PB95-964017
EPA/ROD/R04-95/227
April 1995
EPA Superfund
Record of Decision:
T.H. Agriculture & Nutrition
(O.U. 1), Montgomery, AL
4/17/1995
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DECLARATION
of the
RECORD OF DECISION
OPERABLE UNIT ONE
GROUNDWATER INTERIM ACTION
SITE NAME AND LOCATION
T H Agriculture & Nutrition Site
Montgomery, Montgomery County, Alabama
STATEMENT OF BASIS AND PURPOSE
This decision document presents the selected interim remedial action
for the T H Agriculture & Nutrition (THAN) Site, Montgomery, Alabama,
developed in accordance with the Comprehensive Environmental Response,
Compensation and Liability Act of 1980 (CERCLA), as amended by the
Superfund Amendments and Reauthbrization Act of 1986 (SARA), 42 U.S.C.
Section 9601 et seq., and to the extent practicable, the National
Contingency Plan (NCP), 40 CFR Part 300. This decision is based on
the administrative record for the THAN site.
The State of Alabama, as represented by the Alabama Department of.
Environmental Management (ADEM), has been the support agency during
the Remedial Investigation and Feasibility Study (RI/FS) process for
the THAN site and concurs with the selected remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this Site,
if not addressed by implementing the response .action selected in this
Interim Action Record of Decision (ROD), may present an imminent and
substantial endangerment to public health, welfare or the environment.
DESCRIPTION OF SELECTED REMEDY
This interim remedial action employs the use of extraction wells
combined with a pump and treat system to prevent further migration of
contaminated groundwater from the Site and to initiate groundwater
restoration pending completion of the RI/FS and implementation of the
final remedial action.
The major components of the selected remedy for this interim remedial
action include:
Extraction of contaminated groundwater to contain
contamination within the boundaries of the THAN and Elf
Atochem properties;
Discharge of water to the local publicly-owned treatment
works (POTW). If EPA discovers during remedial design that
discharge to the POTW is technically impracticable or cannot
be implemented in a cost-effective or timely manner, then the
treated groundwater shall be discharged on-site via
reinjection or infiltration. This action will be consistent
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with final actions taken to address contamination at the THAN
Site.
STATUTORY DETERMINATIONS
This interim remedial action is protective of human health and the
environment in the short term, and is intended to provide adequate
protection until a final ROD is signed. It complies with federal and
state applicable or relevant and appropriate requirements for this
. limited-scope action, and is cost~effective. This action is interim
and is not intended to utilize permanent solutions and alternative
treatment technologies to the maximum extent practicable for this
operable unit. Because this action does not constitute the final
remedy for the Site, the statutory preference for remedies that employ
treatment that reduces toxicity, mobility or volume as a principal
element, although partially addressed in this remedy, will be
addressed by the final response action. Subsequent actions are
planned to address fully the threats posed by the conditions at this
Site. Because this remedy will result in hazardous substances
remaining on-site above health-based levels, a review will be
conducted to ensure that the remedy continues to provide adequate
protection of human health and the environment within five years after
commencement of the remedial action. Because this is an interim
action ROD, review of this Site and of this remedy will be ongoing. as
EPA continues to develop final remedial alternatives for the Site..
~~~~
RICHARD D. GREEN
ASSOCIATE DIVISION DIRECTOR
WASTE MANAGEMENT DIVISION
U.S. EPA REGION IV
\ ~ \:\~R '\.6
DATE
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1.0
2.0
3.0
4.0
5.0
6.0
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8.0
TABLE Of CONTENTS
Si te Locat ion and Description. 0 . . . . . 0 . 0 . . . 0 0 . . . . . . 0 0 . . . . . . . . . . . . . 0 . . . .1
Site History and Enforcement Activities..... .....,... ......... .... ....3
Highlights of Community Participation......o ."...' ... ...... ..........4
Scope of Operable Unit. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .4
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Summary of Site Characteristics... . . . . . . . . 0 . . . . . . . . . . . . . . . . . . . . . . . . . . .5
5.1 Geology/Soils...... .0.............................. ................5
5.2 Surface Water and Sediments. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .6
5 . 3 Hydrogeology[[[ 6
Summa ry 0 f Sit ~ Ri s k. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .10
Description of Alternatives....... ........ .......... .... .............11
7.1 Alternative No.1 - No Action...................................11
7.2 Alternative No.2 - Extraction with Discharge to River..... .....11
7.3 Alternative No.3 - Extraction with Discharge to Ditch... .......12
7.4 Alternative No.4 - Extraction with Discharge to PO'IW...... .... ..12
7.5 Alternative No.5 - Extraction with Reinjection/Infiltration~...14
Summary of the Comparative Analysis of Alternatives............. .....14
8.1 Overall Protection of Human Health and the Environment..........15
8.2 Compliance With ARARS.......................................... .16
8.3 Long-Term Effectiveness and Permanence....... .............. .....16
.8.4 Reduction of Toxicity, Mobility or Volume Through Treatment. ....16
8.5 Short-Term Effectiveness....................................... .16
8.6 Implementability...................... .:........................ .16
8 . 7 Cos t . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .: . . . . . . . . . . . . . . . . . . . . . . . . 17
8.8 State Acceptance... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .17
8 . 9 . Communi ty Acceptance...... . . . . . . . . . . . . . . . . . . . . . . . 0 . . . . . . . . . . . . . .17
9.0
The Selected Interim Remedy. . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . .17
10.0
Statutory Determination............................................ 21
10.1 Protective of Human Health and the Environment..... ..... .....21
10.2 Attainment of ARARs.......................................... 21
10.3 Cost Effectiveness....................;...................... 23
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Figure 1
Figure 2
Table 1
Table 2
LIST OF FIGURES & TABLES
Area Map for the THAN Site............................. ...2
Site Map for the THAN Site.... ..... .... ...... ... ....... ...2
Frequency of Detection for Constituents in Groundwater. ...8
Description of Cleanup Alternatives..~...................13
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Record of Decision
Operable Unit One
Groundwater Inter~ Action
T H Agriculture & Nutrition Site
Montgomery, Alabama
1.0 SITE LOCATION AND DESCRIPTION
The T H Agriculture & Nutrition (THAN) Site is located on the west side
of Montgomery, Alabama, about two miles south of the Alabama River and
. 1,600 feet west of Maxwell Air Force Base (Figure 1). Access to the
Site is from State Highway 31-82. The Site is basically flat and
includes two properties: the THAN property and the Elf Atochem property.
The Site covers 16.4 acres, with the THAN property covering about'
11.6 acres and the Elf Atochem property covering 4.8 acres (Figure 2).
The only structure on the THAN property is a warehouse that was used for
storing water treatment chemicals, plating chemicals, and agricultural
. chemicals. The remaining areas consist of mixed pine forest and a low,
marshy area. The middle half of the Elf Atochem property has an .
operating area including' a concrete paved area and a number of
buildings. The area was formerly used for mixing, repackaging, and
distributing agricultural and industrial chemicals. The east po~t~on
has an open parking area, and the west portion is an open area covered
by grass and brush.
The land west of the Site: was used for farining 1n the past. However,
the land does not appear to have been actively farmed for a number of
years. The property to the northwest is a mobile home park called
Lakewood Estates (formerly Twin Lakes Community). Beyond the mobile
home park is a small residential area. Undeveloped land covered by
mixed forest, brush, anq grass is on the north border. The entire area
around the Site is zoned for general industrial use. A residential
commu~ity lies about a mile southwest of the Site.
