
Vf •'
•'.'.*» * '
''• ff
•'« * •:
Requirement
Storage Prohibitions :
Storage of harmed wastes must he in accordance with
40 (TR 26H. When such storage occurs beyond otic
year, the owner/operator Ix'ars (lie hurdcn ol
providing that such storage is solely for the puqx>se
of accumulating sufficient quantities to allow for

d d 11 (1
retrievable storage, thermal treatment other than
incinerators, open burning, open detonation, chemical.
physical, and bioh>gic;d treatment units using other
than tanks, surface impoundments, or land treatment
units) require new miscellaneous units to satisfy
environmental performance standards by protection of
groundwnier, surface water, and air quality, and by
limiting surface and subsurface migration.
Treatment of wastes subject to ban on land disposal
must attain levels achievable by best demonstrated
available treatment technologies (Ml) AT) for each
ha/ardous constituent in each listed waste.
IVcrequlsHcs

l\e of other units for treatment of
ha/ardous wastes. 'Iliesc units do not meet
the definitions for umis regulated eKe where
under RCRA.
l-ffective dale for CliRCLA actions is
November 8, 1988. for F001-F005
ha/ardous wastes, dioxin wastes, and
certain "California List" wastes. Other
restricted wastes have different effective
dates as promulgated in 40 (T'R 2(SX
( italion
40 Cl-R 268. M)
40 (TR 2(>\
(Subpan X )
40 C'l-R 26K
(Subpart I))
ARAR
Potentially
Apftlit-alilc
Relevant and
A[^)ropnaie
Applicable
Apjilicable
Relevant and
Appropriate
( 'nnmicnls

Hie iL't|nireinenl will Iv relev.uil aiul
a|>jnopn.ite in the Lomiiuction, operation,
miscellaneous treatment unit (a treatment
unit that is no! d sew he re regulated)
constmcted on the PdDP site lor treatment
and/or disposal o! notvha/ardous wastes
'Iliese requirements would Iv applicable to
the construction ajid operation of a
miscellaneous treatment unit tor the
treatment and /or disposal of ha/ardous
wasu-s
Ihese regulations are applicable to the
ilis|x)sal of any waste that c;ui be defined a
restricted wastes.
Ihese requirements are relevant and
disposal of any wastes that contain
components of restricted wastes in
concentrations that make the site wastes
sufficiently similar to the regulated wasics
Ilie requirements sjK'cify levels of (reatmei
that must be attained prior to land disposal

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                                                                                             Table B-l
                                             IDENTIFICATION OF POTENTIAL ACTION-SPECIFIC ARARs FOR WOOI.FOLK CHEMICAL WORKS
                                                                                                                                                                                         Page 9 of 9
 .%V*-V  Actions'
                  Requirement
                                                                  Prerequisites
                                                                                                   Citation
                     ARAR
                                                 Comments
 Trcat/ncnl (Continued)
Design and operating standards for unil in which
hazardouds waste is treated.
                                                                              Treatment of hazardous waste  in a unil.
                                                                                                40 CFR
                                                                                                264.190-
                                                                                                264.192 ffanks)

                                                                                                40 CFR
                                                                                                264.601
                                                                                                (Miscellaneous
                                                                                                Treatment
                                                                                                Units)

                                                                                                40 CFR
                                                                                                265.373
                                                                                                ('Ihcrmal
                                                                                                Treatment
                                                                                                Units)
                  Applicable

                  Relevant and
                  Appropriate
                                                                                                                                                           'Ihese regulations are applicable lo Ihe
                                                                                                                                                           disposal of hazardous waste.

                                                                                                                                                           Ihese requirements are relevant and
                                                                                                                                                           appropriaie for design and operation of
                                                                                                                                                           treatment units which treat non-RCRA
                                                                                                                                                           hazardous waste.
Devise fugitive and odor emission control plan for
this action.
CAA Section
101"
and
40 CFR 52b
                                                                                                                                           Applicable
                                                                                                                                  See discussions under Air Stripping.
•*»•'•
File an Air Pollution Emission Notice (APEN) with
state lo include estimation of emission rales for each
pollutant expected.
                                                                                                                         40 CFR 52"
                                                                                                                                           Applicable
                                                                                                                                  See discussions under Air Slnpping.
         for TABLE B-1:
       .
•'A'ction alternatives from ROD keyword index.
 ""Athof the Clean Air Act ARARs that have been established by the Federal Government are covered by matching slate regulations.  The slate has the authority lo manage ihese programs through the approval of ils
 rmplijmenlalion plans (40 CFR 52,
 TMk storage requires the preparation and implementation of a spill prevention, control, and countermeasures (SPCC) plan (see 40 CFR 76l.65(c)(7)(ii) for specifications of container sizes that arc considered "bulk"
 storage containers).  Substantive
   requirements may be ARARs if bulk storage is performed on Ihe site.
 IjTlajs I wells and Class IV wells are the relevant classifications for CERCLA. Class 1  wells are used to inject hazardous waste beneath the lowermost formation containing an underground source of drinking water
•within one-quarter mile of the injection
 •, /well. Class IV wells are used to inject hazardous or radioactive waste into or above a formation containing an underground source of drinking water within one-quarter mile of the injection well.
 Thfse regulations apply regardless of whether the remedial action discharges into the sewer or trucks the waste to an inlet to the sewage conveyance system located "upstream" of the town.

