PB98-964014
EPA 541-R98-068
March 1999
EPA Superfund
Record of Decision:
T. H. Agriculture & Nutrition
(Montgomery) OU 2
Montgomery, AL
9/28/1988
-------
RECORD OF DECISION
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
TH AGRICULTURE & NUTRITION SITE
OPERABLE UNIT TWO
MONTGOMERY, MONTGOMERY COUNTY, ALABAMA
PREPARED BY
U. S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV
ATLANTA, GEORGIA
-------
DECLARATION
Of the
RECORD OF DECISION
OPERABLE UNIT TWO- FINAL GROUNDWATER ACTION
AND FINAL SOILS ACTION
SITE NAME AND LOCATION
T H Agriculture & Nutrition Site
Montgomery, Montgomery County, Alabama
HP BASIS AND PURPOSE
This decision document presents the selected remedial action
for the T H Agriculture & Nutrition (THAN) Site, Montgomery,
Alabama, developed in accordance with the Comprehensive
Environmental Response, Compensation and Liability Act of 1980
(CERCLA) , as amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA), 42 U.S.C. Section 9601 et
sea. , and to the extent practicable, the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP) , 40 CFR
Part 300. This decision is based on the administrative record
for the THAN site.
The State of Alabama, as represented by the Alabama Department
of Environmental Management (ADEM) , has been the support agency
during the Remedial Investigation and Feasibility Study (RI/FS)
process for the THAN site and concurs with the selected remedy.
QF TP"B SITE
Actual or threatened releases of hazardous substances from this
Site, if not addressed by implementing the response action
selected in this Record of Decision (ROD) , may present an
imminent and substantial endangerment to public health, welfare
or the environment.
DESCRIPTION OF SELBCT)
This remedial action is the final of two actions planned for
this Site. The previous action is an interim groundwater action.
This final action addresses the remaining principal threats posed
by this Site by remediating the contaminated soils and sediments;
furthermore, this action finalizes the interim groundwater
action. The remedial action for soils involves the removal,
biological treatment, and replacement of impacted soils and
sediments .
The major components of the selected remedy for this remedial
action include:
• Designation of the areal extent of contamination as a
Corrective Action Management Unit (CAMU) ;
-------
• Excavation of soil and sediment from those areas exceeding
cleanup standards;
• Backfilling of the excavated areas;
• Biological treatment of the excavated soils and sediments
until cleanup standards are met;
• Replacement of the treated soils and sediments onsite;
• Institutional controls which include fencing and deed
restrictions limiting site use for industrial purposes
only; and,
• Continuation of the interim remedial action until the
groundwater performance standards are met.
In addition, a contingent remedy is in place in case a
determination is made that biological treatment is unable to meet
the performance standards for soils and sediments in a timely
manner. The contingent calls for removal and off-site disposal
at an approved facility.
STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the
environment, complies with Federal and State requirements that
are legally applicable or relevant and appropriate to the
remedial action, and is cost-effective. This remedy utilizes
permanent solutions and alternative treament technology, to the
maximum extent practicable, and satisfies the statutory
preference for remedies that employ treatment that reduces
toxicity, mobility, or volume as a principal element.
Since the remedy chosen will result in hazardous substances
remaining on-site above health-based levels (until groundwater
performance standards are met), the five-year review will apply
to this action. Thus, a review of the groundwater remedy should
be conducted at five year intervals after the remedial action is
begun; the purpose of this review will be to ensure that the
remedy continues to provide adequate protection of human health
and the environment.
\
RICHARD D. GREEN DATE
DIVISION DIRECTOR
WASTE MANAGEMENT DIVISION
U.S. EPA REGION 4
-------
TABLE OF CONTENTS
1.0 Site Location and Description 1
2.0 Site History and Enforcement Activities 3
3.0 Highlights of Community Participation 4
4.0 Scope and Role of Operable Units and Overall Site Strategy 5
5.0 Summary of Site Characteristics 5
5.1 Hydrogeology/Soils 5
5.2 Surface Water and Sediments 6
5.3 Nature and Extent of Contamination 7
5.3.1 Groundwater 7
5.3.1.1 Phase I, II Remedial Investigation Results 9
5.3.1.2 January, 1996 Results '. 10
5.3.1.3 October, 1997 Results 10
5.3.2 Soils 11
5.3.3 Sediments 11
5.3.3.1 Phase I, II Remedial Investigation Results 15
5.3.3.2 Draft Supplemental RI Results 15
5.3.4 Dioxins 16
5.3.5 Surface Water 17
5.3.6 Biota 17
5.3.7 Soils/Sediments Areas of Concern 17
. 0 Summary of Site Risk 19
6.1 Baseline Risk Assessment 19
6.1.1 Human Health Risk 20
6.2 Anticipated Future Land Use 21
6.3 Ecological Risk 22
6.4 Contaminants of Concern 23
7.0 Description of Alternatives for Soils/Sediments Remediation 25
7.1 Alternative No. 1 - No Action 26
7.2 Alternative No. 2 - Institutional Controls 26
7.3 Alternative No. 3 - On-Site Consolidation and Containment 27
7.4 Alternative No. 4 - Removal, Thermal Treatment,& Replacement....29
7.5 Alternative No. 5 - Removal, Biological Treatments Replacement.31
7.6 Alternative No. 6 - Removal and Off-Site Disposal 32
8.0 Summary of the Comparative Analysis of Alternatives for
Soils/Sediments Remediation 33
8.1 Overall Protection of Human Health and the Environment 34
8.2 Compliance With ARARS 36
8.3 Long-Term Effectiveness and Permanence 36
8.4 Reduction of Toxicity, Mobility or Volume Through Treatment 36
8.5 Short-Term Effectiveness 37
8.6 Implement ability 37
8.7 Cost 37
8.8 State Acceptance 39
-i-
-------
8.9 Community Acceptance 39
9 .0 The Selected Remedy 3J|
9 .1 Groundwater Performance Standards 4^
9.1.1 Aquifer Response and Pump Testing 42
9.1.2 Compliance Testing 42
9 .2 Soils/Sediments Performance Standards 42
10.0 Statutory Determination 43
10.1 Protective of Human Health and the Environment 44
10.2 Attainment of ARARs 44
10.3 Cost Effectiveness 46
10.4 Utilization of Permanent Solutions to the Maximum Extent
Practicable 47
10.5 Preference for Treatment as a Principal Element 47
11.0 Explanation of Significant Changes 47
Appendix A - Responsiveness Summary 48
Appendix B - Concurrence Letters 60
Appendix C - Selected Tables from the Baseline Risk Assessment 61
Appendix D - Selected Tables from the Ecological Risk Assessment
Selected Map, Table from the Supplemental RI 62
Appendix E - Explanation of Data Qualifiers 64
LIST OF FIGURES & TABLES
Figure 1 Area Map for the THAN Site 2
Figure 2 Site Map for the THAN Site 2
Figure 3-2 Contaminated Areas A,B,C,D, and E 18
Figure 4 Soil Isoconcentration Map, DDD+DDE+DDT (0-1 ft) 12
Table 1 Frequency of Detection, Maximum Concentrations, MCLs,
Groundwater Protection Standards, and Performance
Standards for Constituents of Interest in
Groundwater 13
Table 2 Frequency of Detection and Maximum Concentrations for
Constituents of Interest in Soils, Sediments, and
Surface Water- Phase I, II RI 16
Table 3 Description of Cleanup Alternatives: Soils/Sediments 35
Table 4 Performance Standards: Soils/Sediments 43
-------
Record of Decision
Operable Unit Two
Final Groundwater Action and Final Soils Action
T H Agriculture & Nutrition Site
Montgomery, Alabama
1.0 SITE LOCATION AND DESCRIPTION
The T H Agriculture & Nutrition (THAN) Site is located on the west side
of Montgomery, Alabama, about two miles south of the Alabama River and
1,600 feet west of Maxwell Air Force Base (Figure 1). Access to the Site
is from U.S. Highway 31-82. The Site is basically flat and includes two
properties: the THAN property and the Elf Atochem property. The Site
covers 16.4 acres, with the THAN property covering about 11.6 acres and
the Elf Atochem property covering 4.8 acres (Figure 2).