Wittichen Chemical Company first developed the THAN property as a sales,
packaging, and storage facility for water treatment and plating
. chemicals. THAN, which was then known as Thompson Hayward Chemical
Company, bought the facility in 1966 for storage and distribution of
agricultural and industrial chemicals. THAN, a wholly owned subsidiary
of Phillips Electronics North America Corporation, closed the facility
in 1978 and leased it for various time periods before selling it in 1986
to Williamson Industries, Inc. THAN recently re-purchased this property
from williamson Industries.
The Elf Atochem property was first developed by Montgomery Industries.
Elf Atochem North America, Inc., formerly known as pennwalt Corporation,
purchased this property in 1951 and used it as a chemical blending and
distributing facility. Astro Packaging, Inc. bought the Elf Atochem
property in 1979 and leased it to. Industrial Chemicals. Elf Atochem now
leases the property from Astro Packaging.
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Figure 1 - Area Map for the THAN Site
Figure 2 - Site Map for the THAN Site
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2.0
SITE HISTORY AND ENFORCEMENT ACTIVITIES
In October 1980, the Alabama Water Improvement Commission (AWIC)
(a predecessor to the Alabama Department of Environmental
Management or ADEM) inspected the THAN property in connection
with THAN's closing of its facility. During this inspection,
AWIC found waste material in open and underground pits. In 1981,
under the supervision of the Alabama Department of Public Health,
Division of Solid & Hazardous Waste, THAN excavated waste and
contaminated soil from 13 burial areas and collected contaminated
groundwater, treated it, and discharged it to a publicly-owned
treatment works (POTW).
In April 198Q, THAN sold the THAN property to Williamson
Industries, Inc. ,In August 1994, THAN purchased this property
back from Williamson and is the current owner of this portion of
the Site.
Elf Atochem, f/k/a Pennwalt Corporation, owned and operated a
chemical formulation and distribution facility on its property
which is adjacent to and up gradient from the THAN property. Elf
Atochem handled substances similar to those handled by THAN. Elf
Atochem maintained a 700,000 gallon evaporation lagoon on its, .
property for the storage and treatment of wastewater. The Elf,
Atochem property is currently owned by Astro Packaging, Inc.
Astro Packaging leased it to Industrial Chemicals, Inc. (IC),
until March 1994. IC operated a warehouse distribution center on
the Elf Atochem property. IC vacated the Elf Property in March
1994 and Elf Atochem currently leases it from Astro Packaging.
The THAN property was listed on the National Priority List in
August of 1990. Thereafter, it was discovered that contamination
from the Elf Atochem property was impacting the THAN property and
the, Site was expanded to include both the THAN property and the
Elf property.
In,March 1991, Elf Atochem agreed to perform the Remedial,
Investigation/Feasibility Study (RI/FS) pursuant to the terms of
a consent order issued by EPA. This detailed study of Site
contamination is ongoing and is being conducted under EPA
oversight. This study includes several phases and has
investigated soil, surface water, sediment, groundwater, and air
at the Site. Geophysical surveys and both surface and subsurface
soil sampling on an extensive grid system have been completed. A
wetlands survey and an ecological assessment are underway. The
results of the remedial investigation are in the information
repository. ,In addition, numerous treatability studies and a
focused feasibility study which concentrates on groundwater
alternatives have' been completed.
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3.0
HIGHLIGHTS OF COMMUNITY PARTICIPATION
The proposed plan for interim remedial action was presented at a
public meeting held on Tuesday,. December 12, 1994 at the Hunter
. Station Community Center. Representatives from EPA attended the
meeting and answered questions regarding the Site and the
proposed plan under consideratipn. The administrative record was
available to the public at both the information repository
maintained at the Air University Library and at .the EPA Region IV
Library at 345 Courtland Street in Atlanta, Georgia. The notice
of availability of these two documents was published in the'
Montqomerv Advertiser on December 9 and December 12, 1994. The
public comment period on the proposed plan was December 9, 1994
through January 9, 1995. EPA extended the comment period by
thirty days to February 8, 1995, upon requests from the public.
Responses to the significant comments received during' the public
comment period and at the public meeting are included in the
Responsiveness Summary, which is included in this ROD as Appendix
A.
In addition, EPA held an availability session at a local library
at the start of field work in August, 1991. EPA chose the Air
University Library at Maxwell Air Force Base as the local
information repository because of its proximity to the Site. In
March 1992, EPA held a public meeting at what is now Lakewood
Estates Trailer Park to discuss the remedial"investigation
findings at the Site.
This decision document presents the selected interim remedial
action for operable unit one of the THAN Site, chosen in.
accordance with CERCLA, as amended by SARA,; .and the NCP. The
decision for this Site is based on the administrative record.
The requirements under Section 117 'of CERCLA/SARA for public and
sta~e participation have been met for this operable unit.
4.0
SCOPE AND ROLE OF OPERABLE UNIT AND OVERALL SITE STRATEGY
EPA has organized the work at this Superfund Site into two
operable units (OUs). These units are:
. OU one:
An interim remedial action for containment of
groundwater contamination at the 'Site.
. OU two:
The final action for the cleanup of the contamination
in the soils, sediment, air and groundwater at the
Site. .
Operable unit one encompasses the interim remedial action and
involves the implementation of a multiple-well gathering and pump
and treat system to control and contain the contaminated
groundwater plume, to initiate groundwater restoration activities
prior to final site remediation, and to obtain information on the
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aquifer's response to pumping. Data obtained during the remedial
investigation indicates that there is contaminated groundwater
within the unconfined surficial aquifer at the Site. This aquifer
is classified in the Guideline for Ground-Water Classification
Under EPA Ground-Water Protection Strateqy, Final Draft, December
1986, as a Class II Groundwater, that is a current source of
drinking water. Although this interim remedy does not constitute
a final remedy for the Site, it will reduce the levels of
contaminants within the aquifer and prevent further migration of
contaminants from the Site pending completion of the RI/FS. Upon
completion of the RI/FS, EPA will select the final remedy for
cleanup of the Site. The groundwater pump and treat system may
be incorporated into the final remedial action in addition to
other remedial activities which EPA determines are necessary to
cleanup the Site.
5.0
5.1
SUMMARY OF SITE CHARACTERISTICS
GEOLOGY/SOILS
The Site is situated on Quaternary alluvial and terrace deposits
consisting of sand, gravel, silt, and clay which were encountered
from the surface to a depth of approximately 45 feet. Below
these, an approximately 950 foot thick sequence of Cretaceous
units extends to Paleozoic bedrock. The Cretaceous units
include, in descending order, the Eutaw, Gordo, and Coker
Formations, consisting of various sand, silt, and clay deposits.
Groundwater occurs in an unconfined surficial aquifer (Alluvial/
Terrace Deposits aquifer) at the Site with the water table at
approximately 15 feet below ground surface.: Groundwater in the
surficial aquifer flows generally toward the northwest at an
average rate of approximately 0.28 feet per day. A
potentiometric mound located north of the Site appears to direct
so~e groundwater flow from the Site toward the northeast.
Differences in head between nested monitoring wells at the Site
indicate that groundwater also has a very small vertically
downward component of flow within the aquifer.
The surficial aquifer is underlain at approximately 60 feet below
ground surface by the approximately 60-foot thick Middle Eutaw
confining unit. The top of the Middle Eutaw confining unit is
characterized by a dense green clay layer, which is underlain by
interbedded layers of sand and clay. Although a downward
vertical gradient exists across this confining unit, the low
permeability zones restrict vertical groundwater flow to an
approximate rate of 4.3 x 10-5 feet per day. At this flow
velocity, the most mobile constituents would require
approximately 4,800 years to ~igrate from the surficial aquifer
through the confining unit to the next deeper aquifer below.
