PB97-963158
EPA/541/R-97/186
Febraury 1998
EPA Superfund
Record of Decision Amendment:
Marzone Inc./Chevron Chemical Co.
Tifton, GA
6/18/1997
-------
5 9 ' 0009
AMENDED RECORD OF DECISION
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
^ MARZONEINCJCHEVRON CHEMICAL COMPANY SITE
OPERABLE UNIT ONE
TIFTON, TIFT COUNTY, GEORGIA
PREPARED BY
U. S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV
ATLANTA, GEORGIA
-------
5 9 0010
DECLARATION
Of the
AMENDED RECORD OF DECISION
STTE NAME AND LOPATTQN
Marzone Inc. /Chevron Chemical Company Site,
Tifton, Tift County, Georgia
STATEMENT OP BASIS AND PtTRPOfiE
This decision document (Amended Record of Decision) presents an
amendment to the selected remedial action for the Marzone Inc./
Chevron Chemical Company Site, Tift County, Georgia, developed in
accordance with the Comprehensive Environmental Response,
Compensation and Liability Act of 1980 (CERCLA) , as amended by
the Superfund Amendments and Reauthorization Act of 1986 (SARA)
42 U.S.C. Section 9601 et seq., and in accordance with, the
National Contingency Plan (NCP) 40 CFR Part 300.
The original selected remedy was signed in September 1994. Based
on new information obtained during the Remedial Design, it was
determined that the soil remedy should be amended. This ROD
Amendment provides for necessary changes to the remedy to
increase the protectiveness or effectiveness of the remedy. This
ROD amendment is consistent with the Superfund Administrative
Reforms Guidance.
This amended decision is based on the administrative record for
the Marzone Inc. /Chevron Chemical Company Site. In addition,
this ROD amendment will become a part of the Administrative
Record for the site. The Administrative Record for this site can
be found at the Information Repository located at the United
States Environmental Protection Agency, 100 Alabama Street,
Atlanta, Georgia 30303 or the Tifton and Tift County Library, One
Library Lane, Tifton, Georgia.
The State of Georgia has concurred on this amendment to the
selected remedy (Appendix B) .
OP THE STTE
Actual or threatened releases of hazardous substances from this
site, if not addressed by implementing the response action
selected in this ROD amendment, may present an imminent and
substantial endangerment to public health, welfare or the
environment .
-------
5 9 0011
P SELECTED
This document is an amendment to the remedial action described in
the Record of Decision (ROD) dated September 30, 1994 for
Operable Unit One of the Site. The function of the remedy, as
described in the ROD as amended, is to remove or treat
contamination and reduce it to health based levels which are
protective of human health and the environment. Contaminated
soils and groundwater are the principal threats at the site.
The groundwater remedy remains unchanged. The major components'
still include:
The implementation of institutional controls,
The design and construction of groundwater extraction
wells,
The installation of a security fence around the on- site
treatment unit,
The design and installation of a groundwater pumping
system, a groundwater filtration system, an on- site
treatment system, and an infiltration gallery,
The start-up and operation of this system,
The transportation, regeneration, recycling, and disposal
of the spent filters, and
The operation and maintenance of a long-term groundwater
monitoring program. This includes periodic monitoring of
parameters in extraction wells and specified monitoring
wells .
The major components of the amended soil remedy are:
The excavation of all surface soil contamination
(exclusive of the former burn pit area) above the
performance standards,
The excavation of subsurface soil to meet performance
standards on a site- wide basis and, thus, achieve
protection of groundwater,
The transportation of the soil from the main portion of
the site (exclusive of the former burn pit area) to a
permitted landfill for off site disposal,
The placement of clean fill soil in the excavated
areas, and
Air monitoring to ensure safety of nearby residents and
workers.
-------
5
0012
STATUTORY DETERMINATIONS
The selected remedy, as amended, IB protective of human health
and the environment, complies with federal and state requirements
that are legally applicable or relevant and appropriate, and is
cost-effective. This remedy utilizes permanent solutions and
alternative treatment technology to the maximum extent
practicable, and satisfies the statutory preference for remedies
that employ treatment that reduces toxicity, mobility, or volume
principal element.
Richard D. Green
Acting Director,
Waste Management Division
Date
-------
5 9 0013
Tahl P> nf Contents
Page
1.0 Site Name, Location, and Description l
2.0 Site History and Enforcement Activities 2
3.0 Reasons for Issuing ROD Amendment .5
4.0 Summary of Site Characteristics and Risks
5.0 Description of Alternatives 7
6.0 Summary of the Comparative Analysis of Alternatives . . 7
6.1 Overall Protection of Human Health and the
Environment 10
6.2 Compliance with ARARs 10
6.3 Long-Term Effectiveness and Permanence 10
6.4 Reduction of Toxicity, Mobility or Volume Through
Treatment 10
6.5 Short-Term Effectiveness 10
6.6 ImplementaJbility 11
6.7 Cost 11
6.8 State Acceptance 11
6.9 Community Acceptance 11
7.0 Selected Remedy 11
8.0 Statutory Determination 12
8.1 Protection of Human Health and the Environment . . 12
8.2 Attainment of the Applicable or Relevant and
Appropriate Requirements (ARARs} 12
8.3 Cost Effectiveness 13
8.4 Utilization of Permanent Solutions to the Maximum
Extent Practicable 13
6.5 Preference for Treatment as a Principal Element . . 13
9.0 Documentation of Significant Changes 13
-------
5 9 0014
List of Figures
Figure 1 - Site Location Map 3
Figure 2 - Landfill Disposal Areas 4
of TaKl
Table 1 Cleanup Alternative Descriptions 8
Table 2 Federal ARARs for Marzone Site OU1 14
Table 3 State ARARs for Marzone Site OU1 17
Table 4 To-Be-Considered Documents for Marzone Site OU1 ... 17
-------
5 9 0015
AMENDED RECORD OF DECISION
The Decision Summary
Marzone Inc./Chevron Chemical Company Site
1.0 Site Name, Location, and Description
The Marzone, Inc./Chevron Chemical Company Site (hereinafter the
Marzone Site or the Site) is located in south-central Georgia in
the City of Tifton, at the intersection of Golden Road and
Norfolk Southern Railroad (Figure 1). The Site consists of two
separate study areas called operable units (OUs). This Record of
Decision covers OU1. OU1 consists of the former pesticide
production area, a part of the property adjacent to the former
formulation area, and part of the adjacent railroad drainage
ditch.
Although the property is accessible from all directions, the only
roadway access is from Golden Road which borders the property to
the north. Across Golden Road to the north is a former lumber
mill. To the west of the property is an active railroad and a
former wood treating facility. To the east and south is
residential property, which includes an open barn and horse
pasture;-^a live-in trailer is also present. A municipal drinking
water supply well is located less than 100 yards to the
northwest. Farther to the north and west of this well is a
residential area. Also, approximately 500 feet east of OUl of
the Site is a red brick house.
Bordering the southern portion of OUl of the Marzone Site was a
former shed and planing mill. Further south of the former
production area was a former burn pit area used to burn planing
mill wastes. Beyond the former burn pit area to the southeast is
the Golden Seed property where a former fertilizer facility was
operated. Currently EPA is performing a fund-lead remedial
investigation and feasibility study on Operable Unit 2 which
includes the Golden Seed Property.
