United States
            Environmental Protection
            Agency
Office of
Emergency and
Remedial Response
EPA/ROD/R04-87/029
September 1987
&EPA   Superfund
            Record of Decision:
             Powersville L.F., GA

-------
                                   TECHNICAL REPORT DATA
1  M*O*TNC.
 EPA/ROD/R04-87/029
                                                           3 • «<;:•'«*« r S »CCtss. :s
4. T1TU1 ANO SU4TITV.1
 SUPERFUND RECORD OF DECISION
 Powersville Landfill, GA
 First. Remedial Action - Final
                                                                    September  30,  1937
           ORGANIZATION NAMC ANQ AOQ*(U
                                                           10. •«OG«AM
                                                                           NO
                                                          I I '  WwNrWACl'G^ANr NO
1]. SPONSORING AGINC^ NAMC ANO AQOMC33
 U.S.  Environmental Protection Agency
 401 M Street, S.W.
 Washington,  D.C.  20460
                                                                     Fina
                                                                            COO«
                                                                     800/00
      fMINTAHV NOTI3
   •The Powersville Landfill, which occupies approximately 15 acres,  is  located  in  Peach
 County, Georgia.  General crop farming is the major agricultural practice  in  the  region,
 however, cattle farms and orchards are also common.  Locally the Providence aquifer.  ^,
 system is a source of water for both consumption and irrigation.   From  the early  1940s
 to 1969 the landfill site was a borrow pit which provided sand  and fill  material  to the
 County for local use.  During 1969 Peach County began operating the site as a sanitary
 landfill receiving municipal and industrial wastes.  In December 1972 the  Georgia
 Department of Natural Resources Environmental Protection Division  suggested the
 separation and maintenance of areas for pesticides and associated  wastes which was
 attained.  Disposal records indicate pesticide manufacturing wastes were disposed  of in
 the municipal section of the landfill prior to June 1973 and in the hazardous waste are;
 between June 1973 and 1978.  Neither the quantity nor the location .of the  waste  in che
 municipal landfill is known.  The landfill was closed- in 1979 due  to its location  in a
 highly permeable sand and gravel aquifer.  The primary contaminants of  concern affeccinc
 the soil and ground water include:  VOCs (vinyl chloride), organics,  heavy metals  (lead
 and chromium) and pesticides.
    The selected remedial action for this site includes:  surface capping of hazardous
 waste and municipal fill areas using artificial material or clay,  with  grading,  drainage
 and closure; installation of eight additional monitor wells (at a  minimum) in the  upper
                               MY WOMO* AMO OOCUMCMT
                 0««C*ITOII«
                                                            fNQIO
                                                                        C. COSATI
 Record of Decision
 Powersville Landfill, GA
 First Remedial Action - Final
 Contaminated Media: gw, soil
 Key contaminants: organics, heavy metals,
  pesticides, vinyl chloride
I. OlSTKltuTIQN
                                             I*
                                                                        I 21  NO C» •AC IS
                                                                        I       178
                                             20
                                                               s*r*i
   '«• 2770-1 (*•.. 4.77)

-------
EPA/ROD/RO4-87/029
Powersville Landfill,  GA
First Remedial Action  - Final

16.   ABSTRACT (continued)

region of the aquifer  to" determine cap area leaching or migration; and extension of the
municipal water supply pipe line as an alternate water supply.  The State of Georgia
indicates an inability to pay their portion of the costs, which is 50%, if the PRPs do
not come forth to conduct the remedial action.  The total present worth cost for this
remedial action is $4,000,000 with present worth O&M of $577,013.

-------
                            RECORD OF DECISION
                      REMEDIAL ALTERNATIVE SELECTION
SITE


Powersville Landfill

Peach County

Powersville, Georgia


STATEMENT OF PURPOSE
This decison document represents the selected remedial action for the
Powersville  Landfill site and is consistent with the Comprehensive
Environmental Response, Compensation and Liability Act of  1980  (CERCIA),
the. Superfund Amendments and Reauthorization Act of 1986 (SARA) and the
National Oil and Hazardous Substances Pollution Contingency Plan (40 CFR
Part 300).  The remedy described below provides adequate protection of
public health, welfare, and the environment.  The State of Georgia has
been consulted and concurs with all points of the selected remedy.
However, they do indicate that they are not presently in a position to pay
their portion of the costs, which is 50%, if the PRPs do not come forth
to conduct the remedial action.  The selected remedy is estimated to cost
$4.0 million.
STATEMENT OF BASIS
The decision is based on the Administrative Record which  is on file in
the EPA Region IV offices, 345 Courtland.Street, Atlanta, GA, or  is
available at the Powersville Fire Station, Powersville, GA.  The  attached
index indicates the documents which comprise the Administrative Record
upon which the selection of a remedial action is based.
DESCRIPTION OF SELECTED REMEDY
The recommended alternative for the Powersville Landfill site  includes:

0  Surface capping of the hazardous waste and municipal fill areas.  The
   cap for the municipal area will be constructed in accordance with EPA
   guidance document, Covers for Uncontrolled Hazardous Waste  Sites,


-------
   EPA/540/2-85/002.  The cap for the hazardous waste area will be con-
   structed using the same guidance indicated above, with the additional
   stipulation that the top liner be constructed with an artificial
   material or equivalent two foot thick layer of compacted clay.  Closure
   will be in accordance with applicable State and Federal regulations.

   Grading of the area to ensure proper slope and drainage of water off
   of the cap.  Drainage would be designed to direct surface runoff toward
   the present natural drainage channels.

   Installation of a minimum of eight additional monitor wells in the
   upper region of the aquifer to determine if contaminants are leaching
   or migrating from the capped areas.

   Provision of an alternate drinking water source.  The most likely
   alternative for this water is the Byron municipal water supply.  The
   present termination point of this water supply is approximately 2
   miles north of the site on Georgia Highway 49.

   Site deed restrictions to prevent any drilling or construction activities
   that would comprcmise the integrity of the remedy.  Deed restrictions
   need also be established to prohibit the drilling of water wells in the
   area between the site and Mule Creek/ the area in;which groundwater is-
   likely to be affectd by the landfill.
           — •            •'—.••.. ~,-i,   ..       .

   Operation and maintenance (0 & M) will include regular inspection of
   the cap for signs or erosiorf;: 'settlement or deterioration.  Inspections
   should be conducted frequently during the first six months.  Periodic
   monitocing of .new and existing monitor wells will be required.
DECLARATION

The selected remedy is protective of human health and the environment,
attains Federal and State requirements that are applicable or relevant
and appropriate, and is cost-effective.  This remedy satisfies the prefer-
ence for a treatment that reduces toxicity, mobility, or volume as a
principal element.
Lee A. DeHihns                                    Date7  7
Acting Regional Administrator

-------
                                   SECTION I
                          SITE LOCATION & DESCRIPTION


The Powersville Landfill is located just north of the  intersection  of Georgia
Highway 49 and Newell Road, a cross-roads in  the small community of Powersville
in Peach County, Georgia.  The Landfill, which occupies approximately 15  acres,
is centered on latitude 32°36'36" north and longitude  83°47'33"  west (Figures 1
& 2).

The landfill is located in a rural area of Peach County.  This area is
characterized by broad, fairly level interfluvial areas cut  by deeply incised
streams.  Across the county, maximum relief is on the  order  of-120  feet.  At
the site, the maximum relief is approximately 75 feet. General  crop farming
is the major agricultural practice in the region, However cattle farms and
orchards are also common.  Locally, the Providence  aquifer system is a source
of water for both consumption and irrigation.

-------
                                          -N-
                                           I
                         POWER SV1LLE
                      '   SITE
            REM II
     SITE LOCATION MAP
POWERSVILLS- LANDFILL SITE
     PEACH COUNTY, CiEORGIA
FIGURE N


    1

-------
                     HAZARDOUS WASTE AREA
         APPROXIMATE
        SITE BOUNDARY
            RtŁM II
      SITE LAYOUT MAP
POWcRSVILLE LANDHU SITE
     PEACH COUNTY. GEORGIA

-------
                                   SECTION II
                                  SITE HISTORY


Operational History

The landfill site originated as a borrow pit which provided sand and fill
material to the County for local use.  The excavation of soils continued from
the early 1940's .to 1969.  During 1969, Peach County began operating the site
as a sanitary landfill receiving municipal and industrial wastes.   In  December
1972, Georgia Department of Natural Resources Environmental Protection Division
(EPD) sent a letter following an inspection of the landfill to Peach County
suggesting a separate area be set aside and maintained in a rigidly prescribed
manner to contain pesticides and associated wastes.  This area was  established
and in operation by June 1973.  No information is available regarding  the types
and quantities of waste disposed of at the site prior to the  establishment of
the hazardous waste enclosure.
                                        ^
Disposal records indicates wastes associated with the manufacturing of pesticides
were disposed of in the hazardous waste area from June 1973 through 1978.  It
is strongly believed, based upon citizens and EPD files, that these hazardous •
wastes were discarded in the municipal section of the Powersville Landfill
prior to June 1973.  Neither the quantity nor the location of this  waste in  the
municipal landfill is known.

In March 1977, the Georgia EPD sent a letter to the Peach County Board of
Commissioners recommending that the site be closed due to its location in the
highly permeable sand and gravel of the Providence aquifer. At the  time that
the landfill was closed in 1979, the entire site covered approximately fifteen
acres.  In 1983 the site was included on the National Priorities List  (NPL)
issued by the EPA under mandate of the Comprehensive Environmental  Response,
Compensation and Liability Act of 1980 (CERCLA).  Table 1 provides  a brief
summary, listed chronologically, of historical events at the  site.


-------
                                  TABLE 1

                            CHRONOLOGY OF  EVENTS
                            POWERSVILLE LANDFILL
                           PEACH COUNTY, GEORGIA
                                  REM II
   DATE
                       ACTION
April, 1983


May, 1983

June, 1983


August, 1983

September, 1983

September, 1983


October, 1983
January, 1984
February, 1984


March, 1984




April, 1984


May, 1984
Georgia EFD collected water samples froa Lizzie Chapel
Well.

Georgia EFD sampled surrounding private wells.

Georgia EFD collected water samples from Lizzie Chapel
Well.

Georgia EFD requested that EPA investigate the site.

NUS performed the initial site visit.

The Powersville Landfill Site was proposed for inclusion
on the NFL.

EPA FIT Contractor, NUS Corporation (NUS), performed a
geophysical study of the site to determine the potential
for and extent of ground water contamination.  The study
included EM-31 magnetometer and soil resistivity
surveys.  Also, a topographic map was developed by NUS.

NUS released report, Geophysical Study, Powersville
Site, Peach County, Georgia.

NUS collected three soil samples from the site and four
wells located in the vicinity of the site.

NUS collected one composite soils sample from the site
and installed eight onsite monitor wells.

NUS collected samples from onsite monitor wells and two
private wells.  Duplicate samples were split with
Clayton Environmental Consultants, Inc. (CEC) of
Atlanta, Georgia, and the Georgia EPD.

NUS released report, Monitoring Well Installation,
Powersville Site, Peach County, Georgial

CEC released report, Hydrogeologic Investigations for
Powell, Goldstein, Frazier, and Murphy at Pox/ersville
Landfill Site, Peach County, Georgia.

-------
                                (continued)
   DATE
                       ACTXCN
July, 1984


July-August, 1984

December, 1984

January, 1985

February, 1985

February, 1985



March, 1985

August, 1985


February, 1986



August, 1986


November, 1986
NUS collected three samples from private wells in the
vicinity of the site.

NUS installed two more wells at the site.

CDM was assigned to initiate an RI/FS on the site.

CDM completed the Work Plan Memorandum for the site.

CDM completed Letter Report on available data.

NUS released, Monitoring Well Installation for
Powersyille Site, Peach County, Georgia, giving results
of analyses of monitor wells and private wells.

CDM submitted the Interim Report for the site to EPA.  "

USGS performed an inventory of all wells with a one mile
radius of the site.

CDM collected soil and water samples from the existing
monitor wells and water samples from 12 surrounding
private wells.

CDM completed the installation of nine new monitor
wells.

CDM submitted a Site Investigation Letter Report to EPA
summarizing the remedial investigate field activities.

-------
Previous Studies

On April 21, 1983, EPD collected a water sample fran the Lizzie Chapel well.
Chemical analyses indicated trace amounts of pesticides as shown  in Table  2.
Water samples collected from surrounding private residential wells in May
1983, indicated no prescence of pesticides.  The Lizzie Chapel well was sampled
again on June 2, 1983.  The levels of pesticides present were slightly higher
than in the initial sampling.  As a result, in August 1983, EPD requested  that
the church discontinue use of the well for drinking water.

NUS Corporation (NUS), the EPA PIT contractor, began geophysical  investigations
at the site in October, 1983 (NUS, 1984).  The results indicated magnetic  and
electromagnetic anomalies in the areas known to have received general waste.
Distortions in the electrical resistivity profiles indicated the  presence  of
buried materials, but failed to identify any confining layer.  However, the use
of penetration resistivity at various depths in an attempt to define confining
layers was possible.  The results of the soundings revealed no clear evidence
of any continuous confining layer beneath the site to a depth of  at least  200 feet.

The hydrolcgic investigations began when NUS installed ten monitor wells at the
site in 1984.  The siting and installation of the monitor wells are presented
in the NUS report, Monitoring Well Installation (NUS 1984).  In addition,  ground
water samples were taken from nine monitor wells and five private wells.   Table
3 is a summary of the private well sample analyses.  The following toxic
chemicals were detected in the monitor well samples:  benzene hexachloride
(BHC), vinyl chloride, 1,2 dichloroethane, lead and chromium.

Drilling logs for all the monitor wells and gamma logs performed  at three  of
the monitor wells indicated the existence of multiple clay lenses.  The depth
to the water table ranged from 30 to 80 feet.  The average water  table elevation
was reported to be 373 feet above mean sea level (msl) except at monitor well
MW-9, where the elevation averaged 385 feet, approximately 12 feet higher  than
the surrounding area.  This apparent mound was inconsistent with  the generally
planar water surface.  The direction of ground water flow could not be completely
defined based upon the existing data.  The NUS report concluded that the aquifer
beneath the site appeared to be unconfined with various isolated  clay lenses
throughout.  However, this particular report was inconclusive with regards to
the direction of ground water flow.

In December 1984, Camp Dresser & McKee Inc. (CDM) was given the Work Assignment
to perform a Remedial Investigation/Feasibility Study (RI/FS) on  the site.
Information gathered during this study indicated that groundwater flow is  to
the southeast.  The combined RI/FS report was completed in July of 1987 and
presented to the public for comment on August 4, 1987 at the Feasibility Study
Public Meeting.  The  Agency's response to comments and questions generated by
this meeting are found in the responsiveness summary.

-------
Previous Site Response Actions

Following the closure of  the  landfill  in  1979,  the only response action at the
site was undertaken by Peach  County at the request of both  the  State  and EPA
during early 1986.  The activity was limited  to the  regrading of a steep bank
leading up to the hazardous waste disposal area that had eroded away  due to
past rain events.  It was feared if the erosion was  left unchecked that the
disposal cells in the hazardous waste  area would be  breached.


-------
                                                     TABLE 2
                               SUMMARY OF GEORGIA EPD ANALYSIS CONCENTRATIONS (ug/1)
                                             POWERSVILLE LANDFILL SITE
                                               PEACH COUNTY, GEORGIA
                                                       REM II
Dave Sample
Was Taken
April 21, 1983
June 22, 1983
May 17, 1983


Kay 21, 1984
I

June 8, 1984
Well
Sampled
Lizzie Chape]
Lizzie Chapel
Adams
Mobley
Pickens
Adama
Mobley
Pickena
Pickena

Alpha
0.30
0.30
UD
UD
UD
UD
UD
UD
	

Beta
0.01
0.10
UD
UD
UD
UD
UD
UD
	
txachloride (BHC
Delta
0.06
0.20
UD
i
UD
UD
UD
UD
UD
	

	 	 	 	 	 	
Gamma (Llndane)
0.22
0.40
UD
UD
UD
UD
UD
UD

Dleldrln
0.15
0.20
UD
UD
UD
UD
UD
0.40
UD
UD  - Undetected
	   Analysis not performed

-------
                                                                            TABLE  3
                                                 SINUIt Or MIS  ANALYTICAL MSULTI Or fllVATt HtLL tAMTLINC 


 .041

 .Oil

.OMI
01 -M -uci ft fki •*!•!•
      A
Fhcnol

•ulanulc Acid

Uci«t>ydi o*««phlnoM

tcniunlc Acid

<-rVll.y Iptvcnul

lUHanulc Acid

Pluti*nulc Acid

H, lhr Ibul.nolC Acid

Pffuaiiulc Acid

Hriliyl(xm«i«alc  Acid

Tl.n«-| , J-dlchloflMllMM
                   A
I .^-dlirhlor
I.I .?. J-i«liachloio«lh«M

Tel i«rhloiu«in«iM

To I uritc
             •
Cl lu. «ni*a«
.11

.21

1.1

.*}
                                                                                                                                            1QA
                                                     JA

                                                     JA

                                                     1A
                                                                 4A
Vlnrl Chlalld*

Al 1 1 un«
                     MO
 III « Illtll ul loulU*«lllltlMf

 li-l I irJi ul ill An

-------
                                  Section III
                              Current Site Status
The physical characteristics of the Powersville site were determined and
evaluated in the Remedial Investigation  (RI) process.  As a result of  the
RI field study/ the current status of the site has been well defined.   In
order to understand the current site conditions,  it is necessary  to know
what chemical compounds were disposed of that created the concern associated
with the site, e.g., DQA and Woolfolk disposal lists.  This information
is presented in Appendix B.  The data can be best understood by breaking
it down into soil, groundwater, surface water, air, and general hydrogeo-
logical portions.

Soils
The objective of the soil sampling was to define the limits, depth and
composition of materials in the portion of the site used for the  disposal
of municipal waste and to determine if any contaminant leaching is occurring
from the hazardous waste area.

As shown in Figure 3, thirteen vertical soil borings were drilled in or
around the municipal fill area (MFB-1 to MFB-13) and two angled borings
were drilled under the hazardous waste area (HW-1 & HW-2).  Table 4
summarizes the indicator chemicals frcm samples collected from the soil
borings.  The soil boring samples were collected at five foot intervals,
starting at ten feet below ground surface.

The upper soil region consists of medium grained permeable  sand.   The
sand is part of the Gosport Sand unit common to the area.   The thickness
of this sand region at the site ranges frcm 0 to 50 feet.   The majority
of the municipal fill area is located in the Gosport Sand unit.

Underlying the upper sand region is the Providence Sand unit which contains
many clay lenses and seams.  Although the lower sand is usually fine grained
with a less uniform size distribution, it is difficult to differentiate
between the two regions at the Powersville Landfill Site.

The boundary of the municipal fill area shown on Figure 3 was derived using
the boring logs.  The region containing debris and other waste material
was distinguished by its black color.  Similarly/ the depth of the fill
area was determined.  Using the area and varying depths derived,  the
volume of the municipal fill area was calculated to be approximately
292,000 cubic yards.

Two borings were drilled under the hazardous waste area at  the locations
shown on Figure 3.  A noticeable pesticide odor was present during the
final sampling of HW-2.  Table 5 sumnarizes the analytical  results for
the HW-1 & HW-2 samples.  The endangerment assessment identified  the
following chemicals as indicators for the landfill soils:

.  ,  °  Alpha - BHC
     0  Toxaphene
     0  Chlordane


-------
                   OEM II
!r
MUNICIPAL FILL &. ANGLE SORir4G LOCATIONS

        POWEBSVILLE LANDFILL SITE
             PEACH COUNTY. GEORGIA

-------
                                 TABLE 4
ANALYTICAL  RESULTS FOR INDICATOR CHEMICALS IN MUNICIPAL FILL SAMPLES
                         POWERSVILLE LANDFILL SITE
                           PEACH COUNTY. GEORGIA
                                  IEH II
•OR INC
NUMIEI CHROMIUM LEAD
<-«/k«) (1/kl)
WO 1 -001
WOI-O02
WO 1-003
HPOI-OOS
HP02-OOI
HPU2-O02
MP02-OOI
MP03-OOI
HP03-O02
HP03-O03
W04-OOI
HP04-O02
MF04-001
HPOS-OOI
HFOS-O02
MP06-OOI
WOb-002
WO 7 -001
W07-002
W08-OOI
W 09-001
HP09-002
HPIO-OOI
HG 10-002
WII-OOI
HM 2-001
HP 12-002
W 13-001
HP 13-002
HP14-OOI
10
•
4.8
II
14
•1
t.4
IS
23
S.4
17
4.1
S.t
IS
3.f
».8J
I.4J
If
20
S.6J
28J
I6J
7
S7
I3J
S.7J
23J
II
4
14
7
47
U
7.2
4.3
320
U
8.7
63
U
U
U
U
U
U
U
U
8
S
U
18
U
U
16
U
4.8
7.6
U
U
U
ALPHA-RHC
U
U
130
U
U
U
U
U
U
U
U
U
U
27
U
U
U
UR
UR
U
U
U
UR
U
UR
U
U
U
UR
UR
CAMMA-IHC
(LINOANE)
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
UR
UR
U
U
U
UR
U
UR
U
U
U
UR
UR
OIELDRIN
U
U
U
U
U
U
U
U
74
U
U
U
U
J
U
U
U
U
440
U
U
U
U
U .
U
U
U
U
u
u
TOIAPHENE
U
U
U
U
U
U
U
U
U
U
U
2400
U
U
U
U
u
u
u
14.000
u
u
u
u
u
u
u
u
u
u
CAMHA-
CHLOR0ANE
U
U
U
U
U
U .
U
U
U
6.6
U
I400C
20
IS
u
u
u
u
u
u
u
u
u
u
u
u
S.6
8.6
U
U
ALPHA-
CHLORDANE
U
U
U
U
U
U
U
U
660
6.6
U
130
3.8
II
U
U
U
U
U
U
U
U
U
U
U
0
S.6
8.6
U
U
VINYL 1,2-01-
CHLORIDB CHLOtOBTtUNR
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
u
u
u
u
u
u
u
u
u
u
u
u
u
u
u
u •
u
u
il
u
u
u
u
u
u
u
u
u
u
u
u
u
u
u
u
u
• All concent r.t loo* ... |o ,,,/k, elcep, chro.lu.
A - Aver.ge  Value
C - Confirmed  by Ce« Chrmutoi r.phy
J - EatlMted  Value
R - S.aple Rejected
U - Undetected

Mote:
                          ,  d
                               ?,•* rieiMi mi boH- 
-------
                                                             TABLE 5

                            ANALYTICAL RESULTS FOR INDICATOR CHEMICALS IN ANGLE BORING SAMPLES (iig/kg)
                                                     POWERSVILLE LANDFILL SITE
                                                       PEACH COUNTY. GEORGIA
                                                              REM II
WELL
NUMBER
HWI-001
HU 1-002
HW2-OOI
HW2-002
HW2-O03

CHROMIUM
IIOR
4IOR
350R
370R
2SOR

LEAD
(••/kf
U
U
U
U
U

ALPHA-BHC
)
U
U
U
U
U
CAHHA-BHC
(LINDANE)
U
U
U
.9IJ
U

DIELDRIN
U
U
U
U
U

TOXAPHENE
U
U
U
U
U
CAHHA-
CHLORDANE
U
U
0
U
U
ALPIIA-
CHLORDANE
U
U
.U
U
U
VINYL
CHLORIDE
U
U
U
U
U
1,2-DI-
CHLOROKTHANE
U
U
U
U
U
*   All concentrations are In ug/kg except chroalu* and lead.
R - Result a of analyala rejected due to aorne Indlccrepancy
U - Undetected
J - Eat I mated value

-------
Analytical results from the soil samples were used to locate source  areas
of the indicator chemicals.  At the beginning of  the investigation,  the
primary area of concern was the hazardous waste area.  However,  the
samples collected from under the hazardous waste  area failed to  show any
detectable concentrations of indicator chemicals.  The hazardous waste '
area should still be carefully considered since records  (refer to Appendix
B) show that significant amounts of the indicator chemcials were deposited
there.  The absence of indicators reveals only that no residual  contaminants
were present in the soil below the hazardous waste area where the samples
were collected.  However, migration of contaminants from the hazardous
waste area to the ground water by infiltration and percolation will  occur
if conditions at the site remain unchanged.