The only structure on the THAN property is a warehouse that was used for
storing water treatment chemicals, plating chemicals, and agricultural
chemicals. The remaining areas consist of mixed pine forest and a low,
marshy area. The middle half of the Elf Atochem property has an
operating area including a concrete paved area and a number of buildings.
The area was formerly used for mixing, repackaging, and distributing
agricultural and industrial chemicals. The east portion has an open
parking area, and the west portion is an open area covered by grass and
brush.
The land west of the Site was used for farming in the past. However, the
land does not appear to have been actively farmed for a number of years.
The property to the northwest is a mobile home park called Lakewood
Estates (formerly Twin Lakes Community). Beyond the mobile home park is
a small residential area. Undeveloped land covered by mixed forest,
brush, and grass is on the north border. The entire area around the Site
is zoned for general industrial use. A residential community lies about
a mile southwest of the Site.
Wittichen Chemical Company first developed the THAN property as a sales,
packaging, and storage facility for water treatment and plating
chemicals. THAN, which was then known as Thompson Hayward Chemical
Company, bought the facility in 1966 for storage and distribution of
agricultural and industrial chemicals. THAN, a wholly owned subsidiary
of Phillips Electronics North America Corporation, closed the facility in
1978 and leased it for various time periods before selling it in 1986 to
Williamson Industries, Inc. THAN recently re-purchased this property
from Williamson Industries.
The Elf Atochem property was first developed by Montgomery Industries.
Elf Atochem North America, Inc., formerly known as Pennwalt Corporation,
purchased this property in 1951 and used it as a chemical blending and
distributing facility. Astro Packaging, Inc. bought the Elf Atochem
property in 1979 and leased it to Industrial Chemicals. Elf Atochem now
currently leases the property from Astro Packaging.
-------
Figure 1 - Area Map for the THAN Site
Figure 2 - Site Map for the THAN Site
-------
2.0 SITE HISTORY AND ENFORCEM^T*
In October 1980, the Alabama Water Improvement Commission (AWIC)
(a predecessor to the Alabama Department of Environmental
Management or ADEM) inspected the THAN property in connection
with THAN's closing of its facility. During this inspection,
AWIC found waste material in open and underground pits. In 1981,
under the supervision of the Alabama Department of Public Health,
Division of Solid & Hazardous Waste, THAN excavated waste and
contaminated soil from 13 burial areas and collected contaminated
groundwater, treated it, and discharged it to a publicly-owned
treatment works (POTW).
In April 1986, THAN sold the THAN property to Williamson
Industries, Inc. In August 1994, THAN purchased this property
back from Williamson and is the current owner of this portion of
the Site.
Elf Atochem, formerly known as Pennwalt Corporation, owned and
operated a chemical formulation and distribution facility on its
property which is adjacent to and up gradient from the THAN
property. Elf Atochem handled substances similar to those
handled by THAN. Elf Atochem maintained a 700,000-gallon
evaporation lagoon on its property for the storage and treatment
of wastewater. The Elf Atochem property is currently owned by
Astro Packaging, Inc. Astro Packaging leased it to Industrial
Chemicals, Inc. (1C), until March 1994. 1C operated a warehouse
distribution center on the Elf Atochem property. 1C vacated the
Elf Property in March 1994 and Elf Atochem currently leases it
from Astro Packaging.
The THAN property was listed on the National Priority List in
August of 1990. Thereafter, it was discovered that contamination
from the Elf Atochem property was impacting the THAN property and
the Site was expanded to include both the THAN property and the
Elf property.
In March 1991, Elf Atochem agreed to perform the Remedial
Investigation/Feasibility Study (RI/FS) pursuant to the terms of
a consent order issued by EPA. This detailed study of Site
contamination has been conducted under EPA oversight. This
study included several phases and has investigated soil, surface
water, sediment, groundwater, and air at the Site. Geophysical
surveys and surface/subsurface soil sampling on an extensive grid
system have been completed. A wetlands survey and an ecological
assessment have also been completed. The results of the remedial
investigation are in the information repository, located at the
Montgomery County Public Library - Rufus Lewis Branch. In
addition, numerous treatability studies and a focused feasibility
study that concentrates on groundwater alternatives have been
completed.
-------
In April of 1995, the Interim Action Record of Decision was
issued for Operable Unit One (OU1). The Final Construction
report for OU1 was released in February 1998.
3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION
EPA held an availability session at a local library at the start
of field work in August, 1991. EPA chose the Air University
Library at Maxwell Air Force Base as the local information
repository because of its proximity to the Site. In March 1992,
EPA held a public meeting at what is now Lakewood Estates Trailer
Park to discuss the remedial investigation findings at the Site.
The proposed plan for the groundwater interim remedial action
(OU1) was presented at a public meeting held on Tuesday, December
12, 1994 at the Hunter Station Community Center. Representatives
from EPA attended the meeting and answered questions regarding
the Site and the proposed plan. The administrative record for
OU1 was available to the public at both the information
repository maintained at the Air University Library and at the
EPA Region 4 Library located in Atlanta, Georgia. The notice of
availability for both the OU1 proposed plan and administrative
record was published in the Montgomery Advertiser on December 9
and December 12, 1994. The public comment period on the OU1
proposed plan was December 9, 1994 through January 9, 1995. EPA
extended the comment period by thirty days to February 8, 1995,
upon requests from the public. Subsequent to this proposed plan,
an Interim Action Record of Decision was signed on April 17, 1995
summarizing the interim action for OU1. Responses to the
significant comments received during that public comment period
and at the public meeting were included in the Responsiveness
Summary of the Interim Action ROD, and are not included again
here.
The proposed plan for the final remedial actions for groundwater
and soils (OU2) was presented to the public on August 13, 1998.
Representatives from EPA also attended this meeting and answered
questions regarding the Site and the OU2 proposed plan under
consideration. The notice of availability for the OU2 proposed
plan and the administrative record was published in the
Montgomery Advertiser on August 4, 1998. The information
repository was moved to the Rufus Lewis Branch Library based on
public comments received in the past. The public comment period
for the proposed plan was originally August 4, 1998 to September
4, 1998. However, a notice was placed in the Montgomery
Advertiser on September 8, 1998 advising the public that the OU2
public comment period was extended to September 18, 1998. This
extension was granted after it was found that the OU1
administrative record still resided at the Air University
library; the OU1 administrative record was subsequently moved to
the Rufus Lewis Branch Library on August 19, 1998. Responses to
the comments received during the OU2 public comment period and at
-------
the OU2 public meeting are included in the Responsiveness Summary
of this decision document, in Appendix A.
This decision document presents the selected final remedial
actions for soils and groundwater of the THAN Site, chosen in
accordance with CERCLA, as amended by SARA, and the NCP. The
decision for this Site is based on the administrative record.
The requirements under Section 117 of CERCLA/SARA for public &
state participation have been met for both OU1 and OU2.