Beneath the Middle Eutaw confining unit are three regional
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aquifers, as follows in descending""order: Lower Eutaw aquifer,
Gordo aquifer, and Coker aquifer. These aquifers are the source
of groundwater for the City of Montgomery's West Well Field,
which, at its nearest point, is 1.3 miles from the Site. Based
on water levels reported from the West Well Field, as compared to
water levels in one on-site well completed in the Lower Eutaw
aquifer, groundwater in these deeper units most likely flows
south, in the vicinity of the Site, toward the well field.
However, these deeper aquifers are not believed to be affected by
the Site at this time. "
5.2
Surface Water and Sediments
Surface water near the Site includes Catoma Creek, located
approximately 1.5 miles to the west-southwest; the Alabama River,
located 2 miles to the north-northeast; and the West End Ditch,
which is located approximately 2,000 feet east of the Site.
Catoma Creek and the West End Ditch are tributaries of the
Alabama River.
Surface water drainage on the THAN property is toward a small
marshy area west of the warehouse into a small drainage ditch
that parallels the western Site boundary and terminates at the" .
southern Site boundary. This surface water is perched on low'
permeability soil (clay and silt) and may act as a minor recharge
area for the Site. Water in the west ditch flows through a low
"point in the bank and then flows on an intermittent basis
southwest through a combination of ditches and marshy areas.
Drainage from the eastern portion of the Site flows through storm
drains into a ditch on the eastern boundary" of the Site. Water
in the ditch at times is pooled and stagnant, but during high
water periods, flows south from the Site in the ditch. The ditch
crosses under Highway 31-82 approximately 3,000 feet south of the
Si~e. At that point, it flows east into the West End Ditch,
which drains a large portion of western Montgomery. The storm
sewe~ system that services a majority of the Elf Atochem property
discharges to the east ditch at the outfall location. "In"
addition, a much smaller drainage ditch east of Highway 31-82,
which collects stormwater runoff from properties on that side of
the highway, drains to the east ditch via three storm culverts in
the vicinity of the Site. "
5.3 Hvdroqeoloqy
The groundwater monitoring system at the Site consists of
47 monitoring wells. Twenty-eight shallow monitoring wells are
completed in the uppermost portion of the surficial aquifer and
are screened across "the water table. Thirteen intermediate
monitoring wells are completed in the lower portion of the
surficial aquifer. All intermediate wells are coupled with, or
adjacent to, a shallow well. Five deep wells are completed in
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the permeable zones of the Middle Eutaw confining unit, and a
sixth deep well is completed in the top of the Lower Eutaw
aquifer.
Groundwater at the Site was analyzed for 158 constituents.
Constituents of interest in groundwater were defined as all
organic constituents detected at any level in any groundwater
samples, and all inorganic constituents detected at any level in
any groundwater samples obtained using a slow-purge sampling
. method. Confirmed detections of constituents of interest were
limited to the surficial aquifer, with the exception of samples
from one deep well in the uppermost permeable zone of the Middle
Eutaw confining unit. Low concentrations of constituents in this
well are believed to have originated from seepage through a
former deep water-supply well located on the Site. The former
water-supply well was abandoned during the RI. The frequency of
detection of the various constituents found in groundwater at the
Site, as well as the maximum concentration detected, is
enumerated in Table 1.
Eighteen pesticide compounds (including multiple isomers of some
compounds) and four herbicides were detected in the groundwater.
samples during the RI. In general, the most notable
concentrations of pesticides and herbicides in the shallow wells
occur in two distinct areas. One is located in the vicinity of
the operations area at the Elf Atochem property and the other is
located in the vicinity: of the former THAN disposal area and the
northeast corner of the THAN property. In contrast, pesticide
concentrations in the intermediate wells are highest downgradient
from these areas. The constituents of interest in the
intermediate wells appear to be the downgradient extension of the
detections in the spallow wells. . .
Twe~ty-one volatile organic compounds were identified as
constituents of interest in the RI groundwater samples. The
distribution of volatile organics in groundwater at the Site is
very similar to that of pesticides. The highest concentrations
of volatile organics .occur in the shallow wells at or very near
the operations area at the Elf Atochem property and the former
THAN disposal area. As was the case with pesticides, the highest
concentrations of volatiles in the intermediate wells occur
within an area that includes the THAN property and extends
downgradient in the aquifer. Therefore, the relationship of the
distribution of volatiles between the upper and lower portion of
the surficial aquifer is essentially the same as that for
pesticides and for the same reasons.
Nineteen semivolatile organic compounds were detected in at least
one of the groundwater samples from the shallow and intermediate
wells during the RI. Semi-volatiles were detected primarily in
the shallow wells with the highest concentrations centered in the
vicinity of the Elf Atochem operations area. The majority of the
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Frequency of Detection and Maximum Concen'"~tioM for Constituents of Interefn in Groundwater
CoaoU&..nt . 01 Bil8l'J'otal . or SampliDl E_te WuIa... Delacled Co_nbation
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I Frequency of Detection and Maximum COncentrations" for Constituents of Interest in Groundwater I
Conolltuent . o(HiwTotlol . o(50molin. Eftn" M.Ximum Detected Concentr.llon(plIILl
PESTlCIDESlHERBICIDES
alnha-BHC 49/108 19
beta-BHC 601198 3.8
nmma.BHC 401108 42
d@lta.BHC 621108 17
4.4'.DDD 281108 22
4.4'DDE 5/108 11
4 4'.DDT 61108 38
Dieldrin 27/108 0.80
Endosulfan I 11108 0.066
1i:ndrin 181108 9.4
Endrin .ldehvde 11108 0.20
Hentachlor e-xide 1/1 08 0.09
.I,,},a-Chlordane 6/108 0.26
llamma.Chlordane 21108 0.05
Endrin ketone 19/108 14
2.4'.DDD 4/108 4.3
2 4'.DDE 201108 3.8
2.4'.nDT m08 77
2 " 5.TP 31108 22
D;no....b Sl108 25
Pmmeton 2Ili1 3.8
Bmmacil 3151 6.7
METALS (total)
Q.4I1AA . 689.000
111108 . 118
Barium 1081108 2270
Cadmium 121108 11
Cobalt 79/108 411
Iron 97/108 1 370 000
Mansranese 100!1 08 30 700
MereuI'Y 19/108 2.4
Vanadium 81/108 768
Z;nc 731108 6640
MRTALS (soluble\
Aluminum 16/51 790
Annmonv 7151 34
Barium 45/51 138
Cadmium 2/51 4.9
Cobalt 7151 14
Iron 85/108 86 300
Mansrsnese 60151 2960
M ereuI'Y 1137 2.0
Vanadium 4151 6.5
Zinc 23151 245
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semi-volatiles detected in the groundwater in this area are
polynuclear aromatic hydro~arbons.
Ten inorganics were retained as constituents of interest in
groundwater from shallow and intermediate wells during the
remedial investigation. There appears to be no discernible
pattern of inorganic constituents in groundwater. Constituents
of interest have been detected in groundwater on-site and in
near-site areas in the surficial aquifer. The precise extent of
affected groundwater is not entirely defined to the north, east,
and west. The furthest off-site detections of constituents of
interest in groundwater were at wells MW-41S and MW-42I, located
600 feet north of the Site, and well MW-48I, 3,250 feet northwest
of the Site. .
6.0
SUMMARY OF SITE RISKS
EPA is in the process of completing a formal baseline risk
assessment for the Site to determine the current or potential
threat to human health and the environment in the absence of any
remedial action. An ecological assessment is also being
conducted that will address any impact the Site may have on the.
marsh/drainage areas' of the Site. EPA's decision to initiate. .
interim remedial action at this Site is based upon data collected
during the remedial investigation. Th~s information indicates
that hazardous substances released from this Site are migrating
through groundwater. Primary contaminants of concern are
pesticides, including d~lta-BHC, lindane, DDT, and chlordane,
herbicides, volatile organic ,compounds, including trichlorethene
and tetrachlorethene, and semi-volatile compounds. This interim
remedial action will be conducted to address the most imminent
and substantial problem identified thus far: at the Site. This
interim remedial action will prevent groundwater contamination
fro~ migrating and also will begin groundwater restoration
activities.