Three other areas within the municipal fill area  were identified as  poten-
tial contaminant sources.  Figure 4 shows the locations  of these areas.
The contaminants detected within these potential  source areas can be
generally classified as slightly soluble and insoluble.   The areas containing
slightly soluble chemicals must be considered as  sources  for ground  water
contamination.  The areas which contain insoluble chemicals can  be considered
immobile with regards to transport by infiltration and ground water.
Based upon the available records, the hazardous waste area is known  to
contain slightly soluble contaminants.  Because of the presence  of Alpha-BHC,
area number one can be classified as slightly soluble sources.   Area
number two, which contains low concentrations of  dieldrin and chlordane
related chemicals, can be classified as a stable  insoluble source.   Area
number three, which is actually connected to area number  one, was identified
separately because it contained concentrations of mostly insoluble chemicals
such as chlordane, toxaphene and dieldrin, which  are stable in soil.
Photographs taken by Georgia EPD personnel confirm that  pesticides were
deposited in area three.

Figure 5 shows the age relationship of coastal plain geological  units in
western Georgia.  These units were confirmed at the site  by lithological
and geophysical logging 'of the municipal fill bore holes  and monitor well
holes.  The logging indicated that the subsurface is composed of alternating
layers of sands and clays with varying mixtures of the two.  The layers
vary in thickness from less than an inch to approximately 30 feet.

The overlying Gosport Sand unit is composed predominantly of medium
grained sand and outcrops mainly in the northern  portion of the  site,
outside the area of waste burial.  The Providence unit is composed of
interlayered sands, clays and clay sands which are commonly cross-bedded
and channeled.  Minor gravel layers occur but form no persistent units.
Both units are of recent Cretaceous age.
                                            «-»

-------
            •IK II
CONTAMINANT OOUflCE LOCATIONS

-------
 SERIES
    UJ

    s
    §
    O

    O

    Id
    UJ
     Ld

     CJ
     tr
     u

     e
     UJ
     a.
     a.
WESTERN GEORQA
            OCAUA UUESTONE
             ffi
LISBON FORMATION
          TACUHATTA FORMATION
                          rux
            JSCAHOMA FORMATION
          I
           CLAYTON FORMATION
            PROVIDENCE SANO
            R1PLEY rORMATlON
              CUSSETA SANO
          8LUFTTOWN FORMATION
            EUTAW FORMATION
          TUSCALOOSA FORMATION
                       SURFACE UNIT IN PEACH  COUNTY
                                  LEGEND
                                                   UNITS NOT REPRESENTED

                                                   IN WESTERN GEORGIA
NOTE:  MODIFIED  FHCU BROCKS.  CUkflKE  AND FAYE. 1983, 1C #75
REM II
GENERALIZED GEOLOGIC COLUMN
POWERSVILLE LANDFILL SITE
PEACH-COUNTY. OFHRQiA
FIGURE N<
5

-------
The .thickness of the Gosport Sand unit was not determined  in  the site area
but has been reported in similar areas as being  up  to  60  feet thick.  The
boreholes indicate that the Providence sands and clays extend from an
average surface elevation of 460 feet above rasl  to  at  least  270 feet
above rasl.  The base of the oldest Cretaceous unit  in  the  Powersville
area occurs at an elevation of approximately 480 feet  below sea level.
Thus, a thickness of approximately 1,000 feet can be assumed  for the
.Cretaceous units in the area.  The Cretaceous unconformably overlies the
raetaraorphic Piedmont complex in the region.
Hydrogeology

The goals of the hydrogeologic investigation were to develop a more defi-
nitive understanding of the local geology, to establish  the direction of
ground water flow, to determine the various physical parameters associated
with the site and to determine the sources and extent of contamination.
To accomplish this, nine additional monitor wells were installed -  (MW-9A,
MW-12 through MW-19).  Figure 6 shows the location of the monitor wells
and private wells that were sampled.  The groundwater flow in the vicinity
of the site occurs in an unconfined sand aquifer with the phreatic  surface
at a depth ranging from 50 to 75 feet below the ground level.  Considering
the geology of the region, the bottom of the aquifer should be located at
the base of the Providence Sand unit several hundred feet below.  The
direction of flow is generally toward the southeast (Figure 7).

Some water appears to be perched on several clay lenses  which occur in
the permeable sands.  This perching effect was noted by  the slightly
elevated water levels measured in the shallow monitor wells which were
screened above the clay.  From the results of the geophysical and litho-
graphic logging, there appears to be no continuous clay  layer present in
the upper region which could form an extensive confining unit, so the
perching effect must be considered as a local condition.  The perched
regions must, likewise, be considered hydraulically connected to the
lower region.

The values of the hydraulic conductivity ranged from 3.5 to 11 feet per
day in the upper sand and silty sand zones.  In the lower sand zones, at
depths greater than 120 feet, the values ranged from 5 to 7 feet per day.
The main region of interest in the aquifer as a migration pathway is the
upper zone where the clay lenses cause the perching of. the ground water.
The perched zones averaged about 30-60 feet in thickness above the  clay.
Using average values for thickness and hydraulic conductivity of 40 feet
and 7 feet per day respectively, the transmissitivity for the upper zone
was determined to be 280 square feet per day per.  The slope of the
hydraulic gradient at the site averages in 9 vertical drop of .0025 to
.0030 feet per foot of length.

-------
               REM II
PRIVATE & MONITOR WELL LOCATIONS
    POWERSVILLE LANOFILL SITE
                                                           '•	-^.^r*^"

-------
NOTTS:  1) BOHOM or SCXCEN A80VF w*TCT LCVC1       2) SC»CFV*0 M OAV :o«
                                               HEM h
                              GROUND  WATER CONTOURS (JULY  1986)
                                   POWERSVILLg UVNDFIM, SITF

-------
The analytical results of the ground water samples collected during  the
remedial investigation (February^July, 1986)  from the existing.monitor
wells, the.new monitor wells and the private wells during  the study  are
summarized in Table 6.  Those results and the results reported in the
previous NUS study were used in the endangerraent assessment to evaluate
the potential health risk associated with the consumption  of ground  water
from the site.  Two scenarios were used to evaluate the potential health
risks:  a current-use scenario and a futureuse scenario.   The assessment
was performed on the basis that no remedial action would be performed.  The
future-use scenario assumed the leaching of contaminants from the soil
would be continuous with time.  The assessment calculated  the chronic
daily intake of contaminants using average concentrations  found at the
site and also projected maximum concentrations, thus developing a worst
case scenario.  The endangerraent assessment identified the following
chemicals as indicators for ground water:


        Alpha-BHC
        Gamna-BHC  '
        Vinyl chloride
        1,2-Dichloroethane
        Lead
        Chromium


The endangerment assessment concludes that there is a potential long term
health risk associated with the consumption of contaminated ground water
from the site.  The risk is associated with contaminants which are classified
as both carcinogens and noncarcinogens.  The  carcinogens are vinyl chloride
and 1,2Dichloroethane.  The noncarcinogens are chromium and lead.  The
benzene hexachloride (BHC) iscmers are considered possible carcinogens.
Table 7 summarizes the current and proposed standards for  the above
chemicals  (also referred to as Applicable or Relevant and  Appropriate
Requirements, ARAR).

The monitor wells at the site can be classified as shallow and deep
wells.  The shallow wells are those with screens set above the locally
confining clay lenses identified in the previous subsection.  These
lenses occur at depths of 30 to 60 feet.  Conversely, the  deep wells are
those with screens installed below the clay lenses.  The larger concentra-
tions of contaminants were found in shallow wells.

Vinyl Chloride was detected in three shallow existing monitor wells  and 1,2-
Dichloroethane was detected in one shallow existing monitor well.  Two of
the analytical values for vinyl chloride were estimated values.

Concentrations of chromium and lead were found in almost all of the  monitor
wells.  The highest concentrations were found in the existing shallow  wells
which are constructed of galvanized steel.  None of the concentrations of
lead or chromium detected in the new or deep wells exceeded the MCL  (50
ug/1 for both chemicals) established under the Safe Drinking Water Act (SCWA).


-------
                       TABLE 6

       ANALYTICAL IESULTS fO> INOICATM CNBMICALS
       IN HOKlTOt AND PIIVATC W8LL SAMPLES (ug/1)
                ro»erevllle Landfill Sit*
                  reech Countf> Georgia
                         •CM II
Type ol
Wall AJplw-MIC CaeM-ftHC
Vinyl
Chloride
1 ,2-Olchlofocthc
M Uad
ChroaluB
MW-OI Abandonee*
KW-02
KU-O1
MU-04
HW-Oi
WJ-06
HW-07
MU-08
•MW-09A
HW-IO
HW-II
•MW-12
•MU-IJ
•MW-14
•KW-li
•MW-16
*nt-n
•MW-J8
•»«-l9
rw-oi
PU-02
pw-oi
PW-O4
pu-05
PW-06
PM-07
PW-08
PU-O9
PU-II
••W-12
PV-A6
S
s
S
s
s
s
D
S
S
S
s
0
D
0
D
D
S
D
S
-
-
-
-
-
-
-
-
-
-
"
u
u
u
.42M
U
U
U
U
0.)
.I9N
U
U
U
U
U
U
0.)
U
0.41
U
U
U
U
U
U
U
U
U
U
u
u
u
u
u
u
u
u
u
.J8J
U
u
u
u
u
u
u
0.32
U
0.78
U
U
U
U
U
U
u
u
u
u
u
U
4J
U
18
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
U
u
U
17
U
u
u
u
u
u
u
u
u
u
u
u
u
u
u
u'
u
u
u
u
u
u
u
u
u
u
u
u
u
2000
220
I/O
70UJ
490
BOUJ
u
90UJ
200
U
U
JOU
JOU
u
30UJ
JOUJ
20UJ
U
u
u
u
u
u
6.)
U
u
u
u
u
U
220
140
22
40
43
10
7
24
14
32
U
14
U
21
21
U
IS
u
u
. u
. u
u
u
u
u
u
u
u
u
*  Den Ignite* new Monitor well
J- t*l lM«ied value
   Pre«u«ptlve evidence
  ^Undetected, nueibcr ehown le
   Sh.llow w«||
n- rw-cn '^i i
lnlaiui detection Halt

-------
                                  TABLE 7

            APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS.
                      FOR INDICATOR CHEMICALS  (ug/1)
                         POWERSVILLE LANDFILL SITE
                           PEACH COUNTY,  GEORGIA
                                  REM  II

INDICATOR
CHEMICAL

Alpha-BHC
Gamma-BBC
Toxaphene
Chlordane
Vinyl Chloride
1,2-
Dichloroe thane
Lead
Chromium
SAFE DRINKING
WATER ACT
INTERIM
(MCL)
—
4'
5
	
	

—
50
50C
SAFE DRINKING
WATER ACT

(MCL)
	
	 .
—
	
2

5
—
— —
SAFE DRINKING
WATER ACT
PROPOSED
(RMCL)
	
0.2
0"
0" '
—

ob
20
120e
*ARAR is for Lindane (99% gamma-BHC)
 Recommended Maximum Contaminant Level is set for zero for
 all potential carcinogens
cTotal chromium (hexavalent and trivalent)
	No ARAR available

-------
The Benzene Hexachloride isoners (alpha and gamma) were detected  in  five
shallow wells.  Area 1 and the hazardous waste area,  shown  in  Figure 4,
were considered as sources of the slightly soluble BHC chemicals.  Gamna
BHC is the only BHC isoner with .an MCL (4 ug/1) established under  the SDWA.
None of the BHC concentrations exceeded the MCL set under the  SDWA..

All of the contaminant concentrations which exceeded existing  standards were
detected in shallow wells with screens located above  the clay  lenses.  These
data indicate that the contamination is limited to the upper zone  of the
aquifer" where the water is perched on the clay lenses.  Although  the deeper
zones of the aquifer are hydraulically connected to the perched regions,
they appear to be free of contamination.  This would  indicate  that downward
movement of the contaminants is presently being restricted by  the  multiple
overlapping clay lenses.

Based upon the analytical results and existing standards, the  following goals
for cleanup of contaminated ground water were selected, should such  a. task
be required.
     Gamma - BHC
     Vinyl Chloride
     1-2, dichlroethane
     Lead
     Chromium
 4 ug/1
 1 ug/1
 5 ug/1
50 ug/1
50 ug/1
Surface Water & Sediment Investigation

The purpose of this section was to determine if any contaminant migration by
way of runoff had reached the local streams.

Site Drainage & Runoff

Surface soil and leachate samples were collected from the site area to deter-
mine if surface runoff should be considered as a migration pathway.  Although
surface runoff in the area is minimal due to the sandy soil, heavy rains are
often sufficient to produce erosion and possibly carry contaminants off the
site.  Figure 8 identifies the locations of where these samples  (RO-1 through
RC-6) were collected.

There was little evidence of leachate present at the site, however, four
samples, LFL 1-4, were collected from suspected leachate points  as shown in
Figure 8.  Surface runoff is generally toward the southeast through runoff
channels that direct surface water to a ditch parallel to State  Highway 49.
The channels are located to the northeast and southwest of Lizzie Chapel.
Sediment samples were collected from both channels  (samples RC 2-5).  In
addition, sediment samples were collected at the culvert which crosses
under Highway 49 (RC-6) and from the erosion channels that carry surface
runoff down the hill from the hazardous waste area  (RC-1).


-------
                                HAZARDOUS WASTE AREA
                    APPROXIMATE
                       BOUNDARY
                                    UZZIE
                                     HAPSL
                   • RUNOFF CHANNEL SAMPLE

                   A LANDFILL SAMPLE
                                                    SCALE IN FEET
     .  .                REM II
LEACHATE & RUNOFF CHANNEL SAMPLE LOCATIONS
           POWERSVILL6 LANDFILL SITE
                PEACH COUNTY. GEORGIA
FIGURE NO.

    8

-------
Table 8 sumnarizes the analytical results of the surface soil and  runoff
channel samples.  The endangerment assessment  identified dieldrin  as an
indicator chemical for surface soils although  it was only detected in two
samples.  Typical background concentrations for the area were taken from
standard publications for comparison.  Dieldrin was found to exceed the
typical background concentrations.

However, only one of the soils samples contained a concentration higher
than- the typical values.  Since there are no existing standards for
maximum allowable contaminant concentration in soil, typical background
levels were used to determine the cleanup goals.  The cleanup goal of 20
ugAg was selected for dieldrin.  Based upon the analytical results of
the sampling and the absence of indicator chemicals in the associated  "
sediment, surface runoff is not a pathway for contaminant migration.  The
erosion observed at the site does, however, indicate potential future
problems with surface runoff.

The possibility of a potential health risk resulting from physical contact
with surface soil was also considered.  The endangerment assessment
evaluated the risk associated with direct contact with the soil over both
a short and long term period.  The endangerment assessment considered the
results of all samples collected during this remedial investigation in
addition to the results of two soil and one leachate sample taken  from
the site during a previous investigation in January 1984.  The conclusion
of the endangerment assessment was that no health risk is associated with
short term contact with the surface soils and only a marginal risk (5xlO~^)
would be associated with long term contact.

Surface Water & Sediment

In conjunction with the collection of samples from runoff channels, surface
water and sediment samples were taken at locations adjacent to the landfill
to determine if any contaminant migration to nearby streams had occurred.
(Figure 9).  However, due to drought conditions, the collection of both
surface water and sediment samples were possible at only three locations
as indicated in Table 9.  The sample location on Mule Creek upgradient of
the site (SW-4/SD-4) was selected as background for comparison.  Table 10
and Table 11 show the analytical results for surface water and sediment
samples, respectively.  No chlorinated organics or other compounds associated
with the pesticides disposed of at the site were detected in either the
surface water or the sediment samples.  The endangerment assessment found
none of the detected chemicals in these samples to be toxic to human or
aquatic life.

No indicator chemical was identified for surface water.  Based upon the
analytical results, contamiant transport by runoff for the site to local
streams was determined not to be a migration pathway at this time.

Air Investigation
Air monitoring levelt never exceeded the action level oŁ 5 ppb above back-
ground during  che remedial investigation.  The endangerment assessment
detenu nod that there was no short term health risk assoicated with the
site except during activities such as construction or excavation, which
may expose huiis3d- contaminants.  -

-------
                                 TABLE 8

                       SUMMARY OF ANALYTICAL RESULTS
               FROM SURFACE SOIL AND RUNOFF CHANNEL SAMPLES
                         POWERSVILLE LANDFILL SITE
                           PEACH COUNTY,  GEORGIA
                                  REM II
Compound
    Sample
Concentrations
    Range
   (mg/kg)
Number of Samples
 above Detection
Limit/Total Number
   of Samples
  Background
Concentrations*
    Range
   tag/kg)
Arsenic
Chromium
Vanadium
Aluminum
Manganese
Magnesium
Iron
Barium
Calcium
Lead
Dieldrin
<5.1-37
<9.1-30
r-
3.1-56
260-18,000
6-240
< 45-250
3,200-32,000
3.4-48
<160-510
<2.6-27
<7.9-37b
3/11
10/11
10/11
11/11
11/11
3/11
11/11
6/11
5/11
3/11
2/11
< 0.2-73
7-150
10-100
2,000-50,000
20-700
100-1,000
10,000-50,000
30-150
200-5,000
<10-15
<10-20b
  Sources:  Inorganic compounds - USGS 1975 (samples taken from Georgia

  plow zone); Dieldrin-Carey 1979 (samples taken from Georgia cropland

  soils).  The background concentrations were selected as representative

  of the agriculture area surrounding the Powersville Landfill Site.
  ug/kg.

-------
                    REM n
SURFACE WATER AND SEDIMENT SAMPLE LOCATIONS
          POWERSV1LLE LANDFILL 31TE
              PPACH COUNTY. GEORGIA
FIGURE wp.

   9

-------
                                  TABLE 9
              LOCATIONS OF SURFACE WATER AND SEDIMENT SAMPLES
                         POWERSVILLE LANDFILL SITE
                        •   PEACH COUNTY,  GEORGIA
                                  REM  II
Figure
 Code
Type of Sample
    Taken
Sample'Point Description
SW-1
SD-1
SW-2
SD-2

SW-3
SD-3

SW-4
50-4
sw-5
SD-5

SW-6
SD-6
    None (Dry)      Upgradient on tributary northeast
    None            of the site, insufficient flow to
                    sample.

    None (Dry)      On tributary north of Centerville
    None            Road, insufficient flow to sample.

    Water           On tributary north of Powersville
    Sediment        Road.

    Water           Mule Creek swamp area approximately
    Sediment        0.5 miles northwest of Georgia
                    Highway 49.

    None (Dry)      On tributary west of Georgia
    None            Highway 49.

    Water           Mule Creek swamp area approximately
    Sediment        0.25 miles south of Powersville
                    Road.

-------
                                TABLE 10
                    SUMMARY OF ANALYTICAL RESULTS FROM
                           SURFACE WATER SAMPLES
                         POWERSVILLE LANDFILL SITE
                           PEACH COUNTY, GEORGIA
                                  REM II
Compound
Barium
Zinc „
Manganese
Calcium
Iron
Sodium
Copper
Magnesium
Methylethyl
ketone
Lead
Range of
Downgrade en t
Samples*
(ug/1)
15-34
7-12
97-260
1,400-3,900
1,600-4,300
1,700-3,600
<2.8-3
1,000-1,400

<10-16
<5
Concentration
of Upgradient
Sample"
(ug/1)
12
6
89
760
1,700
1,900
<2.8
440

<5
<5
Number of Samples
with Compound above
Detection Limit/
Total Number
of Samples
3/3
3/3
3/3
3/3
3/3
3/3
1/3
3/3

1/3
0/3
* Sample locations SW 03, SW 06.

b Sample locations SW 04.