Existing features on OUl of the Marzone Site include the north
and south warehouse buildings. A drainage ditch, referred to as
the 'railroad drainage ditch,* runs along portions of the Norfolk
Southern Railroad and the railroad spur.south and southeast of
the Site. Former features included a drum storage area, a liquid
formulation area, a vertical chemical storage tank, an adjacent
tank pad which supported above-ground chemical tanks, a loading
dock area, and an asphalt parking area and concrete slab (Figure
2). Additional features on OUl included a rinsate pond (lagoon)
in the southeast portion, and a former truck loading area in the
eastern portion. A drainage ditch ran along the southern
boundary and was referred to as the "south drainage ditch."
-------
5 9 0016
2.0 Site History and Enforcement Activities
The pesticide formulation facility was developed in 1950 and
operated as such until January 1983. After 1983, OU1 of the Site
was used primarily for general storage and plant seedling
distribution, as well as vegetable washing and repackaging
activities. Currently, no operations exist on OU1 of the Marzone
Site.
Prom 1950 to 1970, Chevron Chemical Company operated a pesticide
formulating plant at OU1 of the Site. From 1950 to about 1960,
Chevron formulated dry pesticide dusts and in 1960 liquid
formulation was added. The liquid formulation used xylene and
xylene-based mixtures as carrier liquids. Bulk chemical handling
facilities operated during these years included unpaved railcar
and truck loading areas for base materials and finished products;
bulk liquids were unloaded by tanker truck into vertical
aboveground storage tanks. Only the western portion of the
current building was in existence. The remainder of OU1 was
unpaved. In 1970, Chevron sold the facility to Mr. Billy
Mitchell who founded the Tifton Chemical Company which formulated
and marketed liquid and dry pesticides similar to Chevron's.
These included DDT, toxaphene, parathion, methyl parathion,
malathion, and chlordane; Tifton Chemical Company also produced
sulfur-based products.
Tifton Chemicals sold the operation in 1977 to Tifchem Products,
Inc. Inspections'made by the Georgia Department of Natural
Resources (GaDNR) indicated repeated rinsate discharges to
unlined drainage ditches leading to the former rinsate pond
(lagoon) located at the southeast corner of the property, off-
site discharges, and poor housekeeping practices inside and
around the buildings. It is likely that Tifchem formulated
common organophosphate and organochlorine pesticides. GaDNR
records mention atrazine, endrin, and toxaphene in connection
with this operation. Tifchem defaulted to the Farmer's Bank of
Tifton in 1979 leaving large quantities of pesticides on-site.
Marzone Chemical Company (Marzone) purchased the property in
January 1980, and operated it as a pesticide formulating facility
until September 1962. Marzone reportedly formulated methyl and
ethyl parathion, toxaphene, lindane, DDT, chlordane, Sevin,
atrazine, malathion, and heptachlor at the Site. Prior to
operation, Marzone was required by the GaDNR to remove the
estimated 70,000 pounds of pesticides which remained at the Site
-------
5 9" 001?
from the Tifchcm operation. GaEPD also required Marzone to close
the rinsate pond (lagoon) and replace it with a system resulting
in zero discharge. The pond water and sludge reportedly were"
disposed at the Pinewood disposal facility in South Carolina.
In 1963, regular commercial operation of the Site ceased when
Kova Fertilizer, Inc. (Kova) acquired the property in at
foreclosure. A GaEPD inspection of the Site, following Kova'e>
acquisition, identified open drums of pesticides and pesticide
wastes on-site. In 1984, a notice of violation was issued and
the GaEPD required Kova to remove all hazardous waste,
contaminated soil, and debris from the Site within 45 days. Kova
manifested 49 drums of pesticide waste for off-site disposal by
Chemical Waste Management. In May 1985, ownership was
transferred to Kova of Georgia.
In August 1985, the Site was purchased by Milan, Inc., the
current owner of the Site. The Site has been used fcr general
storage, plant seedling distribution, and vegetable washing and?
repackaging. A fence to secure the Site was added in May 1993.
To date a number of Removal Actions have been taken at the Site.
Records of the Georgia Environmental Protection Division (GaEPD)
identified concerns at the Site as early as 1973. In 1979,
Marzone, Inc. in;response to a GaEPD compliance order, removed
Flfiirel
Map of Mirzone She
-------
5 9
00
waste free the rinsate pond. Marzone reported that they removed
35 tons of sludge froa the rinsate pond area. The rinsa.te pond
was filled vlth ecmpacte.: topeoil and clay. Analyses of the
sludge sarples identified atrazine, lead, nnrt arsenic. An
additional 5 tons of pesticide wastes were removed by Kova
Fertilizer. Inc.,-under GaBPD's direction in March 1984. In
September 1584, the SPA conducted an investigation at the Marzone
Site. Analyses of soil and water samples collected at the Site.
indicated that pesticides, including endurin, heptachlor,' DDT,
chlordane, toxaphene, atrazine. methyl »n* ethyl parathion, «.'
lindaae, DDD, and x&alathion were still present in the soil and/or
groundwater. la October 1934. based on the results of the
Investigation, SPA initiated response actions at the Marzone
Site.. Approximately 1,700 tons of waste were reportedly removed
£rcs the Site and disposed of at a permitted hazardous waste
landfill. In May 1985, Chevron contracted with OH Materials Co.
Cor an additional removal of contaminated materials from trhg
rinsate pond and drainage ditches. Approximately 2,200 tons of
material was removed during rhis action. These removal actions
vere conducted to abate substantial threats to human health and
the environment. Residual risk of a lesser degree remained at
the Site subsequent to the emergency removal actions.
SheL«joot
-------
5 9 ' 0019
The Marzone, Inc./Chevron Chemical Company Site was proposed for
the National Priorities List (NFL) in June 1988, and became final
in August, 1989. In September 1990, Kova Fertilizer, Inc., Kova
of Georgia, Chevron Chemical Company, and Billy G. Mitchell,
signed an Administrative Order by Consent (AOC) with EPA for the
Site. The AOC directed the PRPs to develop and implement a
Remedial Investigation/ Feasibility Study (RI/FS) which
identified the nature and extent of contamination and proposed
remedial action for the Site. The RI report presented the
methods, results, and conclusions of the investigation. The FS
report included development, screening, detailed analysis,
conclusions and recommendations for the Remedial Action
Alternatives.
EPA issued its Record of Decision selecting the original remedy
for the site in September 1994. EPA continued its enforcement
activities by sending Special Notice Letters to those identified
as potentially responsible for the contamination at the Site.
None of the responsible parties were willing to enter into a
Consent Decree (CD) agreeing to carry out the Remedial
Design/Remedial Action (RD/RA) . Accordingly, in July of 1995,
EPA issued Unilateral Administrative Orders (UAOs) to implement
the ROD to Chevron Chemical Company (Chevron) and Kova Fertilizer
Inc. (Kova) to carry out the remedial design and the remedial
action (RD/RA) at the site. After issuance of the UAOs, Chevron
and Kova expressed interest in entering into a CD. A CD was
lodged with the U.S. District Court, but was later withdrawn by
the United States. Work at the Site continues under the UAO.
Remedial design began in September 1995. Early remedial actions
such as site preparation and building demolition have been
completed. Soil excavation and stockpiling has been completed,
except in the railroad drainage ditch and former burn pit area.
