PB97-964022
EPA/541/R-97/188
January 1998
EPA Superfund
Record of Decision:
Newsom Brothers/Old Reichhold
Chemicals, OU 2
Columbia, MS
8/8/1997
-------
DECLARATION FOR THE
RECORD OF DECISION
SITE NAME AND LOCATION
5 9 0003
Brothers Site - Operable Unit 2 (North Pond)
Columbia, Mississippi
STATEMENT OF BASIS AND PURPOSE
This Record of Decision (ROD) presents the selected response
action for Operable Unit 2 (OU2) at the Newsom Brothers Site
(Site) in Columbia, Mississippi. This remedy for the Site was
chosen 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 the National
Contingency Plan (NCP) , 40 CFR Part 300. This decision is based
on the administrative record file for this Site.
In accordance with 40 CFR 300.430, the State of Mississippi,
as represented by the Mississippi Department of Environmental
Quality (MDEQ) , has been the support agency during the Remedial
Investigation for Operable Unit 2 (OU2 RI) at the Site. The
Environmental Protection Agency (EPA) has received a formal
letter of concurrence from MDEQ.
DESCRIPTION OF THE SELECTED REMEDY
.:.:•.. r .1. ....pL.^s to the groundwater contamination and
subsurface soil contamination beneath the North Pond areas which
constitutes OU2 of the Site. Contaminated soils and sediments
were removed from the Site as part of the remedial action for
Operable Unit 1 (OU1) and the source for groundwater
contamination therefore no longer exists at the Site. The
groundwater at OU2 wa_s thoroughly characterized during the OU2
Remedial Investigation (RI) . Sampling revealed only sporadic,
isolated.:.sample* results in exceedance of any health-based Maximum
Contaminant Levels (MCLS) , and no discernable plume can be
identified. Those MCL exceedances occurred only within the
boundaries of OU2 or in the immediate vicinity of OU2, and
sampling establishes that contamination has not migrated outside
that area. There is no current on-site exposure pathway because
the contaminated soil has been removed and the Site is serviced
by the municipal water supply. There is no current off -site
exposure pathway for .the -groundwater because groundwater
contamination has not migrated off -site. Finally, there is no
future exposure pathway for the groundwater because there is no
evidence that the limited groundwater contamination is migrating,
because the entire area is serviced by the municipal water
supply, and because future installation of private water supply
wells "is unrealistic. Because of the limited and sporadic nature
of the groundwater contamination and because no exposure pathway
-------
5 9 0004
exists, EPA has determined that no remedial action is required to
address OU2. However, to further ensure that Site conditions
remain constant, EPA will initiate a three year grcundwater
monitoring plan.
EPA will require quarterly monitoring during the first year and
semi-annual monitoring dur.ng years two and three.
- If groundwater monitoring indicates that the Site po~es a
threat to human health or the environment, EPA, in consultation
with the State of Mississippi, will reconsider the feasibility of
groundwater remediation. If the groundwater monitoring indicates
that the Site no longer presents a threat to human health and the
environment, monitoring will terminate after the three year
period. -
DECLARATION STATEMENT
Based on the results of the OU2 RI and Risk Assessment
conducted for OU2, EPA has decided that no action with monitoring
is necessary to protect human health and the environment. £PA
plans no further response actions at the Site unless the
groundwater monitc. .ng indicates the presence o^ contaminants
remaining onsite above health based levels. EPA has determined
that with the exception of supplemental groundwater monitoring,
its response at this Site is complete.
Richard D.- Green, Acting Director- - Date
Waste Management Division
-------
5 9 0005
RECORD OF DECISION
Summary of Remedial Alternative Selection
NEWSOM BROTHERS SITE
Columbia, Mississippi
Prepared by:
U.S. Environmental Protection Agency
Region 4
Atlanta, Georgia
-------
5 9 0006
TABLE OF CONTENTS
1. 0 Site Name, Location and Description 1
'2.0 Site History and Enforcement -
3.0 Highlights of Community Participation 5
4 .0 Summary of Site Characteristics 6
4.1 Site Geology/Hydrogeology '. .6
4.2 Remedial Investigation and Groundwater Monitoring 7
5 . 0 Summary of Site Risks 10
5 .1 Contaminants of Concern 14
5 . 2 Exposure Assessment , 14
5 . 3 Toxicity Assessment 15
5.4 Risk Characterization 17
6 . 0 Environmental Assessment 19
7 . 0 Description of Alternatives 19
7.1 Alternative No. 1 - No Action 19
7.2 Alternative No. 2 - No Action with Monitoring 20
8.0 Summary of Comparative Analysis of Alternatives 20
8.1 Overall Protection of Human Health and the Env 21
8 . 2 Compliance with ARARs "n
8.3 Long-Term Effectiveness and Permanence -_
8.4 Toxicity/Mobility /Volume Reduction 22
8 .5 Short-term Effectiveness 22
8 . 6 Implement ability .."..: . ."."." . . 22
8.7 Cost 22
8 . 8 State Acceptance 22
8 . 9 Community Acceptance ^- ."..'. -"23
9 . 0 Monitoring Plan 23
10.0 Explanation of Significant Changes 23
-Appendix A - Responsiveness Summary. . 25
-------
5 9 0007
LIST OF FIGURES AND TABLES ;
Figure 1 Site Location Map 2
Figure 2 Site Layout Map 3
Figure 3 Direction of Groundwater Flow 8
Figure 4 Monitor Well Locations Operable Unit #2 9
Table 1 Shallow Groundwater Zone Monitor Wells 11
Table 2 Deep Groundwater Zone Monitor Wells 12
Table 3 Newsom Brothers Analytical Data - March 12, 1996 13
Table 4 Summary of Potein_ial Future Exposure Pathways 16
Figure 5 Groundwater Monitor Well Locations - OU2 24
-------
5 9 0008
DECISION SUMMARY FOR THE RECORD OF DECISION
OPERABLE UNIT TWO (OU2) NEWSOM BROTHERS SITE
COLUMBIA, MISSISSIPPI
1.0- SITE NAME. LOCATION. AND DESCRIPTION
The Newsom Brothers Site (Site) is located in Columbia,
Marion County, Mississippi (Fig 1). The 81-acre Site is
surrounded by residential neighborhoods which, in some cases, are
located directly adjacent to the Site boundaries. There are
numerous businesses located along High School Avenue which
borders the western boundary of the Site. The Site is completely
fenced and .access to the Site is restricted.
The North Pond Area is located in the northeast corner of
the Site adjacent to the Site boundary near Chinaberry Street
(Figure 2). The North Pond Area is completely fenced and marked.
No structures ar^ located within the North Pond Area and the
ground is covered with thick vegetation.
2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES
The Site was used for industrial 2r.d commercial activities
for over 50 years. From the early 1930s until 1943, J.J. White
Lumber Company operated a sawmill on t"he Site. The Southern
Naval Stores Company, Limited, c; •:.••.•.;.;;.;'.;«ciy ran an operation,
called Naval Store;, _. ..___•... •.::•.. : • :.- .^e, from 1936 to
1951. Naval Stores produced wood derivatives such as resin,
turpentine, pine oil, and tall oil. ll-.e ov.nership and operation
of Naval Stores changed several times between 1936 and 1951, -but
the plant consistently produced the same wood-derived products .