-------
                                 TABLE 11
                    SUMMARY OF ANALYTICAL RESULTS FROM
                          STREAM SEDIMENT SAMPLES
                         POWERSVILLE LANDFILL SITE
                           PEACH COUNTY,  GEORGIA
                                  REM II
Compound
Barium
Zinc
Manganese
Calcium
Iron
Copper
Chromium
Aluminum
Vanadium
Magnesium
Cobalt .
Nickel
Lead
Range of
Downgradient
Samples*
(ug/1)
2.7-160
2.3-35
7,9-140
24.8-1,000
4,200-15,000
< 3. 3-17

-------
Endangered & Threatened Species

The Department of the Interior (DOI), in their Preliminary Natural  Resources
Survey of the site, states  that the habitat  in the area  is not  used or
suitable for use by any endangered species.  DOI did, however,  determine
that migratory birds use  the site for feeding, nesting and cover.   There
are no DOI lands or trust resources in the vicinity.  The information
contained in the RI/FS and other investigations indicates that  off-site
contamination of surface waters or surface soils is unlikely  at present.
Based on pre-RI/FS investigations, DOI does not believe  that migratory
birds will be exposed to  contaminants, and has therefore determined that
no cause exists to pursue a claim for damages to natural resources  under
their trust for this site.

-------
     Section IV
Enforcement Profile
                                  1984.  The


                                       On
The initial RI/FS notice letters were sent out on September 28, 1984
recipients included Peach County and the United States Department of
Agriculture.  On November 20, 1984, a notice letter was also sent to
Canadyne Georgia Corporation, which owns Woolfolk Chemical Company.
July 15, 1985, EPA Region IV issued an Administrative Order on  consent,
and Peach County and Canadyne Georgia were granted until  November  1,
1985,  to present a revised Consent Order to EPA.  Since neither party
ever submitted a revised order  by  that  date negotiations  were terminated
and EPA initiated RI/FS  activities.  A  November 4,  1985 letter to  Canadyne
Georgia confirmed their  unwillingness to conduct the RI/FS.due to  a lack
of additional PRPs willing  to conduct the  RI/FS.

 Notice letters for  the RD/RA were issued  on August 21, 1987, to Canadyne
 Georgia, Peach County, the Department of  Agriculture, and Eagle Bridges
 Paint Company.  The latter party was discovered through PRP search efforts
 conducted after the RI/FS notice letters were issued.  On September  18,
 1987, a group of PRPs met with EPA to  initiate  negotiations on the site.

-------
                                   SECTION V

                            ALTERNATIVES EVALUATION


Public Health & Environmental Objectives

The problem at the Powersville Landfill Site can be divided into two categories,
contaminated soil and contaminated ground water.  Both are potential pathways
for migration of contaminants.  Soil is a pathway by physical contact or
ingestion of contaminated soils.  Ground water acts as a pathway when contaminants
in the aquifer are transported to wells which supply drinking water.  The
remedial investigation  identified areas of contaminated soils which contain  the
following types of chlorinated organics and pesticides:

        Benzene Hexachloride  (BHC) - slightly soluble
        1,2-Dichloroethane - soluble
        Dieldrin - insoluble
        Chlordane - insoluble
        Toxaphene - insoluble

The contaminated ground water contains the following chemicals:

        Benzene Hexachloride  (BHC)
        1,2-Dichloroethane
        Vinyl chloride
        Lead
        Chromium

The endangerment assessment for the Powersville Landfill Site has evaluated  the
potential risks to public health and the environment from chemicals detected in
ground water and soil on site based on data generated prior to the RI/FS Report.
Using an excess lifetime cancer risk of 10~6 and a hazard index of one as points
of comparison, under the current-use scenario, the assessment indicates that there
is a potential long-term health risk associated with consumption of ground
water for the Lizzie Chapel well; no health risk is associated with contact
with landfill surface soils.  Under a future-use scenario in which the site  is
redeveloped and a drinking-water well is established on site, a potential
long-term health risk' is associated with ground-water consumption, but not with
soil contact during construction.  A marginal risk of 5xlO~~6 is associated with
future residents who may come in contact with landfill soils under a plausible
maximum case scenario.

The assessment of risk from ground water at the site is based in part on an
equilibrium model that assumes that pesticides in the soil will leach into the
ground water.  The model probably overestimates the actual leaching.  Because
pesticides have generally low mobility in soil-ground water systems, the actual
leaching and a gradual increase in ground-water concentrations may take place
over a long period of time.

A comparison of data collected under a previous investigation by NUS (in 1984-
1985) with the current  study  indicates that the overall risk levels for soil
exposure, drinking water wells, and monitor wells are similar.  For the private

-------
wells, the NUS data  indicates the possible presence  of  low levels  of  volatile
organics, which would add slightly .to the overall  risk.   The  NUS data for
monitoring wells  indicates a lower risk compared  to  the CEM data;  however,
predicted by the  soil leaching model.

Technologies Considered

Several technologies were considered for remediating the Powersville  site.   The
technologies were presented in.groups targeted at  remediating a single aspect
of the site.  Table  12 shows the technologies'considered for  remediation of
surface and groundwater contamination, technologies  considered for remediation
of soil contamination, and technologies responding to institutional controls.

Several combinations of technologies will provide  remedial actions which comply
with applicable,  relevant and appropriate environmental laws. However,
preference was given to treatment technologies or  resource recovery options
which reduce the  toxicity, mobility or volume of  the waste to the  maximum extent
practicable.  Remediation of the site will respond to issues  raised under the
Safe Drinking Water  Act (SCWA), Clean Water Act (CWA),  the Resource Conservation
and Recovery Act  (RCRA).

Figure 10 is a schematic diagram showing the preliminary group of  technologies
identified.  The  remainder of this section provides  a brief description of
each remedial response technology that was screened.

Screening Of Technologies

The screening of  remedial action technologies and  altenatives uses a  broad
evaluation criteria  based on technical feasibility,  public health, environmental
protection and cost. The purpose of the initial  screening is to eliminate all
technologies except  those that are applicable and  feasible based on the site
conditions.  The  retained technologies will be used  to  develop remedial action
alternatives.  A  more detailed screening will then be performed on each of the
selected alternatives.

Screening based upon technical criteria involves  eliminating  technologies that
may prove extremely  difficult to implement, that wil not achieve the  remedial
objectives in a reasonable time period, or that rely on unproven technology.
.Technical feasibility factors considered in the non-economic  analysis of
technologies include effectiveness and reliability of the proposed systems.
The remedial action's effectiveness is measured in terms of its ability to
control and eliminate public health and environmental risks and to protect
natural resources.   Reliability can be expressed.as  the degree of  assurance
that the selected remedy will meet or exceed the  cleanup objectives as well  as
the remedial action  expectations.

Using environmental  and public health criteria, technologies  posing significant
adverse environmental effects will be excluded.  Only those technologies that
satisfy the response objectives and contribute substantially  to the protection
of public health, welfare, or the environment are  considered  further.   The
evaluation of public health and environmental protection involves  a collective
assessment cf demographic, geographic, physical, chemical, and biological
factors that contribute to the impacts of hazardous  substances.

-------
Table 12.  All Technologies Considered for Remedial Response at  the
           Powersville site.
Ground Water

0  Ground Water Extraction
0  Injection Wells
0  Activated Carbon Adsorption
0  Biological Treatment
0  Filtration
0  Precipitation/Flocculation
0  Sedimentation
0  Ion Exchange/Sorptive Resins
0  Reverse Osmosis
0  Air Stripping
0  Spray Irrigation
0  Horizontal Irrigation
0  In situ Treatment by Neutralization
0  In situ Treatment by Hydrolysis
0  In situ Treatment by Oxidation-Reduction
0  Permeable Treatment Beds
0  Polymerization
0  Slurry Walls
0  Grout Barrier
0  Sheet Piling
0  Subsurface Drains
0  Alternate Drinking Water Source
0  Relocation of Receptors

Surface Water

Although surface water was not characterized as a problem at the Powersville
Site, surface runoff resulting from the application of other technologies will
have to be addressed in the development of remedial alternatives.  The
following sub-sections describe technologies that deal with the collection and
diversion of surface water.  Collection and diversion techniques are designed
to prevent both surface water infiltration and off site transport of contaminated
surface waters.

0  Channels and Waterways
0  Seepage Basins and Ditches

Soils and Sediments

0  Excavation and Off site Disposal
0  Excavation and Onsite Disposal
0  Excavation and Thermal Treatment
0  Capping
0  Solidification and Stabilization
0  In Situ Treatment by Chelation
0  Enzymatic Degradation
0  Extraction (soil flushing)
0
   Hescoration and Vegetation

-------
Other

0  No Action
0  Monitoring
0  Resident Relocation
0  Air Monitoring

-------



T?
O
•o m
> 5
~^
d !—
1-
o 2.
IT f-i
s§
2 r-
> r-
O)
-*
m




TJ
33
m
I
2
31
O
33
O
C !D
o =

-1
m
o
X

0
r"
O
Q
rn
O)
-n
0
' 0 3) J
GROUND MIAIfR It
 SUtfACt WA11M

-------
Cost screening involves the elimination of technologies  that have an estimated
present worth cost far greater that the other  technologies  under consideration.
For the initial screening, the cost estimates have an accuracy of plus  50
percent and minus 30 percent.  The total cost  includes the  cost of  implementing
(planning, permitting, testing and construction) the technology in  addition to
the cost of operation and maintenance (O&M).  The ratio  of  present  worth capital
costs, to the present .worth operation, monitoring, and maintenance costs are also
considered.

The Superfund Amendment and Reauthorization Act (SARA) of 1986 stipulates that
preference should be given to treatments that reduce the volume,- toxicity or
mobility of the hazardous waste even if the estimated present worth cost may be
greater than other technologies that dp not.

Cleanup criteria for assessing the effectiveness of the  remedial technologies
selected for use at the Powersville Landfill Site will be based on  applicable or
relevant federal and state standards and criteria.  The  contaminants selected
as indicator chemicals in the endangerment assessment will  be used  to evaluate
the cleanup operations.  Applicable drinking water standards for the indicator
chemicals are summarized in Table 7.  There are no established criteria or
standards for soil.  Cleanup'criteria for soil were based on background soil
concentrations.

The following cleanup goals will be considered for preliminary screening purposes:

     0  Surface Soils
           Diedldrin                    20 ug/ng

     0  Subsurface Soils
           Alpha-BHC                    *
           Toxaphene                    *
           Chlordane                    *

     0  Ground Water
           Gamma-BHC                     4 ug/1
           Vinyl Chloride             .   1 ug/1
           1-2, Dichloroethane            5 ug/1
           Lead                         50 ug/1
           Chromium                     50 ug/1

*  No standard exists and no concentrations above detection limits  were found
   in background samples.

Technologies Eliminated

Several technologies were eliminated in the preliminary  screening phase and in
.the detailed screening (Table 13).  The following is a list of remedial options
which were eliminated during the screening phase and the reasons for elimination.

-------
TABLE 13.      Technologies Eliminated During the Powersville
               Site Screening Process
   -Technologies Eliminated
       Reason
   Soil Technologies

   In situ - Chelation
   Enzymatic Degradation
   Extraction (soil flushing)
   Attenuation of Soil
Ineffective for pesticides
Lack of development; impractical
Difficult to apply to pesticides and in combination
Waste too deep for effective use
   Water Technologies

   Injection Well

   Biological Treatment
   Ion Exchange/Sorptive Resins
   Reverse Osmosis
   In situ - Neutralization
   In situ - Hydrolysis
   In situ - Oxidation/Reduction
   Permeable Treatment Beds
   Polymerization
   Slurry Walls
   Grout Barrier
   Sheet Piling

   Subsurface Drains
   Relocation of Receptors
Aquifer is only water source:  state regulatory
   prohibits
Ineffective for halogen and insoluble compounds.
Difficult to apply; other method more effective
Difficult to apply; other method more effective
Plume not acidic or basic
Possible toxic end products
Possible toxic end products
Water table too deep
Not good for a mixture of compounds
Water table too deep
Unconsolidated soil and water table too deep
Water table too deep; primary flow from source is
   vertical
Water table too deep
Impractical; alternate source easier to implement

-------
Soil Technologies
        In Situ-Chelation - This technology is effective for inmobilizing metal
        cations but is ineffective for treating pesticides.  Chelation would
        be difficult to use in combination with other technologies.  Research on
        this technique for application to hazardous wastes sites is very limited.
        This, technology will no longer be considered.

        Enzymatic Degradation - Enzymatic treatment is a very precise technology.
        Specific enzymes must be matched with specific contaminants.  The currrent
        state of development of this technology does not provide any practical
        method for application to large amounts of soil, therefore it will no
        longer be considered.

        Extraction (Soil Flushing) - Complexing and chelating agents would have
        to be used in the flushing solution to remove heavy metals.  Surfactants
        can be used to improve the treatment of low soluble compounds, however,
        the availabilty of appropriate surfactants for use with the low soluble
        chlorinated organics found at the Powersville Site is limited.  Because
        of the combination of pesticides and metals found at the site, this
        technique would be difficult to apply.  The technique is also difficult
        to use in combination with other technologies.  Extraction is better
        suited for use with soluble compounds other than pesticides and will no
        longer be considered.

        Attenuation of Soil - Clean soil may not be readily available onsite,
        and use of attenuation is not technical feasible for contamination at a
        depth greater than 3 feet.  The contaminated soil at the Powersville
        site extends to a depth of approximately 30 feet.  This technology will
        not be retained for further consideration.

-------
Water Technologies
        Injection Wells - Injection wells could be used  for one of two purposes.
        The first technique involves the injection of clean water into the
        aquifer to force contaminated water toward extraction wells.  This method
        would be difficult to use at the Powersville Landfill site due to the
        multiple clay lenses and perched water table.  In addition, there is no
        readily available source for clean water at the  site other than pumping
        from deeper in the aquifer.  Injection of treated ground water back
        into the aquifer can also be done.  However, state regulations prohibit
        such injection.  This technology is impractical  and will no longer be considere

        Biological Treatment - Biological treatment has  a limited effectiveness
        for the degradation of halogen-substituted organic compounds and
        insoluble compounds.  This method should not be  used when the treated
        water is to be used for final consumption by humans or animals unless
        the water is processed afterward for removal of  all bacteria.  This
        method will no longer be considered.

        Ion Exchange/Sorptive Resins -  Ion exchange is useful for the treatment
        of water with low levels of heavy metals and sorptive resins can remove
        a variety of organic compounds.  The treatment process is expensive and"
        difficult to apply.  Other technologies are more reliable and practical,
        therefore, this technique will  no longer be considered.

        Reverse Osmosis - Reverse osmosis requires a high level of maintenance
        to prevent membrane plugging.   Compared with other treatment technologies
        this is a complicated process to operate and is  significantly more
        expensive without additional benefits.  Therefore, reverse osmosis will
        not be retained for further consideration.

        In situ Neutralization - This technology is useful for the treatment
        of acidic or basic plumes in ground water.  These conditions are not
        applicable to the Powersville Site and this technology will not be
        retained for further consideration.

        In situ Hydrolysis - This technology require an  in depth research of
        the contaminants present and the reaction pathways.  Hydrolysis reaction
        products may be more toxic than the original compounds.  This is therefore
        not a good method for the in situ treatment of ground water.  It will
        not be retained for screening.

        In situ Oxidation-Reduction - Oxidation-reduction is useful for the
        treatment of wastewater but" it  is not practical  for the in situ
        treatment of ground water.  There is also the possibility of the
        formation of more toxic or mobile degradation products.  This method
        will not be retained for further consideration.

-------
Permeability Treatment Beds - This technology is applicable  for areas
with a shallow water table.  Permeable treatment beds require a high
degree of maintenance resulting from bed saturation, precipitate plugging
of bed, and short life treatment of materials.  Due to the depth of the
water table at the Powersville Landfill Site and the degree  of maintenance
required for this technology, it will no longer be considered.

Polymerization - This technique is applicable for the treatment of
ground water contaminated with a single compound.  Polymerization
does not remove contaminants from the aquifer; some chemical reactions
can be reversed allowing contaminants to again migrate with ground
water flow.  This procedure has limited application at an uncontrolled
hazardous waste site with a mixture of chemicals.  Polymerization will
not be retained for further consideration.

Slurry Walls - The use of slurry walls is generally limited  to sites
with shallow water tables.  The water table at the Powersville site
ranges approximately 50 - 70 feet in depth.  The existence of multiple
clay lenses would make it very difficult to select the appropriate
Impervious layer for confinement.  This technology is, therefore,
impractical for use at this site and will no longer be considered.

Grouting - In order to apply this technology at the Powersville Site,
the grout would have to be injected into the soil surrounding the source
of contaminants.  Because a grout curtain can be three times as costly
as a slurry wall, it is rarely used when ground water has to be
controlled in unconsolidated soil such as present at this site.  The
best application of this method at waste sites is for sealing voids in
rocks.  This technology is therefore impractical and will no longer be
considered.

Sheet Piling - Because the sources of contamination are located in the-
unsaturated zone approximately 50-70 feet above the water table, the
flow direction of water through the source area is primarily vertical
in lieu of horizontal.  The use of sheet piles is generally  limited to
horizontal barriers.  Therefore, this technology is impractical and
will no longer be considered.

Subsurface Drains - The use of subsurface drains to intercept the flow
of ground water is limited to sites with a shallow water table.  The
50 - 70 feet depth of the water table make the use of subsurface drains
impractical.  Therefore, this technology will no longer be considered.
However, the use of collection drains for surface runoff will be retained
in combination with control of surface water.

-------
     0  Relocation of Receptors - Although relocation of local residents
        and receptors is possible, this is not a practical option.  Legal
        aspects, cost and consideration of public opinion make such a
        solution questionable.  The option of an alternate water source
        provides the same solution in a much more practical manner,
        therefore this technology will no longer be considered.

Surface Water

Since surface water has not been identified as a problem at the Powersville
Landfill Site, collection of surface water and runoff will only be
considered in combination with other technologies which alter the area or
cause a diversion of water,  this technology will not be discussed
separately, but will be included in the consideration and pricing of
other related technologies.

Air Control Technologies

Air contamination was not identified as a problem at the Powersville
Landfill Site, however, the application of other technologies may require
the consideration of provisions for air monitoring.  Any technology which
involves excavation will require temporary dust control and air monitoring
procedures.  Similarly, any application of source capping or encapsulation
will require gas control provision for venting gas generated during
decomposite of wastes.  Air control technologies will not be considered
separately any further.  Air control provisions will only be considered
and included in combination with other technologies as required.

Technologies Retained

Several technologies were retained for final consideration as alternatives
for remediating the site.  These individual technologies are listed in
Table 14.  In -depth discussion of each technology can be found in the FS.

During the Feasibility Study process, the retained technologies were
grouped into remedial units which would accomplish specific remedial
objectives.  These remedial units were then combined to develop full
remedial alternatives which would respond to the conditions surrounding -
the Powersville site.  A total of 13 comprehensive remedial alternatives
were designed from the various technologies retained after the screening
process.  Each of the possible alternatives was analyzed based on
effectiveness implementability and cost.  A general .summary of the concerns
surrounding each technology is presented in Table 15.  It is important to
note that the No-Action alternative is included in the 13 alternatives
considered for final remedy slection although it was eliminated during
the initial screening phase.  The No-Action alternative must be included
at this point to fully comply with the legal requirements.

ALTERNATIVE DESCRIPTIONS

ALTERNATIVE 1 - NO-ACTION ALTERNATIVE

Under the No-Action alternative, soils and groundwatei would romain
contaminated with toxic substances regulated by local, state, and federal
laws.  Potential impacts of no remediation might inciudo the fol'owinq:

-------
TABLE 14       "technologies Retained For Final Consideration
               to Remediate the Powersville Site
Soil Technologies

No-Action Alternative
Excavation and Offsite Disposal
Excavation and Thermal Treatment
Excavation and Onsite Disposal
Capping
Encapsulation (use as onsite disposal)
Solidification and Stabilization
Restoration and Vegetation

Water Technologies

No-Action Alternative
Groundwater Extraction
Activated Carbon Adsorption
Precipitaiton/Flocculation
Mr Stripping
 ?ray Irrigation
^orizontal Irrigation
Alternate Drinking Water Source

-------
                                                                        TABLE  15

                                                           SW*URI Of REHf.niAL ACTION ALTERNATIVES
                                                                  rouERSviLLe MNOFII.L SIT«
                                                                    PEACH COUNTT. GEORGIA

                                                                            •EN II
       ALTERNATIVE
                                nCHMICAL COMSIOMATIOMS
                                                                        ENVIRONMENTAL
                                                                    HEALTH CONS I DURATIONS
                                                                                                    INSTITUTIONAL CONSIDERATIONS
                                                                                                             ESTIHATED COST-
                                                                                                              RANGE ( 401
                                                                                                           CONriDENCE INTERVAL)
I.   No Action Altrrnatl>a
1.   Cap Natafdoii* Waal*
    Ataa;  Cap Municipal
    fill Ai«.
    Ooalle Inc Int r at loa>
    ol  Hafafdou* Waal*
    Arts; Cap Municipal
    Fill Al*a
    Solldll leal Ion/
    Slab!IlialIon ol
    Haiatdoua Waal* Acaa;
S.  Cap Haiaidoua Waal*
    At**; Cap Municipal
    rill At**; f»-p and
    Traal Ciound W.lat
Doc* mat faduca »olua)« of aoll
of oaltr cont*ajl*allon; doae not
laduca •Igraltoa.

Skould alUlnate »urlaca, alc-
korai* a»4 (rou»J xalac •Igrailon
t>«llw«yci laduca* awblllly b|r
pr*v««llo* of InfIlltalloa;
4oaa »ol caduca «oluaw ol
conlaailaalad aoll 01 (found
Matai.

rafllally all«l«al«a conlaal-
•atad aoll; ahould «ll»li>a(a
•itrlaca. alfkorna and iiound
vat* l a>lf«a(lon pathway a;
laducaa •obllliir by pt»vanilon
el !•!I It tat Ion; Joea not
laduca »oluaM ol conla«lnalad
grotind walar.

Should •llalnal* auclac*.
•IfboiiM and (found walet
•Ifcat Ion palhvara; i«duc«a
•obi Illy kr plavanlloo ol
lullllftllon; aluof raduclloa
l» toilcllr; •light Inccoaa
In loll voluB*; do«i not
laduca Ik* »O|UM ol
co'taalaialad (found watar.