3.0 Reasons for Issuing ROD Amendment
This ROD Amendment does not modify the results of the risk
assessment or change the cleanup goals/action levels documented
in the original ROD and the September 1996 amended proposed plan
fact sheet. The purpose of this Amended ROD is to consider new
information regarding the most effective soil remedy.
The major components of the original selected remedy provided for
in the Record of Decision signed September 1994 include remedies
for groundwater and soil. The major components of the
groundwater remedy remain unchanged, including:
The implementation of institutional contols,
The design and construction of groundwater extraction
wells,
-------
5 9' 0020
The installation of a security fence around the on-site
treatment unit,
The design and installation of a groundwater pumping
system, a groundwater filtration system, an on-site
treatment system, and an infiltration gallery,
The start-up and operation of this system,
i
The transportation, regeneration, recycling, and disposal
of the spent filters, and
The operation and maintenance of a long-term groundwater
monitoring program. This includes quarterly monitoring
of parameters in extraction wells and specified
monitoring wells.
The major components of the amended soil remedy are:
The excavation of all surface soil contamination
(exclusive of the former burn pit area) above the
performance standards,
The excavation of subsurface soil to meet performance
standards on a site-wide basis and, thus, achieve
protection of groundwater,
The transporation of the soil from the main portion of
the site (exclusive of the former burn pit area) to a
permitted landfill for offsite disposal,
The placement of clean fill soil in the excavated
areas, and
Air monitoring to ensure safety of nearby residents and
workers.
EPA's rationale for modifying the remedy selected in the original
ROD is based on new information obtained during the Remedial
Design phase. The modification involves changing the selected
soil remedy for the major portion of the site (exclusive of the
former burn pit area) to off site dispoal.
4.0 Summary of Site Characteristics and Risks
Site characteristics and risks remain as described in the
original ROD and the September 1996 amended proposed plan fact
sheet. During the Remedial Design phase for the soil
remediation, the community group, People Working for People, Inc.
requested the Agency for Toxic Substance and Disease Registry
(ATSDR) to review the operations of the proposed low temperature
-------
5 9 0021
thermal desorption unit. ATSDR made recommendations to EPA for
additional monitoring and operational controls. The cost of
implementing the recommendations significantly increased the
projected cost of the thermal remedy. Due to this cost increase,
EPA decided to consider other alternatives for the soil remedy.
5.0 Description of the Alternatives
EPA re-evaluated three possible alternatives identified in the
Feasibility Study (FS) for cleaning up the soils from the major
portion (exclusive of the former burn pit area) of OU#1 at the
Marzone Site. The treatment alternatives of bioremediation and
incineration were eliminated from re-evaluation, since the low
temperature thermal desorption treatment alternative was
previously selected as a better treatment alternative. The table
on page 10 lists each alternative, the cost associated with each,
and the time required to implement each one.
6.0 Summary of the Comparative Analysis of Alternatives
This section of the ROD amendment 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 original FS was to develop, screen, and evaluate alternatives
for the remediation at the Marzone Site. Three alternatives were
re-evaluated using the following nine evaluation criteria:
Overall protection of human health and the environment.
Compliance with applicable and/or relevant Federal or
State public health or environmental standards.
Long-term effectiveness and permanence.
Reduction of toxicity, mobility,* or volume of hazardous
substances or contaminants through treatment.
-------
ALTERNATIVE DESCRIPTIONS
Description Of Aitarnatlvfts
Alternativ* i *:. Ho Action
The no ict'ion alternative 1« used as requited
jy the National Contingency Plan (NCP), the
regulation implementing the Super fund law. It is
used as a baseline for comparing other
alternatives, this alternative involves rid 5 i
active measure*, so no capital costs would b« rf i
required* : Monitoring for a five-year review :>'iib
rtoUld b« requited. , , .. . .' . . ;U,~.::.tf:i^:;k:J£d
Alternative 2 * Institutional Controls ?;;
This alternative uses deed restrictions and x
physical barriers to restrict access to the site i
Deed restriction* could include zoning ordinances
to prohibit construction on or use of the site
while the soil remains contaminated. Physical I;
9arri.ers could include fencing and warning sighs
to prevent access to and Use o it the site; .^k -.:* :;
4onitoringi for -M.: five*year teview would Bi jff.1^??^'.
re::. ^JtiM:^,^. -. >:.:... .i'; ^ ^..^ ^i;;..
.Alter»iativ.3 ::*:::-fcaiidliii biitiojtll r : : '? ,< ;: u$ - - %^.
This alternative includes landfill disposal of
the excavated soil at a permitted landfill and i
Mefcfili with clean sell ./?. ^ .,=. :-,:^. &, .: , :.,>:.;.:.;.. \^.,.^m\
Ait«rnatlvil#:^i: fcbW .' i'ett^rlti^ii^tfie-riial:!'^^ ^M-
De'sbrp'Hon' .»«<<< -^ -^ -:t";"r :. 'i : ;: : - * .-.' . , - 'v':l.v ?;..: -:.;-;:4
on-site low tewperature thermal desorption
consists of a i heated chamber which drives off :
contaminants from the soil; The cdntamlnants ifil
the gas stream are captured by an air pollution
control system which utilizes baghouses, y
condensers, filters, and/or actlviated carbon.
Cost *
$0
.^:W-^'f. :"V'"/.r^;:^SM'
'' '. - - : ' -: ', '-.-. """:-. ''.'. :': ': ': ' ' ' -. :-: : '. . .''.'.' '' ' '-: ::::':' '. ;';':'
: : :.-.. -. '.'.- .' :. '-.'..' ' :..:: . .-::;::.:
;/i. :/ ;-,:,;: ^):-l, **£&'$& ;:v: +; f- ^m(
' ''.''':'.':' t~ ::'.X::. ''' '^l.. W'i\ 'f ';::' '''^if-'
' -. :' .": ::,\ ''' '.': i;^-.::':-?.:5i;-?'₯;^ Z?-'^ '<?$%'?:'.
'''''< *:i:@:W^:'4&5S: SliS: 1;
: ,: :: .;i l&M S ''iiiiioh :»*&>%:n* ^
':.:-> .-/:.; '$4 ^l.mliiibll ', :.r::;:V '. . : :
.'.,.: ""..'. : ';'l. -;:.ri.::i-':':::: ^.H-::v:::;d ::," F'
''' :..' '-vi T' .--'^V;-i::.:.:.'::. '^iS^' '.,;""?..
f iaM to Xa|»l«Baftt
& months
'"$&l f S :: '"'Sip' ';:?;f- tt.if :'S.C-; ' :V.:;;:K'-;:;i;::'- c
..:;: ?wS /. -i* :;:": ^.:;;;i.'::-??5.:. : :v^.?^^S^ .: ""'$--i!tet '>:
;|.p|:J: . IS^^^Si^^i.^M^^. t'.uv?':£!:::
; y i;:-::': . V ;:i;: ;l; 1?;'; v ..^5^ i^S' l^fe J::':i ?!: : ' :; v : i ' :'' '
iS, Wiii^:"^^im^X^!i:
' .:':":"' ;:: :V: ::. '" ::'':-';:-::''i :';": '::; ^-''''l-y':':1'' :;; : ' ;,' : ': . i ': -' ' ';''' :"''-i&& '.- ': ::'"''':' ;";'' ':'.'.*]* :':
' .;::!*:.":-;:':;. v:;' ::. ':'.::;V:-:|;'. .:::;'>: :: :::::'%;':-!^X '''''' -'j.';^'! :''! '':':'v';ft;:;;:'-'- 7 :.* : :|.':-' !:* : . '.'! ;: :'.| !i;';. ''
.: :J : . :->.-:-::.. :' vii-S.v:-'-'-'-' :;.- '::': .-.: ''/:::'/: :;: *.'*''. :'..'. .-:;.'!-. :. :'::::. . .Y.-!-. '! :-'-'-'-:- ' '',- :-.- :'! .'.