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Table B-2
IDENTIFICATION OK POTENTIAL LOCATION-SPECIFIC ARARs AT WOOLFOI.K CHEMICAL VVOKK.S
'•> . I'^c 1 of 1
s Location
I. I'r •
.1 \
?#:.
•f / .
. 1
Within area where acvion may
cause irreparable harm, loss,
or destruction of significant
artifacts
Critical habitat upon which
Endangered species or
'. threatened species depends
Within coastal zone
Requirement
Action to rct/over anil preserve
artifacts
Aclion to, conserve endangered
species or threatened species,
including consultation with the
Department of the Interior
Conduct activities in manner con-
sistent with approved state man
agemeni programs
Prercqulsite(s)
Alleration of terrain thai threatens
significant scientific, prehistoncaJ,
historical, or archaeological data
Determination of endangered species
or threatened species
Activities affecting the coastal /.one
including lands thereunder and
adjacent shorelands
Citation
National
Archaeological and
Historical Preservation
Act (16 USC Section
46()); 36CFR Part 65
F-'ndangered Species
Act of 1973 (16 USC
mi et scq.l; 50 CI:R
Part 200. 50 CI:R Part
402
Coastal /one
Management Act (16
USC Section 1451 et
seq.)
ARAR
Unknown
Unknown
Potentially
Applicable
(!nmincnls
Should scientific, prehisioncal, or
histontal itmfacts he found at the site, this
will lx_'coiiK' applic'able
No endangered ^pecles are known to esul
1X1 llu' Mil'
Ilie site ha.s direii CHICKS to i oastal are;i^

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TABLE B-3
IDENTIFICATION OF CHEMICAL-SPECIFIC ARARS FOR THE WOOLFOLK
CHEMICAL WORKS SITE
CLEAN WATER ACT - 33 U.S.C. §§ 1251-1376
A
R&A
40 CFR Part 131 - Ambient Water
Quality Criteria
40 CFR Part 403 - National
Pretreatment Standards
Suggested ambient standards for the
protection of human health and aquatic
life.
Sets standards to control pollutants which
pass through or interfere with treatment
processes in publicly-owned treatment
works or which may contaminate sewage
sludge.
RESOURCE CONSERVATION AND RECOVERY ACT - 42 U.S.C. §§ 6901-6987
R&A
R&A
40 CFR Part 261 - Identification and
Listing of Hazardous Wastes
40 CFR Part 262 - Standards
Applicable to Generators of
Hazardous Waste
Defines those solid wastes which are
subject to regulation as hazardous wastes
under 40 CFR Parts 263-265 and Parts
124, 270, and 271.
Establishes standards for generators of
hazardous waste.
CLEAN AIR ACT - 42 U.S.C. §§ 7401-7642
R&A
40 CFR Part 50 - National Primary
and Secondary Ambient Air Quality
Standards
Establishes standards for ambient air
quality to protect public health and
welfare.
SAFE DRINKING WATER ACT - 40 U.S.C. §§ 300
R&A
R&A
A-. ... At
SP
AC
R&A- RI
A
01
SI
w
40 CFR Part 141 - National Primary
Drinking Water Standards
PL No. 99-339 100 Stat. 462 (1986) -
Maximum Contaminant Level Goals
(MCLGs)
Establishes maximum contaminant levels
(MCLs) which are health-based standards
for public water systems.
Establishes drinking water quality goals
set at levels of no known or anticipated
adverse health effects with an adequate
margin of safety.
>PLICABLE REQUIREMENTS WHICH WERE PROMULGATED UNDER FEDERAL LAW TO
ECIFICALLY ADDRESS A HAZARDOUS SUBSTANCE, POLLUTANT, CONTAMINANT, REMEDIAL
:TION LOCATION OR OTHER CIRCUMSTANCE AT THE WOOLFOLK CHEMICAL WORKS SITE.
:LEVANT AND APPROPRIATE REQUIREMENTS WHICH WHILE THEY ARE NOT "APPLICABLE" TO
HAZARDOUS SUBSTANCE, POLLUTANT, CONTAMINANT, REMEDIAL ACTION, LOCATION, OR
PHER CIRCUMSTANCE AT THE WOOLFOLK CHEMICAL WORKS SITE, ADDRESS PROBLEMS OR
TUATIONS SUFFICIENTLY SIMILAR TO THOSE ENCOUNTERED AT THE WOOLFOLK CHEMICAL
ORKS SITE THAT THEIR USE IS WELL SUITED TO THE SITE.
***.*•.•