Should alUlnala (uilaca. alt-
bo fna a>d (lound Malar ••(ration
•atKvaya; c«4uc«« •ability by
• r«*««llon ol lafl Ural Ian;
do*a not taduca Ih* «o|ua>« ol
coa)la«ln«l«4 Bolli r*4uc«a
voluaM ol conta«ln«l«4 ground
Matai.
Ooca not. cllalnat* flak
aaaoclalcd ullh ahotI or long
!*!• ground Malar conauaptlon.

Should allailnat* rlaia
aaaoclaled Mllh contact Milk
coniaelnaKd aol); altiMitn*
•l|tallon; long l«t« ground
Malar conauaptlon.
Should alUlnal* rlaka
aaaoclatvd Milk contact Mick
contact Milk contaminated coll;
alibotn* •Igratlon; long lara
ground Malar conauaplloo*
Should •llalncl* rlak*
aaauclalcd Mllh contact
Mllh conlaalnaKd •oil;
airborne algratlon; long
ground Malar coniuapllon.
                                                                Should cllalnaK rlaia
                                                                .aaaoclatcd Milk contact Mllh
                                                                conta*tnalcd aoll; airborne
                                                                •l(i>lIon; |on( !*!• ground
                                                                M*i«r conaunpllon.
                                                                                                  Ctound Malar and ill* ua*
                                                                                                  prohlbllcd.
                                                                                                  Ground Maler and all* uaa
                                                                                                  prohlbllad.
                                                                                                  Ground Malar and  alt*  uaa
                                                                                                  prohibited.
                                                                                                         }   )0;.000-f   411.000
                                                                                                                                      |).106.000-14.1.4.000
>».>14.000->II.li9.000
                                                                                                  Ground Malar  and  alia  uaa
                                                                                                  pfohlbllad.
f i.»»J.000-J l.m.OOO
                                  Slla ua* prohibited; ground M*l«r
                                  ua« prohibited  lor ahorl tern;
                                  NrotS paratttlng c*4)ulr«d lot dla-
                                  ckarge ol •tteaied Malar; aludga
                                  dlapoaal aay hava lo be conaldeiad.
                                                                      t 1.4JS.000-J  ».190.000

-------
                                                                       (continued)
       ALTC*. NATIVE
                                 TECHNICAL COMIMRATIONS
                                                                         CNVIIOMlKNTAL
                                                                    HEALTH CONSIDERATIONS
                                                                                                     INSTITUTIONAL CONSIDERATIONS
                                                                                                             ESTIMATED COST
                                                                                                              HAHCE ( iOI
                                                                                                           CONflDCNCe INTEXVAL)
6.
    Onelte  Inclnet at Ion  of
    Hatardoua Uaafe  Area;
    Cap Municipal  fI I I
    Area; fump and  Tieat
    Ciound  Water
I.
    Solidification/
    Slabllliel Ion ol

    Cap Municipal Pill
    Alea; Fump and Treat
    Ciound Water
8.  Cap Haiardoua Uaate
    Aica; Cap Municipal
    Fill Alaa; Alternate
    Walaf Source
f.  Onalte Incineration
    ol Haiardoua Waele
    Area; Cap Municipal
    rill Alaa; Alternate
    .Water Source
10. SolldHlcal Ion/
    St ablI IlatIon ol
    Hatardoua Waale Area;
   • Cap Municipal FlI I
    Aiaa; Alternate Water
    Source
Should •Main*.!* eurfaca, air-
borne and ground water Migration
pethwaye; ffeducee Mobility by
prevention of  IndllretIan;
doea not reduce Ik* volueie ol
contaalnated eoll; reduce*
volueM ol contaminated ground
»a«ar.

Should ellvlnal* (urlac*. air-
borne and ground netat algratlon
pattn>aia; reduce* •okllltr by
r>r««**tlo« ol  Inlllt rat Ion;
•Inor reduction In toilclty;
•light Incrca** In eolI eolwae;
doe* not reduce iroluaM ol
contanlnaled ground Mater.

Should ellnlnate aurlace, ali-
born* and ground xater •((ration
•airway*; reduce* nobility by
prevention of  Infiltration;
do«e not reduce the volu»« ol
conlanlnatad *oll or ground
oater.

Should •llejlnnte •urface. air-
borne and ground water Migration
•athwaya; reduce* Mobility by
prevention of  Infiltration;
reduce* *olun« of conlanlnated
•oil but not ground water.
Should el Initiate eurlace, air-
borne and ground water Migration
pathwaya; reducea Mobility by
prevention of Infiltration;
nlnor reduction In toilclty;
alight Increaae In aoll volime;
doe* not reduce volune of
content oated ground water.
Should ellMlnale rleka
aaeoclated with contect with
conlanlnated aoll; airborne
Migration; long tern ground
water conaunptlon.
Should eliminate rleke
aeeoclated with contact with
contaminated aoll; airborne
Migration; ahort and long tere
ground water cnneunptlon*
Should ellMlnete rlake
aaaoclated with cont*nln*ted
•oil; aliboine Migration;
•horl and long tern ground
water coneunptlon.
Should eliminate rleke
•••oclated with contact with
contaolnaled *oll; airborne
Migration; abort and long ten
ground water coneunptlon.
Should eliminate rlake
aaaaclated with contact with
contaminated eoll; airborne
Migration; ehort and long Itcra
ground water con*uMptIon.
Site uee prohibited; ground water
uee prohibited lor ehort lerM;
NfOES permitlInf required for die-
charge of treated water.
Site uee prohibited; ground water
uae prohibited lor ehoit term;
tlrOtS permitting required for die-
charge ol treated water.
Ground water and alte uae
prohibited.  '
Ground water and alte uae
prohibited.
Ground water and alle uee
prohibited.  Admlnl*!t*tIon
of water eupply ayatcm.
                                                                                                                                       llJ.OU.OOO-Jli.oOt.OOO
                                                                      t •.M».000-}l 1.401,000
                                                                        i.ait.ooo-t J.oio.ooo
110.264.000-111.8)7,000
                                                                       I 4.688.000-$  8.621.000

-------
                                                                      (co«tUua4)
       ALrr.uuiivi
                                nOMICAL CWSIMRATIIINS
                                                                    HEALTH CONSUMMATIONS
                                                                                                     INSTITUTIONAL CONIIOMATIONS
                                                                                                                                           ISTIMATKO COST
                                                                                                                                            •ANCE (  JOt
                                                                                                                                         COMrlOCHCI INTEIVAL)
II. Cap Haiar4o«a UaatO
    Aiaa; Cap Hunlclpal
    fill *i««; PiMf> ••*
    Trial Cioun4 Ualarj
    Allarnala Waiaf (OMCC*
                 curfac*. •!>-
                 ««i^r •l|
          i«4 M*|«r C0»»amftto».
                                  Sit* uaa f«>klkll*4; gf»u*4 water
                                  uaa p>oblklla4 lot abaci (•!•;
                                  NrDCS foallllng r«^.lr<4 lai
                                  4lack«cta ol lia«l*4 walaf.
                                  A4alnlalfatlw» af walat
                                                                                                         I 4.0*1.ooo-t  i.*;o.ooo
II. On«ll« laelnarctlooj •!
    IUiflrdo*a Uaata Araa{
    Cap hunlclMl 'HI
    Af»; famf i»4 Tr**l
    CtOM+i W.l.lj All«t««l«
ff •Ą*•(!•• •<
        llM •*
                  •aklllly kf
                   af
                                                      ol
                                          •all.
II.
    Slttllliil IM of
    Naiiidoui Wxt* Ar«*{
    Cap fenlclpsl rill
    Ar««; rut **4 Tc««l
    Cioun^ Ualvr;
    AlKrnal* W«l«r S*«CC«
                             IkonK •llalitx* •uitsc*. «lr-
                                           llalnat*  rl*k*
                                   •••ocU(«4 -Ilk caoocl with
                                   co«l*«li>*l«4 loll; (IckoiiM
                                   • IgrilIan;'(hart  ••4
                                   Kf*
                                                                          J
                  •okiiity kr
plavanlloaj at Infiltration;
•ln*r r«4«clloaj In tailclti;
• llgkl Incfcaaa In aol I vnluaMj;
        llta «aluaw at canlaail«ata4
Shoul4 alfvlnala flak*
aaaoclat*4 with contact with
conlMlnata4 aol I; alrkorn*
• Ifrat Ion; ahofl and long l«la
       uata,i coaauapdon.
                                  Slla «M aroKlklt«4;
                                  wa« frohlklt«4 for ahail laraj
                                  HrpCS faialltlng i«qul(a4  I of
                                  4lackac|* ol Iraalc4 walar.
                                  Adalnlaltalto* ol M«I«C avpoly
                                  •yalav.
                                                                     Ilia «aa protilkllt4;  (rou>4  wal«I
                                                                     uaa arohlklla4  lor  akarl  tar*]
                                                                     MfDCS farajlllUg  ra«ylra4 lor
                                                                     4lachaiga ol  Iraala4  walar.
                                                                     A4aj|nlatratloa  al watar auapty
                                                                     a>alaa].
                                                                                                 wntai    UJ.IOI.OOO-llt.llJ.OOO
                                                                                                                                       t »,0»i.000-111.HI.000

-------
     0  Occupational or public exposure
     0  Decline in property values
     0  Depressed area growth
     0  Environmental impacts

Several activities would need to occur under this alternative.  A  fence  would
need to be erected around the entire site and warning signs posted.  Periodic
monitoring of existing monitor wells as well as the installation of several
additional shallow/deep monitor wells.

Total Construction Costs   $103,572

Present Worth Operation &
  Maintenance Costs        $239,048

Total Present Worth Cost   $342,620

ALTERNATIVE 2 - CAPPING THE HAZARDOUS WASTE AREA AND MUNICIPAL FILL AREA

Surface capping involves constructing a three layered cap  according to RCRA   .
guidelines.  The installation of a surface cap will reduce the infiltration
through the contaminated soil and thereby reduce the migration of  pollutants to
the groundwater.  The cap would be installed over the hazardous waste area,
which encompasses approximately one acre, and the municipal fill area, which
covers 7.5 acres.

Capping would first include the. placement of a two foot clay layer compacted in
six inch lifts.  A twenty mil thick synthetic liner would  then be  placed over
the clay.  Next, a one foot thick drainage layer of gravel would be spread and
a filter fabric placed on top of the gravel.  The filter fabric would help to
stabilize a final layer of eighteen inches of topsoil.  The topsoil would be
vegetated to prevent erosion.  Also, the cap would have a minimum  slope of two
percent generally toward the southeast.  Drainage would .be designed .to. direct
surface runoff toward the present natural drainage channels.

Since the municipal fill area was previously used as a sanitary landfill, the
generation of natural gas can be expected.  Provisions for venting and monitoring
of the gas produced would be required.  Initial gas monitoring would probably
be performed quarterly and later reduced if no problems occur.

Groundwater monitoring would be required in conjunction with this  alternative.
Monitoring would involve continued use of existing monitor wells and the
installation of a minimum of eight new shallow monitor wells in the upper region
of the aquifer to determine whether contaminants are leaching or migrating from
the capped areas.

-------
The following is a summary of the estimated cost associated with this alternative:

Total Construction Costs       $3,460,670

Present Worth Operation &
  Maintenance Costs

  Hazardous Waste Area Cap     $  122,527
  Municipal Fill Area Cap   -   $  247,527

Tbtal Present Wroth Costs      $3,830,724

ALTERNATIVE' 3 - EXCAVATE AND INCINERATE THE HAZARDOUS WASTE AREA CNSITE;
                CAP TOE MUNICIPAL FILL AREA

This alternative would involve the use of source control for the hazardous
waste and municipal fill areas.  A surface cap would be .used on the municipal
fill area to reduce migration of contaminants to the ground water.  Incineration
of the contents of the hazardous waste area would eliminate that source of
contaminants.

The surface capping of the minicipal fill area would cover approximately 7.5
acres and would involve the same considerations and procedures described in
Alternative 2.

The hazardous waste area occupies approximately one acre.  It is estimated that
removal of top soil and subsoil in the area will require the removal and
incineration of approximately 19,300 cubic yards of solids contaminated with
dieldrin, BHC, toxaphene, chlordane, and other pesticides.  Excavation of the
hazardous waste area could be accomplished using standard excavation equipment.
The pits would then be backfilled with treated soil.  The incineration process
typically removes greater than 99 percent of these contaminants.

The most commonly used incineration methcdolgies for hazardous waste remediation
include rotary kiln, fluidized bed, and multiple hearth technologies.  In
addition, there are several emerging technologies that are gaining acceptance
including molten salt bed and infrared incineration.  The two that are considered
viable for the Powersville site are either the rotary kiln or the infrared
incinerator.

Total Construction Costs       $11,098,746

Present Worth Operation &
  Maintenance Costs

  Onsite Incineration of
  Hazardous Waste Area         $   466,582
  Municipal Fill Area Cap      $   247,094

Tbtal Present Worth            $11,812,422

-------
ALTERNATIVE 4 - SOLIDIFICATION/STABILIZATION OF THE HAZARDOUS  WASTE AREA;
                CAP THE MUNICIPAL FILL AREA

This alternative  involves the use of source controls  to  reduce leaching  and
migration of contaminants to the groundwater.  A surface cap would  be  installed
over the municipal fill area and solidification/stabilization  techniques would
be applied to the hazardous waste area.

The procedures and considerations associated with  the surface  capping  of the
municipal fill area are identical to those described  for the same area in
Alternative 2.  The solidification of the hazardous waste  area,  approximately
19,300 cubic yards, would involve a cementacious fixation  of the contaminated
soil enabling it  to be permanently stored at the site.

Total Construction Costs          $6,587,852

Present Worth Operation and
  Maintenance Costs
  Solidification/Stabilization-
  Hazardous Waste Area            $  195,114
  Municipal Fill  Area Cap         $  247,094

Total Present Worth Cost:         $7,030,060

ALTERNATIVE 5 - CAP THE HAZARDOUS WASTE AREA AND MUNICIPAL FILL;
                PUMP AND TREAT THE GROUNDWATER

Implementation of this alternative involves both source  control  of  contaminated
soil and direct treatment of contaminated groundwater.   Source control of  the
soil would be accomplished by installing a surface cap on  both the  hazardous
waste area and the municipal fill area.  The procedures  and considerations
associated with the surface cap are identical to those described in Alternative  2.

The treatment of  the contaminated groundwater would be accomplished by the use
of a package treatment plant and activated carbon  columns. Treatment  would
include extraction and storage of the groundwater, precipitation, flocculation,
sedimentation, filtration, carbon adsorption and discharge of  the treated  water
.to local surface water.

Total Construction Costs              $4,816,626

Present Worth Operation and
  Maintenance Costs

  Municipal Fill  Cap                  $  247,094
  Hazardous Waste Area Cap            $  122,527
  Extraction/Disposal of Groundwater  $  394,363
  Treatment of Groundwater            $  759,262

Total Present Worth Cost             $6,339,872

-------
ALTERNATIVE 6 - EXCAVATION AND ONSITE INCINERATION OF THE HAZARDOUS WASTE AREA;
                CAP THE MUNICIPAL FILL AREA; PUMP AND TREAT THE GROJNEKATER

This alternative is a combination of Alternatives 3 and 5.  The considerations
and procedures will be the same as those described in Alternative 3 for onsite
incineration of the hazardous waste area and capping of the municipal fill
area.  Likewise, the considerations for pumping and treating the groundwater
will be the same as described in Alternative 5.

Total Construction Cost                 $12,688,971

Present Worth Operation and
  Maintenance Costs

  Municipal Fill Cap                    $   247,094
  Onsite Incineration of
    Hazardous Waste Area                $   466,582
  Extraction/Disposal of Groundwater    $   394,363
  Treatment of Groundwater              $   759,262

Total Present Worth Cost                $14,456,272

ALTERNATIVE 7 - SOLIDIFICATION/STABILIZATION OF THE HAZARDOUS WASTE AREA;
                CAP THE MUNICIPAL FILL AREA; PUMP AND TREAT THE GROJNEWATER

This alternative is a combination of Alternatives"4" and 5.  The considerations
and procedures will be the same as those described in Alternative 4 for
stabilizaiton/solidification of the hazardous waste area and capping of the
municipal fill area.  Likewise, the considerations for pumping and treating the
groundwater will be the same "as described in Alternative 5.

Total Construction Costs                $9,512,702

Present Worth Operation and
  Maintenance Costs

  Solidificaiton/Stabilization of
    Hazardous Waste Area                $  195,114
  Municipal Fill Area Cap               $  247,094
  Extraction/Disposal of Groundwater    $  394,363
  Treatment of Groundwater              $  759,262

Total Present Worth Cost                $11,108,535

ALTERNATIVE 8 - CAP THE HAZARDOUS WASTE AREA "AND THE MUNICIPAL FILL AREA;
                PROVIDE AN ALTERNATE DRINKING WATER SOURCE

Implementation of this alternative would involve source control by the installation
of a surface cap on the hazardous waste area and the municipal fill area.  The
considerations and procedures for the cap would be identical to those decribed
in Alternative 2.


-------
Under this alternative, an alternate source of drinking water would be supplied
to the local residences which presently have wells that are potential receptors
of contaminants.  The provisions of this alternate source would not improve or
treat the present contamination, but would eliminate the long term potential
risk identified in the endangerment assessnent (Appendix C).

The alternate water source considered by this study consisted of the extension
of the municipal water supply pipeline from the city of Byron.  The Byron system
is the closest existing municipal supply to the Powersville Landfill Site.  The
present termination point is located approximately two and a half miles north
of the site on Georgia Highway 49.

Total Construction Costs               $3,928,920

Present Worth Operation and
  Maintenance Costs

  Hazardous Waste Area Cap             $  122,527
  Municipal Fill Area Cap              $  247,094
  Alternate Water Source               $  207,392
Total Present Worth Cost               $4,505,933

ALTERNATIVE 9 - EXCAVATE AND INCINERATE THE HAZARDOUS WASTE AREA CNSITE;
              CAP THE MUNICIPAL FILL AREA; PLUS ALTERNATE DRINKING WATER
              SOURCE •

This alternative is a combination of Alternative 3 and the provision of an
alternate drinking water source as described in Alternative 8.  The considerations
and procedures will be identical to those discussed in the respective alternatives.

Total Construction Costs               $11,742,589

Present Worth Operation and
  Maintenance Costs

  Municipal Fill Area Cap              $   247,094
  Onsite Incineration of
    Hazardous Waste Area               $   466,582
  Alternate Water Source               $   207;392

Total Present Wbrth Cost               $12,663,657

ALTERNATIVE 10 - SOLIDIFICATION/STABILIZATION OF THE HAZARDOUS WASTE AREA;
               CAP THE MUNICIPAL FILL AREA; PLUS ALTERNATE DRINKING
               WATER SOURCE

This alternative is a combination of Alternative 4 and the provision of an
alternate drinking water source as described in Alternative 8.  The consideration
and procedures will be identical to those discussed in the respective alternatives.

-------
Total Construction Costs                $7,231,696

Present Worth Operation and
  Maintenance Costs

  Municipal Fill Area Cap               $  247,094
  Solidification/Stabilization of
    Hazardous Waste Area                $  195,114
  Alternate Water Source   -             $  207,392

Total Present Worth Cost                $7,881,296

ALTERNATIVE 11 - CAP THE HAZARDOUS WASTE AREA AND MUNICIPAL FILL AREA;
                 PUMP AND TREAT THE GSOUNDWATER; PLUS ALTERNATE DRINKING
                 WATER SOURCE

This alternative is a combination of Alternative 5 and the provision of
an alternate drinking water source as described in Alternative 8.  The
considerations and procedures will be identical to those discussed in the
respective alternatives.

Total Construction Costs              $5,460,470

Present Worth Operation and
  Maintenance Costs

  Municipal Fill Area Cap             $  247,094
  Hazardous Waste Area Cap            $  122,527
  Alternate Water Source              $  207,392
  Extraction/Disposal of Groundwater  $  394,363
  Treatment of Groundwater            $  759,262
Total Present Worth Cost              $7,191,108

ALTERNATIVE 12 - EXCAVATION AND ONSITE INCINERATION OF THE HAZARDOUS WASTE AREA;
                 CAP THE MUNICIPAL FILL; PUMP AND TREAT THE GROUNDWATER; PLUS
                 ALTERNATE DRINKING WATER SOURCE

This alternative is a combination of Alternative 6 and the provision of
an alternate drinking water source as described in Alternative 8.  The
considerations and procedures will be identical to those discussed in the
respective.

Total Construction Costs               $13,232,814

Present Worth Operation and
  Maintenance Costs

-------
  Municipal Fill Area Cap              $   247,094
  Cnsite Incineration                  $   466,582
  Extraction/Disposal of Groundwater   $   374,363
  Treatment of Groundwater             $   759,262
  Alternate Water Source               $   207,392

Total Present Worth Cost               $15,287,507

ALTERNATIVE 13 - SOLIDIFICATTON/STABILIZATICN OF THE HAZARDOUS WASTE AREA;
                 CAP THE MUNICIPAL FILL AREA; PUMP AND TREAT GROUNDWATER;
                 PLUS ALTERNATE DRINKING WATER SOURCE

This alternative is a combination of Alternative 7 and the provision of
an alternate drinking water source as described in Alternative 8.  The
considerations and procedures will be identical to those discussed in the
respective alternatives.

Total Construction Costs                   $8,672,421

Present Worth Operation and
  Maintenance Costs

  Solidification/Stabilization
    of Hazardous Waste Area                $   195,114
  Municipal Fill Area Cap                  $   247,094
  Extraction/Disposal of Groundwatsr       $   394,363
  Treatment of Groundwater                 $   759,262
  Alternate Water Source                   $   207,392

Total Present Worth Cost                   $10,475,646

-------
                                 SECTION VI
                              COMMUNITY RELATIONS
               x


Connunity relations efforts for the Powersville Landfill were  initiated  in
July of 1985 when EPA completed the site Conntunity Relations Plan.  Area
residents were contacted as part of connunity relations work.  The major
concern expressed by residents at that time concerned contamination of
their drinking water, but historically, concerns also included odor and  airborne
contamination.  Overall connunity interest has been moderate.  An information
repository was established at the Powersville Fire Station, which is near
the site.  All final documents, plus the draft Remedial Investigation/Feasibility
Study were sent to the repository for public access.