.:?!; A:' ::;r::-i 'ii;'?;^ ^raOhthi .^/^l .::.:Vf vr '^;
11 iliililiilllii:
%' ' '.. ^I'^^^^l^?-^^^^- '/V^-:' ':^;--
-^- - :>i:::s:::iM::';i;-« ttohthis >: ji5jfW;i:^-;,- :
:g;|;;:^ ^^^2^-;:^^;f|;r.J^l-§-.
:S^-' :' S'SF.1 ?SS -M- "'Lfffi' i= ' =)3^ '
* Costs to implement remedy in addition to costs Incurred to date.
** For disposal in Subtitle D landfill
8
VO
O
O
ro
ro
-------
5 9"' 0023
Short-term effectiveness, i.e., the impacts a remedy might
have on the community, workers, or the environment during
the course of implementing it.
Implementability, i.e., the administrative or technical
capacity to carry out the alternative.
Cost-effectiveness considering costs for construction,
operation, and maintenance of the alternative over the life
of the project, including additional costs should it fail.
Acceptance by the State.
Acceptance by the Community.
The NCP categorizes the nine criteria into three groups:
(1)Threshold Criteria - overall protection of human health
and the environment and compliance with ARARs (or invoking a
waiver) are threshold criteria that must by satisfied in
order for an alternative to be eligible for selection;
(2)Primary Balancing Criteria - long-term effectiveness and
permanence; reduction of toxicity, mobility, or volume;
short-term effectiveness; implementability, and cost are
primary balancing factors used to weigh major trade-offs
among alternative hazardous waste management strategies; and
(3)Modifying Criteria - state and community acceptance are
modifying criteria that are formally taken into account
after public comment is received on the proposed plan and
incorporated in the ROD amendment.
The selected alternative must meet the threshold criteria
including compliance with all ARARs or be granted a waiver for
compliance with ARARs. Any alternative that does not satisfy
both of these requirements is not eligible for selection. The
Primary Balancing Criteria are the technical criteria upon which
the detailed analysis is primarily based. The final two
criteria, known as Modifying Criteria, assess the public's and
the state agency's acceptance of the alternative. Based on these
final two criteria, EPA may modify the remedial action.
The following analysis is a summary of the evaluation of
alternatives considered for remediating the major portion
(exclusive of the. former burn pit area) of the Marzone Site under
each of the criteria.
-------
5 9 0024
Threshold Criteria
.1 Overall Protection of Human Health and the Environment
Contamination which could pose a threat to human health or the
environment is present in the stockpiled surface and subsurface
soil (exclusive of the former burn pit area) of OU#1 of the
Marzone Site. The soil poses a direct exposure risk to people.
The no action alternative would not provide protection from the
direct exposure risks. Because the no action does not meet a
threshold criteria, it will not be carried forward in the
evaluation.
Alternative 2 (institutional controls) would restrict access to
the site and prohibit future uses which could result in direct
exposure. Alternative 3 (offsite disposal) and alternative 4
(low temperature thermal desorption) provide protection by
reducing risk levels through disposal or treatment of
contaminated soil.
6.2 Compliance with ARARs
Alternatives 2,3 and 4 would be implemented to comply with all
ARARs. No waivers from ARARs would be required.
Primary Balancing Criteria
6.3 Long-Term Effectiveness and Permanence
Alternative 2 does not provide long-term effectiveness or
permanance, since contaminated soil would remain stockpiled on-
site. Alternative 3 provides an effective remedy because it
removes contaminated soil so that action levels are met. The
contaminated soil would be disposed offsite in a permitted
landfill and replaced with clean backfill. The LTTD alternative
is a more permanent remedy, since pesticides and other organic
contaminants are removed from the soil.
6.4 Reduction of.Toxicity, Mobility or Volume Through Treatment
Under alternatives 2 and 3, toxicity, mobility and volume through
treatment would not be reduced. However, alternative 3 would
reduce mobility by placing contaminated, soil into a regulated
landfill. Alternative 4 would remove toxicity, eliminate
mobility, and possibly reduce volume through treatment.
.5 Short-Term Effectiveness
All alternatives would be implemented with measures to protect
workers and residents from airborne dust and emissions. Workers
would also be protected from direct contact with the soil. .
Additional steps would be taken to reduce noise, truck traffic
10
-------
> v- »-
and other nuisances. Alternatives 2 and 3 could be implemented
most quickly and, therefore, would have more short-term
effectiveness.
.6 Implementability
Alternative 2 can be easily implemented using administrative and
legal procedures and proven construction methods. Alternative 3
uses proven equipment and construction methods and could be
completed within B to 12 weeks. Alternative 4 involves
specialized equipment and controls. Such equipment is available,
but requires more extensive mobilization than Alternative 3.
Alternative 4 could be completed in 6 to 9 months.
6.7 Cost
The cost for each alternative is provided in the table on page
10.
Modifying Criteria
6.8 State Acceptance
The State of Georgia has concurred on this amendment to the
selected remedy (Appendix B).
6.9 Community Acceptance
EPA has selected off-site disposal as the remedy for the former
burn pit area. Comments received during the public comment
process for the proposed plan for this amended ROD were
considered in the remedy selection process. A Responsiveness
Summary is attached to this amended ROD which provides EPA's
response to comments received on the Proposed Plan for the
amended remedial action.
7.0 Selected Remedy
Based upon the Administrative Record, consideration of the
requirements of CERCLA, the NCP, the detailed analysis of
alternatives and public and state comments, EPA has selected an
amended remedy for OU 1 of this site. The selected cleanup
alternative to reduce to levels protective of human health and
the environment risks posed by contamination found at the major
portion (exclusive of the former burn pit area) of the Marzone
Site is Alternative 3 - Landfill Disposal. This remedy involves
hauling excavated soils which exceed the performance standards
(exclusive of the former burn pit area) from OU 1 to a permitted
waste disposal facility for offsite disposal. The excavated area
will be backfilled with clean soil. The soil will be placed in
either a RCRA Subtitle D or Subtitle C landfill, depending on the
soil characteristics.
This remedy will protect human health and the environment by
removing soil above the clean-up level, and disposing of the soil
in a permitted landfill. ARARs can be easily met. Although this
remedy will not reduce toxicity and volume through treatment,
11
-------
59.. 0026
nobility will be reduced by placing contaminated soil in a
regulated landfill. The selected remedy is easily implemented
and is cost effective. :
Performance Standards
The selected remedy will achieve the cleanup levels specified in
the original ROD. All activities shall comply with ARARs, and
state standards. Testing methods approved by EPA will be used to
determine that the cleanup levels have been achieved.
All remedial activities shall comply with applicable or relevant
and appropriate requirements (ARARs), including, but not limited
to RCRA and Land Disposal Restrictions. Results of testing
specified by regulations under RCRA will be used to determine
whether the soil will be placed in a Subtitle C or Subtitle D
landfill.