From the 1950s until 1965, the Site was owned and operated by
Leach Brothers, Incorporated. - Reasor Chemical Corporation owned
the Site from 1965 to 1972, and Chem-Pro International Inc. owned
it from 1972 to 1974.
Southern Naval Stores Company, Reasor Chemical Corporation,
and Chem-Pro International ran similar production processes.
These processes involved grinding .pine stumps and digesting them
with a boiling liquor of sodium hydroxide and sodium sulfite.
The products were tall oils, which are 35 to 40 percent resin and
50 to 60 percent fatty acids. Turpentine was also extracted from
the pine stumps using naptha. —In addition, Reasor Chemical
Corporation specifically manufactured calcium and zinc resinates,
polymerized resin, and rubber resins.
-------
5 9 0009
II
SITE LOCATION MAP
NEWSOM BROTHERS SITE
COLUMBIA, MISSISSIPPI
MALCOLM PIRNIE. tN<
FIGURE 1
-------
5 9 QDA
PearJ
.
*^_ Builds
t
£
•kj "*»
" 6
St.
1
_J
1'
V
%
OPERABLE
UNIT No
OU2 SOIL
STOCKPILES
'
-------
In January 1975, Reichhold Chemicals, Inc., (Reichttold)" 0 ' 7
purchased the property. Reichhold's operation included mixing
pentachlorophenol (PCP) with diesel oil. The PCP and diesel oil
were mixed and heated using Dowtherm as a heat transfer medium.
In other operations, boron trifluoride was mixed with phenol and
di-isobutylene to form octal phenol resin. Xylenes were also
used in a number of processe;.
- Reichhold continued operations at the property until NL-.rch
1977, when an explosion and fire in one of the boiler units
destroyed most of the processing facility. No operations were
conducted at the Site from 1977 to 1980. During this time the
Site was secured behind a locked gate.
In 1980 and 1981, ownership of the 81-acre Site transferred
to R.R. Newsom, Sr. and R.R. Newsom, Jr. (owners of New-Cros
Construction Company) and Mr. William Earl Stogner (owner of
Stogner Trucking Company). The Newsoms' owned 49 acres of the
original 81 acres and Mr. Stogner owned the remaining 32 acres.
Both Stogner and the Newsoms had buildings on the property from
*/hich they operated their respective trucking and construction
businesses. In November 1988, Reichhold regained complete
ownership of the Sit in connection with resoluti, n of legal
proceedings brought by Mr. Stogner and the Newsoms.
The Site was listed on the National Priorities List (NPL) in
198£, ar.r3. an initial Record of Decision was signed on
Sepi-emb*»r 18, 1989 (1989 ROD) . A detailed history of the Site is
presented in the Phase I and Phase II Remedial Investigation
Rep-'iLt -uiteu September 21, 1987, and November 8, 1988,
:•••:•-•--:-.••- :y. ir.- readability Study was completed in December of
1988. P«=>medial activities specified in the 1989 ROD included:
* Removal of asbestos-containing material;
* Removal of above ground and underground storage tanks;
* Excavation of contaminated soils for offsite disposal;
* Excavation of black tar-like waste material (BTM) for
off-site thermal destruction and disposal;
* Drainage of on-site ponds, and excavation of contaminated
sediments for off-site disposal at an approved facility;
and
* Groundwater monitoring and actions to prevent erosion.
The on-site ponds were drained and the contaminated
sediments recovered. After the removal action,
post-remediation verification sampling (PRVS) confirmed that the
upper 1 to 2 feet of soil in-the bottom of the ponds had been
cleaned to the criteria specified in the 1989 ROD. Reichhold
placed clean topsoil on the banks of the ponds and recontoured to
prevent erosion. Approximately one foot of clean fill was placed
-------
5 9 0012
in the center portion of the ponds to fill in the low areas.
Substantial completion of remedial activities under the 1989 ROD
was achieved for all areas in September 1993. '•
In the final stages of remedial activities under the 1989
ROD, potential contamination not previously identified was
discovered i,. the North Pond area. Appro^xmately 3,000 cubi^
yards of potentially contaminated materials were removed from an
area' immediately north of the North Pond and stockpiled onsite
near the Double Gable Warehouse. During excavation of these
materials, suspected contamination extending below the bottom of
the pond into the groundwater was observed. In order to address
the stockpiled excavated materials and the potential for
groundwater contamination at the North Pond, the United States
Environmental Protection Agency (USEPA) designated this area as a
separate unit. Operable Unit Number 2 (OU2).
•*.
The material was sampled along with the OU2 groundwater and
assessed for disposal purposes. RCRA characterization of the
stockpiled material indicated that it was not a RCRA hazardous
waste. In October 1995, these stockpiled materials were removed
from the Site and taken to an approved facility for disposal.
This action was conducted in the same manner as actions under the
1989 ROD.
3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION
The Site has always been of interest to the communities
surrounding the Site. EPA has been involved directly with the
community since the Site's inclusion on the NPL in 1986. Several
we.j.-attended public meetings have been conducted for the Site.
The community has always had significant input into any action
EPA has taken at the Site. At one time the Agency for Toxic
Substances and Disease Registry MATSDR) was actively -involved in
the Site. However, at the time, the community did not accept the
plan ATSDR had asserl^led. ATSDR ceased involvement at the Site
because these differences could -not be resplved. -. - ;—
Several community groups have formed to represent concerned
citizens over the years. The most recent group is the Jesus
People Against Pollution (JPAP). JPAP formed in 1992. JPAP has
been an active participant in the Site ever sincer and currently
is the only active group around the site. JPAF has also been
awarded the Technical Assistance Grant (TAG) for the Site. The
Pearl River Valley Coalition centered in Southeast Louisiana has
shown interest in the Site recently because of concern for impact
on the Pearl River. .JPAP has been involved in a Public Health
Service/EPA project on medical assistance for communities.
For the OU2 Proposed Plan, EPA published full page notices
-------
5 9 0013
in the Columbian Progress on May 23 and June 13, 1996. EPA also
published notice of the availability of the Proposed Plan and the
administrative record and the public meeting in the Hattiesburp
American on May 21 and June 16, 1996. About 60 people attended
the June 18, 1996, EPA Proposed Plan Public Meeting held at the
Columbia High School auditorium. EPA received comments from JPAP
on the OU2 Proposed Plan.
4.0- SUMMARY OF SITE CHARACTERISTICS
4.1 SITE GEOLOGY/HYDROGEOLOGY
The Site is located in Marion County, Mississippi, within
the Coastal Plain Province, which is a thick blanket of
southwestward sloping sediments. In Marion County, these
sediments are greater than 30,000 feet thick with a thick deposit
of salt near the base of the sediments. Above the salt bed is a
varying sequence of sandstones, shales, clays, and limestones
that extend upward to the surface.