In preparation for the public meeting, a fact sheet was- sent to  interested
parties listed in the Coirrunity Relations Plan.  The fact sheet  provided
interested parties with a summary of all remedial alternatives being
considered by EPA for remediating the problems associated with the Powersville
Landfill site.  Additionally, notice was placed in the local paper indicating
all remedial alternatives and announcing the time and location of the public
meeting.                                   ....

On August 4, 1987, a public meeting was held to discuss the findings of  the
RI/FS.  The public meeting served to initiate a 3 week public  comment period
which closed on August 25, 1987.  Attendance at the public meeting was
moderate, with aproximately 30 people in attendance.  A number of written
comments were received during the public comment period.  These  comments
have been fully addressed in the Responsiveness Summary (attached), which
will be placed in the information repository.


-------
                            SECTION VII



            CONSISTENCY WITH OTHER ENVIRONMENTAL LAWS
Other environmental  laws which may be applicable  or relevant to the remedial
activity being proposed for  the Powersville Landfill site  are:

               — Safe Drinking Water Act
               — Resource and Conservation Recovery Act (RCRA)
               — Clean Air  Act
               — EPA Groundwater Protection  Strategy
               — Clean Water Act
 Locally,  residents obtain  their water  supplies  from the  Providence Sand
 Unit, which  is the shallow saturated unit.  Therefore, the mandates of  the
 Safe Drinking Water Act aoply  to  this  aquifer.  At present,  however, none of
 the contaminants exceed the standards  established  under  this act.   Capping
 should greatly reduce  the  mobility of  the contaminants at the site, which
 will reduce  or eliminate their infiltration into the groundwater.   The
 alternate water supply will provide additional  insurance that local residents
 nave a long-tern source of clean water.

 The caps  will be constructed in accordance with EPA guidance document Covers
 for Uncontrolled Hazardous Sites, EPA/540/2-85/002, September, 1985 and all
 applicable State and Federal regulations.  Since all contaminated  materials
 will be left in place  at the site, compliance with RCRA  disposal regulations
.is not a  factor.  Consistent with RCRA additional  monitor wells will be
 constructed  and long term  site monitoring instituted.

 Future erosion of surface  sediments, especially around the hazardous waste
 area, may lead to surface  water and air  contamination, although neither of
 these media  are presently  considered at  risk.   Capping,  which incorporates
 grading,  drainage control, and the establishment of a vegetative cover,
 will eliminate the potential for  long  term erosion problems.  With these
 erosional concerns eliminated  future concern with  surface water and air
 routes will  also be removed.   During construction  of the caps, air monitoring
 will be used to guard  against  a release  of contaminants  into the air.

-------
                     VIII. RECOMMENDED ALTERNATIVE
The remedial action alternative recortnended for the Powersville Landfill
site is construction of caps over both the hazardous waste area and  the
municipal landfill, coupled with an alternate drinking water source  for
residents living close to the site.  For the municipal waste area the cap
will be designed to provide long-term minimization of liquids through the
closed landfill.  The hazardous waste area should be constructed with an
artificial liner and/or an equivalent two foot layer of compacted clay.
These caps shall be constructed in accordance with EPA guidance, Covers
for Uncontrolled Hazardous Sites, EPA/540/2-85/002, September 1985, .and
in accordance with applicable State and Federal regulations.  This
recommended alternative is similar to Alternative # 8, as outlined in
Section V of this document.  Due to differences in the specifications for
cap construction, the recommended remedy can be expected to cost $0.5
million less than Alternative Ł8, or about $4.0 million.

Implementation of this alternative would provide source control with the
installation of surface caps over the hazardous waste area and the municipal
fill area.  Coupled with the caps would be the installation of an alternate
water supply.  Residents upgradient of the site whose property is imnedi-
ately adjacent to the site and residents downgradient of and likely  to be
impacted by contaninants leaving the site will be connected to this
alternate water system, thus supplying them with a reliable, long-term
source of safe drinking water. •

Finally, deed restrictions need to be established for those lands between
the site and Mule Creek prohibiting the drilling of water wells.  This
land defines the areal extent of the groundwater that is expected to be
effected by the site.  Similar restrictions need to be established for the
site itself, but should also prohibit any additional activities that could
cause damage to the remedy implemented at the site.

Surface capping involves construction of the caps in accordance with the
parameters and guidance indicated above.  The installation of surface
caps will reduce the infiltration of rain and other surface water through
the contaminated soil and thereby reduce the migration of pollutants to
the groundwater.  The caps would be installed over the hazardous waste
area which encompasses approximately 0.8 acre and the municipal fill
area, which covers 7.5 acres.

A cross section of a cap typical for this type of site is presented  in
Figure 11.  This diagran is presented only as an example, and actual cap
construction will be based on the guidance and paraameters referenced in
the first paragraph of this section.  Differential compaction and settling
due to the variety of materials contained within these areas area will
also influence the design parameters for these caps.  Drainage will  be
designed to direct surface runoff toward the present natural drainage
channels.

-------
               2% MFNIMUM SLOPE
      I.51
TOPSOIL
                               •FILTER FABRIC
-. .-20 MiL SYNTHETIC  LiNER

REM II
CROSS SECTION OF SURFACE CAP
- POWERSVILLE LANDFILL SITE
PEACH COUNTY, GEORGIA
FIGURE NC
11
                  11-5

-------
As the part of this alternative, an alternate source of drinking water
will be supplied to the local residences which presently have wells  that
are potential receptors of contaminants.   It is known  that  the  Byron
municipal system is the closest supply system, being a maximum  of  two and
a half miles from  the site.  Conversations with county officials on
August 4, 1987, indicate that the termination point for that system  may
now be as close as one mile away.  Engineering considerations will need
to evaluate the present capacity of the system to see  if:

   •  - additional  wells will be needed,
     - the treatment plant can handle the extra demand, and
     - additional  pump stations and storage tanks will be needed.

The provision of an alternative drinking water source  will  not  improve or
treat the present  contamination, but would eliminate the long term potential
risk indentified in the endagerment assessment.

Since the municipal fill area was previously used as a sanitary landfill
the generation of  natural gas can be expected.  Provisions  for  venting
and monitoring of  the gas produced will need to be considered.  If venting
is required, initial gas monitoring would probably be  performed quarterly
and later reduced  if no problems occur.
                                                       •
Groundwater monitoring is required in conjunction with this alternative.
Monitoring involves continued use of existing monitor  wells and the
installation of at least eight new shallow monitor wells in the upper region
of the aquifer to  determine whether or not contaminants are leaching from
either of the capped disposal areas.

Site capping should reduce or eliminate the mobility of the contaminants
in both disposal areas.  Public concern from the short and  long term threat
to the groundwater will be eliminated with the installation of  an  alternate
drinking water source.  Incineration or stablization/solidification  alter-
natives for the landfill were considered infeasible for three reasons:

 0 There is not enough information available to locate the  contaminated
   areas within the municipal landfill.  Additional sampling does  not
   ensure that all such areas will be located.

 0 Costs of treatment would be very high.  If it is assumed that the
   whole landfill  was treated then very large volumes  of wastes would need
   processed and treated.  Costs would also be high if an attempt  were
   made to locate  and treat only the "hot spots" in the landfill,  due to
   the large number of samples that would need to be taken  to attempt to
   locate and confirm these areas.  Such sampling also would present a
   risk to personnel from having to drill frequently into the landfill
   where pockets of explosive gases could be located.

 0 The third drawback is the technical cortplexities associated  with  these
   two alternatives.  The municipal landfill contains  debris that  would
   have to be sorted out and/or shredded to ensure compatibility with the
   chosen process, a task that may be difficult to accomplish given  the
   variety of materials that one can expect to find in such an  area.  In


-------
   the case of stabilization/solidification, a solidification mix would
   need to be developed that was of satisfactory performance in reducing
   leachability and providing long term stability.  Mixing or mixing/
   drilling techniques would likewise need to be developed to assure
   adequate performance of the mix.  Incineration is a highly automated
   process that is highly prone to mechanical failure when amorphous
   materials are to be incinerated, and must be constantly monitored for
   the release of contaminants into the air.

Applying solidification/stabilization or incineration to only the smaller
hazardous waste area removes the problem of locating "hot spots" as the
whole area would be treated.  Being a smaller area and so of smaller volume,
treatment costs would be reduced, but still significantly higher than the
proposed alternative.  Stabilization/solidification of the hazardous
waste area would cost about $ 3.0 million more than constructing a cap
for the same area.  Incineration would cost approximately $.8 million
more than capping the hazardous waste area.  The problem of technical
complexity would not change significantly if treating the hazardous waste
area instead of the municipal landfill.                  r

Pumping and treating.the water is of questionable feasibility as the
Providence unit is a complex assemblage of interlayered sands and clays.
Such geology lends itself to the existence of saturated or "perched"
water zones To be most effective, all such saturated zones would have to
be defined with soil borings or other measures before withdrawal wells
were installed.  The complexity of the geology makes it difficult to
predict the viability of this methodology.

Presently, no ARARS are being exceeded or are in danger of being exceeded.
Thus, the preferred alternative will not be concerned with meeting these
standards.  The data indicating that ARARS are not presently being met for
lead and chromium does not appear to be valid for two reasons.  First,
high lead and chrome values are associated only with the older galvanized
wells, which is a material that should not to be relied upon for the monit-
oring of metals.  Secondly, the samples from newer stainless steel wells
do not show high lead and chrome content, which supports the concern that
the galvanized pipe wells are the cause of the high values of lead and
chromium.  Short and long term concerns about exceeding ARARs in private
wells will be eliminated by the implentation of an alternate drinking
water source.

The capping, in accordance with Covers for Uncontrolled Hazardous Waste
Sites and the other parameters specified, will satisfy a key element of
concern by reducing the mobility of the hazardous wastes in both areas.
This will be accomplished by eliminating the infiltration of rain water
and other surface waters through the hazardous wastes.  With leachate
generation eliminated contaminants will not seep down into the saturated
zone of the Providence sand unit.  A minimum of eight additional monitor
wells will-confirm the performance of the two caps.

Capping Will provide minimum direct exposure of workers  to hazardous
materials' as "they will remain in place.  Thus short term risks to on-site
materials and to the environment will remain low since there is a minimum

-------
of disturbance and exposure.  The relative simplicity of this alternative
also reduces risks to a minimum.  In contrast incineration requires
constant monitoring to ensure no release of contaminants into the air and
groundwater pump and treat methodologies require monitoring of the discharged
treated water.

The installation of an alternate drinking water supply provides both
snort-term and long-term relief for concerns about drinking water.  This
portion of the remedy provides immediate relief once in place, and will
assure a reliable source of water for the long term period.  Like capping,
the alternate water source is an easy to implement technology and exposes
the workers and the public to a minimum of risks.

Long term reliability of the caps will depend on the quality of the design,
the care taken during installation, and on long term maintenance.  The
additional monitoring wells will evaluate the long-term performance of
the caps.  It is expected that the monitoring will show a decrease in
contamination over time due to the elimination (or high degree of reduction)
of contaminant mobility.  Thus the potential for exposure to contaminants
through groundwater, which is considered low, will be even lower.  Instal-
lation of the caps will also reduce short" term and long term concerns
that could arise from the exposure of hazardous wastes due to erosion.
There presently is a significant amount of erosion at the site and capping
would reduce such erosion to a minimum.

Both capping and the installation of an alternate water supply are compa-
ratively simple, established technologies.  The reliability of both
technologies is expected to be good and with the additional monitor wells
in place it is possible to confirm the performance in eliminating or
reducing the amount of leachate from the municipal and hazardous waste
areas.  No permits are needed to implement this alternative but coordination
with Peach County will be necessary in implementing the alternate drinking
water supply.  The equipment necessary to implement the alternative
should be easily available as the technologies are well established and
widely in use.


                           COMMUNITY ACCEPTANCE

Very little specific comment was received from the community concerning
what elements of the recommended alternative were acceptable but one
resident commented that he preferred the proposed remedy.  The major
concern of residents present was that the quality of their drinking water
is good and that it continue to be good.  While not specifically approving
or disaproving the alternate drinking water supply/ it seemed clear from
the public meeting that this proposal alleviates citizen concern about
having drinkable water.  Some concern was expressed about the damage that
construction of houses could cause at the site once the remedy was in
place, but EPA indicated that deed restrictions would eliminate the
possibility of such construction.  There were also several residents at
the public r^eeting vho seated that they wanted the site "cleaned up", but
did not elaborate or. what they meant by "cleaned up".

-------
                             STATE ACCEPTANCE

The State of Georgia concurs with the implementation of an alternative
water supply for all residents whose"property is upgradient  and  immediately
adjacent to the site, and those residents lying downgradient of  and  likely
to be impacted by contaminants leaving the site.

The State also agrees with EPA that periodic groundwater monitoring  on and
around the site should be conducted with a minimum of eight  monitor  wells.
For the municipal landfill, the State agrees with EPA that the area  be
capped in accordance with EPA guidance, Covers for Uncontrolled  Hazardous
Waste Sites.  They believe that a properly designed and installed tvro
foot thick clay cap or equivalent artificial liner constructed in accordance
with the guidance referenced above and the Georgia Hazardous Waste Management
Act, Corrective Action Provisions, will provide adequate protection  for
the hazardous waste area.

This site, since it was^operated by a county of the State, is a  50%  cost
share site.  Because of this, the state has a strong interest in the
costs associated with the alternative selected.  If a remedy more costly
than the recommended alternative is selected, it is highly likely that
the State would not concur.  The cost factor may also be a significant
factor in the State's disapproval of portions of the recommended alternative.


STATEMENT OF COMPLIANCE WITH SECTION 121 OF SARA

The remedy proposed for the Powersville Landfill site is the most effective
alternative in terms of removing the threats posed by the site,  and  is
considered the most effective choice given the current state of  clean-up
technologies.  This remedy is a cost-effective remedy which  achieves an
acceptable level of  public health protection and will remove the threats
this site poses to the environment.  The remedy will provide protection
which will meet all applicable, relevant, and appropriate requirements,
and is cost-effective.  Finally, the remedy utilizes permanent treatment
technologies to the maximum extent practicable.

-------
                                SECTION IX
                        OPERATIONS AND MAINTENANCE
The cap should be inspected on a regular basis for signs of erosion,
settlement, or deterioration. It is recommended that inspections be
conducted frequently in the first six months because problems are most
likely to appear during this period.  Maintenance of the final cap would
be limited to periodic mowing of the.vegetative layer to prevent invasion
by deep rooted vegetation and burrowing animals.  Any signs of unexpected
settling or deterioration should be addressed immediately by removing the
overburden to inspect and repair the affected areas.

In addition to the operation and maintenance required for the surface caps,
standard maintenance and repair of pumping equipment, valves, structures,
meters, etc. associated with the new pipeline would be required.  Provisions
for additional use monitoring and billing procedures would be required.

Since the municipal fill area was previously used as a sanitary landfill,
the generation of natural gas can be expected.  Provisions for venting
and monitoring of the gas produced will need to be examined.  If venting
is necessary, initial gas monitoring would probably be performed quarterly
and later reduced if no problems occur.

Groundwater monitoring would be required in conjunction with this alterna-
tive.  Monitoring would involve continued use of existing monitor wells
and the installation of a minium of eight new shallow monitor wells in
the upper region of the aquifer to determine whether contaminants are
leaching or migrating from the capped areas.  For the first and second
year, quarterly monitoring will probably be required.  After the first
two years, and depending on results from the initial monitoring period,
the monitoring will probably be limited to once or twice per year.

-------
                                SECTION X
                                SCHEDULE
Schedule Landmark                        Date for Implentation




1.  Finalization of ROD                          9/23/87


2.  Complete Enforcement Negotiations           12/14/87
                    s*

3.  Initiate Design                              1/14/87


4.  Complete Design                              7/14/87


5.  Initiate Remedial Action-                     7/14/87


6.  Complete Remedial Action                     7/14/89

-------
                                SECTION XI
                              FUTURE ACTIONS
Sucessful Implementation of the selected remedy will ultimately remove
the Powersvllle Landfill site from under the jurisdiction of the Compre-
hensive Environmental Response, Compensation, and Liability Act (CERCLA)
and as amended by the Superfund Amendments and Reauthorizatlon Act (SARA).
Implementation of the selected remedy will provide a permanent solution
to the problems surrounding this site and will require no subsequent
actions under CZRCLA or SARA.

It will be necessary to confirm the performance of the caps to insure that
contaminants are not migrating from the site.  This will be accomplished
by the installation of a minimum of eight monitor wells at Che site.  It
will also be necessary to maintain the cap to assure the performance of
this .portion of the remedy, a task that will be carried out as part of the
operations and maintainence plan.

No future action will be required for alternate drinking water supply,
other than the standard maintenance required for such a system.


-------
      Appendix A





RESPONSIVENESS SUMMARY

-------
                PCWERSVILLE LANDFILL, PEACH COUNTY GEORGIA
                          RESPONSIVENESS SUMMARY
1. OVERVIEW
The alternative proposed at the time of the public comment period was
Alternative #8, which is comprised of constructing a RCRA three  layer
cap over the municipal and hazardous waste areas.  This alternative also
includes an alternate drinking water supply for residents living close
to the site.

The only responsible party to comment did not support the capping proposal
but did agree with the alternate drinking water supply and continued
monitoring.  The PRP believes that non-RCRA caps should be examined, but
presently recommends only site grading and drainage control.  Georgia EPD
favors a cap on the hazardous waste area, grading and drainage control
for the municipal fill area, and an alternate drinking water  supply.  The
public did not, except in one comment, indicate a clear preference for any
specific remedial alternative.  The major public concerns centered on the
safety of the drinking water, and to a lesser degree, making  sure the
site was cleaned up.  The one specific comment from the public on a
remedial action supported EPA's recommended alternative.
2.  BACKGROUND ON COMMUNITY INVOLVEMENT AND CONCERNS
Community concern regarding the Powersville site has been most pronounced
during two periods.  From 1963 until 1979, when the Peach County Landfill
received waste regularly, residents complained often about problems
associated with the landfill.  Since the discovery of ground water contami-
nation in 1983 and the installation of monitoring wells in 1984, residents
have been concerned about the quality of their drinking water.

In August 1973, Alvah E. Adams, who lived immediately adjacent to the
landfill along Newell Road, complained to EPD officials about blowing
pesticide dust at the landfill and uncontained surface water runoff.  Mr.
Adams also expressed concern that bundles of empty pesticide bags were
being dumped in the the non-contained areas of the landfill.  In July
1975, Mr. Adams telephoned EPD officials to complain about about odors
and pesticide runoff from the site.  In August 1975, another resident
(who no longer lives in Powersville) wrote to EP\ offices in Atlanta "to
see if we here in [Powersville] cannot get something done about the county
dump."

-------
When dumping at the landfill was terminated in 1979, additional letters
fron residents expressed concern that  the county might  not  have taken
sufficient measures to cover and regrade the fill area.  Renewed comiunity
complaints regarding  the Powersville site during 1983 coincided with  the
initial presence of EPA and EPD officials investigating the ground water
for contamination at  the site, according to Peach County Administrator
Franklin.  EPD files,  support this claim, although some residents appear
to have been concerned about ground water quality prior to  1983.

After the discovery of pesticides in the Lizzie Chapel Baptist Church  .
well in August 1983,  citizens began requesting sampling of  their wells
and press coverage of the site increased.  On May 1984, EPD officials
received a complaint  from an area resident about a skin rash  that the
resident thought to be attributable to contaminated well water.  Mrs.
Willie C. Pickens wrote a letter to EPA Headquarters that described
health problems in the community that she believed had been caused by
drinking contaminated water.  EPD officials stated that Mrs.  Pickens  also
contacted her congressman about problems at the Powersville site.


3.  SUMMARY OF PUBLIC COMMENTS DURING PUBLIC COMMENT PERIOD AND AGENCY
    RESPONSES

1.  Comment;  Is that water safe to drink?

    EPA Response;  The water sampled at the Pickens residence did have an
    extremely small amount of contamination.  This amount was significantly
    below the maximum contaminant level (MCL) established by  the EPA.
    The MCL is the maximum level of contamination that  is safe to drink
    and since the water is far below this level, yes, the water is safe
    to drink.

2.  Comient;  Who will pay for later developing health  illnesses?

    EPA Response;  Before one can determine who will pay for  a developing
    illness, one must show that something or someone in particular causes
    such an illness.  The Powersville Site has not contaminated anyone's
    water to an extent which should cause any health problems.  The reason
    for the concern at the Powersville Site is not that people are presently
    in danger from exposure, it is to prevent exposure to people in the
    future which may  result if something is not done at the site.  The
    possible things that can be done are the alternatives that EPA presented
    at the Public meeting.

3.  Comment;  Suggest capping both areas with alternate water source.

    EPA Response.;  This is the only public comment that specifically
    endorsed a specific alternative.

4.  Comment:  Who is  paying for all the testing that was carried out  at the
    landfill and for  whatever action is taken now?  Is Woolfolk Chemical
    being held responsible for paying or am I and the other taxpayers of
    this country?

-------
    EPA Response;  The work done by the Environmental Protection Agency
    (EPA) to date has been paid for with Superfund money, which is a tax
    levied on chemical products.  The upcoming work will be paid for either
    by EPA or Woolfolk Chemical and other potentially responsible parties
    (PRPS).  If Woolfolk and other PRPS do not pay for or carry out the
    remaining work needed' to clean up the site, EPA will seek to recover
    costs through litigation.

5.   Comient:  Who will pay for the extension of water service to this
     area?  Will it cone from Ft. Valley or Byron?

     EPA Response;  First,  it should be made clear that residents will
     not have to pay anything to be hooked up to the municipal water
     service.  Who will pay is not yet clear, but will be determined
     through negotiations with Woolfolk and the other PRPs as indicated
     in the answer to comment #1.

     Based on discussions with county officials, it is most likely that
     water will come from the Byron municipal water system, as pipelines
     fron Byron are already close to the area.