4.0 SCOPE AND ROLE OF OPERABLE UNITS AND OVERALL SITE STRATEGY
EPA has organized the work at this Superfund Site into two
operable units (OUs). These units are:
• OU1: An interim remedial action for containment of
groundwater contamination at the Site.
• OU2: The final action for the cleanup of the contamination
in the soils, sediment, and groundwater at the
Site.
Operable Unit One (OU1) encompasses the interim remedial action
and involved the implementation of a multiple-well gathering and
pump system to control and contain the contaminated groundwater
plume. In addition, geological and engineering information on
the aquifer's response to pumping will be obtained that will be
used to determine the effectiveness of the design's hydraulic
control. Data obtained during the remedial investigation
indicates that there is contaminated groundwater within the
unconfined surficial aquifer at the Site. This aquifer is
classified in the Guideline for Ground-Water Classification Under
EPA Ground-Water Protection Strategy. Final Draft, December 1986,
as a Class II Groundwater, that is a current source of drinking
water.
Operable Unit Two (OU2) encompasses the remediation of the
contaminated soils and sediments on the Site, and also
establishes the performance standards for the groundwater remedy.
Upon reaching the cleanup standards for groundwater at an
established point(s) of compliance, the groundwater pumping
system will be shut down.
5.0 SUMMARY OF SITE CHARACTERISTICS
5.1 HYDROGBOLOGY/SOILS
The Site is situated on Quaternary alluvial and terrace deposits
consisting of sand, gravel, silt, and clay that were encountered
from the surface to a depth of approximately 45 feet. Below
these, an approximately 950 foot thick sequence of Cretaceous
units extends to Paleozoic bedrock. The Cretaceous units
-------
include, in descending order, the Eutaw, Gordo, and Coker
Formations, consisting of various sand, silt, and clay deposits.
Groundwater occurs in an unconfined surficial aquifer (Alluvial/
Terrace Deposits aquifer) at the Site with the water table at
approximately 15 feet below ground surface. Groundwater in the
surficial aquifer flows generally toward the northwest at an
average rate of approximately 0.28 feet per day. A
potentiometrie mound located north of the Site appears to direct
some groundwater flow from the Site toward the northeast.
Differences in head between nested monitoring wells at the Site
indicate that groundwater also has a very small vertically
downward component of flow within the aquifer.
The surficial aquifer is underlain at approximately 60 feet below
ground surface by the approximately 60 foot thick Middle Eutaw
confining unit. The top of the Middle Eutaw confining unit is
characterized by a dense green clay layer, which is underlain by
interbedded layers of sand and clay. Although a downward
vertical gradient exists across this confining unit, the low
permeability zones restrict vertical groundwater flow to an
approximate rate of 4.3 x 10"5 feet per day. At this flow
velocity, the most mobile constituents would require
approximately 4,800 years to migrate from the surficial aquifer
through the confining unit to the next deeper aquifer below.
Beneath the Middle Eutaw confining unit are three regional
aquifers, as follows in descending order: Lower Eutaw aquifer,
Gordo aquifer, and Coker aquifer. These aquifers are the source
of groundwater for the City of Montgomery's West Well Field,
which, at its nearest point, is 1.3 miles from the Site. Based
on water levels reported from the West Well Field, as compared to
water levels in one on-site well completed in the Lower Eutaw
aquifer, groundwater in these deeper units most likely flows
south, in the vicinity of the Site, toward the well field.
However, these deeper aquifers are not believed to be affected by
the Site at this time.
5.2 SURFACE WATER AND SEDIMENTS
Surface water near the Site includes Catoma Creek, located
approximately 1.5 miles to the west-southwest; the Alabama River,
located 2 miles to the north-northeast; and the West End Ditch,
which is located approximately 2,000 feet east of the Site.
Catoma Creek and the West End Ditch are tributaries of the
Alabama River.
Surface water drainage on the THAN property is toward a small
marshy area west of the warehouse into a small drainage ditch
that parallels the western Site boundary and terminates at the
southern Site boundary. This surface water is perched on low
permeability soil (clay and silt) and may act as a minor recharge
-------
area for the Site. Water in the west ditch flows through a low
point in the bank and then flows on an intermittent basis
southwest through a combination of ditches and marshy areas.
Drainage from the eastern portion of the Site flows through storm
drains into a ditch on the eastern boundary of the Site. Water
in the ditch at times is pooled and stagnant, but during high
water periods, flows south from the Site in the ditch. The ditch
crosses under Highway 31-82 approximately 3,000 feet south of the
Site. At that point, it flows east into the West End Ditch,
which drains a large portion of western Montgomery. The storm
sewer system that services a majority of the Elf Atochem property
discharges to the east ditch at the outfall location. In
addition, a much smaller drainage ditch east of U.S. Highway 31-
82, which collects stormwater runoff from properties on that side
of the highway, drains to the east ditch via three storm culverts
in the vicinity of the Site.
5.3 NATURE AND EXTENT OF CONTAMINATION
In the following sections, reference is made to isoconcentration
maps drawn to show the contaminant levels in the various media.
The maps prepared for the RI (cited in Section 5.3.3.1 below) are
oversize maps that are approximately 2 feet by 3 feet. The maps
prepared for the "Supplemental Groundwater Investigation and
Modeling in Support of the Supplement to the Focused Feasibility
Study (OU1)" are 11" x 17". All of these maps are available for
review in the appropriate documents as part of the Administrative
Record, but are not included as part of this document, the OU2
ROD.
However, the isoconcentration map for the DDTr congeners (DDT,
DDE, DDD) was digitized and has been included here as Figure 4.
Also, please note that semi-volatile compounds are not included
as part of Tables 1 and 2. However, the semi-volatile sampling
results were considered when defining the Contaminants of Concern
(COCs, see Table 17 in Appendix C), discussed in Section 6.4.
5.3.1 GROUNDWATER
The groundwater monitoring system at the Site consists of 55
monitoring wells that have been installed during several phases.
Thirty-one wells are screened across the water table in the
uppermost portion of the surficial aquifer. Eighteen wells are
screened across the lower portion of the surficial aquifer.
Six deep wells are completed as follows: five are screened across
the permeable zones of the Middle Eutaw confining unit, and the
sixth is screened across the top of the Lower Eutaw aquifer. In
addition to these 55 wells, there are two wells installed for the
purpose of monitoring water levels (using piezometers).
-------
Groundwater at the Site has been sampled on five separate
occasions. The reports summarizing these results and the report
dates are as follows:
* Phase 1 RI, June 1993: Twenty-five wells installed
beginning in August 1991. Including six previously
installed wells, each well was sampled twice for the
entire range of parameters, or 158 constituents.
Preliminary report delivered to EPA January, 1992.
* Phase II RI, June 1993: Twenty-four wells installed, with
field work finished by June 1992. Along with four
drinking water wells in the area, these wells were also
sampled twice for the entire range of parameters.
Extensive soil, sediment, and surface water sampling was
also conducted during Phase I and II of the RI.
* Draft Supplemental RI, June 1994: Monitoring well MW-53
was installed. This well sampled several zones utilizing
both temporary wells and Hydropunch technology, with the
final completion of the well being screened across the
permeable zones of the Middle Eutaw confining unit. This
Draft Supplemental RI also collected 34 additional
sediment samples that are discussed further in Section
5.3.3.
* Supplemental Groundwater Investigation and Modeling in
Support of the Supplement to the Focused Feasibility Study
(OU1), January 1997: Sampled all forty-eight wells in the
monitoring system during January 1996; analyzed for
pesticide, herbicide, volatile, and total metals
constituents.