The Cahaba, Guyton, and Stough soil series are naturally
occurring soils which have been identified by the Soil Survey of
Marion County, Mississippi (SCS, 1985) to be typical of the
Columbia area. These soils are representative of the Pearl River
basin. Only the Guyton soil series is present in OU2. The
Guyton series is, generally, a poorly drained, silty material,
typically found on flood plains and stream terraces.
The stratigraphic sequence in Marion County is divided into
(from oldest to youngest) the Catahoula Sandstone, the
Hattiesburg Formation, the Pascagoula Formation and the Graham
Ferry Formation. These sediments consist of intermittent sand
and clay layers and are very difficult to distinguish on the
basis of lithologic character; therefore, they have been grouped
together as the Miocene aquifer system.
The occurrence of fresh groundwater in Marion County is
limited to the upper 150 feet of sediments.'" The major aquifers
in the fresh water zone occur in the Miocene and younger
sediments. Groundwater is the sole supply for both industrial
and potable water in the Columbia area.
This shallow aquifer system at the Site is an alluvial
aquifer. The lithology is composed mostly of fine to medium
grained, quartz sands inter-bedded with layers and lenses of clay
and gravel. The alluvial deposit is 149 feet thick and underlain
by a layer of dense clay of low -permeability. "The clay appears
to be laterally consistent beneath the Site and is believed to
confine and protect the underlying Miocene aquifer.
-------
5 9 0014
The lithology found in the top twenty feet at OU2 consists
of topsoil, fill material, sand and clay. The top layer is
approximately four feet thick containing a mixture of' topsoil,
fill and clay. This layer is underlain by approximately nine
feet of a dry, plastic clay, followed by seven to .ten feet of a
white angular sand. According to gamma ray logs on existing
monitoring wells completed on-site as part of OU1, the clay layer
at approximately 16 feet below the ground surface is consistent
throughout the Site. The permeability test run on the
undisturbed clay samples shows a permeability rate of 10"9 to 10"10
cm/sec, which limits the downward migration of the contaminants
into the "aaep" alluvial aquifer.
Groundwater flow across the Site is in a west-southwestward
direction toward the Pearl River Basin. VJater levels were
observed across the Site and contoured. Figure 3 illustrates the
direction o£ groundwater flow. The average depth to water ranges
between 10 to 15 feet below ground surface (bgs) and fluctuates
as much as three feet due tc the surficial recharge effects of
r^asonal precipit:tion. The shallowest portion of the reworked
alluvial deposit contains the shallow saturated zone of OU2.
Data collected during remedial activities indicate that the North
Pond and other on-site ponds contribute to the direct recharge of
the alluvial aquifer at the Site.
4.2 REMEDIAL INVESTIGATION AND GROUNDWATER MONITORING OF OU 2
The Remedial Investigation for OU2 (OU2 RI) was completed in
February of 1995. The scope of the OU2 RI was to determine the
extent of the groundwater contamination at the Site and to
determine if any contaminated soils remained in the North Ponu
area. The stockpiled soils were also sampled to assist in
determining how to address the material. However, the primary
focus of the OU2 "RI was to determine the extent of the "
groundwater contamination at the Site.
Soils in the North Pond area and soil^ stockpiled on-site
were sampled during the OU2 RI using field 'immunoassay testing
and test trench sampling. Analysis indicated the presence of
both organic and inorganic compounds. However, the
concentrations were below action levels established in the 1989
ROD.
Groundwater investigations for OU2 consisted of hydropunch
sampling, extraction well sampling and the sampling of monitoring
wells MW-28, MW-38, MW-39 and MW-40 (Figure 4). The intent of
the "hydropunch sampling was to~~screen the water table and assist
in the placement of permanent monitoring wells and an extraction
well if necessary. Ten volatile organic compounds (VOCs), 17
semi-volatile organic compounds and 21 inorganic elements were
-------
5 9 0015
MONITOR WELLS WiTH
-GROUNDWATER ELEVATION'
in
a-
~ i
r
>\
MAimM
1
'JK wUNIUUKINU -^
GROUNDWATER CONTOUR
1 FOOT INTERVAL
DIRECTION OF FLOW ARROW
DIRECTION OF GROUNDWATER
IN SHALLOW ZONE — MAY 7.
NEWSOM BROTHERS SITE
COLUMBIA, MISSISSIPPI
Sv^ L
•^ ' -L
i
FLOW MALCOLM =IRN|£ *INC
iys=>fc>
FIGURE 3
-------
3704 i 1195lfc5000\l'\RtlCII\NB -008B SCALE' l*OU 01/19, 1995 at ll>48
Ji Jj
> hiliioi • - IM ^^ NX
\ \. . v\\
•»•'/
200 100 0
SCALE IN MET
! LEGEND
Slit PROPERIY LINE
MW-33B EXISTING MONITOR WELL LOCATION
GRAVEL ROADS.
i i
BOUNDARY OF
OPERABLE UNIT No. 2
COPYRIOIIl (C) 1985
MALCOLM. _P!RHILJWL.
NEWSOM BROTHERS SITE
MONITOR WELL LOCATIONS
FIGURE 4
COLUMBIA. MISSISSIPPI
OPERARLF: UNIT NUMRER ?.
-------
5 9 0077
detected in the groundwater at the Site. Only PCP (60 ppb) , '
naphthalene (10 ppb), ethylbenzene (150 ppb) and total xylene
(500 ppb) were detected during the OU2 RI and only the PCP
concentration in MW-28 exceeded the Maximum Contaminant Levels
(MCLs). However, these substances were detected only in certain
well? and only during certain sampling events during the OU2 RI.
Therefore, the OU2 RI sampling results do not demonstrate a
likely plume of cor*amination in the North Pond Area. The source
of whatever limited contamination that may be present appears to
have been the stockpiled soils which were excavated from the
North Pond.
Several sampling events have occurred since the completion
of the OU2 RI. As part of the groundwater monitoring plan
under the 1989 ROD, a network of wells are sampled on a
semiannual basis. During the November 1995 sampling event, two
of the sampled wells indicated the presence of PCP. These wells
were MW-19 (3.2 ug/1) and MW-37 (4 ug/1). Monitoring well 19 is
located approximately 1200 feet southwest of the North Pond and
monitoring well 37 is located approximately 100 feet southeast of
the North Pond. These same wells have been sampled on numerous
occasions during the monitoring period. In all other quarterly
and semi-annual monitoring events, the sampled wells had
concentrations below the MCLs or non detect (See Tables 1 and 2).
To ensure Site conditions were consistent with the OU2 RI,
EPA conducted an in house round of monitoring well sampling of
six onsite wells including MW-19 and MW-37. The sampling was
conducted in March of 1996 and the results did not indicate the
presence of PCP or any other organic compounds at significant
concentrations. Based on these sample results and this absence
of PCP contamination, EPA believes that the analytical results
from the November 1995 groundwater monitoring event indicating
the presence of PCP were anomalies and do not correctly represent
the actual site picture. Results of this sampling event are
displayed in Table 3.