6.  Garment;  Will this site be used as a landfill again?

    EPA Response:  The possibility has been discussed, but is very unlikely.
    The site needs to be leveled out to prevent erosion and to prepare the
    area for capping.  As you may be aware, there are steep slopes at the
    site that show some erosion.  By filling in the site with some kind
    of material, with garbage being one possibility, the area can be made
    level.  The problems with subsidence and settling due to the inhcmogeneous
    nature of garbage make highly unlikely that it will be be used.

7.  Comment;  Am I wrong to fear for the future of this country and the
    world if chemical and nuclear contamination isn't stopped?  Can we
    continue to clean up behind industry?

    EPA Response;  While EPA shares this concern for chemical and nuclear
    contamination, laws & regulations have been established to curb such
    contamination.  A major problem that remains is when these laws are
    not complied with by polluters.  That is where the public can be of
    help, by contacting the local, state, or Federal Government if they
    believe there are violations occurring.

    As for cleaning up behind industry, laws now regulate how and where
    industries dispose of hazardous wastes they generate, and are set up
    to make sure that these wastes will not endanger the public.  Once
    again, the major concern is when the laws are not adhered to by pollu-
    ters.  In summary, there are reasons both for optimism and for concern.
    Public involvement plays a significant role in bringing problems to
    light so that action can be taken.

-------
                REMEDIAL INVESTIGATION COMMENTS FROM PRPS
Comment on Hazardous Waste Area:  The Report does not discuss the design
and construction of the hazardous waste area.  The Report fails to note
that Georgia  Environmental Protection Division ("EPD") directed that a
specially designed area be constructed for the disposal of hazardous
substances.  The EPD supervised the design and approved the construction
of this area.  The EPD regularly inspected the area during its construction
and according to written memoranda, determined that the area was constructed
properly according to approved specifications.  In fact, during the period
in which the hazardous waste area was operated all disposal activities
were undertaken with the full knowledge and consent of the EPD.

The bottom surfaces of the trenches in the hazardous waste area were
lined with an impervious clay layer of at least five feet.  The construction
of these trenches is crucial to an understanding and evaluation of the
ultimate potential for leaching from the area.  It does not appear that
the EPA properly considered the physical characteristics of these trenches.

The report indicates that the EPA conducted several angled borings under
the hazardous waste area.  It is not clear from the Report how the the
locations for these borings were selected, and whether they were designed
to give maximum information concerning leaching from the area.  Further,
it is not evident that the EPA has taken into account all of the available
information concerning the hazardous waste area in determining these
locations, including the grade of the trenches and the most likely source
of leachate.

EPA Response;  While the PRP indicates that the trenches in the hazardous
waste area are clay lined, the PRP has yet to provide documentation that
conclusively Indicates how the hazardous waste area was constructed.  EPA
does not argue that the site was constructed in a manner that was considered
acceptable at the time, but is more concerned that such closure methodologies
would be inadequate by today's standards.

Although the report does not indicate how the angled borings were drilled
or selected, EPA did examine locations and drilling methodlogies before
selecting the appropriate locations and techniques.  The borings were
located in such a manner that they would collect any contaminants that
were leaching down into the soil from the hazardous waste area.

Comment on Capping;  The Report shows a clear preference by the EPA that
capping of the Site be the focus of remedial actions at the Site.  Unlike
the "no action alternative", EPA fails to address the negative aspects of
this alternative.  First, a significant amount of site preparation would
be required, such as re-grading and backfilling prior to capping the
Site.  Second, because of the original construction and use of the municipal
landfill, a significant differential settlement problem exists at the
Site.  Therefore, extensive study and design would be required prior to
the construction of the cap.  Third, the potential for the build-up of
methane gas would have to be addressed and sophisticated venting procedures.
would have to be designed and implemented.

-------
We note that the Report only considered a multi-layer cap which is designed
in accordance with the applicable Resource Conservation and Recovery Act
("RCRA") regulations.  The Report did not consider alternate surface
actions, such as'grading and drainage control, which would achieve the
purpose of the RCRA-type cap at a substantial savings in cost.

Finally, we note that the justification for capping the Site appears to
be the concern that the hazardous waste area will leach eventually and
that contaminants found in the landfill will move into the- groundwater.
However, as noted earlier, these assumptions are based on data that is,
by the EFA's own acknowledgement, inconclusive.

EPA Response;  EPA's preference for capping the site is based on the concern
that both the hazardous.waste area and municipal landfill area are sources
of the contamination observed in the groundwater, and it is our policy
not to permit the degredation of a. potential drinking water source.  We
do not believe that this concern can be adequately addressed by the the
minimal action outlined in the "no action" alternative, or by any action
that does not compare with the performance of a cap.

Some of the negative aspects of capping are presented in section if 13 of
the RI/FS.  This indicates that we aware of the problems mentioned by the
PRP that are associated with the RCRA type "C" cap.  Other capping
methodologies are currently under consideration.

CoBgaent on Groundwater;  Of the five indicator contaminants detected in
the monitoring wells on-site, only one, lindane, Is normally associated
with pesticide-type wastes.  Vinyl chloride, 1,2-dichloroethane, lead and
chromium are not generally associated with pesticides.  The existence of
these compounds supports the view expressed above that the search for
potentially responsible parties should continue unabated.

The Report Indicated that concentrations of lead and chromium in excess
of drinking water standards were found only in certain shallow minitoring
wells.  Further, these wells were all constructed of galvanized steel.
The EPA acknowledges that it is not uncommon for these compounds to be
present as a result of corrosion of wells of this type.  In light of the
fact that lead and chomium were detected in significant concentrations
only in these galvanized wells, the results should be deemed suspect and
discarded.

Finally, we note that sampling of the off-site private wells revealed only
traces of contamination, In each case well below the drinking water
standard for the respective contaminant.  We note that the highest concen-
tration found by the EPA during the RI/FS was .78 ug/1 of gama BHC (lindane),
far below the drinking water standard of 4 ug/1.

-------
EPA Response;  Since Canadyne Georgia agrees with  EPA that  the  lead  and
chromium values are a probable  result of  the well  construction,  there is
no need to seek out PRPs associated with  these compounds.   Vinyl  Chloride
is a.widely used compound  that  could come from any one.of a number of
sources:  plastic packaging, resins, PVC  materials such as  pipes,  and
propellants in aerosol  sprays.  A number  of these  materials are quite
caution in municipal landfills.  Similarly, 1,2-dichloroethane is  a widely
used compound, mainly in the manufacture  of a variety of products and as
a sol vent'.  It is used  in  extracting agents, drycleaning fluids,  gasolines,
water softening, and photography, to name a few.   Such widely used
compounds as these two  would be difficult, if not  impossible, to  associate
with a specific manufacturer without additional  information.

While the levels of lindane in  off-site wells are  below drinking  standards,
it does verify that there  is a  release of pesticides  into the groundwater.
Also, historic sampling has shown levels  as high as 1.2 ug/1, not the .78
ug/1 mentioned by the PRP.  It  is the potential threat posed by these
compounds that provides the Agency reason for concern.
                             FEASIBIITY STUDY


Comnent on No Action Alternative;  Throughout  the Report,  the  EPA states
that the "no-action alternative" was considered only because its  consider-
ation is required by the National Contingency  Plan.  In fact,  it  does not
appear that the EPA actually considered a no-action alternative on its
merits.  This is illustrated by the fact in  its discussion of  this alter-
native, the EPA noted the following so-called  "potential impacts"  which
might result from this alternative:


    a.  occupational or public exposure

    b.  decline in property values

    c.  expenditure for legal services

    d.  depressed area growth

    e.  expenditure for laboratory analyses  and
        monitoring

    f.  restricted access to the site

    g.  environmental impacts


While these are labelled "potential impacts,"  they are  all in  fact what
the EPA considers to be potentially adverse  effects of  implementing this
alternative.  By presenting only the adverse effects of the no-action
alternative, the Report suggests that there  is no virtue whatsoever in
seriously considering this alternative.

-------
 Further,  the  listing of  these  "impacts"  in the discussion of the no-action
 alternative suggests  that these potential adverse effects are not present
 under  the other  remedial alternatives which were considered.  In fact, each
'of  these  "impacts"  would be present under any alternative selected.
 Nevertheless,  none  of  these effects are  listed in the discussions of the
 alternatives.  It appears from the foregoing that while the EPA states
 that it "considered"  the no-action alternative, in fact the EPA did not
 accord that alternative  the weight given to the alternatives actually
 considered.

 EPA response;  The  "no action"  alternative increases the risk to the
 public to unacceptable levels,  and allows the continued contamination
 of  a potential source  of drinking  water.   These factors makes this alter-
 native unacceptable.

 It  is  agreed  that some of the  "potential  impacts" would exist for other
 alternatives.  The  report does discuss and eliminate, in Section 9,
 unacceptable  alternatives.   After  that section, the report then more
 closely examines the  "pros" and "cons" of the remaining remedial alternatives.
                             /"
 Garment on  the Municipal Landfill;  Throughout the Report, it is suggested
 that pesticides  and "related industrial wastes" were disposed of in the
 municipal landfill  area. While the Report clearly indentifies "pesticides",
 no  effort has been  made  to identify "related industrial wastes," as well
 as  the probable  generators  of  these wastes.   An attempt to identify the
 nature of the "related industrial  wastes" would undoubtedly aid in the
 determination of additional potentially  responsible parties with respect
 to  the Powersville  site.

 As  indicated  in  the previous subsection,  the EPD regularly visited the
 Powersville site and  inspected its operations.  To the extent that the EPD
 became aware  of  disposal practices at the site during this period, EPD
 personnel would  be  an invaluable resource in helping to identify additional
 potentially responsible  parties.

 We  understand that  with  respect to previous NPL sites, the EPA has retained
 a professional search firm to  help identify potentially responsible parties.
 We  also understand  that  in  this case this course of action was not followed.
 This raises the  question as to whether the EPA should have employed such
 a firm in order  to  identify all possible  potentially responsible parties.

 EPA response;  "Related  industrial wastes" are mentioned in the report
 and, to the extent  possible, EPA has sought out PRPs associated with these
 wastes.  EPA  has requested PRP information from Peach County, which
 operated  the  landfill, and  the cities of  Fort Valley and Byron.  These
 parties either operated  the landfill or were major contributors and
 are the best  sources of  information regarding additional PRPs.  Their
 responses have provided  no information that would provide additional PRPs.
 EPD has worked with with EPA on this site,  and the information provided
 by  them has not  helped to 'locate additional PRPs.

-------
It is EPA's option to employ the services of a professional search firm.
to help identify PRPs.  In the case of the Powersville Landfill site, EPA
believes that the cost of such a firm would not be justifiable as the
parties knowledgeable about the site had already been contacted and
had provided the information available to them.
                         ENDANGERMENT ASSESSMENT

The ultimate conclusion of the EPA that a threat of off-site contamination
exists at the Site is based in large part on the Endangerment Assessment
containined in Appendix "C" of the Report.  However, it is not clear
whether this is a preliminary assessment, as is suggested in the Executive
Summary section of the Report, or a final Endangerment Assessment.  We
believe that any conclusions and recommended remedial alternatives should
be based on a final endangerment assessment.

We are primarily concerned with the assumption made as to the current-use
and future-use scenario at the Site, and the dependence of these models
in evaluating and selecting a remedy.  Under EPA's current-use scenario,
only groundwater and soil are considered to be significant exposure
pathways.  The off-site exposure point for groundwater evaluated is the
Lizzie Chapel well*  Although concentrations of lindane in this well are
less'than 25 percent of current drinking water standards, the Report  •
suggests that under a "plausible maximum case" lindane would exceed the
Safe Drinking Water Act maximum concentration level goals ("MCLG") of  .2
ug/1.  We not that the use of MCLG'a do not represent any existing standard.
Further, we point out that the EPA itself is not in favor of using these
MCLG'a as groundwater standards.

As to potential soil exposure, we note that the current-use scenario is
based on assumptions regarding the ingestion rates for children of certain
ages.  We note that the "maximum plausible case" under this scenario
would result in the ingestion by each child of 130 liters of soil over a
5-year period.  Even if such a scenario is indeed "plausible", the fact
is that the surface soils do not currently pose a significant health
risk.  As the Report states, only a marginal risk is associated with
long-term contact with soil, and no risk is associated short-term contact.
Further, even if a risk were present, various cost cost effective measures,
already included in the no-action alternative, could be taken to satisfac-
torily address any such risks.

As to the future-use scenario, we note that the EPA projects that certain
parameters will exceed MCGLs in off-site wells in the future.  In addition
to our reservations concerning the MCGLs, we find no support for the
assertion that these parameters will exeed such levels.  The assumptions
made concerning the potential for leaching into the groundwater or the
rate-s of flow from the landfill site do not take into account the actual
construction of the Site.  Further, rhe assumptions concerning groundwater
flow do not consider Che fact chat, while no continous clay layer was
observed, a series of clay lenses and overlapping confining structures
appears to be present which vpuld retard the movement of contaminated


-------
water into potential receptors.  By the EPA's own acknowledgement, the
model used in assessing the future-use scenario actually overestimates
the actual concentrations which would be expected over time.

With respect to soils, the future-use scenario assumes on-site development
of homes or other buildings, the installation of drinking water wells
onsite and exposure of construction workers and others to the on-site
soils.  In reality, any such development on-site is virtually precluded.
As was acknowledged by the EPA at the August 4, 1987, public meeting at
Fort Valley, Georgia, deed restrictions would preclude any such development.
Ve question the use of this scenario in evaluating the risk of exposure
or the remedy to be implemented when the assumptions underlying the
scenario are implausible.

Throughout the Endangerment Assessment, the EPA acknowledges that concen-
trations levels and exposure potential is overestimated, but were adequate
for purposes of a "preliminary assessment."  It is our belief that the
evaluation of the actual risk posed by the Powersville Site, and the
selection and implementation of a remedy, must be based not on a preliminary
risk assessment but on a final risk assessment.

Based on our review of the Report, we conclude that no groundwater contam-
ination currently exists off-site.  Further, because of facts known by us
and the EPD as to the construction of the hazardous waste landfill, and
the inconclusive nature of the groundwater results reported, we believe
the risk of groundwater contamination off-site in the foreseeable future
is low.  However, even if a future threat of off-site groundwater contam-
ination exists, we believe that this threat can be addressed by continous,
open-ended groundwater monitoring, as would be contemplated by a no-action
alternative.

With regard to soils, no realistic present contamination or future threat
of contamination exist at the Site.  Further, even if such risks were
present, the fencing and posting of signs contmplated by a no-action
alternative would eliminate any pratical risk of exposure.  We feel
that such actions would be adequate and cost effective in light of
the observed risk or threat of future risks.

While we do not believe that a significant risk of off-site groundwater
contamination exist, we acknowledge and are sensitive to the concerns of
the local residents regarding their drinking water supplies.  We recognize
that while no danger is presented to these residents, the perception by
these residents that a danger exists and the anxieties attendant to such
a perception constitute a public health Issue which should be addressed.
Therefore, in addition to endorsing a no action alternative with respect
to the Powersville site, we support the investigations currently being
conducted regarding the establishment of an alternate drinking water
supply foi these residents.  We hope that all possible alternate drinking
water sources would be investigated, so that one may be selected which
both meets Che needs of the local residents and can be implemented and
maintained in as efficient and cost-effective a manner as possible.

EPA response: The Endangerment Assessment is a final document.  The «<
-------
during editorial review.  As noted by the commentor, MCLGs are used in
the endangerment assessment.  Please be aware that MCLs are indeed the
parameters preferred by the Agency, and that the MCLGs are included for
informational purposes only.  While MCLs play an important role, many other
factors contribute to the final decision made by the Agency, and each NFL
site is decided on its own merit.  At the Powersville Landfill it is
clear that there is a release into the groundwater of hazardous compounds.
There is no assurance that the release will not worsen over time.  EPA
thus believes there is a potential for endangerment of the public health,
therefore action should be taken to reduce, if not completely eliminate,
that potential.

Future use, as indicated above, is a major concern for the Powersville
Landfill.  Canadyne Georgia has yet to provide documentation that confirms
the actual final construction of the hazardous waste site.  The statement
that there are overlapping confining structures is not one that EPA
agrees with or that available information could support.  Any such inferences
to the contrary made in the RI/FS report will be revised as may be necessary.
The cross sections provided in section 5 of the RI/FS support EPA's
concern that:

          - No continuous aquiclude can be considered to exist, and:

          - in the Providence and Gosport units, hydraulic interconnections
            are likely to exist, thus providing a pathway for migrations
            of leachate into the groundwater.


The endangerment assessment, which is a final document, is valid in
discussing the on site development of homes in the current and future use
scenarios, as it evaluates a complete no action situation, as stated on
page 11 of the endangerment assessment.  It appears that the no action
alternative indicated earlier in the report, where deed restrictions are
mentioned, is being confused with a no-action situation, where absolutely
no remedial steps are taken.  Deed restrictions were mentioned at the
August 4, 1987 meeting, but not in the context of a risk assessment and
such restrictions are not in place at this time.  Risk exposure is based
on the present status of the site and on future situations, where no
action is taken.

EPA appreciates that the FRF agrees that contlnous monitoring should be
carried out at the site.  The FRF states that there is no groundwater
contamination occurring off-site, but we believe that data from the
groundwater monitoring carried out during the RI/Fs does confirm limited
off-site contamination.
The following comments from Che PRP refer to the July 23,  1987 Draft Remedial
Investigation/Feasibility Study for the Powersville Landfill site.


Comment:  On Page ES-1, the Powersville Landfill site is refeircd to as a
class 3 site.  What does this classif lection mean and wha«- .-. s Ch? significance
of this classification?

-------
EPA response:  The class 3 designation is not relevant to  the summary
presented and will be deleted.

Comment;  On Page ES-3f the Endangerment Assessment  is referred  to  as
"Preliminary".  However, the Endangerment Assessment (Appendix C) to' the
RI/FS document does not indicate that it preliminary.  Are there two versions
of the endangerment assessment, and will the final Endangerment  Assessment
be appended to the final Report?

EPA response; As indicated previously, the word "Preliminary" is an error
that was not found during editorial review.  The Endangerment Assessment
is the final document.

Garment;  On Page ES-1, three potentially responsible parties (PRPs)
were indentified.  What efforts were used to research PRPs?  The presence
of such contaminants as vinyl choride, 1,2-dichloroethane, lead  and
chrome in soil and groundwater samples at the site indicate  the  presence
of nonpesticide related hazardous materials.  Were any efforts made to
corrolate these waste types with other businesses that exist or  once
existed in Peach County?  Did EPA retain a professional search firm to
indentify PRPs as it has for other sites?

EPA response;  This question has been answered in a  previous portion of
this summary.  A professional search firm was not required and thus
not used for the Powersville Landfill site.

Comment;  The RI/FS should include a Quality Assurance (QA)  Project Plan
in accordance with the December 29, 1980 Interim Guidance  from EPA. This
requirement includes a final QA report.  The Report  does not discuss quality
control over such activities as soil borings, particularly the 148  foot,
45° angled boring under the Hazardous Waste (HW) area, laboratory QA
activities, and field sampling activities.  Will the QA project  plan and
final QA reports be made part of the Appendix in the final Report?
                           *
                                                                      •
EPA response;  The Quality Assurance Project Plan is in the  records at our
office and at the public repository for public review.  It is part  of the
RI/FS but will not be included as part of this particular  report.

Comment:  On Page 1-1, the Report.States that EPA notified Peach County of
the unacceptability of the landfill facility for solid waste disposal.
Was it the EPA or the Georgia EPD which in fact made this  determination.
Shouldn't the report indicate that the Georgia EPD allowed the site to
operate from 1972 until 1979 before making this determination?

EPA response;  The report should state that EPD notified Peach County.
It is already clear that the site was allowed to operate until 1979.

Comment;  On Page 1-1, the Report indicates that Georgia EPD officials
observed the dumping of pesticides by the Woolfork Chemical  Company.
This observation is not documented in the Appendix to the  Report.   Will
this observation be documented and detailed in the -final Report?

-------
EPA Garment;  No.  Those picture and associated documents are  in  EPD and
EPA files and available for  review.

Comment;  On Page 1-6, Table 1-1 indicates that the USGS conducted  a survey
of all wells within  1 mile radius of the site.  .The results  of this survey
were neither discussed nor included in the Report.  Will this  data  be
attached as an Appendix item in the final Report?

EPA response;  No.  The survey is in the files at EPA and the  public
repository and available for review.

Garment;  On Pages 1-9 and 1-10, the Report concludes that the HW area was
constructed in undisturbed soil and the disposal trenches were not  lined.
A letter from the Georgia EPD to the Peach County Comiission,  dated December
29, 1972, specified  that the trenches in the HW area.be lined  with  3 feet
of clay.  Subsequent EPD memoranda, dated April 13, 1973, and  July  26,
1973, indicate that  the trenches were lined with clay as specified  and the
site was "constructed properly" and was being "operated satisfactorily."
Did the EPA consider these memoranda and take into account the construction
of the trenches?

EPA response;  EPA-has given full consideration to the issues  mentioned
above, but there is still a concern as to whether or not the site was
actually constructed as indicated.  For example, what does "lined with
clay" really indicate?  Was compacted low permeability clay  put on  the
bottom and side walls of the trenches, or were the trenches  dug down to a
depth where a clay bed of unestablished permeability was located?  In
addition, even a compacted, low permeability clay does not guarantee the
integrity of the site.  While the site was constructed on standard  practices
of the time, such practices often are insufficient by today's  standards.

Cctrcnent;  On Page 5-6, the Report discusses the two 45° borings under the  HW
area.  Was the trench slope design and trench construction considered by
the EPA when selecting the boring locations?
                                                           *

EPA response;  Yes, to the degree that the available information  allowed.

Comment;  On Page 5-8, the Report concludes that the HW area will eventually
leach unless remedial activity is initiated.  This generalized comment can
be made about any site, including those that have been remediated-.   In
this context, the statement does not aid in an understanding of the
condition of the site.  This statement should be removed or  clarified.

EPA response;   We disagree with the commentor, and the statement will
remain in the report.  Remediated sites take steps to reduce or eliminate
leaching.  For example, remedial activities that incorporate incineration
can destroy and thus effectively remove the leachable hazardous wastes.