* October 1997: Sampled forty wells in the monitoring system
for volatile, pesticide, and herbicide constituents.
The ROD written for OU1, dated April 17, 1995, and describing the
Interim Remedy for groundwater, discusses in detail the
groundwater sampling results of the Phase I and Phase II RI. The
OU1 ROD went on to note that confirmed detection of constituents
of interest was limited to the surficial aquifer, with the
exception of samples from one deep well in the uppermost
permeable zone of the Middle Eutaw confining unit. Low
concentrations of constituents in this well are believed to have
originated from seepage through a former deep water supply well
located on the Site. The former water-supply well was abandoned
during the RI.
The groundwater presentation made here for purposes of the OU2
ROD is shown on Table 1. Groundwater results from Phase I and
Phase II of the RI are shown in columns 2 and 3 of Table 1, for
8
-------
only the pesticide, herbicide, and volatile compounds, and are
part of the same results tabulated with the OU1 ROD. Frequency
of detection and maximum levels detected are given for each
constituent shown.
Groundwater results from the January 1996 sampling event (report
dated January 1997) are shown in columns 4 (frequency of
detection) and 5 (maximum level detected). Metals were analyzed
also during this event, but are not shown on Table 1: none were
above Maximum Contaminant Levels (MCLs) .
Groundwater results from the October 1997 sampling event are
shown in columns 6 (frequency of detection) and 7 (maximum level
detected). Metals were not analyzed during this sampling event.
5.3.1.1 PHASE I. II RI GROUNDWATER RESULTS
The following three paragraphs are taken directly from the OU1
ROD (see pages 7 and 10 of that document) and discuss the
pesticide, herbicide, volatile, and total metal results from RI
groundwater sampling (refer to Table 1, columns 2 and 3). The
shallow surficial water table (see Section 5.1 also) is
approximately 45 feet thick. Wells were screened in this aquifer
either across the upper interval, or across the bottom interval,
i.e., just above the top of the Middle Eutaw confining unit.
Wells in the shallow surficial aquifer are thus referred to as
either "shallow" or "intermediate" wells.
Eighteen pesticide compounds (including multiple isomers of some
compounds) and four herbicides were detected in the groundwater
samples during the RI. In general, the most notable
concentrations of pesticides and herbicides in the shallow wells
occur in two distinct areas. One is located in the vicinity of
the operations area at the Elf Atochem property and the other is
located in the vicinity of the former THAN disposal area and the
northeast corner of the THAN property. In contrast, pesticide
concentrations in the intermediate wells are highest downgradient
from these areas. The constituents of interest in the
intermediate wells appear to be the downgradient extension of the
detections in the shallow wells.
Twenty-one volatile organic compounds were identified as
constituents of interest in the RI groundwater samples. The
distribution of volatile organics in groundwater at the Site is
very similar to that of pesticides. The highest concentrations
of volatile organics occur in the shallow wells at or very near
the operations area at the Elf Atochem property and the former
THAN disposal area. As was the case with pesticides, the highest
concentrations of volatiles in the intermediate wells occur
within an area that includes the THAN property and extends
downgradient in the aquifer. Therefore, the relationship of the
distribution of volatiles between the upper and lower portion of
-------
the surficial aquifer is essentially the same as that for
pesticides and for the same reasons.
Ten inorganics were retained as constituents of interest in
groundwater from shallow and intermediate wells during the
remedial investigation. There appears to be no discernible
pattern of inorganic constituents in groundwater. Constituents
of interest have been detected in groundwater on-site and in
near-site areas in the surficial aquifer. The precise extent of
affected groundwater is not entirely defined to the north, east,
and west. The furthest off-site detections of constituents of
interest in groundwater were at wells MW-41S and MW-42I, located
600 feet north of the Site, and well MW-48I, 3,250 feet northwest
of the Site.
Isoconcentration maps have been prepared for all the groundwater
data collected during the RI, and are available for review as
part of the Site's Administrative Record; they are not included
here as part of this ROD for OU2 (see Section 5.3) .
5.3.1.2 JANUARY. 1996 GROUNDWATER RESULTS
As noted above, all wells in the monitoring system were sampled
again in January, 1996. Results from this sampling event are
discussed in the "Supplemental Groundwater Investigation and
Modeling in Support of the Supplement to the Focused Feasibility
Study (OU1), January 1997", and are shown on Table 1, columns 4
and 5. Isoconcentration maps were also prepared for the
groundwater data collected during this sampling event; however,
they are part of the Site's Administrative Record and are not
included here as part of the ROD for OU2 (see Section 5.3).
Table 1 shows only those constituents that were found in
groundwater at levels exceeding drinking water standards, for the
January, 1996 sample data (see Section 5.3.1 also).
Contaminant levels in the groundwater for this sampling event
were found to be much lower than those levels documented during
Phase I and Phase II of the RI. This is most likely due to
natural attenuation, or biodegradation of the constituents within
the aquifer rock, although it is also possible that migration and
dilution of the contaminants away from the site has occurred.
5.3.1.3 OCTOBER. 1997 GROUNDWATER RESULTS
The groundwater monitoring system was sampled again in October
1997. Metals were not analyzed for, based on results of the
previous sampling. Again, most constituents of concern were
shown to be decreasing, although some compounds did show
increased levels. Results are shown on Table 1, columns 6 and 7.
10
-------
5.3.2 SOILS
Constituents of interest in soil appear to be due primarily to
the presence of pesticides. . Isoconcentration maps developed for
pesticide groups, using data from the RI (these maps are part of
the Administrative Record for OU2, and only Figure 4 for the DDTr
congeners is included here- see section 5.3), indicate
constituent presence in surface soils across portions of the
Site, with limited presence to depth. BHC isomers were generally
found in similar locations of the southwestern portion of the
Site. DDD, DDE, and DDT constituents, as a group, were detected
throughout portions of the Site (see Figure 4). Toxaphene, as
well as other pesticides and herbicides, were detected at
isolated locations on the Site. In general, pesticide
concentrations were highest in the surface soil and
concentrations decreased with increasing depth below the surface.
Isoconcentration maps were also presented in the RI for Total
Volatile Organics (TVO) excluding acetone and methylene chloride
(both of which appeared to be primarily related to sampling
and/or laboratory artifacts). The TVO maps indicated constituent
presence to depth, but only at low to moderate concentrations.
The highest concentrations were detected in samples from four to
six feet below the ground surface. The areas most affected on
the Site were the operating areas that consist of the buildings
and paved areas.
The results of the semi-volatile compounds analyses showed that
they do not appear to be an issue at the Site. Semi-volatiles
were detected in low concentrations and in a somewhat random
pattern across the Site. The presence and concentration of semi-
volatiles generally decreased from the surficial sample interval
to deeper intervals.
Data for metals and cyanide establish that concentrations above
background were limited mainly to the near surface soil (0 to
6 feet) in the vicinity of the THAN former disposal area on the
west side of the property.
Table 2 shows frequency of detection and maximum levels detected,
for those constituents on which performance standards are based,
for all the soil samples collected during the RI. A detailed
discussion of the constituents identified in the soil is included
in Section 7.2 of the RI report.
See Section 5.3.4 for a discussion of dioxin results in soils.