5.0 SUMMARY OF SITE RISKS
A Baseline Risk Assessment was conducted by Reichhold with
EPA oversight as part of the OU2 RI to estimate the health or
environmental threats that could result if no further action were
taken at the Site. Results are contained in the Final Baseline
Risk Assessment Report and Addendum to the Baseline Risk
Assessment. A Baseline Risk Assessment represents an evaluation
of the risk posed if no remedial action is taken. The assessment
considers environmental media and exposure pathways that could
result in unacceptable levels of exposure now or in the
foreseeable future. Data collected and analyzed during the OU2
RI provided the basis for the risk evaluation. The risk
10 '
-------
i TABLE 1
SHALLOW GROUNDWATER ZONl MONITOR WELLS
NOVEMBER 1996 SEMI-ANNUAL SAMPLING EVENT
I REICHHOLD CHEMICALS. INC., NEWSOM BROTHIKS SITE, COLUMBIA. MISSISSIPPI
PCP CONCENTRATIONS (MR/I)
Weil ID
OWPS
MW-15
MW-17
MW-19
MW-25R
MW-27
MW-29
MW-31
MW-32
MW-33
MW-34
MW-35
MW-S6
February 1994
1
IU
IU.IOU
IU
IU
IU
IU
IU
IU
IU
IU
IU
IU
May 1994
1
IU.1U*
IU
IU
IU
IU
IU
IU
IU.IOU
• «u
IU
IU.IOU
, iu
AURUII 199-1
1
IU. IU.IOU
IU.IOU
IU
IU
NA
NA
IU
NA
NA
NA
IU
IU
November 1994
1
IU.NA
IU.NA
_/ IU.IOU
IU
NA
NA
IU.NA
NA
NA
NA
IU. IU*
1.2
M:IV 1995
1
IU
IU
IU
IU
KA
MA
n
l-\
NA
NA
IU
IU
November 1995
1
IU
IU
IU. J.;.IU
IU
NA
NA
IU. IU
NA
NA
NA
IU
IU
March 1996
1
NA
20U.NA.4U
20U.IU.4U
NA
NA
NA
NA
NA
20U.1U.NA
20U, NA, NA
NA
NA
May 1996
1
IU
IU
IU
IU
NA
NA
IU
NA
NA
NA
•• tu
IU
November 1996
1
IU
'IU
IU
IU
NA
NA
IU
NA
NA
NA
IU
IU
Review "Gcncfiil Notes" .*
i '
told llaliciitd values indicate contaminant concentrations were detected above the
tcsulw indicated for the November 1995 larttplingevent for MW-19 represent (I) Rcichhold1 analysis results. (2) MDEQ split sample result by the GC/MS mctliod;
md (3) o second MDUQ snmplc result by the electron capturc/GC method. ,
rABLE6ENDNOTES: i '
' * /85
=» 7
Jumbcr of samples onul
Dumber of "Delects" above CRDL including estimated values
dumber of "Delects" nbovc OWPS
Cn
vo
o
o
CD
11
-------
TABLE 2
DEEP GROUNDWATER ZONE MONITOR WELLS
NOVEMBER 1996 SEMI-ANNUAL SAMPLING EVENT
REICHHOLD CHEMICALS. INC., NEWSOM BROTHERS SITE, COLUMBIA, MISSISSIPPI
PCP CONCENTRATIONS (UR/|)
Well ID
GWPS
MW-OI
MW-02
MW-16
MW-18
MW-20
MW-26
MW-30
MW-J1
February 1994'
,1
IU, IOU
IU
IU. IU«
IU
IU
IU
IU
IU. IU'
Miy 1994
\
IU
IU
IU
IU
IU. IU»
IU
IU
,IU. W
AURUJI 199-4
1
NA
NA
IU
IU
IU. IU*
IU
NA
IU
November 199-1
1
NA
NA
IU
IU
IU
IU. !U. H 1
NA
IU
May 1995
1
NA
NA
:u
IJ
IU
!i.l
I-A
IU
November 1995
1
NA
NA
IU
IU
IU
IU
NA
•*. IU.IU
Mnrch 1996
1
NA
20U, NA. NA
NA
NA
NA
NA
NA
20U. IU.NA
Mny 1996
1
NA
NA
IU
IU
IU
IU
NA
IU
November 1996
1
NA
• NA
NA
IU
IU
IU
NA
IU
I
.cvjew "General Noics".
:olil iialiclieil values indicate contaminant concentrations were delected nbovc the QwPS.
'.csulis indicated for tlic November 1995 sampling even! lor MW-37 represent (I) Rcic'' M n ly;i n ;.iliv. (2) MDEQ split sample result by the GC/MS method,
nd ()) o second MDOQ sample result by the electron ciipturu/GC mctbod.i
i
ABLE I6ENDNOTES:
'umber of samples analyzed
.'umber of'Dclccis" obovc CRDL including cslimutcd values
.'umber of "Detects* above G WPS ;
53
; I
' I
cn
12
O
O
-------
T/uiLt J
NEWSOM BROTHERS
ANALYTICAL DATA SUMMARY
MARCH l'2. 1996
5 9 0020
MW-02 MW-17S MW-19 MW-33 MW-34 MW-37
INORGANIC ELEMENT
Aluminum
Barium .
Cobalt
Chromium
Copper
Manganese
Strontium •
Titanium
Vanadium
Ytrium
Zinc
PURGEARI F ORHANICS
Toluene
MISCELLANEOUS
PURGEABLE ORGANICS
Isopropylbenzenc
P-lsopropyltoluene
1 ,2.4-Trimethylbenzene
Unidentified Terpene
Pentachlorophenol
J/O/I (JQt\ A'O/l A'O/I T-'O/I //O/l
3.800 530 1.900 260 3,400 940
75 380 110 110 80 31
9.9
23 14 12 - 10 -
9.6 - -
59 2.700 930 970 400 11
26 210 99 220 52 23
37 23 15 '- 24 13
49 12 -- 7.6
6.6 44 30 -- 7.5
14 35 27 -- 11
von Mn pa* PO/I ^/i
12A -- •- 6.1
i/0/1 PQ/1 //Q/l (JQn //g/I A/g/1
0.78AJ
0.78AJ -" -
.. _ _ •-.. T.2
200JN - • -
"" ™ ™
— --.—.-.
•
Footnotes:
- - Bemeru «n«lYzed (or but not detected
A - Averaged Value
J • Ectimated Value
N - Presumptive Evidence of pretence of material
13
-------
5 9 0021
assessment process can be divided into four components:
contaminant identification, exposure assessment, toxicity
assessment, and risk characterization.
5 .1 CONTAMINANTS OF CONCERN
The objective of contaminant identification is to screen the
information that is available on hazardous substances present at
the -Site and to identify contaminants of concern (COCs) in order
to focus subsequent efforts in the risk assessment process.
COCs are selected based upon their toxicological properties,
concentrations and frequency of occurrence at the Site.