Comment; On Page 5-8, the Report refers to the fact that photographs taken
by Georgia EPD personnel confirm pesticide disposal in Area  3  of  the
municipal landfill.  It is not clear how photographs can actually confirm
that "pesticides" were in fact disposed of at this site?  Will these
photographs be included in the Appendix of the final Report  to
this conclusion?

-------
EPA response:  We believe chat Che phoCographs, coupled with information in
EPA and EPD files, support Che statement.  The photographs are in EPA
records but will not be included in the report.

Comment:   On Page 5-8, the Report describes the conclusions reached regarding
three contaminated areas of the municipal landfill.  Considering the fact
that the  landfill was uncontrolled and open to all county citizens and
business, the placement of any wastes would have been haphazard at best.
The method of delineating the three contaminated areas is unconvincing and
inconclusive.  The manner in which these conclusions were reached should
be clarified.

EPA response;  Please note that the report indentifies these three areas
as potential contaminant sources.  Bearing that in mind, the conclusions
reached and the methods used to reach those conclusions are adequate.

Comment:   On Page 5-28, the study of saturated soils beneath the site
concludes thac the hydraulic conductivity is between 3.5-11 feet per day
in the upper aquifer and 5-7 feet per day in the lower aquifer.  Assuming
that this water movement capacity of the soils is correct, how does the
Report reconcile the fact that no unacceptable levels of contamination
have been measured in offsite groundwater wells In the upper or lower
aquifers?

SPA response;  The comentor does not argue the fact that contamination
has been observed off-site and this contamination does indicate that such
water migration is possible.  Please note that hydraulic conductivity
does not, by itself, determine the speed at which groundwater travels.
The other major factor that must be taken into account is the hydraulic
gradient  (i), which is basically the "slope" of the water table.  The
formula is v = Ki, where v is the specific disharge, or velocity, at
which the groundwater moves.  The low hydraulic gradient at this site
would keep specific discharge low.

Comment;   On Page 5-34, the Report concludes that the highest concentrations
of lead and chrome were discovered in the older, possibly deteriorating,
galvanized steel monitoring wells.  The EPA relies on these results to
conclude that significant contamination exist in the upper aquifer.
Since the Report suggests that this data is possibly Influenced by the
well construction materials, should not this data either be discarded and
not considered in the remedial alternative selection process or confirmed
by additional field investigation and water quality analysis?  We note
that these wells contain the only evidence of concentrations of contaminants
above drinking water standards on or off site.  Therefore, a remedy
should not be selected based on results from these wells if they are in
any way unreliable.

EPA response:  The influence of well construction materials in older wells
can explain the elevated lead and chromium values, buc it does noc explain
the presence of other contaminants in these wells.  Data from the galvanized
wells can therefore be used in conjunction with the data from newer wells.
It cannot, however, be relied upon by itself.  It is- Che combined useable
daca from all wells Chac was evaluated.

-------
Connent:  On page 6-1, the Report very briefly describes the air  investi-
gation at the site.  While it is generally agreed that no air contamination
is presently associated with the site, the Report has insufficiently
documented this conclusion.  A phoionization detector is an inadequate
instrument to measure all contaminants that could potentially be  present
in the ambient air around this site, e.g., lead and chrome transported on
dust particles.  The investigation should have included strategically
placed vacuum pumps with filters along with other instruments to  conclu-
sively support the air investigative efforts.

EPA response:  It appears that lead and chrome contamination is a result
of the galvanized monitor wells and consequently not a significant concern.
The present condition of the landfill is such that airborne particles
were not considered to be a problem, and the endangerment assessment
supports that conclusion.

Comment;  On Page 7-2, the last paragraph of Section 7.2 should read, "The
endangerment assessment indentified no short or long term health  risk...."

EPA response;  Agreed.  No short or long term health risk may be  associated
with contact with surface soil at the site, unless erosion alters the
characteristic of~the area.

Comment:  On Page 8-2 and at several other locations within 'the Report, the
term "capping" is described as a treatment technology.  This technology
is more appropriately described as a source control of contaminants,
since the placement of a site cap does not actually result in any physical
or chemical change to the waste/ soils, or contaminants.

EPA response:  Agreed.

Comment;  On Page 8-4 and in numerous other locations in the Report, the
EPA states that it considered the "No Action" alternative simply  because
there is a requirement to do so in the National Contingency Plan  (NCP).
Why was this alternative not seriously considered allong with all others?
There appears to be an effort to eliminate "no action" from serious
consideration early n the evaluation process.  Why are the "potential
impacts" of "no action" discussed in the initial disscusions, while such
impacts were not considered in the initial discussions of the other
technologies indentified?

The potential impacts of "no action" should be discussed in light of the
actual significance of those impacts.  Such a discussion should also
acknowledge that alternative, and that each of these impacts would accompany
any remedy selected at the site.

- Occupational or public exposure - No Action specifies fencing around
  the site to restrict access and public exposure.  Deed recordations
  would restrict occupational exposures.  There are no air or surface
  soil or water pathways indentified.

- Decline of property values -  Property values in rural area surrounding
  a closed municipal landfill should not decline any further than they may
  have already.  The RCRA capping of the site or. any other selected

-------
  remedy could have a negative effect on property values surrounding the
  site, and such a decline should not be attributed soley to a non-action
  alternative.

- Expenditures for legal services - What legal services would be required for
  this alternative?  The Report's cost estimates project no legal fees for "no
  action".  Indeed, other alternatives would require even higher expenditures for
  legal fees.

- Depressed area growth - As this is an agricultural community, growth rate
  is expected to be extremely low.  Would this rate be affected by the
  selection of any other alternative.

- Expenditures for laboratory analysis and monitoring - whether covered
  with a RCRA-type cap or treated onsite, hazardous consituents will need
  to be monitored in groundwater for indefinite periods of time;  The "no
  action" alternative analysis and monitoring expenditures would be no higher
  than those required for any other alternative.

- Restricted Access to Site - Short of a removal action, access to the site
  would be restricted regardless of the remedial action implemented.

- Environmental Impacts - The endangerment assessment revealed the only
  realistic environmental impact as long term exposure to contaminated
  groundwater offsite.  To date, drinking water standards in offsite wells
  are not being violated.  In fact, the highest concentration of any contaminant
  detected in an offsite will is less the highest concentration of any
  contaminant detected in an offsite well is less than 202 of the drinking
  water standard for that contaminant.

EPA response:  The "No Action" alternative was considered and judged to be
unsuitable for this site.  It is agreed that some of the impacts mentioned
under the "No Action" alternative would apply to some fo the other alternatives.

- Deed restrictions and fencing do not ensure the elimination of occupa-
  tional or public exposure.  Access to the site can still be gained with
  such measures in place.  Also, erosion and subsequent runoff could
  alter the site characteristics to such a degree that exposure would be
  a problem both offsite and on site.

- Legal fees would most likely be a part of any alternative.  To state
  that legal fees would be higher for alternatives other than the No
  Action alternative is speculative.

- The commentor also states that growth in the area would be extremely low.
  We believe the statement is strictly speculative.

- Monitoring costs could be reduced under some alternatives.  The inciner-
  ation of wastes in the hazardous waste area would reduce monitoring
  requirements, as it permanently removes the source of contamination.

- Thp comraentor draws upon present contamination concentrations to argue
  long term health effects.  There is no assurance that these contamination
  levexs will remain low, and this a the real concern where long term
  health impacts are Involved.

-------
Ccnrnent;  On Page 8-6, should not the design problems associated with
capping this particular site be discussed?  These would  include differential
settlement, significant regrading provisions, and methane venting.

EPA response;'  More detailed' discussions of capping are  included later
sections of the report.

Comment;  On Page 8-6, the statement is made that "a three layer cap is--
required by the RCRA land disposal regulations".  This site  is not a
hazardous waste land disposal facility regulated by RCRA.  Why should the
RCRA regulatory standards be required for site capping?  Why weren't
other surface activities considered which might be more cost effective?

EPA response; EPA believes it is important to use methodologies that are
compatible with other laws that apply to similar types of sites or that
achieve a similar level of performance.  While the RCRA  type "C" cap
is the alternative mentioned in the report, other capping methodologies
are also being examined.

Comment;  On page 9-23, Table 9-3, what is the significance of listing
capping the municipal site with asphalt?  No discussion of asphaltic caps
is offered to explain this reference.

EPA response;  Page 8-6 of the RI/FS report does briefly discuss asphalt
caps.  However, the presentation of these costs is chiefly for comparison
purposes.

Comment;  On Table 9-3, under disposal.of groundwater, what does the term
"trucking" refer to and what is the cost?  Offsite disposal  into a POTW?
Does the disposal have a cost?

EPA response;  Trucking refers to transporting the water to  a nearby
treatment plant.  The cost would be. approximately $400,000.

Comment;  On Page 10-4, all the alternatives to be considered are listed.
Why was the alternative of an alternate drinking water supply only not
listed?  Presuming the site to be the source, the groundwater to be the
pathway and the surrounding residences to be the receptors of contamination,
providing an alternate drinking water supply would eliminate the receptors
and eliminate any present or future threat of contamination.

EPA response;  The alternate drinking water supply does not  eliminate or
reduce the leaching of contaminants into the aquifer and thus was not
considered by itself.  EPA will not accept any alternative that allows
the continued contamination of the aquifer/ as this aquifer  is still a
potential drinking water source.

Comment;  On Page 11-35, the EPA-preferred alternative is described.
Appendix F outlines the costs associated with this remedy.   Why was a
deep public well system to provide alternate drinking water  not considered?

-------
Its casts could be significantly less than utilizing the City of Byron
water system.  What residences would receive the alternate drinking water
and what justification would be be used to distinguish between residences
in the Powersville area.  Will an alternate supply be offered to any new
residents of Powersville?

EPA response;  A deep well is a possible alternative which will be considered
during the Remedial Design Phase.  The final decision as to which residences
will* be tied into the municipal water sourcewill be made during the
Remedial Design.  For cost purposes, a 1/2 mile radius downgradient of
the site was used to establish which residents will get drinking water.

Comment: The following comments relate to the Alternate 8 Cost Estimate from
Appendix F.

 -   Contractor's Bonds are generally 2Z or more for hazardous waste work.
     The $10,000 amount referred to seems low.

 -   Site preparation costs are too low. Excessive regrading and compaction
     of the municipal fill area 'is required.

 -   Fencing is available at $12 per linear foot, and would not cost $16.50.
     At this calculation, $61,875 is too high.  In the technology cost
     estimates, fencing costs are projected at $30.00 per linear foot,
     significantly higher than necessary.

     Gravel is available at $4.00 per ton, (EPA quotes $12.50).  Local sand
     is available in large quantities at even lower prices and meets perm-
     eability requirements for cap drainage layer.

 -   Topsoil can be purchased and installed for $10 per cubic yard (EPA
     quotes  $18.00)

     What does $20,000 for drainage specify?

     Contractor supervision is a function of job time and not capital
     costs.

 -   Estimate is too high.

 -•  Legal fees and permit cost should be limited.   Cost estimates are
     too high.

In technology cost estimates, costs for capping the hazardous waste area
are missing drainage layer and.topsoil layer estimates.  Costs for capping
the municipal landfill area are missing topsoil estimate.

In general,  the overall cost estimate tables and associated discussions
tend to be generic in nature and not site specific.  For example, what
permits will be required for each alternatives?  What drainage provisions
need implementing?

-------
EPA response:  Estimating costs for hazardous waste site construction is
more difficult than with a normal construction site.  Additional costs
include on site monitoring, special insurance, protective gear, and
medical monitoring of the workers.  Consequently, the additional cost is
reflected in the costing estimates.  These estimates in the report were
generated by a contractor with experience hazardous waste remedial actions
and represent a "best estimate" for the site.  Drainage cost estimates
are provided for the constuction of ditches, culverts, etc., that wiir~be
needed to provide proper drainage for the site once a cap is constructed.
The additional comments concerning the cost estimate will be taken into
consideration and revisions made as is necessary.

Comment:  The following comments and question relates to the review of the
Endangerment Assessment.

The Endangerment Assessment utilizes several models and scenarios to project
risks associated with contact with soils and waters potentially affected by
the Powersville site.  The Endangerment Assessment acknowledges that these
scenarios are unrealistic and overestimations.  For instance, the future-
use scenario of the landfill site for residential development and drinking
water wells is stated as unrealistic (page 11).  The Assessment acknowledges
that the model used to project the diffusion rate into groundwater of
contaminants overestimates actual concentrations expected (page 16).  The
assessment states that the actual risk from exposure to carcinogens could be
considerably lower but unlikely higher (page 23).  If the assessment upon
which the assessment is based are admittedly unrealistic and unlikely, how
can they be seriouslly utilized to project risks for decision making
purposes?

EPA response:  The evaluation of Public Health and Environmental Impacts
is in accordance with EPA guidance and are consistent with assumptions
used at silmilar sites.  As stated in the Endangerment Assessment, the
long-term status of the site cannot always be predicted.  Thus, the
scenarios presented provide an adequate upperbound worst-case assessment.

-------
                 RESPONSIVENESS SUMMARY FOR STATE COMMENTS
Comment;  The presentation of  extensive geological interpretation  is  noted.
In accordance with the 1985 Amendments to the Georgia Water Wells  Standards
Act, it is  requested that a Georgia registered geologist coaign/certify
the final report.

EPA response:   EPA agrees.  The report was prepared with the help  of  a
Georgia registered geologist and we will request that he sign  the  report.

Comment:  In overview, the remedial investigations have yet to focus  attention
on the  fundamental requirement for "Waste Characterization".   No work is
apparent in this  report regarding the physical or chemical nature  of  the
materials buried  in the Hazardous Waste Area.  It is reported  that the
results of  the  angle borings failed to discover any appreciable leaching
of constituents as anticipated beneath these trenches.  Additionally, the
landfill borings  encountered extremely sporadic evidence of contamination
effects and little, if any, indication of appreciable hazardous waste
deposition. However, the apparent complete estimated total volume (292,000
cu. yds.) of solid waste in the landfill is used as a design criterion
based on the data presented in TABLE 5-1, page 5-5-       --..

EPA response:   The physical and chemical nature of the materials buried
in the  landfill is well documented by the disposal records contained  in
Appendix B  of the RI/FS report.  EPA felt that.boring into or  through the
hazardous waste area would cause risks that were unnecessary to this
investigation.

The total volume  of the landfill was used due to the sporadic  nature
of the  contamination in that area.  The logic in using total volume of
the landfill is  to make certain that all contaminated areas would  have to
be remediated,  as  it would be  very difficult to separate the contaminated
areas in the municipal fill area from the uncontaminated areas.

Comment;  We concur that groundwater and soil represent current exposure
pathways, however, we note that soil effects are defined by the consultant
as not  representing a health risk in Chapter 4 and then in Chapter 8
concluding  that soils exposure is a design criterion for remedy selection.
EPD does not believe that solutions should be designed for problems with
no apparent associated risk.  Additionally, we also concur that air and
surface water are not exposure pathways.

EPA response:   Short term health risks due to soil contmaination are  not
currently a concern at the site, but due to onsite erosional problems
surface soil contamination could be a concern if left unchecked.   For this
reason  the  remedy selection should take into account the possibility  of
future  surface  contamination problems.  Please note, however,  that the
intent  of Section 8 i= tc present overall remedial technologies for the
purpose of  screening f.o select rhe most feasible of these technologies.
 .,....•.~-.---••••••. •   ._._,.. ...,..      ._,   ,......„..„..,,_,,._......r...v__?,.._,.__,__^—r
&n"U-;>j..,v«Jiv-,-^~--lii-tl-;L'^-:;i,-..;^ ^V ;>;'' ' '•'-'-''•"' "• ~-V'?;:S\r^;\i^.:v^y^>^^^

-------
                                     -2-
          A potentiometric map is included which covers both the shallow
and deep flow components together.  However, water level data are reported
on one event only.  If the shallow wells and deep wells are contoured
separately, two separate flow regimes emerge.  The deep wells conforms to
the potentiometric map presented in the report (East-Southeast); however,
the shallow component is distinctly South.  This is important because the
shallow wells show most of the measured contamination.  It is also worth
noting that the shallow water levels form a topographic image of the
former borrow pit used for the disposal site.  One could expect flow
through the borrow pit area to be several magnitudes greater than the
deeper flow regime.

EPA response :  EPA agrees that the water level data is somewhat subject
to interpretation, but we do not feel that the data conclusively supports
EPD's belief that there are two separate flow regimes.  We believe that,
based on available data, the report's potentiometric map provides a sound
interpretation of the flow regime beneath the site.

Comment;  Priority pollutants were run on groundwater and soil samples ;
however, indicator parameters were chosen to track the plume.  While
this approach is cost effective and satisfactory for plume tracking,
no analysis was performed on plume periphery wells to confirm the
original selection of indicators.  Since speed of migration was not a
criterion for indicator selection, a contaminant of higher mobility
could conceivably be beyond the indicator plume .

While indicator parameters were used to track the plume, all analyses
were evaluated for priority pollutants.  The referenced indicator
plume has been removed from the revised report, as we believe that there
is not enough data to conclude that there actually is a plume in the
area.

Comment :  The data suggest, that although there may be aquifer interconnection,
there is significant interlayering of formation clays.  These clays are,
in fact, naturally filtering the groundwater.  No pump test data or
complete boring logs to confirm the presence and extent of a confining
unit are presented.  The location of this interlayering may influence the
selection of a proposed alternative.

EPA response; Slug test data and some gamma logs are available.  Boring
logs could be helpful, but given the geology of the area it would take a.
substantial number to adequately define- the location of the clay layers.
Conducting pumping tests for the deeper wells raises the risk of drawing
contaminants down from shallower, already contaminated, zones.

Comment :  The future-use scenario, as employed by the consultant, uses
an environmental transport model.  This model as described in Appendices
A and C is based on  the work of Summers, ei: al , 1980.  Summers" work,
howfcver, was designed to assess contamination from inorganic salts in
gcothevm&l systems ( e.g., geysers, not volcanic rock, ef*. .).

-------
The model is not appropriate for trace organic chemicals in Coastal Plain
aquifers.  For this reason, toxaphene and chlordane cannot be estimated
with this model.  Moreover, in addition to using an inappropriate model,
the consultant also made errors in the hydrogeologic calculations.  For
example, runoff was ignored in calculating recharge and the aquifer
thickness was incorrectly estimated.  Additionally, no Information is
found regarding the physiochemlcal properties of the soil materials
beneath the site.  Properties such as:  vertical permeability, organic
content, attenuation capacities, directly impact leachate modeling/
prediction.

EPA response;  The Summers model, used to predict future groundwater
concentrations, is applicable to releases of trace organlcs.  The particular
form of the Summers model cited in the Endangerment Assessment is simply
a form of mass-balance equation, and as such, is applicable to any type
of pollutant release.  The same approach has been used on numerous Superfund
sites to assess future risk.  At the Geiger and Independent Nail sites
the model was used to develop soil cleanup levels.  Summers is cited only
to provide a reference for the nomenclature used.  In order to prevent
further confusion, it might be best to remove the citation to Summers and
simply refer to a mass-balance equation.  We may wish to modify the
results to account for runnoff or a different aquifer thickness, although
these modifications are not likely to have a large impact on the results.
However, trying to account for additional soil parameters"as is suggested
is, in our Judgement, not warranted.  The model_accounts for organic
carbon content- of the soil, which is the major component to be considered
in this non-time dependent model.  Soil testing for parameters such as
permeability was not Included in the RI.  Estimating these parameters or
trying to use a more sophisticated model would simply add additional
uncertainty to the assessment.

Comment:  The groundwater monitoring results do not indicate a relationship
regarding the groundwater contamination discovered on the site and the
identified waste products or suspected source areas.  There are no reliable
data to suggest drinking water quality standards for groundwater used
domestically will be exeeded.

EPA response;  This comment appears to address two separate issues.  The
first is the relationship of the groundwater contamination to waste
characteristics.  It is not inconsistent to see different contaminants in
groundwater and soil.  The more mobile contaminants, such as vinyl chloride
and 1,2-dicholroethane, are more likely to leach from soil to groundwater,
whereas the less soluable pesticides will remain in the soil for a longer
period.  'The second issue relates to potential exceedences of groundwater
standards.  The assessment indicates that levels of contaminants detected
in monitoring wells exceed MCLs or proposed MCLs for vinyl chloride,
1,2-dichloroethane, and toxaphene.  This assessment is based on assuming
that a drinking water well is established on site, or alternately that
the groundwater represents a Class I or Class II aquifer capable of being
used as a drinking water source.  Therefore, according to EPAs' most
recent guidance on ARARs, MCLs are applicable standards for comparison
to contamination levels.

-------
Comment:  The Quantitative Risk Characterizationis not realistic.  The
site is currently unused.  Thus, the current Chronic Daily Intake (GDI)
calculations are incorrect.  In this regard, the GDI for drinking water
from the Lizzie Chapel well can be significantly reduced from the worst
case assumption used.  Further, the GDI for soil ingestion can be signifi-
cantly reduced by using a. much more reasonable assumption for children
playing on the site.  Incorporating these changes can readily reduce the
calculated exess lifetime cancer risk due to groundwater and soils ingestion
by a factor of ten or more.

EPA response;  We believe that that the exposure assumptions underlying the
Quantitative Risk characterization are reasonable.  They are in keeping
with EPA guidance and are consistent with assumptions used at similar sites.
In addition, the scenarios involving soil ingestion by children do not
result in unacceptable risk levels, if a 10~6 excess lifetime cancer risk
level is taken as an acceptable level.  Therefore, the scenarios presented
provide an adequate upperbound worst-case assessment.