5.3.3 SBDIMRTJTS
Sediment samples have been collected in two separate sampling
events. During the RI, 127 sediment and 39 surface water samples
were collected primarily onsite from drainage features. The
11
-------
M
to
ADAPTED FROM FIGURE 7-5 FROM
REMEDIAL INVESTIGATON REPORT
175
SCALE
175
300
FED
THAN SflE
MONTGOMERY. ALABAMA
SOIL BOCONCENTRATON MAP
ODD + DOE + DOT (0-1 FT)
eaamuan me.'
Figure 4
-------
Table 1
Frequency of Detection, Max Concentrations, MCLs, Groundwater Protection Standards, and Performance Standards for Constituents in Groundwater
T H Agricultural and Nutrition- Montgomery, AL
Remedial Investigation Supplemental Groundwater
Phase 1,11 Investigation... Sampling Event
June, 1993 January, 1997 October, 1997
Constituent
• of Hits/ Total
I of Samples
Maximum
Detected
Conc'n (ug/L)
(a)
# of Hits/ Total
If of Samples
Maximum
Detected Conc'n
(ug/L)
(a)
VOLATILES
1 , lH&i<&iord<&th«m* -
1,2-fJDichioi'oethene ..
' " "(fc*t*l)
1 , 2 -Dichloroethane
SarbOA Tfctrachioride
1 , 2-Dichloropropane
Trichlfcfoethene
• > Ben^en^
T^ttacshloroettwn* >
Ethyl benzene
Xylene (total)
22/108
29/108
8/108
IS/108
2/108
42/108
IS/108
33/108
4/108
9/108
250
570
100
170
10
260
3,100
7$
8,300
70,000
11/61
19/61
4/61
9/61
2/61
21/61
4/61
16/61
2/61
2/61
18
770E
7.7J
220D
5.2J
160
76
12
3800D
27,0000
# of Hits/ Total
f of Samples
Maximum
Detected Conc'n
(ug/L)
(a)
13/40
tie * i*/4»
trans * 1/40
1U/40
7/40
3/40
20/40
S/40
13/40
1/40
1/40
30
cl* * 35fl
trarw = J,S
-
70
4.4J
72
24
33
380D
1800D
MCL (b)
GWPS (c)
(ug/L)
7
ota * 70
trans s» J60
5
5
5
5
5
S
700
10,000
13
-------
Table 1 (Con'd)
Frequency of Detection, Max Concentrations, MCLs, Groundwater Protection Standards, and Performance Standard* for Constituent* in Groundwater
T H Agricultural and Nutrition- Montgomery, AL
Remedial Investigation Supplemental Groundwater
Phase I, II Investigation... Sampling Event
June, 1993 January, 1997 October, 1997
Constituent
PESTICIDES
*\ , al|>hVB8C
\ -;" beta-sue
% <3elta-8HC
ga»»a.-BHC (Lindane)
- Dieldrin
Endritt
Heptachlor Epoxide
Dinoseb
« of Hits/ Total
# of Samples
49/10$
50/10*
52/108
40/103
27/108
18/10*
1/108
6/108
Maximum
Detected
Conc'n (ug/L)
(a)
19 ,
3.8
17
42
0.8
9.4
0.09
"25
# of Hits/ Total
# of Samples
27/61
36/61
29/61
28/61
26/61
15/61
14/61
10/61
Maximum
Detected Conc'n
(ug/L)
(a)
2,60
4,80
4.30 "
1.50
1.20
3.50
0.81D
11E
# of Hits/ Total
# of Samples
24/40;'
* 26/40 N'\
25/40
21/40^
27/40
19/40,
16/40
N/A
Maximum
Detected Conc'n
(ug/L)
(a)
0.540 „
" 0.70D y
1 5,20 \ >
\ 0.^0
i.sb v
€.20 %
0.1P
N/A
MCL(b)
GWPS(c)
(ug^)
<0.2)
^ ^0.6)\
• (0.8)^ S
. 0.2
, vO.l
" t X
0.2
— -?
(a) See Appendix E for an explanation of data qualifiers.
(b) MCL = Maximum Contaminant Level, (PS)=Performance Standard based on 10-5 Risk to Adult Resident
(c) GWPS = Groundwater Protection Standard, based on 10-5 Carcinogenic Risk to Adult Resident
(d) Highlighted Constituents Represent Performance Standards for Groundwater Remedy.
(e) Cis and trans (see second row, page 12) refer to two different isomers of the dichloroethene compound.
14
-------
Draft Supplemental RI documents the results of 34 additional
sediment samples taken after the RI, primarily from off-site
locations in order to document off-site migration of
contaminants. Selected sediment samples were also analyzed for
dioxin compounds, as discussed in Section 5.3.4.
Analytical data for sediment samples from the drainage pathways
associated with the Site indicated results similar to those for
soil, although with fewer constituents of interest and at lower
concentrations. Pesticides were detected in the majority of the
samples. The detected pesticides were mainly concentrated in the
east ditch (a manmade drainage structure) and to a lesser degree,
the west ditch and marshy areas. Pesticide detection was highest
in the east ditch samples and the storm culvert. Concentrations
in both ditches and the marshy area substantially decrease with
distance from the Site. In the ditches, pesticide concentrations
were higher in surficial samples than in deeper samples.
Volatiles were detected sporadically and at relatively low
concentrations. Herbicides and semi-volatiles were detected in
few samples. The data from the RI and Supplemental RI show that
frequencies of detection, average concentrations, and ranges of
detected concentrations all decrease with increased distance from
the Site. A detailed discussion of the constituents identified
in the sediment is included in Section 9.3.2 of the Final RI
Report. Table 2 shows the frequency of detection and maximum
levels detected for all the sediment samples collected during the
RI.
5.3.3.2 DRAFT SUPPLEMENTAL RI RESULTS
Subsequent to the RI, additional sediment sampling was conducted
to delineate the extent of contaminant migration off-site via the
surface water drainage pathway. A total of 34 samples were
taken: most were off-site on the southwest drainage pathway. One
sample was taken in the east ditch to further delineate the
contamination documented during the RI. In addition, five
samples were analyzed for dioxin/furan compounds (see Section
5.3.4). Figure 2-1 and Table 2-2 from the Draft Supplemental RI
are included here as .part of Appendix D.
The results of this additional sediment sampling showed that
contaminant levels dropped rapidly away from the site. The
reason for this is that pesticides and herbicides bind tightly to
soils and do not migrate easily. Most significantly, it was
shown that contaminants were not impacting residential areas and
were not impacting Catoma Creek. Although these results are not
presented here as part of the OU2 ROD, a discussion of these
results can be found in the Draft Supplemental RI, dated June
1994. In addition, it is noted that these additional sediment
15
-------
Frequency of Detection
find M wcinmin Conn?
T H Agricultural
Table 2
ntrations for Constituent* of Interest in SoQa and Sediments
Phase I, BUI
and Nutrition- Montgomery, AL
SOILS SEDIMENTS
Constituent
4,4' -DDD
4,4' -DDE
4,4' -DDT
Toxaphene
2,4' -DDD
2,4' -DDE
2,4' -DDT
Lead
Arsenic
# of Hits/
Total # of
Samples
113/575
165/575
148/575
22/575
67/414
58/414
53/414
453/575
475/575
Maximum
Detected
Conc'n
680
160
2,700
4,400
190
41
280
98
138
# of Hits/
Total # of
Samples
50/127
76/127
38/127
2/127
29/104
15/104
16/104
122/126
121/126
Maximum
Detected
Cone ' n
9,700
2,200
160,000
83,000
1,400
2,400
13,000
2,780
439
Note: All values shown above are in mg/kg (or parts per million) .
samples were considered when defining the areas A-E discussed in
Section 5.3.6.