The EPA required Reichhold to select chemicals of potential
concern (COPC) using the following two criteria:
1 . Screen the maximum concentrations of chemicals in all
media against risk based values derived from Region 3's Risk
Based Screening Tables by using a cancer risk of 10~6 and a
hazard quotient oo. 1.0. Select chemicals which exceed these
values .
2. Compare the inorganic chemicals to a value of two times
the average background concentrations for that chemical .
Using these two criteria, the list of Chemicals of Potential
Concern was reduced to the following chemicals:
SUBSURFACE SOIL GROTJNDWATBR
Volatiles: Volatiles :
. -McL-.j inaphthalene ~ Benzene
Pentaohlorophenol Ethylbenzene
Fhenanthrene , Xylenes (total)
Semi Volatiles:
_ t 2-Methylnaphthalene
__ fentachlorophenol
Phenanthrene
Inorganics :
Arsenic
Manganese
5.2 EXPOSURE ASSESSMENT
An exposure assessment was. conducted to estimate the
magnitude of exposure to the contaminants of concern at the Site
and the pathways through which these exposures could occur. The
results of this veyppsu^e assessment are combined with chemical-
specific toxicity information to characterize potential risks .
14
-------
5 9 0022
Groundwater and soil provide the only potential pathways.
Scenarios were developed for human exposure to the soil and
groundwater. These scenarios included possible current routes of
exposure and potential future routes of exposure.
At the time of the Baseline Risk Assessment, the stockpiled
soils on-site had not been removed. However, in October of 1995,
these soils were removed from the Site. This action has a
significant impact on the Exposure Assessment. Since the
stockpiled soil was the only potential threat in the current
scenario, the entire current scenario is eliminated. The future
scenario includes only the potential effects caused by the
uncontrolled groundwater migration to off-site residential wells
located downgradient from the Site. Any future on-site exposure
pathway is incomplete because there are no receptors. The Site
is wholly owned by Reichhold and its access is restricted. All
onsite water is supplied by the City of Columbia water system. A
summary of the potential future exposure pathways is included as
Table 4.
No municipal or private drinking water wells are located
offcite in the dircrtion of the groundwater migration at the
Site. If groundwater continued to migrate in the current
south/southwestern direction, and crossed the Site boundary, it
would seep into the Pearl River before contacting any water
supply wells. The entire area is serviced and supplied by the
City of Columbia municipal water system. Also, the installation
of a private well is not economically viable due to the
availability of city water, the well installation costs and the
additional costs of maintaining a well completed in an aquifer
containing elevated concentrations of naturally occurring
calcium, iron, manganese and sodium.
This scenario was included in the baseline risk assessment
as a theoretical exercise to meet EPA requirements and would only
be realistic if additional water supply wells were reasonably
expected to be established offsite in the tiirection of
groundwater flow. As discussed in the preceding paragraphs,
sampling does not confirm the existence of any plume of
contamination and the likelihood of additional potable water
supply wells being established in the area of the Site is very
low. Therefore, future off-site groundwater is not a complete
pathway and no complete pathways-exist at this Site. ...
5.3 TQXICTTY ASSESSMENT
The purpose of a toxicity assessment is to weigh available
evidence regarding the potential of the contaminants of concern
to cause adverse effects in exposed individuals and to provide an
estimate of the relationship between the extent of exposure and
15
-------
5 9 0023
TABLE 4
SUMMARY OF POTENTIAL FUTURE EXPOSURE PATHWAYS
Potentially
Exposed
Population
Exposure Routes, Medium and
Exposure Point
Reason for Selection
OFF-SHE
RESIDENTS
Ingestion of groundwater from wells
located downgradient from site.
Wells could be located within
contaminated area in the future if
contaminated groundwater migrates off-
site.
Dermal contact with groundwater from
wells located downgradient from site.
Wells couid be located within
contaminated area in the future if
contaminated groundwater migrates off-
site.
Inhalation of chemicals volatilized from
groundwater during home use.
Wells could be located within
contaminated area in the future if
contaminated groundwater migrates off-
site.
16
-------
5 9 0024
the likelihood of adverse effects. The toxicity assessment is
based on toxicity values which have been derived from'
quantitative dose-response information. Toxicity values for
cancer are known as slope factors (SFs) and those determined for
noncarcinogenic effects are referred to as reference doses
(RfDs). "
Slope factors {SFs), which are also known as cancer potency
factors (CPFs), have been developed by EPA's Carcinogenic
Assessment Group for estimating excess lifetime cancer risks
associated with exposure to potentially carcinogenic chemicals.
SFs, which are expressed in units of (ing/kg-day)'1, are
multiplied by the estimated intake of a potential carcinogen, in
mg/kg-day, to provide an upper-bound estimate of the excess
lifetime cancer risk associated with exposure at that intake
level. The term "upper-bound" reflects the conservative estimate
of the risks calculated from the SF. Use of this approach makes
underestimation of the actual cancer risk highly unlikely. SFs
are derived from the re? ilts of human epidemiological studies or
chronic animal bioassays to which animal-to-human extrapolation
and uncertainty factors have been applied. Cancer slope factors
for the potential contaminants of concern may be foun. in Tables
4-5 and 4-6 of the Baseline Risk Assessment.
Reference doses (RfDs) have been developed by EPA for
indicating the potential for adverse health effects from exposure
to chemicals exhibiting noncarcinogenic effects. RfDs, which are
expressed in units of mg/kg-day, are estimates of lifetime daily
exposure levels for humans, including sensitive individuals.
Estimated intakes of chemicals from environmental media (f* T . 1~~~°
amount of a chemical ingested from contaminated drinking water)
can be compared to the RfD. RfDs are derived from human
epidemiological studies or animal studies to which uncertainty
factors have been applied (e.g. to account for the use of animal
data to predict effects on humans). These uncertainty factors
help ensure that the RfDs will not underestimate the potential -
for adverse noncarcinogenic effects to occur. Reference doses
for the potential contaminants of concern may be found in Tables
4-1 and 4-2 of the Baseline Risk Assessment.
5.4 RISK CHARACTERIZATION
In this final stage of the risk assessment, the results of
the exposure and toxicity assessments are combined to provide
numerical estimates of the carcinogenic and non-carcinogenic
risks for the Site. In order to characterize potential
noncarcinogenic effects, estimated intake levels are compared
with toxicity values. Potential concern for noncarcinogenic
effects of a single contaminant in a single medium is expressed
-as the Hazard Quotient (HQ) (or the ratio of the estimated intake
if
17
-------
5 9 0025
derived from the contaminant concentration in a given .medium to
the contaminant's reference dose). A HQ exceeding unity (1.0)
indicates a potential for Site-related noncarcinogenic health
effects. By adding the HQs for all contaminants within a medium
or across all media to which a given population may be reasonably
expc: jd, the Hazard Index (HI) can be generated. The HI prov^es
a useful reference point for gauging the potential significance
of multiple contami. ant exposures within a single medium or
across media.