A major risk that is currently associated with the Site is
contamination in the groundwater. Ingestion of groundwater could
result in exposure to various contaminants. Exposure to
contaminated groundwater may result if wells are used or
installed in a water bearing zone which is contaminated. The
frequency of detection and the maximum concentrations of
contaminants found in groundwater is shown in Table 1. Current
evidence shows that the zone of contamination beneath the Site
does not extend far enough to impact local rivers or streams.
Actual or threatened releases of hazardous substances from this
Site, if not addressed by implementing the response action
selected in this ROD, may present an imminent and substantial
endangerment to public health, welfare, or the environment.
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7.0
DESCRIPTION OF ALTERNATIVES
Five alternatives for the interim remediation of contaminated
groundwater in OU#l at the THAN Site were evaluated in the
Focused Feasibility Study Report and listed in the Proposed Plan
for Operable Unit #1. These alternatives represent a range of
distinct waste-management strategies.addressing the human health
and environmental concerns. Although the selected remedial
alternative will be further refined as necessary during the pre-
design phase, the analysis presented below reflects the
fundamental components of the various alternatives considered
feasible for this Site. Table 2 lists each alternative, along
with implementation times and estimated costs.
7.1
ALTERNATIVE No.1 - No Action
The No Action alternative is carried through the screening
process as required by the National Oil and Hazardous Substances
Pollution Contingency Plan (NCP). This alternative is used as a
baseline for comparison with other alternatives that are
developed. under this alternative, EPA would take no further
action to minimize the impact groundwater contamination has on
the area. Groundwater contamination would remain and possibly-.
migrate. There is no cost associated with this alternative since
no additional activities would be conducted.
7.2 Alternative No.2 - Extraction, Treatment. and Discharqe to
the Alabama River
This alternative includes extraction and on~site treatment of
groundwater, conveyance and discharge to the Alabama River
through a diffuser outfall, and groundwater;monitoring.
Groundwater would be extracted using submersible pumps having
adequate total discharge head (TDH) for conveyance to an on-site
treatment facility. . Frequent monitoring of control facilities by
remote access control devices and/or site inspection would be
required. Control instrumentation at the treatment facility
'would monitor extraction rates and volumes to ensure proper
operation. Treatment processes for this alternative would likely
include solids removal, sludge handling, and disposal.
Treated groundwater would be directed through a underground
discharge pipe from the on-site treatment facility to the Alabama
River. Approximately 2.25 miles of discharge piping would be
required. Access to the Alabama River would require that
discharge piping.traverse multiple road crossings and a railroad
crossing. The discharge outfall will be equipped with a diffuser
to provide the required mixing to meet surface water quality
criteria.
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7.3 Alternative No.3 - Extraction, Treatment, and Discharqe to
the East Ditch
This alternative involves the extraction and on-site treatment of
groundwater, and subsequent discharge of treated groundwater to
the east ditch. Components of the.groundwater extraction system
are identical to those of Alternative No.2. On-site treatment
for this alternative is more rigorous than Alternatives No.2 and
No.4. because no mixing is available in the east ditch.
Extracted groundwater would be treated in accordance with the
standards required by the Clean Water Act, NPDES program, and
Ambient Water Quality Criteria, as delegated to the State of
Alabama. Treated groundwater would then be discharged to the
east ditch using replacement pipe placed along the existing
stormwater piping system. The addition of a concrete or rip-rap
energy dissipater at the outfall pipe to the east ditch would
also be required to prevent sediment erosion within the east
ditch. Groundwater discharge into the east ditch would flow
south along Highway 31-82 to a point approximately 3,000 feet
southeast of the Site, where water would then flow into the West
End Ditch and eventually into the Alabama River.
Prior to discharge into the east ditch, groundwater would be
conveyed to an on-site treatment facility. Major components of.
the treatment process include: metals/solids removal, granular
media filtration, air stripping, granular activated carbon, and
sludge handling and disposal. Modifications to the anticipated
treatment plant location may need to be made to accommodate the
necessary equipment. This would include refurbishing the
building and adjacent areas to meet anticipated space and
enclosure requirements. .
7.4 Alternative No.4 - Extraction, Treatment, and Discharqe to
the Local POTW
This alternative involves on-site groundwater extraction,
discharge to the local publicly owned treatment works (POTW) for
treatment, groundwater monitoring, and monitoring of the
discharge into the POTW and into the receiving water. The
groundwater extraction system for this alternative would consist
of on-site extraction wells using submersible pumps having
adequate total discharge head for conveyance from the well to the
first lift station in the existing sanitary sewer line'between
the Site and the POTW. Extracted groundwater would be conveyed
directly to the existing sanitary .sewer system.
Groundwater monitoring would be conducted to evaluate the
efficiency of the extraction system. In addition, the extracted
groundwater discharged to the POTW and the POTW influent and
effluent would be monitored for constituents of interest.
Monitoring would occur at least quarterly for the first year of
operation, and on a semiannual basis thereafter.
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TABLE 2 . DESCRIPTION OF CLEANUP ALTERNATIVES
EPA evaluated five alternatives identified in rile Focused Feasibility Study (FS) for containing groundwater contamination related to the mAN Site.
a1ternative and provides a shon description, rile total cost associated. wirll the alternative. and the time required to implement each.
The following table lists e
Alternative and Expl~nation ToUIt Cost Implemenlatic
Time
ALTERNATIVE No. I - No Acllon 0 -0-
The No Action altemativo is used u required by the National Contingency Plan (NCP), tho rogulation implementins the SUptrfund law, u a buelino for comparing other altemativea. Under thia option. EPA would
lake no action 10 contoin aroundwaler con\amination. Con\amination would remain and pOlSibly migrate further. CoslI associated with thia alternative would be monitoring of soil and around",al_r. which would
continue in the future.