8.0 Statutory Determination
Under its legal authorities, EPA's primary responsibility at
Super fund sites is to undertake remedial actions that achieve
adequate protection of human health and the environment. In
addition, Section 121 of CERCLA establishes several other
statutory requirements and preferences. These specify that, when
complete, the selected remedy must meet appropriate environmental
standards established under Federal and State environmental laws
unless a statutory waiver is justified. The selected remedy also
must be cost-effective and utilize permanent solutions and
alternative treatment technologies or resource recovery
technologies to the maximum extent practicable. Finally, the
statute includes a preference for remedies that employ treatment
that permanently and significantly reduce the volume, toxicity,
or mobility of hazardous wastes as their principal element. The
amended remedy meets the statutory requirements and preferences
of Section 121 of CERCLA as further explained below.
6.1 Protection of Human Health and the Environment
The selected remedy protects human health and the environment
through removal and disposal of the contaminated soil (exclusive
of the former burn pit area) and treatment of contaminated
groundwater at the site. The selected remedy provides protection
of human health and the environment by eliminating, reducing, and
controlling risk through treatment, engineering controls and/or
institutional controls.
8.2 Attainment of the Applicable or Relevant and Appropriate
Requirements (ARARs)
Remedial actions performed under CERCLA, as amended by SARA, must
comply with all applicable or relevant and appropriate
requirements (ARARs) unless a waiver is justified. All
alternatives considered for the site were evaluated on the basis
of the degree to which they complied with these requirements.
The selected alternative was found to attain ARARs.
12
-------
5 9 0027
ARARs for the major portion (exclusive of the former burn pit
area) of the Marzone Site are found in Tables 2, 3, and 4.
8.3 Cost Effectiveness
Cost effectiveness is determined by comparing the cost of all
alternatives being considered with their overall effectiveness to
determine whether the costs are proportional to the effectiveness
achieved. The cost for the selected remedy is estimated to be
$1.5 million, in addition to costs already expended (for remedial
design, site preparation and excavation) if a Subtitle D landfill
is appropriate for disposal. If testing results indicate that
the contaminated soil must be placed in a Subtitle C landfill,
the costs could be $ 10,300,000.
This remedy is as protective as the low temperature thermal
desozption alternative. This factor, as well as the ease of
implementing this remedy make it a reasonable value.
8.4 Utilization of Permanent Solutions to the Maximum Extent
Practicable
EPA has determined that the selected remedy provides the best
balance among the nine evaluation criteria for the alternatives
evaluated. The selected combination provides protection of human
health and the environment and is cost effective. The remedy,
when complete, will provide a high degree of permanence. The
remedy represents the maximum extent to which permanent solutions
and treatment can be practicably utilized to remediate the major
portion (exclusive of the former burn pit area) of OU 1 of the
Marzone Site.
8.5 Preference for Treatment as a Principal Element
The statutory preference for treatment will not be met by this
selected remedy for the above stated reasons.
9.0 Documentation of Significant Changes
None identified.
13
-------
5 9 0028
1 TABLE 2: FEDERAL AKARs FOR MXRZ1XE SITS OUl
CLZAN MATER ACT - 33 U.S.C. IS 1251-1376
R £ A
A & A
a & A
a & A
A
CXT&TZONS
40 CTK Part 131
Ambient Water Quality
Criteria Requirements
4C CTR Part 141
Rational Primary Drinking
UMfff B»er l^rirwia
40 CFR Part 142
Raticaal Primary Drinking
Hater Regulations
JgPp} yftl^rt^^y ji^ffl
40 CFR Parr 143
national Seconoary Drinking
Hater Regulations
>.
40 CFR Pare 144
Onder around Infection
Caacrol .
Ou»nj.e&T
Specific for
groundwater
f^«4Mt« f» 1
Specific for
Caeaic&l
Specific for
Sjroundwatez
rtyr«jr»t1
Specific for
grcuncwater
Action
Specific for
groundvacer
COMMENTS
Provides for the
establishment of water
quality based on texicaty to
aquatic organisnis aac hirraiTi
health.
Establishes priieary drinking
vater regulations pursuant to
Section 1412 of the Public
Health Service Act, as
amende = by the Safe Prir.fr ?ng
Hater Art; and related
regulations applicable to
public water systems.
Sets forth Sections 1413-
141fi, 1445. and 1450 of the
Public Health Service Act, as
amended .
Establishes Raticaal
Secondary Drinkirc Hater
Regulations pursuant to
Section 1412 of the Safe
Drinking Vater Act, as
amended (42 D.S.C. 300g-l) ;
and ccatrcl exmtnmi nitnts in
drinkinc *ater that primarily
affect the aesthetic
qualities relating to the
public acceptance of drinking
water.
Set forth requirements for
the Dnderoround Injection
Control (DIG) program
promulgated under Parr C of
the Sale Drinking Hater Act.
-------
5 9 0029
1
A
JL & A
A
a & A
R & A
A
RCA
TABLE 2: FEDERAL
ss»- '^^'i * '" ' ' !_ a TJ
RESOURCE CONSERVATION AH
CITATIONS
4C CF£ Part 261
Identification and Listing
of Hazardous Haste
40 CFR Part 262
Standards Applicable to
Generators or Razardouf
Waste
40 CFR Part 263
Standards Applicable to
Transporters of Hazardous
Waste
40 CFR Parr 264
Standards ~ar Cv=ers and
Operators sf Hazardous
Waste Treatment, Storage,
and Disposal (TSD)
Facilities.
40 CFR Part 268
Ijmd Disposal Restrictions
Federal Register /Vol. 50
February 16. 1993
40 CFR Part 260 et al
Corrective Artica
^anageaent_7Bits and
Temporary O&.»ts ; Corrective
Action Provisions; Final
Rule
40 CFR Part 270
EPA Administered Permit
Prograss:
Hazardous Waste Perait
Program
ARARS FOR MAR;
O UfCOVKR? ACT
Action
Specific for
Soil
Action
Specific for
Soil
Action
Specific for
Soil
Action
Specific for
Soil
Chemical
Specific for
Soil
Action
Specific f=r
soil and
groundwater
Action
Specific for
5QNE SITE 001
- 42 U.S.C. SS 6901-6987
COMMENTS
Identifies those solid wastes
which are subject t;-
regulation as hazardous
wastes. Defines me term
solid waste' and hazardous
waste'.
Establishes standards fcr
generator's of hazardous
waste.
Establishes the
responsibilities of
generators and transporters
of hazardous waste in the
haadlir:?, transportation, and
management of that waste.
Establishes «*---«» na--««i
standards which define rhe
acceptable management of
hazardous waste for owners
and operators of facilities
whicb treat, store, or
dispcse of hazardous waste.
Identifies hazardous wastes
that are restricted from land
disposal and describes those
circumstances under which an
otherwise prohibited waste
may be land disposed.
Finalizes provisions for
corrective acriza aanagement
usit* (CATtDs) and temporary
ur..^s uni-sr Sutrart S of 40
CFR Part 164. Defines ^->»y
tern remediation waste
Sstablishes provisions for
the Hazardous Waste Permit
Prograa under Subtitle C of
t£s Solid Waste Disposal Act.
r
15
-------
5 "9
1
TABLB 2: FEDERAL tJ^Rs FOR MARZONE SITS OU1
A ....... APPLICABLE REQUIREMENTS WHICH WERE PROMULGATED UNOC* FEDERAL LMt TO SPEdRaOLT ATOMtSS A
HAZARDOUS SUBRAKCC, fOLUDXAKT. OMZAHZNANT. REMEDIAL ACTION LOCATION OR OTHER CIJtCUMSIAWX
AT an or us HAMOMC SITE.