The total hazard indices would exceed 1.0 for the future
off-site resident scenario exposure to groundwater for both
adults and children if a complete pathway existed. The HI for
the adult scenario would be 1.73E+1 and the HI for the child
scenario would be 3.32E+1 if a complete pathway existed.
The primary contaminants driving these values were Arsenic
and Manganese. Arsenic was detected at levels below the MCL
onsite and both Arsenic and Manganese are elements which are
naturally occurring at elevated levels in the Columbia area.
Furthermore, Manganese is not related to past site activities and
manufacturing processes. Without these two contaminants the HI
for the adult scenario is below 1.0 and the HI for the Child
Scenario is below 3.0.
Excess lifetime cancer risks are determined by multiplying
the intake level with the slope factor. These risks are
probabilities that are generally expressed in scientific notation
(e.g. IxlO"6 or 1E-6) . An excess lifetime cancer risk of 1E-6
indicates that, as a plausible upper b^md, an •i^nivi'iM'U h^p »
one in a million chance of developing cancer, ovei - '. - ye-r
lifetime, as a result of site-related exposure tc c. c-.rcinrgen.
The NCP states that sites should t>e remediated to chemical
concentrations that correspond to an upper^bound lifetime cancer
risk to an individual not exceeding 10 to 10"4 excess lifetime
risk. Carcinogenic risk levels that exceed this range indicate
the need for performing remedial action at'-a site.
COPES that contributed significantly to pathways with cancer
risks that exceed IxlO"4 (1E-4) were selected as chemicals of
concern (COCs). Assuming that a complete future off-site pathway
existed, both the Off-Site Adult Resident Exposure Cancer Risk
Scenario and the Off-Site Child Resident Cancer Risk Scenario
would have cancer risk levels below 8.5E-4. In both cases the
only element of concern would be Arsenic which was found below
the MCL onsite and is a naturally-occurring element found at
elevated levels in the Columbia area.
18
-------
5 9 0026
6.0 ENVIRONMENTAL ASSESSMENT (EA)
The environmental assessment (EA), also known as the
ecological assessment, is a "qualitative and/or quantitative
appraisal of the actual or potential effects of a -hazardous waste
site on plants and animals other than people end domesticated
species." Environmental receptors that are expected to inhabit
the study area were identified during the OU2 RI.
The dominant vegetation type in the site area is southern
pinelands, typified by longleaf, loblolly, shortleaf and slash
pines intermixed with oaks and hickories. An ecological
investigation conducted in 1991 identified that the Site, in
general, is the home of wildlife usually found in woodlands,
riverbanks and swamps. A variety of animals and
vegetation were found to inhabit the Site. Among these were
approximately 50 species of birds, fish, reptiles and amphibians,
many types of insects, and a variety of vegetation. Two species
classified by the state as threatened and by the Federal
government as endangered are known to occur in Marion County 'CDM
1989). These are the ringed sawback turtle (Graptemys oculifera)
and the gopher torto. -. (Gopherus polyphemus). No -ightings of
these species have been reported at the Site.
The constituents of potential concern for subsurface soil
are: ethylbenzene, total xylenes, pentachlorophenol, aluminum and
iron. Although these constituentr exceeded toxicity values for
laboratory species, the potential risk from their presence in
subsurface soil is negligible. The North Pond area does not
represent quality habit-^t* f«"»r f*»t r «piri ial ^oeci^s, and since the
pond collects wate^ zo±^o»^r*£ id^:. events, it is very unlikely
that terrestrial wildlife would Jr:rrov: intc the soils at the
bottom of the pond. Therefore, concentrations of contaminants in
the subsurface soils of the North Pond do not represent a
significant risk to the ecology of the area.
«, .... .
7 .0 DESCRIPTION^ OF ALTERNATIVES "X-
Because no complete groundwater pathway exists, no remedial
action is necessary for OU2. For comparison, purposes, however,
a No Action Alternative and a No Action with Monitoring
Alternative are described in this ROD and analyzed under the
criteria used to select remedies." -
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
19
-------
5 9 0027
developed. Under this alternative, EPA would take no further
action at the Site. There is no cost associated with this
alternative since no additional activities would be conducted.
7.2 Alternative No. 2 - No Action With Monitoring
To ensure that possible contaminants will not pose a threat
to off-site residents at the Site, a monitoring well system will
be established at the site. The five well system will operate
for a three year period. The cost of this alternative is
$194,200.
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 remedial alternatives selected
were evaluated using the following nine evaluation criteria:
* Overall protection of human health and the environment.
* Compliance with applicable and/or relevant Federal or State
public health or environmental standards.
* Lony-Leii'i effectiveness and permanence.
* Reduction of toxicity, mobility, or volume of hazardous
substances or contaminants.
,* Short-*-or*" effectiveness, or the impacts a remedy might have
on che community, workers, or the environment during the ...
course of implementing it.
* Implementability, that is, the administrative or technical
capacity to carry out the alternatives.
* 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 are threshold
*»
20
-------
5 9 0028
criteria that must be satisfied in order for an alternative
to be eligible for selection;
(2) Primary Balancing Cri-teria - 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.
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 tecl.nical 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 OU2
alternatives under each of the criteria. A comparison is made
between each of the alternatives for achievement of a specific
criterion.
Threshold Criteria
8.1 Overall Protecripn of Human Health and the Environment
Because no complete pathway exists, both the No Action
Alternative and the No Action with Monitoring Alternative are
protective of human health and the environment. The No Action
with Monitoring alternative provides additional sampling analysis
to ensure that there is no threat posed at the Site.
8 .2 Compliance with ARARs
Both the No Action Alternative and the No Action -with
Monitoring Alternative will comply with Applicable Relevant and
Appropriate Regulations (ARARs). As described in Section 4.2, PCP
was the only compound detected in groundwater at concentrations
exceeding the MCL. In both cases, additional sampling of the PCP
contaminated wells resulted in repeated non-detect results.
Therefore, the MCLS are not exceeded in the current Site
conditions. The No Action with Monitoring Alternative will
ensure that PCP concentrations do not exceed the MCLS in the
future. „
21
-------
5 9 0029
Primary Balancing Criteria
8.3 Long—Term Effectiveness and Permanence
Neither Alternative provides improvement to the Site
conditions other than natural reduction in contaminant levels.
The primary advantage of the No Action with Monitoring
Alternative is the ability to monitor any change in on-site
conditions.
8.4 Toxicify/Mobility/Volume Reduction
Neither alternative would reduce the toxicity, mobility or
volume of on-site contaminants other than reductions attributable
to natural degradation.
8.5 Short-term Effectiveness
The No Action Alternative will have no effect on the Site
conditions in the short-term. The No Action with Monitoring
Alternative will also have no effect on the Site in the short-
term other than identifying any changes to Cl^e conditions.
8.6 Tnvplement ability
Nothing is required to implement the No Action Alternative.
The No Action with Monitoring Alternative will require the
placement of one additional monitoring well and periodic sampling
of a monitoring well system consisting of five wells. All
aspects of this alternative are easily accomplished using
existing and proven technology.