5.3.4 DIOXINS
Dioxins and furans were also considered as a potential
contaminant of. concern. Dioxin analyses were performed in
response to the infrequent detection of the herbicide 2,4,5-T in
soil and sediment, since dioxins are a byproduct of the
manufacture of 2,4,5-T and often occur in association with the
herbicide. However, 2,4,5-T was detected in only one soil and
one sediment sample (it was not detected in any other media) .
Four soil samples were analyzed for dioxins during Phase II of
the RI. The four soil samples were collected from the Wet Mix
Area (see Section 6.2.2.4 of the RI) and from beneath the 1C
building extension (see Section 6.2.3 of the RI) . In addition,
one sediment from the storm culvert at N010-E805 was resampled
for dioxin (the sediment location where 2,4,5-T was found).
During the Draft Supplemental RI sampling event, five off-site
sediment samples were also analyzed for dioxins.
The results of these samples showed that dioxins and furans are
not a concern at the site.
16
-------
5.3.5 SURFACE WATER
Surface water samples were collected from the various drainage
pathways associated with the Site. Analytical data indicated the
presence of low concentrations of pesticides in only a few of the
samples collected from the east ditch, the west ditch, and the
marsh. Concentrations of most metals and cyanide were low and
were generally consistent among the surface water samples with
minor exceptions. No herbicides were detected. Volatiles and
semi-volatiles were detected sporadically and at relatively low
concentrations.
Surface water samples were also collected.from nearby ponds.
These data showed that the Site had not impacted the ponds. A
detailed discussion of the constituents identified in surface
water is included in Section 9.3.2 of the Final RI Report.
5.3.6 BIOTA
As part of the Ecological Risk Assessment that was conducted for
the Site, sampling was conducted to characterize the impact of
Site contaminants on the environment. Biological samples were
collected of prey species, including mosquitofish, sunfish,
tadpoles, salamanders, worms, crayfish, grubs, dragonfly larvae,
and snails. These samples were collected for tissue residue
analysis to provide information for food web modeling. Tissue
samples were collected from the East Ditch Reference location,
East Ditch-Location 1, Area 1 Reference location, Area 1
Locations 1 and 2, Area 2 Location 1, and Area 3 Locations 1 and
2 (see Table 4-2 in Appendix D). These Areas were defined as
part of the Draft Supplemental Remedial Investigation, and are
also shown on Figure 2-1 in Appendix D. Areas I through 4 are
located roughly equidistant along the drainage pathway that runs
southwest from the Site to Catoma Creek.
Pesticide levels in the tissue samples analyzed decreased with
distance away from the site. DDTr isomers were the most
prevalent pesticides found in tissue samples, with the highest
levels found in mosquitofish in the East Ditch.
5.3.7 SOILS/SEDIMENTS AREAS OF CONCERN
For convenience, contaminated soils and sediments were grouped
into five separate areas for purposes of the Feasibility Study.
These areas are referred to as Areas A,B,C,D, and E and are shown
on Figure 3-2. These areas were used to generate volume
estimates for the contaminated soils to be remediated. Figure
3-2 shows a total of 3900 cubic yards to be remediated, but
actual volumes could range from 3000 to 5850 cubic yards, as
noted in the Feasibility Study (see Section 7.0).
17
-------
UCENP
PROPERTY UNE
TRtt UNC
RAUKM) TRACKS
• RCO EXCEEOANCC LOCATION
UMfTS Of EXCEnMNCe/EXCAVATUN
SUMMARY OF ESTIMATED VOLUMES
fa. 400 CUBIC YARDS
A '» CUBIC YARDS
/C\ 200 CUBIC YARDS
A 100 CUBIC YARDS
fa. 2450 CUBIC YARDS
TOTAL iVQQ CUBIC YARDS
200
e
SCALE
MO
400
a
flET
3-2
APPROXIMATE AREAS AND
VOLUMES OF SOIL AND SEDIMENT
TO BE REMEDIATED
MN.04
m*N SUPCTFVHO sat
UONTOOUEHY. ALABAMA
Figure 3-2
-------
6.0 SUMMARY OF SITE RISKS
A major risk that is currently associated with the Site is
contamination in the groundwater. Ingestion of groundwater could
result in exposure to various contaminants. Exposure to
contaminated groundwater may result if wells are used or
installed in a water-bearing zone that is contaminated. EPA's
decision to initiate interim remedial action at this Site (see
April 1995 ROD for OU1) was based upon data collected during the
remedial investigation. That information indicated that
hazardous substances released from this Site were migrating
through groundwater. Primary contaminants of concern are
pesticides, including delta-BHC, lindane, DDT, and chlordane;
herbicides; volatile organic compounds, including trichlorethene
and tetrachlorethene; and semi-volatile compounds. The interim
remedial action was initiated in late 1997, is currently in
place, and is expected to address the most imminent and
substantial problem identified thus far at the Site. The
groundwater will be extracted and released to the POTW until
performance standards are met.
Soil and sediment contamination has been documented onsite and in
the drainage pathways leading off the site. The remedy that has
been selected for OU2 will address the risk posed to the public
health and the environment by treating these contaminated
soils/sediments, and if necessary, removing them off-site to an
approved disposal facility.
As noted in Section 5.3.3.2, analytical data shows that the
contamination documented at this site does not extend far enough
to impact local rivers or streams.
Actual or threatened releases of hazardous substances from this
Site, if not addressed by implementing the response action
selected in this ROD for OU2, may present an imminent and
substantial endangerment to public health, welfare, or the
environment.
6.1 BASELINE RISK ASSESSMENT (BRA)
EPA has completed a formal baseline risk assessment (BRA,
consisting of final document dated July 29, 1994 and as amended
by subsequent addendums dated November 14, 1994 and September 5,
1995) for the Site, and has determined the current and potential
threat to human health in the absence of any remedial action.
Tables from the BRA have been included as part of this Record of
Decision as Appendix C, placed in numerical order for the
reader's reference. A brief description is given below for each
table, but only Table 15 will be discussed at length in Section
6.1.1.
19
-------
Table 3 (Appendix C) shows the Reasonable Maximum Exposure (RME)
concentration calculated for each Contaminant of Potential
Concern (COPC) found in soil samples. Tables 5, 6, and 7 show
the RME concentrations for surface water, sediment, and
groundwater, respectively.
Table 8 shows the standard intake factors that are used to
calculate risk for each exposure pathway, for the onsite worker.
Tables 9, 10, and 11 show the same information for site visitor,
the hypothetical future child resident, and the hypothetical
future adult resident.
Table 12 and 13 summarize the toxicological data for the COPCs
associated with the site. Table 12 shows the cancer slope
factors that are used to calculate risk for the carcinogenic
COPCs. Table 13 shows the reference doses used to calculate
hazards for the non-carcinogenic COPCs.
Table 14 presents the risk/hazard associated with the current
land use for the onsite worker and the site visitor. Table 15
shows the risk/hazard associated with both a future industrial
land use (onsite worker and site visitor) and a hypothetical
residential land use (child resident, adult resident, and
lifetime resident). Note that since the current land use is
industrial, the information in Table 14 is identical to that in
Table 15, for the onsite worker and site visitor.
Table 17 shows the Contaminants of Concern (COCs) for each
exposure pathway and receptor.
Tables Cl through C7 present example risk calculations.