B ft A IC1CVXMT AND APPROPRIATE REOnZUmfTS WHICH MOLE THET ARE NOT ATPUCABIE- TO A HAZARDOUS
SUBSTANCE. K^IUTAH?. OONTAMIIMWT. REHE9IAL ACT10M, 1ACAT20N, OR OTHER CIRCUMSTANCE AT OU1 OF THE MWxIONE
SITE, ADORES: PROBLEMS OR SITUATIONS svmciEMTLr suauut TO THOSE EXOOUKTKREO AT oui or THE HARZOME SITE
THAT THEIR USZ IS KEIL SUITED TO THE SITE.
-------
5 9 ' OG3t
TABLE 3 1 STA7Z
FOP. KARZOKB SITE OD1
CITATIONS
Georgia Drinlring Hater
Regulations. Chapter 391-3-5
location
Specific for
groundvater
Establishes rules and
regulations for Georgia
drinking water standard*
and addresses wellhe&d
protection cones.
Rules of the Georgia
Department of natural
Resources Bnvironmental
Protection Division. Chapter
Action
Specific for
Soil
Provide* rules for the
Underground Storage T&aJc
Program. GaJBPD na* nor
ec soil action l«v»l*
for ^^TT^*11*^ *»»*^^ » otnar
than petroleum
Georgia Hater dualicy
Control Regulations and
Standard*
Action and
Ousnical
Specific for
runoff
Sstablishes Georgia
surface water quality
criteria.
A . ---APPLICABLE ME9UZRO1CN7S MHICR MERE MOMUUMXCa WCDCX FTKML UO* TO SreCIFICAiiT ADDRESS A
HAZARDOUS SUBSTANCE. MUUXANT. CORAHXHAIiT. MHUUK, ACTION LOCATION OR OTHER CIRCUMSTANCE AT OU1 OF
THE HKRZCNE SITE. . j
K c A -riiaxvjwr AKO AmomuTE KCOUZPEMORS MOCH wou THET ARE HOT »AmicuKf TO A HAZARDOUS
SUBSTANCE, POLLUTANT, COVZAHZKANT. MEMES1U. ACTION, LOCATION. OR OTHER CIRCUMSTANCE AT OU1 OT THE
MARZONE SITE. A53RCSS mOBLEKS OR SXTUATZCMS SUmCZENZLT SIMILAR TO THCSE XNCOUNnUD AT OU1 OF THE
MARZCNE SITE THAT THEIR DSC IS HELL SUITED TO THE STTE.
TABLE 4: TO- BE -CONSIDERED (TBCs) DOCUMENTS FOR MRRZONE SITE
DOCUMENT TITS
TJSWA, Office of Prinking Water.
i=*-**-r-«*. fcA«-;ngt^m. T>.C. . O^CMBO*-
PBSCRTPTIOS
Issue* health advisories baaed oa e:
to various concentrations of cheaicu
* ri BI wi
'
TBO TD-BE-CONSIDERfD OTTERS ARE NC--ntOUULGATED ADV3CSUES AND CV3ANCE THAT AXE VOT LEGALLY
BINDING, BLT SHOULD 3E OONSOEKgD IN DET. 2MIMNC THE NECESSARY LEVEL OF CLEANUP FOB PROTECTION OF
OR THE ENVIRONMENT.
OU1
xposure
OS of
HEALTH
-------
APPENDIX A
RESPONSIVENESS SUMMARY
5 9 0032
-------
5 9" 0033
RESPONSIVENESS SUMMARY
MARZONE INC./CHEVRON CHEMICAL COMPANY SUPERFUND SITE
OPERABLE UNIT ONE
TIPTON. TIFT COUNTY, GEORGIA
The U.S. Environmental Protection Agency (EPA) held a public
comment period from April 1, 1997 through May 1, 1997 for
interested parties to give input on EPA's proposed plan for a
Record of Decision (ROD) amendment for Operable Unit 1 (OU 1) of
the Marzone Inc./Chevron Chemical Company (Marzone) Superfund
Site in Tifton, Tift County, Georgia. EPA conducted a public
meeting on April 17, 1997 at the J.T.Reddick Middle School in
Tifton, Georgia. The meeting presented the proposed remedy
change for OU 1 and gave the public the opportunity to formally
comment on the proposed plan. In addition, EPA held an informal
open house at the Neighborhood Service Center on April 19, 1997
to give community members an opportunity to ask questions. The
open house was advertised in the Tifton Gazette on April 25, 1997
and in the Gazette Lite on April 28, 1997. The public comment
period was extended until June 2, 1997 after EPA received a
request for an extension. Extension of the comment period was
announced on May 3, 6, and 13 in the Tifton Gazette.
A responsiveness summary is required to document how EPA
addressed citizen comments and concerns about the Site, as raised
during the public comment period. All comments summarized in
this document have been factored into this decision for remedial
action for OU 1 of the Marzone site.
This responsiveness summary is divided into the following
sections .
I. Overview - This section discusses the recommended
alternative for remedial action and the public reaction to this
alternative.
II. Background OTD, Community Involvement: and Concerns - This
section provides a brief history of community interest and
concerns regarding the site.
III. Summary of Major Quest lone and Comments Received During
t-ho Ppi->1 ^ r. Comment Period and EPA'fi Responses - This section
presents comments submitted during the public comment period and
provides the responses to these comments.
TV. Concerns to be Addressed in tne Future - This section
discusses community concerns of which EPA should be aware during
remedial design.
-------
5 9 0034
I. Over-view
The remedial alternatives for the amended ROD were presented to
the public in a Proposed Plan released on March 28, 1997 to a
mailing list of 600. Public notices were placed in the Tiften
Gazette on March 31, 1997 and April 14, 1997 and in the Gazette
Lite on April 2, 1997 and April 19, 1997. A public meeting was
held April 17, 1997 with over 100 people attending.
EPA has organized work at this site into two phases or operable
units (OUs). OU 1 involves contamination on the former pesticide
production facility, part of the property adjacent to the
formulation area, and part of the adjacent railroad drainage
ditch, as well as contaminated groundwater related to the Site.
This first operable unit is divided into two separate remedies,
one for groundwater and the other for soil.
For contaminated groundwater, the remedy remains unchanged from
that selected in the original ROD. This remedy is groundwater
pump and treat with reinjection through an infiltration gallery.
For soil contamination, the selected remedy in the original ROD
was low temperature thermal desorption (LTTD). During the
Remedial Design phase for the soil remediation, the community
group, People Working for People, Inc. (PWP) requested the Agency
for Toxic Substance and Disease Registry (ATSDR) to review the
operations of the'proposed LTTD unit. ATSDR made recommendations
to EPA for additional monitoring and operational controls which
significantly increased the projected cost of the thermal remedy.
Due to this cost increase, EPA decided to consider other
alternatives for the soil remedy.
The preferred remedy presented to the public in the proposed plan
for an amended ROD was Alternative 3 - Landfill Disposal. This
is the final selected remedy for the soil (exclusive of the
former burn pit area) at OU 1 of the site. This remedy involves
hauling excavated soils which exceed the performance standards
(exclusive of the former burn pit area) from OU 1 to a permitted
waste disposal facility for offsite disposal. The excavated area
will be backfilled with clean soil. The contaminated soil will
be placed in either a Subtitle D or Subtitle C landfill,
depending on the soil characteristics. The cost is estimated to
be $1.5 million for disposal in a Subtitle D landfill and $10.3
million for disposal in a Subtitle C landfill.