8.7 Cost _ ..__._ . .... ....
The No Action Alternative will not have any cost associated
with it. The cost of the No Action with Monitoring Alternative
is estimated at $194,200. --,_
Modifying Criteria
8.8 State Acceptance
The State of Mississippi, as represented by ±he Mississippi
Department of Environmental Quality (MDEQ), has assisted in the
Superfund process through the review of documents and submittal
of comments. The State has reviewed the proposed plan and
attended the public meeting and concurs with the requirement for
further monitoring.
22
-------
5 9 0030
8.9 Community Acceptance
Based on the comments expressed at the June 18, "1996 Public
Meeting and in the ensuing comment period, the seems more
concerned about Operable Unit 1 and the possible soil
contamination in their neighborhood. EPA received few comments
related to OU2. However, some members of the community do not
believe the Site has been or can be cleaned to a safe level. One
group from outside the community had concerns about site impact
on the Pearl River.
9.0 Monitoring Plan
Although no complete pathway exists and no remedial action
is necessary, EPA believes that additional groundwater monitoring
is appropriate. The proposed groundwater monitoring plan will
consist of five groundwater monitoring wells (MW). Four of the
wells are already in place at the Site. The four existing
monitor wells are MW-28, MW-38, MW-39 and MW-40. The fifth well
will be installed down gradient to MW-28 prior to implementing
the proposed monitoring program. The fifth monitoring well will
be identified as MW 41 as shown on Figure 5. Monitor well MW-41
will be developed one time, 30 days prior to initial monitoring,
to remove any accumulated silt and to ensure that a
representative sample may be collected. A designated bladder
pump will be installed in the well to sample groundwater.
The monitoring program will be conducted over a period of
three years as follows:
* Year 1 Quarterly Sampling
* Year 2 Semi-Annual Sampling
* Year 3 Semi-Annual Sampling
All five wells will be monitored during the three year monitoring
period. Groundwater samples collected during the monitoring
period will be field tested for pH, conductivity and temperature.
Samples collected will be submitted to an off-site laboratory for
analysis according to CLP protocols.
Sample analysis will take approximately four weeks after
sample collection is completed. A report of the sample analysis
results will be prepared for each sampling period and will be
submitted within 45 days of the receipt of analytical results.
10.0 Explanation of Significant Changes — _
There are no significant changes between the proposed plan
and this ROD.
23
-------
c
BuSlis
^ 5
Si
*w
c/\ ^*
\3
V
r
•: ; f
:• f . ,i i
59 0031
— — '
\ \\ ;•!
gVA\ ''
400 200
400
__ .
SCALE IN FEET
LEGEND
STE BOUNDARY LINE
-^ \ ,- .v 1
4F>I
MAUXX-M TONE. t
-------
5 9 0032
RESPONSIVENESS SUMMARY
Newsom Brothers Site
Columbia, Marion County, Mississippi
EPA held a public meeting on June 18, 1996 in Columbia,
Mississippi, to present the proposed remedy to the community and
provide the community with an opportunity to comment on the
proposed remedy. In accordance with the NCP, a 30 day comment
period was provided for written correspondence to be submitted to
EPA. This 30 day comment period was extended by an additional 30
days. This period officially ended on July 23, 1996.
In this responsiveness summary, EPA will respond to
significant comments raised during the public comment period
related to OU2 . Other comments made during the public comment
period will be addressed by the Remedial Project Manager in
separate communications "Tith those individuals who commented.
1. Why are poison signs not posted along perimeter . ' DU2 until
observations show the Site is safe?
1. OU2 is located within the larger boundaries of the entire
Site. The entire facility is fenced with signs posted stating
that the facility is an EPA Super fund site. In addition to the
fencing around the entire Site, OU2 is completely fenced.
2. Is the actual source of the nroundwai-<^r <*<•»•.» ^p>ii:a*-io^ known
and has it been removed from the -.ite;
2. According to past EPA studies, the source of the groundwater
contamination at the North Pond is the previously excavated drums
and sediments located in the North Pond area. Those materials
have been removed from the site. The monitoring required as part
of this remedy should confirm that the source is gone.
3. What about benzene, toluene, ethylbenzene and PCP exceeding
the MCLS in on-site groundwater sampling?
3 . These contaminants were found in groundwater samples
collected -from the North Pond -area -via immunoassay, hydropunch -or
monitoring well samples. However, an actual plume was never
identified and recent groundwater monitoring has indicated a lack
of contamination at the site. :.: ______
25
-------
5 9 0033
Nevertheless, a monitoring program will be established as part of
the remedy for OU2 which will continue to ensure that what
contamination remains under the North Pond is not spreading off-
site.
4. Is the proposed remedy adequately protective of public
health in and around the Site?
4. " Yes, the Baseline Risk Assessment used a protective approach
by acknowledging the fact that the low levels of contaminants
still present onsite are located exclusively beneath the North
Pond. The findings of the risk assessment indicate that the only
threat posed by groundwater is the potential off-site migration
into a potable water supply. As discussed earlier, this is
unrealistic given the site conditions and the City supply of
potable water in the area. Hence, this pathway is not complete.
Nevertheless, a monitoring program will be initiated under the
OU2 ROD which will provide EPA with knowledge of any movement of
contaminants so EPA can require that the proper steps be taken at
that time. Therefore, it is protective of human health and the
environment.
5. Can or will EPA relocate people due to the Site?
5. The groundwater contamination associated with operable unit
two has been found only on the site and residents in the area are
served by municipal wells completed in a deep confined aquifer.
The municipal well locations are upgradient from the site.
Therefore, this does not post? a threat to residents around the
site.
6. Have any contaminants frrm the Site reached the Pearl River?
6. As part of OU1, the tributaries (Jingling Creek) were
sampled to ensure contaminants were not reaching the Pearl River.
No contaminants were detected in those bodies of water.
Contaminated groundwater from OU2 does not^pose a threat to the
Pearl River or it's tributaries because it is confined and seems
to be decreasing.
7. Can groundwater contamination from the North Pond area
possibly get into the municipal water supply lines?
7. Water pressure within municipal water lines is usually very
high due to the amount of pressure required to move the water to
all distribution points servedjpy the system. When a -leak
occurs, water from inside the line will escape the system;
however, due to the water pressure, it is very unlikely to
impossible for groundwater to actually enter the lines. Also,
water supply lines are not located under the North Pond area.
26
-------
5 9 0034
8. Can you clean the Site up?
8. Based on the findings of the Remedial Investigation and the
Baseline Risk Assessment, an actual groundwater plume does not
exist at the site. Also, the limited contaminants located
beneath the North Pond do not pose a significant threat in their
present location. EPA will conduct groundwater monitoring to
determine whether the contaminants are moving to an area whore
they may pose a threat in the future.
9. Would you use the same remedies (no action, and no action
with monitoring) if this Site was surrounded by an affluent white
community?
9. Yes, because there is little room for bias in the decision
process. The data from the Baseline Risk Assessment and OU2 RI
indicate the Site does not pose a threat to the surrounding
communities. These values do not factor income, gender, religion
race or ethnic group. However, separate calculations are done
for children and adult populations.