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                                TABLE B-4
   IDENTIFICATION OF POTENTIAL GEORGIA STATE ARARS FOR THE
                  WOOLFOLK CHEMICAL WORKS SITE
R & A
R & A
R & A
R & A
Air Quality Act of 1978
O.C.G.A. § 12-9-1 et seq. and
Rules, Chapter 391-3-1.
Safe Drinking Water Act
O.C.G.A. § 12-5-170 et seq. and
Rules Chapter 391-3-5.
Georgia Water Quality Control
Act O.C.G.A. § 12-5-20 et seq.
and Rules, Chapter 391-3-6.
Well Standards Act of 1991,
O.C.G.A. § 12-5-120 et seq.
Establishes standards for ambient air
quality to protect public health and
welfare.
Establishes maximum contaminant
levels (MCLs) which are health-based
standards for public water systems.
Establishes treatment standards for
public water systems.
Requirements regarding the closure
of abandoned wells.
R&A -
APPLICABLE REQUIREMENTS WHICH WERE PROMULGATED UNDER
FEDERAL LAW TO SPECIFICALLY ADDRESS A HAZARDOUS SUBSTANCE,
POLLUTANT, CONTAMINANT, REMEDIAL ACTION LOCATION OR OTHER
CIRCUMSTANCE AT THE WOOLFOLK CHEMICAL WORKS SITE.

RELEVANT AND APPROPRIATE REQUIREMENTS WHICH WHILE THEY ARE
NOT "APPLICABLE" TO A HAZARDOUS SUBSTANCE, POLLUTANT,
CONTAMINANT, REMEDIAL ACTION, LOCATION, OR OTHER CIRCUMSTANCE
AT THE WOOLFOLK CHEMICAL WORKS SITE, ADDRESS PROBLEMS OR
SITUATIONS SUFFICIENTLY SIMILAR TO THOSE ENCOUNTERED AT THE
WOOLFOLK CHEMICAL WORKS SITE THAT THEIR USE IS WELL SUITED TO
THE SITE.
        . *
        :•»-.
        • Z'?

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          APPENDIX C:
       STATE CONCURRENCE
3^^

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                       Georgia Department of Natural Resources

                              205 Butler Street, S.E., Suite 1154 Atlanta, Georgia 30334
                                                        Joe D. Tanner, Commissioner
                                                      Environmental Protection Division
                                                          Harold F. Rehsis, Director
                                                         404*56-2833 404/656-7602
                                   March  23,  1994


                          VIA FACSIMILE


Timothy R. Woolheater
Remedial Project Manager
South Superfund Remedial Branch
United States Environmental Protection Agency
Region IV
345 Courtland Street, NE
Atlanta, GA  30365


RE:  Comments on Draft ROD for OU1 - Woolfolk Chemical Works
     Superfund Site, Fort Valley, Georgia

Dear Mr. Woolheater;

     As you know, we have reviewed the proposed Record of
Decision for remediation of contaminated  groundwater at the
Woolfolk site and have provided you with  comments.   To reiterate
our position, all groundwater in Georgia  is considered a
potential source of drinking water,  were this site being
remediated under a Georgia authority, the action levels for all
contaminants in groundwater would be MCLs or  background for those
contaminants having no MCL.

     We understand that EPA plans to remediate certain
contaminants (i.e., chemicals of concern)  in  groundwater to
concentrations that represent either the  MCL  or the health-based
cleanup goal which was developed for those chemicals of concern
which do not have MCLs.  EPA has indicated that the Georgia
standards noted above are not ARARs and,  as such, will institute
the MCL/health-based standard approach in lieu of state
standards.  The actual remediation will,  in general, involve
pumping and treating groundwater with subsequent discharge to a
POTW.  Alternate discharge routes will be investigated, should
the POTW prove unable to handle the treatment system effluent.

     Assuming that EPA has adequately identified all chemicals of
concern and their respective clean-up levels,  EPD concurs that
EPA's plan  (including the pump-and-treat/discharge  strategy) for
remediating "groundwater is'tije-be.st-alternative to'.pursuing the.
Georgia standards.  We also want to reiterate our position .that
the ROD should explicitly state the schedule  and protocol^ for
monitoring Port Valley drinking water wells in order to ensure
the continued safety of the residents.

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     I hope  this  information is sufficient for your needs.   If
you have any further questions regarding this matter, please call
Ken Mitchell  of rr.y  staff  at 404-657-8645.
                                    Sincerely,
                                    Jennifer Kaduck, Chief
                                    Hazardous Waste Management
                                    Branch
Attachments

File:  Woolfolk
R:\Mitchell\Sites\Wool3.let

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