Many of the community's concerns were related to health issues
from possible exposure to either the Marzone site or other toxic
waste sites in Tifton. Of the comments that were related to
EPA's proposed change to the original ROD, several community
members expressed concern that contaminated soil from the site
could be place in a Subtitle D landfill. Community members also
expressed concern regarding possible exposure to dust and other
contamination during truck transport of the soil.
-------
5 9 0035
II. Background on Community Involvement! and Ponperne
Prom 1991 until 1994, EPA held several public meetings and
availability sessions to discuss with the community the original
proposed plan and the South Tift County Environmental Justice
Initiative.
The remedial alternatives for this amended ROD were presented to
the public in a Proposed Plan released on March 28, 1997 to a .
mailing list of 600. Public notices were placed in the Tifton
Gazette on March .31, 1997 and April 14, 1997 and in the Gazette
Lite on April 2, 1997 and April 19, 1997. EPA held a public
comment period from April 1, 1997 through May 1, 1997 for
interested parties to give input on EPA's proposed plan for a
Record of Decision (ROD) amendment for Operable Unit l (OU 1) of
the Marzone site.r EPA conducted a public meeting on April 17,
1997 at the J.T.Reddick Middle School in Tifton, Georgia. The
meeting presented the proposed remedy change for OU 1 and gave
the public the opportunity to formally comment on the proposed
plan. Over 100 people attended the public meeting.
In addition, EPA held an informal open house at the Neighborhood
Service Center on April 19, 1997 to give community members an
opportunity to ask questions. The open house was advertised in
the Tifton Gazette on April 25, 1997 and in the Gazette Lite on
April 28, 1997. The public comment period was extended until
June 2, 1997 after EPA received a request for an extension.
Extension of the comment period was announced on May 3, 6, and 13
in the Tifton Gazette.
The administrative record was available to the public at both the
information repository maintained at the Tifton and Tift County
Libraries and at the EPA Region IV Library at £1 Forsyth Street
in Atlanta, Georgia. The notice of availability of the proposed
plan and the administrative record was published in the Tift en
Gazette on March 31, 1997 and April 14, 1997 and .in the Gazette
Lite on April 2, 1997 and April 19, 1997.
III. Summary of Major Questione and Comments Received Duringr the
Public Comment Period and EPA's Responses
Comment 1: One PRP stated that it supported the proposed
remedy of landfill disposal because ATSDR's insistence upon an
effective zero risk standard for low temperature thermal
desorption (LTTD) makes the current remedy prohibitively
expensive and no technology was available to meet ATSDR's
requirements. Many of ATSDR's recommendations fall outside the
proven design and operational envelope of the selected LTTD unit.
Landfill disposal is a proven, quick and effective way of
cleaning the Marzone site.
-------
5 9 0036
EPA Response: EPA agrees that the cost of implementation of
ATSDR's recommendations made LTTD no longer cost effective and
that many of the recommendations were outside the design and
operational parameters for the selected LTTD unit. However, EPA
believes that LTTD technology is available which could meet
ATSDR's requirements. EPA agrees that landfill disposal is a
proven, quick and effective method for remediating the Marzone
soil.
Comment 2: Two commenters expressed support for landfill
disposal, since it would result in the faster cleanup of the ,
Marzone soil. One of these commenters (a contractor for the PRP)
stated that many residents of Tifton have told the commenter that
they simply want to see the site cleaned up.
EPA Response: EPA agrees that landfill disposal would be the
fastest method to clean up the Marzone soil.
Comment 3: One commenter expressed concern that fill dirt
would be obtained from a source in Tift County which the
commenter had heard was contaminated.
EPA Response: The soil from this source has been tested for
contaminants of concern and dioxin. Levels of all contaminants
were below EPA's action levels. The soil will be tested again
for a wider range of possible contaminants before the soil is
brought to the site.
Comment 4: One commenter asked where permitted landfills are
located in Georgia, do the landfills control dioxin, what
protections will be taken for the community while the soil is
being transported, and what community will be impacted by
landfill disposal of the contaminated soil.
EPA Response: Almost 40 EPA-pezmitted Subtitle D (non-hazardous)
landfills are located in Georgia. No Subtitle C (hazardous)
landfills are located in Georgia. Contamination placed in
permitted landfills is controlled by liners or other groundwater
controls, run-on and run-off controls, and monitoring systems.
Soil must be tested for hazardous characteristics before
placement in a landfill. Soils which are deemed hazardous must
be placed in a Subtitle C landfill.
During the transport of soil from Marzone to a permitted
landfill, real-time and 24-hour air monitoring will take place.
If, at any time, the air monitoring indicates that particulates
or contaminant levels are rising, additional protective measures,
such as wetting the soil, covering the soil, or stopping work,
will be taken. The trucks carrying the soil will be lined with
plastic which will cover the top of the load and covered with a
tarp to prevent soil from blowing or falling out of the truck.
A landfill will be selected which will have minimal impact on
near-by communities. No adverse health impacts will occur, since
-------
5 9 0037
all laws and regulations regarding landfill disposal will be met
in placing the soil in a landfill.
Comment 5: One cotnmenter stated that EPA should insist upon
implementation of the ATSDR recommendations for LTTD operation.
EPA Response: Implementation of the ATSDR recommendations would
increase the cost of the remedy so that it is no longer cost
effective.
Comment 6: Two commenters stated that LTID is the best
alternative for cleanup since it results in a permanent solution.
These commenters stated that landfill disposal should only be
utilized if the soil is placed in a Subtitle C (hazardous waste)
landfill. The removal and transportation of soils for
landfilling should be designed to eliminate all possibilities of
additional contamination threats and to ensure safety.
EPA Response: EPA agrees that LTTD would provide a more
permanent solution for the Marzone soil cleanup. However,
landfill disposal will be protective of human health and the
environment and has become significantly more cost-effective.
As stated above, all laws and regulations regarding landfill
disposal must be met in placing the soil in a landfill. If the
soil, is determined to be hazardous, it will be placed in a RCRA
Subtitle C landfill. If the soil is deemed non-hazardous, it
will be placed in a RCRA Subtitle D landfill.
Protective measures which will be implemented during the
transporting of soil are described in response 4.
Comment 7: One commenter stated that the proposed plan does
not address the clean-up of the former burn pit area, which is
the most toxic part of the Marzone site. This plan should not be
implemented until the burn pit area is addressed.
EPA Response: An amended proposed plan including cleanup of the
former burn pit area was issued in September 1996. EPA has not
prepared a final Record of Decision amendment for the former burn
pit area. The current proposed plan does not include the former
burn pit area and that area will not be a part of this action.
The former burn pit area will be cleaned up in a separate action.
Comment 8: One commenter stated that EPA determined that
offsite disposal to a landfill was unsafe in 1994.
EPA Response: When EPA issued the Record of Decision in
September 1994, it selected low temperature thermal desorption as
the best soil remedy. In the feasibility study, offsite disposal
to a landfill was carried forward as one of the better
alternatives. EPA never determined that offsite disposal was
unsafe.