ALTERNATIVE No.1. Pump and Treat wllh DltchU'lla to the Alabama Rlnr 11,927,000 17 months
Thil alternltive would include withdrawing and treatina around",aler on-alte,' discharging to the Alabama River thlOUgb a dlfruser oUlrall, and around..aler monilOring. Croundwater would be withdrawn using
subm-mble (under the water) pumpa 10 dischargo contaminated water to an on..ite treatment facility. FrequcntlllOllilorina ~~ ln8pecIion would be required to ensure proper ralea and volumea 101 adequate
operation. Treatmenl wollld include solida removal. illidge handling. and diap08a1. Treated .round"'.ter would be clileCled Ihn!ugb a sinai.. undergJOund discharge pipe lrom tho treatment facility to tho Alabama
River about 2.25 milea away. Ace.... to tho Alabama River would require that discharae pipes crou roada OIiahway 31-82 boinltho m08\ aignificant) and a railroad crossing. The dilcharge outfan would be
equipped with a dllTlller to plOvide tho required milina to meet surfaco water quality criteriL
ALTERNATIVE No. 3. Pllmp and Treat wllh Dltch".1 to Ihl Eut Dllch (on-Ille) 14.800,000 27 months
This alternativo would involve the extraction and on. treatment of around",.ter. and di.charge of treated aroundw.t,r to the eaaI ditch. Componenu of the around",al-r extraction (withdraWil) .ystem are
identical to thole of Alternative No.2. On-site tlClllrDmt for Ibis alternativo is more riaoroUlthan diacbargo to the river becauso no mlxinl would be available in the east ditch. The treated aroundwaltr (treated to
levels protective of human health and the environment) would be discharged to tho east ditch using replacement pip. placed alOllatho existing slOrmwater piping IYstem. The addition of a concrete or Itone rip-rap
energy dissipater at the opening of the pipe would alao be needed to preventlediment erosion within the cut ditch. Groundwater discharge into the e.oat ditch would flow 10llth alon, Hiahway 31-82 to a point
approximately 3.000 feet southeast of the Site, where water would then flow inlO the West End Ditch mcI evenmally into tho Alabama River. Prior to dilcharge into the cut ditch, around",aler would be conveyed
to an on-site treatment facility. Major componenta of the treatment proceaa include: metals/solidi removal. Il"IIIIIlar filters, air atripping, aranular activated carbon, and Iludge handling and dUpou\. Otan,eslO the
anticiplted treatment planttocation might be needed to accommodale neceaury equipment
AL TERNA TIVE No.4- Pump .nd Treat ....lIh Dltcharae 10 Ihe Local Publlcly.Owntd Trealment Worlra :CJ'PTW) 6.100.000 /2 months
This alternative would involve around",at_r withdrawal. and discharge of treated a,ound....altr to Ibe local Publicly Owned Treatment Workl (POTW). Dischlrge of .round....aler would be through the existing
unitAry sewer syotem, with lome Inticipated changea. The present gravity unitary lewer Iystem, both immediately on-alte and orr..ite, would require upgrading in order 10 aceeptthe additional I SO gallons per
minute (gpm) truted water discharge. The Site it connected to the local POTW willi an existing 8 inch clay pipe that no..... aouthcut alonB Highway 31-82 to a point about 3,000 feet IOlIthealt of the Site. Atthat
point, it intersecta a 24-inch iron pipe flowing noriheut, generally along the same lOu!e al the Weal End Dild!. to . pump a\aliOll (Station 22) where a 24-inch reinforced concrete pipe now carnes sewage 10 the
POTW. An expansion lIot il available fOI a third pump bued on information provided by POTW officia'" About 700 feet of tho exiatin, on-site 6 inch pipe and 3.500 feel of the existing orr..ite gravity Iystem
would need 10 be upgraded to a l2.inch diameter PVC pipe. Preaent nowa are culTClltly bein, evaluated by City of Montgomery Wute Water Treatment Program officiall in order 10 determine if Idditional nows
could be accommodated. Cost estimates reflect pipe upgrade and usistonce 10 the POTW in installing an additional pump and a new dlfrustr althe exilting POTW.
ALTERNATIVE No.5. Pump and Treat with Dl.acharal to an On-.llllnnllrallon Call-ry or 0""1111 Relnjecllon 16.200.000 27 months
This alternltive would involve the extraction and on-lite treatmenl of around",aler, and diacha'le of treated around",ater on-lite by eilller reinjection or infiltration. Components of the around",aler extraction
(withdrawll) sYltem Ire Identical to thOle of Alternative No.2. On-site treatment for this alternative it tho more risolOUIthan diachargo to the river beclule no mixing would be available. The treated aroundwaler
(treated to levell protectivo of human health and the eaviron..-t). would be discharged on-sile via an lllfiltration sanery or reinjection well. Prior to discharge on-lile, around",.ter would be conveyed to an on-sile
treatmcnt racility. Major componento of the treatmall p- include: mellllholida removal. pnular filters, air strippin" pular activated carbon. and Iludge handling and dilposal. Chonges to the anticipated
treatment plant IDation might be needed to accommodate n_ry equipmcnl
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7.5 Alternative No.5 - Extraction, Treatment, and Discharqe On-
'site to an Infiltration Gallery or Reiniection Well
This alternative would involve the extraction and on-site
treatment of groundwater, and discharge of treated groundwater
on-site by either reinjection or infiltration. Components of the
groundwater extraction (withdrawal) system are identical to those
of Alternatives 2, 3, and 4. Extracted groundwater.would be
treated in accordance with the Safe Drinking Water Act, MCLs and
non-zero MCLGs, Alabama's Primary Drinking Water Standards,
Alabama's Underground Injection Control Program, and Resource
Conservation and Recovery Act land disposal restrictions. The
treated groundwater would be discharged on-site via an
infiltration gallery or reinjection well. Prior to discharge on-
site, groundwater would be conveyed to an on-site treatment
facility. Major components of the treatment process include:
metals/solids -removal, granular filters, air stripping, granular
activated carbon, and sludge handling and disposal. Changes to
the anticipated treatment plant location might be needed to
accommodate necessary equipment.
8.0
SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
This section of the ROD provides the basis for determining which
alternative provides the best balance with respect to the
statutory balancing criteria in Section 121 of CERCLA and in
Section 300.430 of the NCP. The major objective of the focused
feasibility study was to develop, screen, and evaluate
alternatives for the remediation of OU #1 at the THAN site. The
remedial alternatives selected from the screening process were
evaluated using the following nine evaluation criteria:
.8
OVerall protection of human health and the environment.
Compliance with applicable and/or relevant Federal or
State public health or environmental standards. .
8
Long-term effectiveness and permanence.
Reduction of toxicity, mobility, or volume of hazardous
substances or contaminants.
8
8
Short-term effectiveness, or the impacts a remedy might
have on the community, workers, or the environment during
the course of implementing it. .
Implementability, that is, the administrative or technical
capacity to carry out the alternative.
8
Cost-effectiveness considering costs for construction,
14
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.
.
operation, and maintenance of the alternative over the
life of the project, including additional costs should it
fail. .
Acceptance by the State.
Acceptance by the Community.
The NCP categorizes the nine criteria into three groups:
(1)
Threshold Criteria - overall protection of human health
and the environment and compliance with ARARs (or invoking
a waiver) are threshold criteria that must be. satisfied in
order for an alternative to be eligible for selection;
(2 )
Primary Balancinq Criteria - long-term effectiveness and
permanence; reduction of toxicity, mobility, or volume;
short-term effectiveness; implementability, and cost are
primary balancing factors used to weigh major trade-offs
among alternative hazardous waste management strategies;
and
(3 )
Modifvinq Criteria - state and community acceptance are.
modifying criteria that are formally taken into account.
after public comment is received on the proposed plan and
incorporated in the ROD.
. .
. .
The selected alternative must meet the threshold criteria and
comply with all ARARs or be granted a waiver for compliance with
ARARs. Any alternative that does not satisfy both of these
requirements is not eligible for selection.: The Primary
Balancing Criteria are the technical criteria upon which the
detailed analysis is primarily based.. The 'final two criteria,
known as Modifying Criteria, assess the public's and the state
agency's acceptance of the alternative. Based on these final two
criteria, EPA may modify aspects of a specific alternative.
The following analysis is a summary of the evaluation of
alternatives for remediating the THAN Superfund site under
of the criteria. A comparison is made between each of the
alternatives for achievement of a specific criterion.
each
Threshold criteria
8.1
Overall Protection of Human Health and the Environment
Other than, the No Action alternative, all the other alternatives
would protect human health and the environment through
containment of affected groundwater in the surficial aquifer.
15
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8.2
Compliance with ARARs
Because this remedy is an interim measure for the containment of
the contaminated groundwater plume, cleanup levels for
groundwater are not addressed in the ROD and are beyond the
limited scope of this action. Groundwater cleanup "levels will be
established in the final remedial action ROD for the Site.
Accordingly, to the extent that this interim remedy addresses
remediation of groundwater, an interim action waiver pursuant to
CERCLA Section 121(d) ~4), 42 u.s.c ~9621(d) (4) (A), for MCL's and
MCLGs is invoked. All of the alternatives could be designed to
meet the other state and federal ARARS that are not included in
the interim measure waiver.