10. What is going c at the Site now?
10. The only activity ongoing at the site is the groundwater
monitoring for OU1. All planned removal of contaminated
material was completed in October of 1995.
11. Is EPA sure the groundwater under the North Pond is not
miaratincr offsite and affecting the community?
*^. At -.-ic ~xme, the groundwater contamination is not migrating
off-citr. EPA will conduct groundwater monitoring to ensure
groundwater does not migrate off-site for three years.,.
27
-------
5 9 0035
In addition to questions and concerns raised during the June 1996
public meeting, JPAP submitted a technical document prepared with
the assistance of the JPAP technical assistance consultants. The
document discusses JPAP's concerns at the Site and raises issues
to be addressed by EPA. In the following paragraphs EPA will
respond to those questions related to OU2.
OU2 SITE CHARACTERIZATION
JPAP - Disproportionate Focus on Compliance with MILS - One of
the nine evaluation criteria was allocated a disproportionate
weight of consideration during OU2 investigations (compliance
with ARARs). The goal to characterize the extent of migration of
Site-related contaminants is equally important. The focus of the
investigation was more on deep groundwater contaminant levels as
opposed to contaminant migratory patterns. This resulted in the
over emphasis of ARARs such as Drinking Water Standards (MILS).
EPA - During the OU2 RI, EPA focused most of the sampling
activity at what was and is believed to be the source and extent
of groundwater contamination, the North Pond area. EPA used four
different sampling techniques 1) hydropunch, 2) test trench, 3)
monitoring wells, and 4) immunoassay. Therefore, EPA believes it
thoroughly sampled the groundwater under and down gradient of the
North Pond. The depths of sampling ranged from the surface to
approximately 25 feet below the surface. EPA believes that
contaminant levels found in these samples are the highest levels
found at the Site. This thorough sampling protocol was not in
an> way curtailed because of any ARARs analysis.
JPAP - Direction of flow and depths of contaminant plumes - The
OU2 RI was based on an assumption from OUR activities that a
downward, vertical migration of contaminant plumes was the only
significant direction of flow to consider.
-VJ
EPA - Numerous studies and analysis have been conducted
throughout the years of remedial activity at the Site to
determine the direction of groundwater flow. . These studies
indicate that the horizontal groundwater flow direction in the
shallow aquifer beneath the site is South/Southwest toward the
Pearl River. - - -- - - ...._.
JPAP - Test trench sampling results - Test trench sampling were
not analyzed for Site-related_ contaminants. _
EPA - The purpose of the test trench sampling was to provide a
visual of horizontal movement of non-hazardous waxing material.
Hydropunch, immunoassay, and monitoring well samples were used to
provide analytical data.
28
-------
5 9 0036
JPAP - Hydropunch Sampling Results - EPA failed to determine the
extent of groundwater contamination with the Hydropunch sampling
during the RI. The sampling was completed in the area with high
levels of contamination. Therefore a clean boundary was never
established.
EPA - EPA agrees with comments regarding the placement of
Hydropunch sample locations. These samples were collected from
the North Pond Area and indicate that contaminants are located in
the shallow groundwater beneath the Site. However, the primary
means of determining the extent of contamination at the.Site is
via the monitoring wells. The monitor wells at the bite
completely surround the OU2 area and are designed to identify any
horizontal movement of groundwater contaminants. As part of the
monitoring plan for OU2, an additional well (MW-41) will be
installed directly southwest of the North Pond area.
*
PROBLEMS WITH SAMPLE COLLECTION, ANALYSIS AND INTERPRETATION
JPAP - Pentachlorophenol (PCP) - Three significant problems ^ave
characterized the analyses and reporting of PCP throughout the
remedial process. These include: (1) inconsistency in analytical
methods used, (2) SQLs exceed MILS, and (3) Poor recoveries of
PCP leading to routine underestimations of actual concentrations.
EPA - During all sampling events at the Site, current and
approved EPA methods for all analysis were used. EPA also
approved Quality Assurance and Quality Control (QA/QC) samples at
the Site. For PCP analysis, Reichhold used Method 8150 *modified
which has been approved by EPA for PCP analysis in order to
detect concentrations at levels at the M.C.L..
JPAP - Arsenic - The Site standard for arsenic is 50_ug/l. Some
samples have quantitation limits as high as 80 ug/l.~~ Also the
health-based water quality criteria of 0.02 ug/1 is more
appropriate for the Site.
•*» - — -
EPA - EPA uses MILS for cleanup standards when they exist.
Therefore the standard for arsenic in groundwater is 50 ug/1.
This was selected because it is EPA's national M.C.L. for
arsenic. The state of Mississippi also uses 50 ug/1 as the
M.C.L. for arsenic in drinking water. The arsenic water standard
-of 0.002 ug/1 in water is a Health Based Standard for Arsenic an
surface water and does not apply to groundwater contamination
levels associated with OU2 of the Site.
JPAP - Dioxin - Dioxin contamination levels determined as part of
OUR probably inaccurately characterized extent of Dioxin at the
site. Therefore, Dioxin analysis should have been included as
part of OU2.
29
-------
5 9 0037
EPA - Dioxin was never sampled for as part of the RI for OU2 due
to its absence from the overall Site in previous sampling
activities (RI OUR) . During the RI for OUR, EPA sampled some of
the most likely areas of the Site where dioxin contamination
might exist. Results were mostly negative with only trace levels
present on-site. All areas of the Site where even trace levels
of dioxins were detected have since been removed and disposed of
properly. Therefore, EPA had no basis for requiring dioxin
sampling in the OU2 investigation.
OU2 RISK ASSESSMENT
The concerns raised in this paragraph were also -raised in
the preceding paragraphs and have already been addressed.
PROPOSED OU2 REMEDIAL PLAN
-I-
JPAP - Monitoring Strategy Plan - Inadequate detail was provided
on the monitoring strategy t>lan including who will collect the
^ampl°s, what ana^ytes will be tested for and how many samples
will be collected during what quarters and from what wells?
EPA - The monitoring strategy plan will consist of quarterly
monitoring during the first year and semi-annual monitoring
during the second and third years. Five monitoring wells will be
sampled during each sampling event. These will include existing
Monitoring wells MW-28, MW-38, MW-39 and MW-40 and will also
include the newly installed monitoring well MW-41. MW-41 will be
installed south/southwest of the North Pond area. EPA will offer
the chance to Reichhold to conduct this sampling. If Reich old
declines to conduct this sampling, EPA will do it. This
monitoring will be conducted as part of the remedy for OU2.
•
JPAP - Chemical Attenuation and Biodegradation - A three year
monitoring plan is not adequate to ensure that chemical
attenuation and biodegradation continues with time.
EPA - The purpose of the groundwater monitoring is to affirm that
no definable contaminant plume exists at the site or migrating
off-site; the purpose is not designed to monitor chemical
attenuation and biodegradation with time. The three-year period
of monitoring is sufficient to determine if any plume actually
exists and will .migrate off-site.- - ——
30
------- |