-------
5 9 '0038
Comment 9: The same commenter stated that soil from Marzone
will be disposed in a landfill located in a "people of color"
community.
EPA Response: EPA has cot made a final decision on which
landfill will receive the soil from Marzone. All landfills under
consideration are* regulated by the States or by EPA under the
Resource Conservation and Recovery Act (RCRA) and must be in
compliance with the regulations. Neighboring communities will
not be placed at any additional risk by placement of the Marzone
soil into the landfill.
Comment 10: The same commenter stated that EPA has said that
the Marzone soil is hazardous and is now saying that it can be
placed in a non-hazardous landfill.
EPA Response: EPA has not made a final decision on what type of
landfill will receive the Marzone soil. The soil at Marzone is
contaminated with chemicals at levels which can cause adverse
health effects after long-term exposure. The soil from Marzone
will be tested using the RCRA criteria and procedures to
determine whether the soil will be placed in a hazardous or non-
hazardous landfill.
Comment 11: The same commenter stated that EPA is proposing a
change of the remedy to off site disposal only for cost reasons.
EPA Response: The recommendations made by ATSDR for the LTTD
unit increased the projected costs of the LTTD remedy, so that it
was no longer cost-effective. landfill disposal will provide a
fully protective remedy which can be implemented faster and more
cost-effectively.
Comment 12: The same commenter stated that contamination from
the trucks will move into streets, yards, and houses in Tifton.
EPA Response: EPA expects the following precautions to be taken.
After the trucks are loaded, they would be driven to an asphalt
decontamination pad. The plastic liner in the truck bed would be
folded over the top of the soil. A transport tarp would be
placed over the liner. The trucks would be inspected and any
visible soil would be brushed or washed from the truck body and
tires. Soil from the decontamination pad would be placed back
into the soil stockpile. Water from the pad would be treated in
the onsite water treatment system. These measures would be
designed to prevent contamination from being carried into the
community.
Comment 13: The same commenter stated that in 1994 EPA said
that it would take three years to clean the soil. The three
years became 18 months and now has become six months.
EPA Response: The 1994 estimate included design and
implementation time under EPA's traditional approach to
-------
59 0039
conducting remedial design/remedial action activities. The 18
month estimate was based on a more efficient approach to design
and implement the remedy. The estimate for landfill disposal is
only six months because much of the design and site preparation
work has been completed, including most of the soil excavation
work.
Comment 14: One commenter asked how EPA will get all of the
contamination out of the soil. Another commenter stated that
contamination was poured in a hole at a depth of 14 feet.
EPA Response: Soil has been excavated to a depth of seven feet.
This excavation removed all surface soil with contamination above
the EPA cleanup levels and removed all subsurface soil which
would result in further contamination of groundwater.
Groundwater at the Marzone site is found at seven feet below
ground surface. Contamination below a depth of seven feet will
be removed during the groundwater remediation.
Comment 15: One commenter stated that high levels of dioxin
are present at the Marzone site.
EPA Response: Levels of dioxin in the former burn pit area were
found above EPA's proposed action level. EPA issued a proposed
plan for a Record of Decision amendment for this area in
September 1996. Levels in the remainder of the site are below
EPA's proposed action level.
Comment 16: Three commenters stated that EPA has not addressed
contamination in ditches and other areas across Golden Road from
the Marzone site.
EPA Response: During the South Tifton Investigation, EPA sampled
areas across Golden Road from the Marzone site. No contamination
above levels of concern were found in these areas.
Comment 17: One commenter expressed concern that offsite
disposal would harm her and her children through dust exposure.
EPA Response: During loading of the trucks and any other soil
movement activities, the soil would be wetted, as necessary, to
reduce dust. Numerous safety precautions should be taken to
prevent dust exposure from trucks. These precautions are
described in the response to comment 12. In addition, site
workers would monitor the site interior and perimeter for
particulates and would take additional corrective actions,
including stopping work, to control dust.
Comment IB: One commenter expressed concern that the soil will
be packed down, covered with cement, and left.
EPA Response: EPA is not considering an alternative such as
described by the commenter.
-------
5 9 ' 0040
Comment 19: One commenter stated that the truck traffic will
disturb the neighborhood.
t
EPA Response: The operations will take place only during the
day, probably starting after school begins, if transportation is
conducted during the school season. Truck traffic will involve
approximately three to six trucks per hour for ten hours per day.
Traffic will be directed east on Golden Road to avoid most of the
neighborhood area. A flagperson will direct trucks in and out of
the site to minimize impacts on Golden Road traffic.
XV. Concerns to be Addressed in the Future
Several community members expressed concern regarding the former
burn pit area. An amended proposed plan including cleanup of the
former burn pit area was issued in September 1996. EPA has not
prepared a final Record of Decision amendment for the former burn
pit area. This area will be addressed after EPA issues a final
ROD amendment for the former burn pit area.
-------
APPENDIX B
STATE CONCURRENCE LETTER
5 9 0041
-------
Georgia Department of Natural 'Resources
0-^> ' -*\ MMMM^B^H^MfcMWM^BHMMWNMMMMMVM^HMM^HWM^MWM^V^«H«^MBHVHMM^MW^MB"l^^niMaHMaMHI'"MMWW
^ , U ** ^ 205 Butter Stref. Suite 1754. Aiana, Georffia 30334-«ic
(4M) 6M-7K8 FAX <40<) CSV*<2S
June 19,1997
TT
Ms. Annie Godfrey '
USEPA Regior-IV (4V.'DSSRB) -
61 Forsyth Street -.
Al*anta. Georgia 303C5 ^C^ **- "
ftE: Proposed amended reccrc of - -'
tfec&ior for the Marzone !nc-/Che?*«»
Chemical Site. OU#1 area (Exduding
The 2-m Pit Area) Trfton, Tift County,
Georgia
Dear Ms. Godfrey:
The Georgia Environmental Protection Division (GAEPD) has received and reviewed
the above referenced document The GAEPD concurs with the Environmental
Protection Agency's proposed amendment to the Record of Decision (ROD) for the
Marzone site as written for the following reasons:
1. The proposed change to the selected remedy for contaminated OUf 1 soH
(excluding the former bum pit area) would result in s. more cost effective dean-
up. In the orig-al ROD (September 1994) Low Temperature Thermal
Desorption (LTTD) and on site placement of treated soils was selected. Total
estimated cost for this remedy was 4.8 million (later revised to 4.3 million). The
original estimate for excavation aid landfill disposal was 3 million. The cost for
landfill disposal is now estimated at 1.5 million. This is a substantial reduction in
dean-tip cost while accomplishing dean-uc vcjectives.
2. The proposed selected remedy will achieve dear.-up levels specified in the
original ROD.
3. The scope of the proposed changes includes only contaminated soil in the
selected remedy, not the forme- bum pit area, nor the groundwater.
i. Although this selected remedy wffl not reduce *he toxkaty and the volume of
contaminated soil through treatment the ease ?' ~.plementabifity and the cost
effectiveness of this alternative while protecting human health and the
environment make this alternative practical
5. The selected remedy as amended complies with federal and state requirements.
-------
5 9 0043
ft is for these reasons that the GAEPD agrees with EPA's proposed ROD amendment.
If we can be of further assistance to you please contat Norman R. Woodbum at (404)
656-7802.
Sincerely,
Charles D. Williams
Unit Coordinator
Hazardous Waste Management Branch
File: Marzone/Chevron
n norman\a.godfrey
------- |