Primary Balancing Criteria
8.3
Lonq-Term Effectiveness and Permanence
The interim measures described above do not provide for permanent
remediation of the source waste at the Site. However, the
extraction well and pump and treat system will permanently
eliminate contaminants from the extracted well waters, will
prevent further migration, and contain contaminated groundwater.
onsite. All of the alternatives except for No Action are
consistent with EPA's long-term goal of restoration of
groundwater at the Site. Additional data will be generated
during implementation o~ the interim remedial action. This
information concerning hydraulic conductivity and aquifer
response will be used in conjunctionwithRI/FS data to
facilitate final remedy selection. Long-term effectiveness and
permanence will be thoroughly evaluated at ;that time. "
8.4
Reduction of Toxicity, Mobility or Volume Throuqh Treatment
All" the alternatives other than No Action will effectively reduce
toxicity and mobility of contaminants through some form of
treatment. On-site treatment will be done for Alternatives No.
2, No.3, and No.5, with off-site treatment being conducted for
Alternative No.4.
8.5
Short-Term Effectiveness
Significant short-term effectiveness will result from
implementation of .all the alternatives other than No Action
because" they would each reduce the potential threats from
contaminants in the groundwater. Other than the No Action
Alternative, Alternative No.4 involves the least amount of
construction time (12 months) . "
8.6
Implementabilitv
Implementability and availability of equipment, facilities, and
16
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specialists for the design and construction of the discharge
alternatives do not pose any uncommon technical challenges.
Differences among the alternatives exist due to the complexity
and size of the treatment facilities required in each case.
Treatability studies would be required to determine design
parameters and to confirm that the treatment objectives could be
satisfied. Alternative No.4 has the shortest implementation
period (12 months) .
8.7
Cost
The cost summary for all alternatives is presented in Table 2.
The present worth was calculated for a period of 30 years ,at a
10 percent interest rate~ The comparison of the estimated
capital and annual O&M costs and the present worth for each
alternative shows that Alternative No.4 is the least expensive
of the pump and treat alternatives.
Modifying Criteria
8.8
STATE ACCEPTANCE
The State of Alabama, as represented by the Alabama Department-of
Environmental Management (ADEM), has assisted in the Superfund - .
process through the review of documents and submittal of
comments. The State has reviewed the proposed plan and Interim
Action ROD and"concurs:with the selected remedy.
8.9
COMMUNITY ACCEPTANCE
Based on the comments'expressed at the December 12, 1994 public
meeting and the written comments received during the comment
period, it appears that the Montgomery community does not
disagree that a pump and treat system is necessary at this Site
and supports Alternative #4.
9.0
THE SELECTED INTERIM REMEDY
Based upon CERCLA requirements, the NCP, the detailed analysis of
alternatives, and public and state comments, EPA has determined
that the activities as described in Alternative 4 constitute an
appropriate interim remedial action until a final action for the
Site is determined. Alternative #4 involves extraction of
contaminated groundwater with discharge to the local publicly-
owned treatment works (POTW). The selected remedy provides for
the following:
A.
GROUNDWATER CONTAINMENT
Groundwater remediation will contain the contaminated groundwater
17
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within the boundaries of the THAN and Elf Atochem properties in
the aquifer at the Site. Under the selected remedy, groundwater
remediation will include extraction of contaminated groundwater
and discharge to the local POTW.
A.l. The major components of groundwater remediation to be
implemented include:
.
Extraction of the contaminated groundwater to contain
contamination within the property boundaries of the
THAN and Elf Atochem properties;
Discharge of water to the local publicly-owned
treatment works (POTW). Extraction and discharge to
the POTW is the selected remedy. If EPA discovers.
during remedial design that discharge to the POTW is
technically impracticable or cannot be implemented in
a cost-effective or timely manner, then the extracted
groundwater shall be treated on-site and discharged
on-site via reinjection or infiltration. Onsite
treatment and discharge via reinjection or
infiltration is the contingency remedy. This action
would be consistent with final actions taken to
address contamination at the THAN Site.
A.2. Extraction, Treatment, and Discharge of Contaminated
Groundwater
Extracted groundwater will be discharged to the local POTW for
treatment. The groundwater extraction system for this.
alternative shall consist of on-site extraction wells using
submersible pumps having adequate total discharge head for
conveyance from the well to the first lift station in the
existing sanitary sewer line between the Site and the POTW.
frequent monitoring of control facilities by remote access
control devices and/or site inspection will be required.
Extracted groundwater will be conveyed directly to the existing
sanitary sewer system.
Groundwater monitoring will be conducted to evaluate the
efficiency of the extraction system. In addition, the
extracted groundwater discharged to the POTW and the POTW
influent and effluent would be monitored for constituents of
interest. Monitoring would occur at least quarterly for the
first year of operation, and on a.semiannual basis thereafter.
If EPA discovers during remedial design that discharge to the
POTW is technically impracticable or cannot be implemented in a
cost-effective or. timely manner, then, at EPA's sole
discretion, the groundwater shall be treated on-site and
discharged on-site via reinjection or infiltration (the
contingency remedy). Prior to discharge on-site, groundwater
18
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would be conveyed to an on-site treatment facility. Major
components of the treatment process include: metals/ solids
removal, granular filters, air stripping, granular activated
carbon, and sludge handling and disposal. Changes to the
anticipated treatment plant location might be needed to
accommodate necessary equipment.
A.3. Performance Standards
a.
Treatment Standards
Final treatment standards shall be included as part of the
final ROD for OU #2 for this Site. The purpose of this
operable unit is to contain the groundwater contaminant
plume within the boundaries of the former THAN and
Pennwalt properties. The property boundaries are deemed
to be the point of compliance for this groundwater
containment action. Once the groundwater extraction
system is fully operational, all contaminants of concern
should be at non-detect levels outside of the boundaries
of the former THAN and Pennwalt properties. .
If the contingency remedy is invoked by EPA, the
groundwater must be treated to meet all ARARs before
reinjection/infiltration occurs. All contaminants of
concern should be at non-detect levels outside of the
boundaries of the former THAN and pennwalt properties
after the groundwater extraction system is fully
operational.
b.
Discharge Standards
Discharges from the groundwater extraction system shall
comply with all ARARs, including, but not limited to, any
requirements established by the POTW for the selected
remedy. If the contingent remedy is implemented, all on-
site discharges must comply with all ARARs as more fully
described in Section 10 below.
c.
Design Standards
The design, construction and operation of the groundwater
extraction system shall be conducted in accordance with
the standards set forth in RCRA 40 C.F.R. Part 264
(Subpart F). .
B.
Compliance Monitoring
Groundwater monitoring shall be conducted quarterly at this
Site for the first year. After the first year of remedial
action, periodic monitoring will continue to be conducted at
19
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least twice annually until the performance standards are met
(i.e., the contaminated groundwater plume is contained within
the Site boundaries). Once the .contaminant plume is brought
back to within the current boundaries of the THAN and Elf
Atochem properties, existing and possibly new wells will be
sampled and analyzed at least quarterly along the boundaries of
the THAN and Elf Atochem properties for the first year to
ensure that the groundwater contaminant plume is being
contained. After the first year, the wells will be sampled at
least semiannually.
Alternative No.4 will achieve substantial risk reduction through
treatment of the principal threat at Operable Unit #1 of the THAN
Superfund Site. The selected alternative for Operable Unit #1 of
the THAN site is consistent with the requirements of Section 121
of CERCLA and the National Contingency Plan. The selected.
alternative will reduce the mobility, toxicity, and volume of
contaminated groundwater at the Site. In addition, the selected
alternative is protective of human health and the environment,
will attain all Federal and State applicable or relevant and
appropriate requirements for the limited scope of this action,
and is cost-effective. This action is interim and is not
intended to utilize permanent solutions and alternative treatmen~
technologies to the maximum extent practicable for this operable
unit. Because this action does not constitute the final remedy
for the Site, the statutory preference for remedies that employ
treatment that reduces. ~oxicity, mobility or volume as a
principal element, although partially addressed in this remedy,
will be addressed by the final response action. The selected
alternative for OU #1 is consistent with previous and projected
remedial actions at the Site. :
The selected remedy will include groundwater extraction and
monitoring, during which the system's performance will be
carefully monitored on a regular basis and adjusted as warranted
by'the performance data collected during operation.