6.1.1 HUMAN HEALTH RISK
Table 15 of the Baseline Risk Assessment (BRA) shows that the
carcinogenic risk poged by the Site for the onsite worker is 4 x
10-5, whereas for the site visitor the carcinogenic risk was 3 x
10-5. This risk is within the carcinogenic risk range generally
used for Superfund remedial cleanups. That carcinogenic risk
range is 1 x 10-4 to 1 x 10-6. The Hazard Indices calculated for
the current hazard were 0.5 and 1.3 for the onsite worker and
site visitor, respectively, which are acceptable for non-
carcinogens at Superfund remedial cleanups.
For a future hypothetical residential scenario, the total
incremental cancer risk for a lifetime resident was found to be 2
x 10-3. Likewise, the maximum Hazard Index was calculated for
the lifetime resident and was found to be 78.
As noted, the risk to the onsite worker falls within Superfund's
risk range for remedial cleanups, and does not in itself trigger
a Superfund remedial action for the presumed industrial land use.
20
-------
However, the Baseline Risk Assessment did not include a
groundwater exposure pathway for the onsite worker. In addition,
the exposure unit considered for purposes of calculating the
Reasonable Maximum Exposure (RME) concentrations was assumed to
be the entire Site, consisting of both the THAN and Elf Atochem
properties. If the BRA had included a groundwater exposure for
the onsite worker and/or had considered smaller exposure units
(perhaps corresponding to Areas A-E on Figure 3-2), then the
calculated risk/hazard to the onsite worker would have been much
higher, thus providing a possible rationale for triggering
Superfund's remedial action. The selected remedy addresses the
remediation of the most highly contaminated areas of the Site,
thus reducing the potential for future hypothetical exposure
units to present an unacceptable risk/hazard for the onsite
worker.
As noted in Section 9.0, the selected remedy includes
institutional controls to be put in place limiting the future use
of the Site to industrial purposes only. However, it should be
noted that the remedy, when complete, may reduce site risks such
that a residential land use may be protective of public health
and the environment. Until the remedy is complete and the actual
extent of cleanup is known, it is not possible to make this
determination. The performance standards for soil and sediments
are based on the current land use, which is industrial (see next
section). The residual site risk will be re-assessed only when
the remedy is concluded and if warranted, the need for
institutional controls will be re-evaluated.
6.2 ANTICIPATED FUTURE LAND USE
Based on past and anticipated future use of this Site, and
current zoning for the Site and the property adjacent to the
south and southwest, the on-site worker is the most appropriate
potential exposure scenario for this Site. The Site and the
property immediately north and south along the Highway 31
(Birmingham Highway) corridor, and east on the opposite side of
this corridor, are zoned for "general industry". Under this
classification, various industries are permitted such as light
industrial operations, etc.
USEPA OSWER Directive No. 9355.7-04 entitled, Land Use in the
CERCLA Remedy Selection Process (USEPA, 1995), states that "while
many Superfund sites have multiple uses, typically EPA expects
that the vast majority of sites with current industrial/
commercial uses will continue to be used as commercial or
industrial sites". The directive further states "future
industrial land use is likely to be a reasonable assumption where
a site is currently used for industrial purposes, is located in
an area where the surroundings are zoned for industrial use, and
the comprehensive plan predicts the site will continue to be used
for industrial purposes." All three of the prerequisites are met
21
-------
at the THAN site.
As discussed in the directive, the application of this directive
may be most relevant where surface soil is the primary exposure
pathway, which also is applicable to the Site.
6.3 ECOLOGICAL RISK
An ecological assessment has also been conducted to address the
potential risks of site-related contaminants to ecological
receptors, including the marsh/drainage areas portions of the
Site (selected tables from this document are included as Appendix
D) . It is noted that the marshy area on the THAN property was
not found to present an ecological risk, presumably due to the
cleanup activity undertaken on the THAN property in 1981 (See
Section 2.0).
As noted in Section 5.3.3.2, offsite sediment sampling indicated
contaminant levels fall off rapidly along the drainage pathway
leading south-southwest from the site. The Ecological Risk
'Assessment included community assessment studies, toxicity
testing, and food-web modeling using contaminant concentrations
from the tissue residue of prey items.
Community Assessment Results
Community assessment studies included evaluation of plant and
macrobenthic communities for site related location and reference
areas. The plant community analysis indicated a slightly greater
species abundance, species richness, and species diversity
present in the test areas as compared to the reference areas.
The macroinvertebrate species analysis indicated similar average
abundance, species richness, species diversity, and equatability
and evenness between test and reference areas.
Toxicitv Test Results
Toxicity tests were conducted using Ceriodaphnia dubia (48 hour
elutriate test), Pimephales promelas, fathead minnow (48 hour
elutriate test), Chironomus tentans, midge (ten day whole
sediment assay), and Eisenia andri, earthworm (fourteen day soil
assay). Results from the Ceriodaphnia test showed significantly
lower survival in one (0 % survival) of the two East Ditch
locations and one (50 % survival) of three from Area 3 (the
drainage area between the Power Transmission Lines to Hunter Loop
Road) compared to the appropriate reference locations. Results
from the Pimephales bioassay showed significantly lower survival
for both locations in the East Ditch (10 % and 83 % survival) and
for two of three locations in Area 3 (30 % and 63 % survival)
versus the appropriate control stations.
The Chironomus test showed low survival (0-14 %) including
22
-------
reference locations. East Ditch locations show 0% and 4%
survival versus 2% survival in the East Ditch Reference location.
The Area 1 locations showed survival from 0% to 2% compared to
10% survival in the Area 1 Reference location. The Area 2
locations showed ) 0% to 8% survival compared to 0% in the Area 2
Reference location. The Area 3 locations showed survival from 0%
to 14%.
The Eisenia tests showed significantly lower survival in one Area
2 (the drainage area southwest of the facility between the Dirt
Haul Road and the Power Transmission Lines) location (83%) and
one Area 3 location (77%) compared to the Area 2 Reference
location (100%).
Food~Web Modeling
The assessment endpoints related to the food-web modeling would
be expected to be the more sensitive endpoints given the mode of
toxicity, and fate and transport of the site-related contaminants
(organochlorine pesticides). The assessment endpoints evaluated
were avian piscivores (fish-eating birds), avian insectivores,
and mammalian omnivores. Prey item concentration, as well as
abiotic media levels, are used as input parameters in the food
web models to estimate exposure to ecological receptors.
The food web model (Procyon lotor, Raccoon) for the mammalian
omnivore assessment endpoint showed no unacceptable risks for any
location. The food web model (Butorides virescens, Green Heron)
for the avian piscivore showed unacceptable risks for the East
Ditch, Area 1 and Area 2. The food web model for the avian
insectivore showed unacceptable risks for the East Ditch, Area 1
and Area 2 (see Table 4-6 in Appendix D).
6.4 CONTAMINANTS OF CONCERN (COCs)
Human Exposure
COCs for soils, sediments, and groundwater were identified in the
BRA, using data from the RI, and are shown on Table 17 in
Appendix C. These COCs were identified based on a carcinogenic
risk of 10-6 and a Hazard Quotient of 0.1 for non-carcinogens.
Using these criteria, the BRA identified 20 COCs in soil and 8
COCs in sediment, for a residential land use (adult and child
resident). For an industrial land use (site visitor) there were
2 COCs for soil and 1 COC for sediment.
Table 1 shows the 18 compounds that were detected in groundwater
at levels above drinking water standards during the January, 1996
sampling round. In addition to Maximum Contaminant Levels (MCL)
set by EPA for drinking water, these standards include risk-based
performance standards using a cancer risk of 10-5 for an adult
resident.