-------
            APPENDIX B

INVENTORY OF MATERIALS DISPOSED OF
     AT PEACH COUNTY LANDFILL
                                                 J70/47

-------
WOOLFOLX CHEMICAL  WORKS, INC.
         FARM AND GARDEN PRODUCTS
         •at ttt. fort V»0«y. Ooarfia 31030 • (912) S2S-S511
Kr. Sovmfd L. Sarerbot
Obit Coordinator
             ffasardous Vast*
              Prograa
              Prooction  at via ion
270 y<>/Ti'nytton StrwwC, 5.  V.
                  JOJJ4
fltar Mr. a*tmfoot*

Enclosed you will find our records tiat indiota th« dat* and
Łppros±asts qnsa€j.€^ms for a4J p0ttd.cd.dm v**t»s placvd la
MoolrblJc'5 pesticide wast* disposal area at tb*> PowaraviJl*
sit*.  During this tis»,  this area and record* Mtre being
constantly checked by Tfr.  Clyde Fmhn, Industrial
Georgia Dtpartsant o/ Natural JZesources.
      very truly/

HCOLSOLX CHEMICAL  WORKS, IXC.
Łd Chaobless
Plant Manager

SC/Js

enclosures

-------
WOOLFOLX CHEMICAL WORKS, INC.
              4/V0 GARDEN.PRODUCTS
          938. fun Valley. 0«orfia 31030 • (912} 125-5311
SEcuHitf
OBSOLETE HATERIALS BURIED AT DUMP
1975
DATS QUANTITY DESCRIPTION
1/7/75
1/9/75
3/4/75
4/22/75
8/5/75
8/7/75
8/12/75
8/14/75
9/4/75
9/10/75
9/16/75
9/29/75
10/1/75
10/14/75
10/16/75
4000*
7000*
2000*
5000*
2000*
5000*
2000*
5000*
4000*
4000*
500*
2000*
1000*
JOOO*
1000*
500*
1000*
4000*
JOOO*
1000*
1000*
1000*
5000*
1000*
Clean-Out from Lead Plant
Clean-Out from H.O. (farmhouse
Clean-Out from N.O. Plant
Clean -Out Clay from Dust Plane
Empty 25-0 Paraenion Bay*
Sevin (Empty) Bay* a. O. Plant
Clean-Out H.O. tttranou**
Empty Sevin Bay* .
Empty Bay* Dust Plane plus Dust Plane Clean-yp
Clean-^ut Floor Sv&epings ff.O. Plant
Clean-Out Floor SveepLngs Dust Plant
Floor Sue apings Shipping Warehouse
Empty Sevin Bays
Empty Tech. tfepta. Drum*
Floor Sveepiny* N.O. Warehouse plus tfepta. Espty
Drums
Sevin Plane Floor Sveepiny*
Empty ffepta . Oniaa
H.O. Plane Clean -Out
Clean-Out from H.O. Pi Ant
Floor Sweepings from Dust Plant
Floor Sv&epings Shipping Warehouse
Floor Sweepings from Shipping Warehouse
Floor Sweepings from H.O. Ware-nouse
Floor Sweepings from N.O. Plaxt
Enpty Arsenic Fib«r Drums


-------
     WOOL5OLX CHEMICAL WORKS,  INC.
             FARM AND GARDEN PRODUCTS
     SECURITY
      So* 938.
                     ViH«y.
                       31030 . (912) §25-5911
          OBSOLETE JttTERIALS
                    1974
                                       AT LUMP
DATS
QUANTITY
DESCRIPTION
12/5/74






12/10/74


12/12/74
13 -
25 -
a -
56 -
20 -
51 -
35 -
250 -
40 -
20 -
70001
50*
501
50*
501
50*
50 *
50*
sot
40 f
50 f

Po-Iyrim Cost
T.7. Spaciil Duat .
1/2* P«r*.-56X 5ul.
Cl«&n-Out fiotoz
J-V*y ro^. Pu5e
Tri JC*1 .Uusc
Gu+rdfx Dust
Cl««n-Out Do»c Plaae*
3ffC-Łtl«ldrln «ijrtur»
5» Polyraa
CJ«*n-5ut xxua Cuse Plant


-------
DATS QUANTITY OESCKLP7IQH
10/29/75
11/4/75
11/18/75
2000 i
soot
2000t
500*
2000*
3000 »
2000*
Cl«an-Out Clay froa Savin Plant
anpty Arsenic Druaa •
Floor Su9«pin$s Shipping tfarehousa
Eapty BSZ Ł L/A B*gs H.O. Plant
Cl«an-Oue Clat; /ronr Dust Plant
Cl««n-Out day froa tf.O. Plant
Cl«an-Out from Savin Plant


-------
    WOOLFOLK CHEMICAL WORKS,  INC.
            FARM AND GARDEN PRODUCTS
            Port V«**f. <3«org« 3103O • T«*pfto»w (912] 825-5511
                 OBSOLETE MATERIALS BURIED AT DUMP
                            1977
DATE
QUANTITY
DESCRIPTION
1/26/77












2/3/77


3/2/77

3/8/77

3/16/77


3/24/77
3/2S/77

3/29/77
f
.
'. 4/18/77"
•

60-5 gal.
400f
20
soot
5 - 24/21 case
1 - SOf
3-50*
10 - SO*
5 - SOt
2-1 gal.
1-5 gal.
SCO-'
1 - S3 gal.
500*
iooo*
1000*
500*
100*
1000#
60
100
600
1000*
1000*
soo*
500*
1000»
200»
800*
icoo*
30 - S gal.
U-S gal.
•
Empty Cygon 2-E Cans
Clean Up Dust
Empty Dithane M-22 Cone. Bags .
Clean Up Sevin Plant
ROSE & FLOWER
COND. SUL.
FERROUS SULFATE
DIWEEVIL DUST
CHINCH BUG KILLER
ANTIROT Eapty Cans
Enpty Tox-Sol-6 Can
Floor Sweeping Shipping Warehouse
Eapty Plastic Container
Sweeping Sevin Plant
Sweeping N. 0. Plant
Sweeping N. 0. Warehouse
Eapty 30-D Parathion Bags
Eapty Pan-Thion Bags
Eapty Sulfur Bags
Eapty Cases S Bottles Aatrex 4L
Eapty Cygon 2-E.
Eapty Sul. 5 Parathion Bags
Clean Out from Dust Plant
Eapty Sulfur Bags
Empty 30-D Parathion Bags
Empty Sulfur Bags
Sevin Plant Clean Up
Eapty Lead Arsenate Bags
Clean Out from Dust Plant Collectors
Clean Out Clay Dust Plant
Eapty Tox-Soi-6 Cans
Empty Cygon 2-E Cans

-------
                    OBSOLETE MATERIALS BURIED AT DUMP
                                 1977
                                Page 2
DATE
QUANTITY
                                     DESCRIPTION
S/2/77














































2-41
2
1
1
1 - S gal.
2 - S gal.
1 gal.
1 gal.
4 ib.
1 Ib.
2 Ib.
2 Ib.
2 Ib.
10 Ib.
2 - 4»
S gal.
10 Ib.
25 Ib.
1 Ib.
2 - 29
I Ib.
4 qca.
1 gal.
2-1 gal.
«s gal.
1 gal.
4 Ib.
10 Ib.
4 - 1 gal.
1
4 - 1 gal.
4 - 25*
1 gal.
4-5 gal.
S gal.
8-5 gal.
1 gal.
5 gal.
11-5 gal.
S gal.
1
S gal.
2 - 5 gal.
Is Ib.
I gal.
: gai.
'0 Ib, '
PROBE 7SW
Empty Gallon Jugs
Empty Gallon Ac cut TO 1
Empty Pint Peach Thinner
Empty Flowable Sulphur
2* SODIUM AZIDE
ZECTRAN 2E
Empty Elgetol
MIREX BAIT
DURSBAN BAIT
CAPTAN 50-W
KOCIDE
IMIfiAN
UREA
SINBAR
M-2630 SOIL FUMIGANT
NEMACUR '
FLOREX
IS* OIL CHINCH BUG
CORN COB WITH OIL
CORN COB WITH OIL
VYDATE L
SEVIMOL 4
TARGET
VYDATE L
VYDATE L
GALECRON SP
CORN COB GRIT
HERBIMAX SURFACTANT
Empty Metal 5 Gallon Can
BELT MP
2% METHOMYL DUST
BELT * 6
BELT PLUS
HCS-3260-MP
BELT MP
PHOSORIN
BUSAN 72
B I VERT M
B I VERT DPN '
Empty 5 Gallon Security Can
LIME SULPHUR
STARBROM T6-67
TERRACLOR SUPER X
TOfTB
SAVOL
MOCAP 10G

-------
OBSOLETE MATERIALS BURIED AT DUMP
             1977
            Page 3
DATE QUANTITY DESCRIPTION
5/2/77
-












































10 gal.
1
1 gal.
1
1 gal.
6 Ib.
24 Ib.
10 Ib.
1
50 Ib.
3 , 1 gal.
6 - 1 gal.
2 - 2S»
3 - 1 gal.
4 - 4/1 gal. cs.
1 gal.
1 gal.
1
1.
2
8
2 gal.
4-4»
m ib.
2
1
1
SO Ib.
2
10 Ib.
3 Ib.
4 gal.
50 Ib.
7 - 2 Ib.
S gal.
24 Ib. '•
4 ib.
1 pint
S Ib.
2 gal.
1 gal.
6 Ib.
2 - 1 gal.
2 Ib.
1 gal. •

i
SIVERT S * DPN
Empty Fire Ant Bait
ENORX-SOL
Empty Gallon Parathion EC -4 -
MURATIC ACID
NUTONEX SULPHUR
NUTONEX SULPHUR
BLADEX
Eapty Water Jug
DYFONATE .
MO-8AIT
B I VERT TM
MOCAP 10G
PENCAP E
SORBA SPRAY
BENTGRASS HERBICIDE
FAIRWAY HERBICIDE •
Eapty 5 Gallon Prowl Can
Empty 1 Gallon Container
Empty Starbrom T6-67
Empty Quarts Ambush
NU-FILM 17
PROBE 75W
MESUROL
Empty Temik Bags
Case Empty Display Cans
Emoty Quart Jug
TCMTB - 10G
Empty Cases
CORN COB
SODIUM AZIDE
NU-FILM 17
PEANUT SEED
Empty Topsin SO-tf
T-H ATRA2INE 4L
PAN-THION
GRAMJLAR CHINCH BUG
MBR 1232S-4-5
TOMATO DUST
LIME SULPHUR
ANSAR 170
TENORAN
ENULSONINE 3-E
SENCOR
>D's
•


-------
OBSOLETE MATERIALS BURIED AT DUMP
             1977
            Page 4
                 DESCRIPTION
. S/2/77









r>



































"
1 quart
1
% gal.
3
1 gal.
1 - 4*
2 gal.
1 pint
1 bag
1 gal.
2 quarts
3 - 10*
2 - 1 gal.
1 quart
4 lb.
3 gal.
S - 1*
2 - 4f
1 gal.
1 lb.
5 lb.
1 lb.
1 gal.
1 gal.
1 lb.
2 lb.
12 oz.
S lb.
2 - If
6 lb.
1 lb.
3 - kf
2 - l/8f
S - 4 oz.
1 gal.
3 - gal.
1 gair
1 gal.
2 lb.
10 lb.
1 quart
•2 lb.
4 lb.
5 lb.'.
r „
3 lb/
3 - 6-2/3*
CITOWETT PLUS
Empty Quart Dura ban 2 -EC
•BUTOXONE
Eapty Gallon Sorb* Spray
FLO-MO
MANZATE 200
NALCO-TROL
LIME SULPHUR
SENCOR
DURSBAN 2-E
LANNATE L
SUTAN IOG -
AMEX 320
CHLORDANE EC-« . ..-
R 5 H DITHANB M-4S-::
PHOSVEL 3-EC
ED 103 -:•-- .- --^
ED 103 •-•• - -
SUSAN 37 - •••- -
TEMIJC
DESTUN -•••'-• ~ . -
VEL S20C
BROMOCIL
SOYEX
U-27. 267 HERBICIDE
BORAX WEED KILLER
MAINTAIN
BROMEX
USB 31S3
NORLEX KERB -
PLICTRAN
VEL 5028
VEL SOS2
SENCOR
LIME SULPHUR
VCS-506
SORBA SPRAY
SPRAY OIL
BENLATE
LANNATE 90
THIMET
DACONIL 2787
CAPTAiN SO
SEVIN SO-W

DYLOX
30TRA.N 75*
• 2 - lot • • LANNATE wp
• ..../

-------
                    OBSOLETE  MATERIALS  BURIED AT DUMP
                                 1977
                                Page 5
DATE
QUANTITY
DESCRIPTION
S/2/77





































,







1
2 Ib.
1 Case
10 Ib.
10 Ib.
12 oz.
4 gal.
8 Ib.
S gal.
1 gal.
3 gal.
* - 1 gal.
3 gal.
2S Ib.
7
4 Ib.
10 Ib.
4 ib.
3 Ib.
2 Ib.
3 - 1 Ib.
10 Ib.
3 Ib.
2 - S Ib.
2 - 2 Ib.
4 Ib.
2 - 2 Ib.
2 Ib.
3 Ib.
1 Ib.
2 Ib.
1
1 gal.
1 quart
1 quart
2-6 Ib.
2 - S Ib.
2
3 Ib.
4Jj Ib.
.4 - 1 Ib.
7 pints . . . '.
10 Ib.
75 Ib.
s ib.
7 - 25 Ib
S gii.

Empty Lannate WP Can
Old Display Samples
CASORON 4-G
DACTHAL 7SW
MAINTAIN
DYMID PLUS DINITRO
15% PARATHION
DOW GENERAL WK
VAPAM
SORBA SPRAY
SORSA SPRAY
GIKUL
DEMOSAN 10-0
Eapty 6 Gallon Jugs
MANZATE
EPN 2SW
15* PARATHION
CYPREX
KOCIDE 101
OUTER
EPN 2SW
BRAVO 75W
THYLATE
KOCIDE 101
DITHANE M-4S
CAPTAN
DACONIL 2787
CYPREX
40W CHLORDANE
HYVAR XP
Empty Parathion CL Gallon Container
THAGSBEN 200
METHYL PARATHION
. MOTOX 63
TENORAN
. COTORAN
Empty 4 Gallon Plastic Jugs
ZORIAL
DACAGIN
• ZORIAL
. .TRITON X-114
DYLOX
OiTHANE A-4C
- THIVET ICG '
: 3IOTROL
..DYMIO D



-------
OBSOLETE MATERIALS BURIED AT DUMP
             1977
            Page 6
DATE - QUANTITY DESCRIPTION
S/2/77










f*



























"*








1 lb.
2 lb.
3 lb.
4 lb.
1 quart
1 gallon
S lb.
10 lb.
2 - 4 lb.
4 lb.
1 gallon
1 quart
1 quart
1 pint
1 pint
1 pint
1 quart
1 pint
8 oz.
1 pint
1 pint
1 lb.
1 pint
1 pint
8 oz.
1 gallon
10 gallons
2 lb.
S gallons
1
1
2 lb.
1% lb.
4.5 oz.
1 quart
1 gallon
1 - 12/8 oz. case
1 pint
S gallon
5 gallon
S gallon
2 - S lb.
3 lb.
1 gallon
1 gallon
I gallon
1 sack
*
LOROX
CHINCH BUG BAIT
CHINCH BUG BAIT
LOROX
BRAVO
C03EX
PRINCEP
LANNATE WP
HYVAR XWS
OYBAR
GIB-SOL
ACOJTROL
PROWL
LIQUID SEYIN
TOX-SOL-6
WET-AID
MOTOX 63
TOX-SOL-6
NOCULATE 3
ATPLUS 403
TACX TRAP
SOYBEAN PROTECTANT
TORAJC
ATPLUS 401
MOTOX 63
TD-692 PENVAL
PAN-THION
2787 DACONIL
H:0
5 gallon Empty Jug
Cap tan Empty Jar
CAPTAN
DIELORIN
SOROLEX
BACHCIM
2.4-0
MIS. -WETAIDS
LAWN WEED KILLER
THAT FLOWABLE SULPHUR
MP-ENDRI-SOL
PENCAP H
TEM!
-------
                      OBSOLETE MATERIALS BURIED AT DUMP
                                   1977
                                  Page 7
  DATE
 QUANTITY
      DESCRIPTION
5/2/77
5/5/77



8/16/77




9/1/77


9/22/77



10/6/77
   1 sack
   4 . SO*
   S - S gal
   S gal.
   4 ib.
   3 • SO*
  50*
   6-5*
   8-4*
  25*
   2 gal.
   1*
   1 gal.
   1 - 4/1
   1
   1
  10*
   1 gal.
  10*
  25*
   2 - 50*
  20*
   3*
  16*
   1
   1 gal.
  20 gal.

 200*
 700*
 300*

 129
20001
10001   "
  30 - 551

50001
 100*

2000
2000
  25  •

  50
  36
   8
   9
20001
                      gal.  case
-SOYBEAN SEED
 AMIBEN GRANULES
 BUFLOX 30
 BIVERT
 GALECRON SP
 DIPEL  BAIT
 FURADAN 10G
 IMIDAN
 TERRACLOR  7SW
 CASORON
 BUSAN  37
 VITAVAX
 NUMUCUR
 TEMIK-TERR.  SUPER  X
 Eapty  Line Sulphur 5  Gallon Container
 10G  Par. Display
 PROBE
 WEEDONE 170
 CORN COB
 UC-2186S 7SW
 BIOTROL CORN COB/MOLASSES
 NITROGEN INOCULANT
 MESUROL 7SW
 NUTONEX SULPHUR
 Cobex  Display  5  Gallon
 LO-DRIFT
 GREASE

 Empty  Parathion  5  L/A Bags
 Clean  Out  Clay Dust Plant
 Floor  Sweeping N.  0.  Plant

 Empty  5 gal. Methyl Parathion  EC-6
 Floor  Sweeping N.O. Plant
 Floor  Sweeping Sevin  Plant
 Clean  Out  Clay Oust Plant

 Floor  Sweeping Sevin  Plant
 Empty  L/A  Sags

 Empty  80-0 Sevln Bag
 Empty  Tech.  Sevin  Bag
 Empty  5 gsl. Ca.is

 Empty  5 gal, Pai's
 Empty  4/1  gal. Glass  Cygon
 Empty  6/1  gal. Antirot  Cans
 Eirpty  Plastic  5  gal.  Accelerate Jug
 Clein  Out  Clay Dust PUnt.  Floor 5**eping



-------
                         OBSOLETE MATERIALS BURIED AT DUMP
                                      1977
                                    Page 3
  DATE
 QUANTITY
     DESCRIPTION
11/23/77


12/13/77
1000
 500

1000
10001
Empty ParatMon-Tox Bag
Empty Sevin Bags

Empty Lead B'ags
Clean Out Shipping Warehouse

-------
                      OBSOLETE MATERIALS BURIED AT DUMP
                                  1978.
                                 Page 1
DATE
DESCRIPTION
3/22/78
3/23/78
4/17/78
4/25/78
5/30/78
5/30/78
6/1/78
6/1/78
6/6/78
6/13/78
6/22/78
6/27/78
8/29/78
1000
1000
1000
2000
1000
2000
1000
1000
3000
1000
500
4000
2000 %
4000
1000
80
4000
20001
2000
2000
4/1 gal
'1000
1000
2000
10001
4000
4000
2000
3000
50001
50001
50001
5000
2000
500
6 - 5 gal
Empty Pan-Thion Bag
Empty E. Parathion Bag
Empty Sevin Bag
Empty Pan-Th.fon Bag
Empty Ł. Parathion Bag
Empty 30-0 Parathlon Bag
Empty 80-0 Savin Bag
75 Chlorothalonil Empty Drums
Empty 30-0 Parathion Bag
Empty 80-0 Sevin Bag
751 Chlorothalonil Empty Drums
Empty 30-0 Parathlon Bag
Empty 80-0 Sevin Bag
Empty 30-0 Parathlon Bag
Empty 80-0 Sevin Bag
Empty 5 gal. Cans Lorsban, Tox-Sol-6
Empty 30-0 Parathlon Bag
Dust Plant Floor Sweeping
Empty 30-D Parathion Bag
Empty Sevin Bag
Empty Cygon Cont. (approx. 60)-
Empty 50-W Sevin Bag
Empty 01 pel Drum, Fiber
Empty Kel thane Drum, Fiber
Sevin & N.O. Plant Floor Sweeping
Empty 80-D Sevin Bag
Empty Parathion Bag
Empty Captan Bag
Empty BSZ Bag
Floor Sweeping From L/P & Sevin Plant
Floor Sweeping From N.O. Plant i Sevin Plant
Floor Sweeping H. 0. Plant 4 Sevin Plant
80-0 Sevin Empty Bag, 50-W Sevin Ercpty Sag
Parathion Bag Empty
Parathion Sulfur Empty Bag
ll/oal. BHC


-------
                         OBSOLETE MATERIALS
                                     1978
                                    Page 2
                                BURIED AT DUMP
  DATE      QUANTITY
                           DESCRIPTION
9/18/78
9/28/78
20001
2000
1000
2000
1000
1000
1000

1  Load
Floor Sweeping
30-0 Scvln Empty Bag
Cute1 Empty Bag
Parattnon Sulfur Empty Bag
Paratftion Empty Bag
Empty Captan-8SZ Bag
Pentac Empty Bag

Floor Sweeping From Shipping Whse

-------
         UNITED STATES DEPARTMENT OF AGRICULTURE
                   AGRICULTURAL RESEARCH SERVICE
                         SOUTHERN  REGION
          SOUTHEASTERN  FRUIT AND  TREE  NUT  RESEARCH  STATION
                         p. 0.  Box  87
                      BYRON, GEORGIA 31008

                                              February 28,  1974
The following list of agricultural  chemical container* are delivered
for disposal:
No.   Chemical
5     Zolone EC
4     Torak EC
10    Paraquat CL
5     Anzar 529
2     ICel thane EC
1     Methyl  Parathlon  4  EC
S     Toxaphene
2     Galecron EC
1     Supracide  EC
3     Meta Systox-R
 10   Captan 50  W
 10    Ou-ter
 10    Sevln SOW
 2     Chlorodane
 Delivered by Adam Marshall
                                        Metal
                                        5 gal
                                        5 gal
                                               Container size
                                         1  gal
                                         5  gal
                                         5 -gal
                                         5  gal
                                         5  gal
                                         5  gal
PlasticPane
                                                     1  gal
                                                     1  gal
                                         30 qal drums
                                                                  5  I
                                                                  5  i
                                                                  5  (


-------