Modifications may include any or all of the following:
.
at individual wells where cleanup goals have been
attained, pumping may be discontinued;
.
alternating pumping at wells to eliminate stagnation
points;
.
pulse pumping to allow aquifer equilibration and encourage
adsorbed contaminants to partition into groundwater; and
.
installation of additional extraction wells to facilitate
or accelerate cleanup of the contaminant plume.
To ensure that groundwater containment is maintained, the aquifer
will be monitored at least annually for five years following
20
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discontinuation of groundwater extraction for those wells where
pumping has ceased. .
The decision to invoke.any or all of these measures may be made
during a periodic review of the remedial action, which will occur
at least every five years in accordance with CERCLA section 121
(c) and the NCP.
10.0
STATUTORY DETERMINATION
10.1
Protection of Human Health and the Environment
This interim remedy is part of an overall remedy for the Site
which will ultimately protect human health and the environment.
This interim remedy is protective in the short term in that it
will prevent migration of contaminated groundwater until a
permanent remedy is in place.
10.2 ATTAINMENT OF THE APPLICABLE OR RELEVANT AND APPROPRIATE
REQUIREMENTS (ARARs
The selected remedy must comply with the substantive requiremen~s
of federal and state laws and regulations which have been
determined to constitute applicable or relevant and appropriate.
requirements (ARARS).
Applicable requirements' are those cleanup standards, control
standards, and other substantive environmental protection
requirements, criteria, or limitations promulgated under federal
or state law that specifically address a hazardous substance,
pollutant, contaminant, remedial action, location, or other
circumstance at a Superfund site. Relevant.. and appropriate.
requirements are those cleanup standards, control standards, and
other substantive environmental 'protection requirements,
criteria, or limitations promulgated under federal or state law
that, while not applicable, address problems or situations
sufficiently simila~ (relevant) to those encountered and are
well-suited (appropriate) to circumstances at the particular
site.
Safe Drinking Water Act, MCLs and MCLGs; Alabama's Primary
Drinking Water Standards. Maximum contaminant levels (MCLs) and
Maximum Contaminant Level Goals (MCLGs) promulgated under the
authority of the Safe Drinking Water Act (SDWA) are specifically
identified in Section 121 of CERCLA as well as the NCP as
remedial action objectives for groundwater that is a'current or
potential source of drinking water supply. The groundwater
underlying the THAN Site is classified as Class II A groundwater
(i.e., potential sources of drinking water) under EPA's
Guidelines for Ground-Water Classification. MCLs and non-zero
MCLGs are therefore relevant and appropriate as final remedial
action objectives for groundwater cleanup. Alabama's primary
21
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drinking water standards are also relevant and appropriate as
final remedial action objectives for groundwater cleanup because
they set standards for potential sources of drinking water.
However, because this remedy is an interim measure for the
containment of the contaminated groundwater plume, cleanup levels
for groundwater are not addressed in the ROD and are beyond the
limited- scope of this action. Groundwater cleanup levels will be
established in the final remedial action ROD for the Site.
Accordingly, to the extent that this interim remedy addresses
remediation of groundwater, an interim action waiver pursuant to
CERCLA Section 121(d) (4), 42 U.S.C ~9621(d) (4) (A), for MCL's and
MCLGs is hereby invoked for the selected remedy. In the event
the contingent remedy is invoked, extracted groundwater must be
treated to meet MCLs and non-zero MCLGs prior to on-site
discharge.
Resource Conservation and Recovery Act (RCRA); ADEM Hazardous
Waste Regulations; ADEM Solid Waste Regulations. The selected
groundwater remedy involves the short term storage of
contaminated-groundwater before it is sent to the POTW for
treatment and disposal. If the contaminated groundwater is RCRA
characteristic hazardous waste, hazardous waste regulations which
address storage units are applicable. If the contingent remedy.
for contaminated groundwater is implemented, which involves -
extraction, treatment and discharge at the Site by reinjection or
infiltration, hazardous _waste regulations which involve treatment
and storage units may likewise be applicable. Land disposal
restrictions establish treatment standards which must be met
before hazardous wastes may be land disposed. Land disposal
restrictions are applicable if the contingent remedy for
contaminated groundwater is implemented, the contaminated
groundwater is RCRA characteri$tic hazardo~6 waste, and treated
groundwater is discharged at the Site by reinjection or
infiltration. In such an event, the land disposal restrictions
must be met before treated groundwater may be discharged. Any
waste generated by the treatment process, such as sludges and
filters, -are subject to the waste characterization and disposal
provisions of RCRA.
Clean Water Act, Pretreatment Standards. The general
pretreatment regulations set forth in 40 C.F.R Part 403 addresses
the introduction of pollutants into POTWs and are applicable to
the selected interim remedy.
Safe Drinking Water Act, Underground Injection Control
Regulations, as delegated to the State of Alabama. If the
contingent remedy for contaminated groundwater is implemented,
and treated groundwater is discharged at the Site by reinjection
or infiltration, the substantive requirements of the UIC program
- are applicable. See 40 CFR 147.50.
Alabama Regulations Governing Emissions of Pollutants to Air;
-22
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Ambient Air Quality Standards. If the contingent remedy is
invoked and on-site treatment occurs, these standards are
applicable because there will be emissions of air pollutants
the air stripper in ambient air.
from
Department of Transportation (DOT) Regulations and Occupational
Safety and Health Administration (OSHA) Regulations. While DOT
and OSHA regulations do not fall within the technical definition
of ARARs because they are not environmentally based, they are
nonetheless directly applicable to the extent they address
activities associated with the cleanup such as the transportation
of hazardous materials and health and safety requirements for
workers at the Site.
Permanence
The selected interim remedy does not represent a permanent
solution with respect to the principal threats posed by the Site.
However, given the interim nature of this action and the fact
that further studies are needed before a permanent remedy for the
Site can be selected, the statutory preference for use of
permanent solutions and alternative treatment technologies will.
be addressed at the time of selection of the final remedy for th~
Site.
Treatment
The selected interim remedy does utilize treatment as a principal
element. The preference for treatment will be addressed in the
final OU for. this Site.
. .
10.3
Cost Effectiveness
The selected remedy is cost effective, and, with the exception of
th~'No Action alternative, the selected remedy is the least
expensive of the alternatives for this Site. .
11.0
Explanation Of Siqnificant Chanqes
There have been no significant changes in the selected interim
remedy from the preferred interim remedy described in the
Proposed Plan.
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CONCURRENCE LETT~RS
-------
; i.;'1/..
.--ADEM
John M. Smith. Director
Mailing Address:
PO BOX 301463
MONTGOMERY AL
36130-1463
Physical Address:
1751 Cong. W. L
Dickinson Drive
Montgomery. AL
36109-2608
(334) 271-7700
FAX 270-5612
Field Offices:
110 Vulaln Road
Birmingham. AL
3520''''702
,205 )942-6168
FAX 941-1603
400 Well Street. NE
P.O. Box 953
Oeatur.AL
35602-0953
(205 )353.1713 .
FAX 340-9359
2204 Perimeter Road
Mobile. AL
36615-1131
(334 ) 450-3400
FAX 479-2593
.~. ~ ..
\ . .
!::.:----
ALABAMA
DEPARTMENT OF ENVIRONMENTAL MANAGEMENT
.,;,<;.~.~\;::, .
Fob James. Jr.
Governor
March 14, 1995
Mr. Richard D. Green
Associate Division Director
US EP A, Waste Management Division
345 Courtland Street NE
Atlanta, GA 30365
Re:
TH Agriculture & Nutrition Site, Operable Unit One
draft Interim Action Record of Decision
Dear Me. Green:
The Department has reviewed the referenced document. As a decision document, it
presents the selected interim remedial action for surficial groundwater at the mAN NPL
Site and is based on the Administrative Record. It is understood that this is not a final.
remedial action decision for the site. A final decision will be made after the Remedial
Investigation/Feasibility Study has been completed.
The selected remedial action will include extraction of contaminated groundwater,
treatment as necessary, and discharge of water to a local Publicly Owned Treatment
Works. 1bis interim action is being initiated to prevent further migration of contaminated
groundwater from the site. H discharge to the POTW proves unworlcable during
Remedial Design, the treated groundwater will be discharged either on-site, to the East
ditch, or to the Alabama River. The selected remedial action meets all State statutory
requirements.
The Department of Environmental Management concurs with the selected remedy. H you
have any questions, contact Justin Martindale of Special Projects at (334)260-2786.
~#k-
Deputy Director
copy:
Alan Yarbrough, EP A SSRB RPM
JWW Ijem
(J0.
PllfUed on Reqded Paper ~6
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SOUTH'
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o E P.\ R T ~ 1 E ~ T 0 F P r B LI C H E :\~~Ir ~ '51 .
. -1;;-;-;'~~.;)h,'.:':-,\~':.~;'~~I~;~~~\I.'i;~-;-'~I--~ I'I~' 1-1,.'\,~~-,~-~.~~R-QfTEITTAL------'--
March 2. 1995 BRANCH
-.
"h""'_,--,---.---,....-'
Alan Yarbrough, RPM
U.S. Environmental Protection Agency
Region IV, SSRB
345 Courtland Street, NE
Atlanta. Georgia. 30365
Dear Mr. Yarbrough.
I appreciate the opportunity to review the Interim Action. Record of Decision for the
T.H. Agriculture and Nutrition (THAN) Superfund Site, CERCLIS No. ALD007454085.
The Alabama Department of Public Health (ADPH) concurs with the interim action selected .
remedy (Alternative No. 4- Extraction with Discharge to the Publicly Owned Treatment
Works (POTW» for the THAN site. However, if extraction with discharge to the local
POTW becomes not feasible, we feel that Alternative No. 3- Extraction with Discharge to
the East Ditch should not be used' as an option for cleaning up the groundwater unless the
contaminated sediments in the ditch are remove.
The U.S. EPA should consider several factors before using Alternative No.3.
Currently, the East Ditch contains contaminants of concern at levels that may cause adverse
health effects in humans. These contaminants should be remediated before treated water can
be discharged into the ditch. Secondly, if East Ditch sediments are not remediated, the
contaminants in the sediment would compound existing contaminant problems in the West-
End Ditch. These contaminants would be eventually be pushed into the Alabama River, and
might endanger the environment and the public's heaith.
If you have questions regarding our views of any of the selected remedies, please call
me or Brian J. Hughes. Ph.D.. at (334)613-5347.
Sincerely. .
". . - --
\ . / l '~" .". ( /
./ :(;:..~/ I~"~".
Neil Daniell
Geologist
Risk Assessment Branch
Ind
cc:
Richard Kauffman
Rick Gillig. ... . .
\dli1illl"'11.11!~-.: (JI~",..:,: ",:n-.ll1d.I!I.' \1 .II. ~;~ I.:. P.ln"n \\'-1111...- \llIlIf~.'n-;....'f"\" _\l.dum.I.,IIII)
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: :..: i"\.~~~\... .
-~DEM
John M. Smith. Director
Mailing Address:
PO BOX 301463
MONTGOMERY Al
36130-1463
Physical Address:
1751 Cong.W.L.
Dickinson Drive
Montgomery, AL
36109-2608
(334) 271-7700
FAX 270-5612
Field Offices:
110 Vulcan Road
Birmingham. AL
35209-4702
(205 )942-6168
FAX 941-1603
400 Well Street, HE
P.O. BOil 953
Decatur, AL
35602-0953
(205 )353-1713.
FAX 340-9359
220. Perimeter Road
Mobile, AL
36615-1131
(334 ) 450-3400
FAX 479-2593
--.-
ALABAMA
DEPARTMENT OF ENVIRONMENTAL MANAGEMENT
. .
. :I'~:,.,.~"; ., .;:-."i ".
Fob James, Jr.
Governor
March 14, 1995
Mr. Richard D. Green
Associate Division Director
US EPA, Waste Management Division
345 Courtland Street NE
Atlanta, GA 30365
Re:
TH Agriculture & Nutrition Site, Operable Unit One
draft Interim Action Record of Decision
Dear Mr. Green:
The Department has reviewed the referenced document. As a decision document, it
presents the selected int~rim remedial action for surficial groundwater at the 11-IAN NPL
Site and is based on the Administrative Record. It is understood that" this is not a final
remedial action decision for the site. A fmal decision will be made after the Remedial
Investigation/Feasibility Study has been completed.
The selected remedial action will include extraction of contaminated groundwater,
treatment as necessary, and discharge of water to a local Publicly Owned Treatment
Works. 1bis interim action is being initiated to prevent further migration of contaminated
groundwater from the site. If disch~ge to the POTW proves unworkable during
Remedial Design, the treated groundwater will be discharged either on-site, to the East
ditch, or to the Alabama River. The selected remedial action meets all State statutory
requirements.
The Department of Environmental Management concurs with the selected remedy. If you
have any questions, contact Justin Martindale of Special Projects at (334)260-2786.
s~
Deputy Director
copy:
Alan Yarbrough, EP A SSRB RPM
JWW/jem
ro.
p,~ on R.cyde(J Paper ~6
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. ..... .
SOUT'H'
SlJP~RFUND'
ST.\TE OF AI.:\IL\~I.\ I PM tOC
o E P .\ R T \ I E :'\ T 0 F P l' B LIe H E :~~Ir ~ . 51 ~iJ
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March '2. 1995 BRANCH
.,....
I
...-.........--------..... .-'
Alan Yarbrough. RPM
U.S. Environmental Protection Agency
Region IV. SSRB
345 Courtland Street, NE
Atlanta. Georgia. 30365
Dear Mr. Yarbrough.
I appreciate the opportunity to review the Interim Action. Record of Decision for the
T.H. Agriculture and Nutrition (THAN) Superfund Site, CERCLIS No. ALD007454085.
The Alabama Department of Public Health (ADPH) concurs with the interim action selected,
remedy (Alternative No. 4- Extraction with Discharge to the Publicly Owned Treatment
Works (POTW» for the THAN site. However, if extraction with discharge to the local
POTW becomes not feasible, we feel that Alternative No. 3- Extraction with Discharge to
,the East Ditch should not be used.' as an option for cleaning up the groundwater unless the
contaminated sediments in the ditch are remove.
The U.S. EPA should consider several factors before uS,ing Alternative No.3.
Currently. the East Ditch contains contaminants of concern at levels that may cause adverse
health effects in humans. These contaminants should be remediated before treated water can
be discharged into the ditch. Secondly, if East Ditch sediments are not remediated, the
contaminants in the sediment would compound existing contaminant problems in the West-
End Ditch. These contaminants would be eventually be pushed into the Alabama River, and
might endanger the environment and the public's heaith.
If you have questions regarding our views of any of the selected remedies, please call
me or Brian J. Hughes. Ph.D.. at (334)613-5347.
Sincerely.
,\~~> ~---:.~,~" " "
, I
./ r
I
Neil Daniell
Geologist
Risk Assessment Branch
Ind
cc:
Richard Kauffman
Rick Gillig , 1'-"
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