23
-------
Five of these compounds were found during the October, 1997
sampling round to have fallen to levels below drinking water
standards. However, they are shown on Table 1 for purposes of
illustrating the declining levels of these contaminants in the
groundwater. For comparison, there were 23 compounds found in
groundwater during the 1993 RI, at levels above drinking water
standards.
Soil Levels Protective of Groundwater
In addition to the risk-based soil performance standards for
inhalation, ingestion and dermal contact, soil clean-up levels
(action levels) protective of ground water were calculated.
These action levels are based on the prevention of soil leachate
migration into ground water which would cause the ground water
performance standard to be exceeded. Kay Wischkaemper's memo to
Alan Yarbrough dated August 27, 1996 presents the development of
these action levels. When site soil concentrations were compared
to the action levels protective of ground water, delta-BHC was
the only compound that could potentially pose a threat to ground
water quality via leaching through soil. The maximum soil
concentration detected at the site for delta-BHC was 200 mg/kg.
The calculated action level for delta-BHC of 143 mg/kg would
prevent the risk-based ground water performance standard shown in
Table 1 from being exceeded (note that there is no Federal
Maximum Contaminant Level, or MCL, for delta-BHC... the
performance standard is based on the risk-based performance
standards calculated in the Risk Assessment for the site
contaminants). Delta-BHC is not shown in the soil performance
standard table; however, treatment of delta-BHC to the action
level of 143 mg/kg will occur due to it's coexistence with other
soil contaminants that will be in the body of soil/sediment
treated in the in-situ biological cell(s).
Ecological
Finally, from an ecological perspective, hazard indices
indicating unacceptable risks are driven by the DDT isomers 2,4'-
DDD, 4,4' -DDD, and 4,4'-DDE. The food web models discussed in
the previous section were back-calculated to determine
Preliminary Ecological Sediment Values (PESVs) that would be
protective for a given risk level (see Table 5-1 in Appendix D).
Assuming a Hazard Quotient of 1.0, these PESVs ranged from 0.39
ppm for 2, 4'-DDD; 0.023-0.19 ppm for 4,4'-DDD; and 0.13-0.21 ppm
for 4,4'-DDE (see Table 5-1 in Appendix D). These PESV values
provide a starting point for the determination of ecological
remedial goals for these COCs. Other information used in making
the determination of the remedial goals may include: the
distribution and concentration of the contaminants; the
feasibility of remedial action including such factors as
comparison to reference locations, the quantity and quality of
the habitat destroyed by the remedial action and its ability to
24
-------
be restored; and the uncertainty associated with and the
assumptions used for in the Ecological Risk Assessment.
Background values for COCs in offsite sediments are shown on
Table 3-2 in Appendix 3-2. The 4,4-DDTr isomers were the only
pesticides detected, and averaged up to 3.5 ppt, 15.3 ppt, and
1.9 ppt for 4,4'-ODD, 4,4'-DDE, and 4,4'-DDT, respectively.
Table 2-2 in Appendix D shows the offsite sediment sample results
obtained from the Supplemental Remedial Investigation, and
provides a basis for comparison to the PESVs and the background
levels found. As can be seen, pesticide levels fall off rapidly
as you move along Area 1 towards Area 4, which borders Catoma
Creek.
7.0 DESCRIPTION OF ALTERNATIVES FOR SOILS/SEDIMENTS REMEDIATION
Six alternatives for the remediation of contaminated soils and
sediments at the THAN Site were evaluated in the Feasibility
Study Report for Operable Unit Two (OU2), revised July, 1996.
These six alternatives were listed in the Proposed Plan for OU2.
These alternatives represent a range of distinct waste-management
strategies addressing human health and environmental concerns.
Although the selected remedial alternative will be further
refined as necessary during the design phase, the analysis
presented below reflects the fundamental components of the
various alternatives considered feasible for this Site. Table 3
lists each alternative, along with implementation times and
estimated costs.
As previously discussed in Section 5.3.6, and for the purpose of
evaluating remedial alternatives, the volume estimates shown for
each of the five areas (Areas "A", "B", "C", "D", and "E") on
Figure 3-2 have been utilized. However, since one of the
objectives of the FS is to provide an estimate of costs
associated with a remedial action, a sensitivity analysis was
performed with the objective of examining the upper and lower
limits of soil and sediment that are expected to be remediated.
The range of volumes given for a particular response action is
intended to represent a "reasonable range" of impacted soil or
sediment based on the number and location of samples collected
during the RI, and the resulting areas delineated around these
sample locations. For example, in areas where the sampling grid
was more closely spaced, such as Areas "B", "C", and "D", the
range used for volume estimates is expected to be narrower.
However, in Areas "A" and "E", where sample locations are more
spread out, the range used for volume estimates is greater due to
fewer sample locations. Soil and sediment data summaries and
isoconcentration maps presented in the Final RI Report (these
maps are part of the Administrative Record for OU2, and are not
included here- see section 5.3) were evaluated to estimate these
areas. Therefore, the limits of a given area are defined by
25
-------
evaluating adjacent sample locations and their concentrations.
The following detailed evaluations further addresses the
estimated volume ranges, such that the impact of potentially
higher remedial volumes will be reflected in the overall costs
and evaluation of alternatives.
7.1 ALTERNATIVE NO. 1 - NO ACTION
The National Oil and Hazardous Substances Pollution Contingency
Plan (NCP) requires that a No Action alternative be evaluated as
part of the screening process, in order to provide a baseline for
comparison to other alternatives. Under this alternative for
OU2, no further actions would be taken to address the soil and
sediment at the Site. A review of the conditions at the Site
would be performed at five-year intervals to evaluate whether the
remedy is still protective of public health and the environment.
Extraction and off-site treatment of groundwater would continue
to be conducted in accordance with the groundwater remedial
action.
7.2 ALTERNATIVE NO. 2 - INSTITUTIONAL CONTROLS
This alternative consists of the use of institutional controls,
including deed or use restrictions and fencing and gates,
implemented for the portion of the Site in which controls do not
already exist and for areas off-site where soil and sediment
concentrations exceed RGOs. A land deed and/or some other legal
instrument that is normally examined during a title search would
address the property.to be controlled and will notify potential
owners of the property. Institutional controls would also be
used to notify workers of residual risks and/or restrict
access/use of the Area. A 6 foot high chain link security fence
would be installed along the western boundary of the THAN
property, and would replace the existing barbed wire fence. In
addition, deed or land use restrictions would be established for
all five areas, and work protocols and signs would be setup for
the two off-site areas.
Currently, existing Site controls include secured buildings and a
fence, which consists of a six-foot chain link fence along the
eastern, northern, and southern Site property boundaries, and
along the western 1C property boundary. The fence along the
western and a portion of the northern THAN property boundary
consists of three strands of barbed wire. With the exception of
the existing egress from the Birmingham Highway, no other access
exists for the Site.
Periodic site inspections and routine maintenance, which includes
keeping the buildings secured and in good repair, would also be
implemented. A soil and sediment monitoring plan will also be
implemented and will consist of collection of a limited number of
surface soil and/or sediment samples collected annually and
26
-------
analyzed for a focused list of constituents. Extraction and off-
site treatment of groundwater would continue to be conducted in
accordance with the groundwater remedial action. A review of the
Site conditions would be performed at five-year intervals to
evaluate whether the remedy is still protective of public health
and the environment.
7.3 ALTERNATIVE NO. 3A/3B - ON-SITE CONSOLIDATION AND
CONTAINMENT
This alternative includes the excavation of sediment from off-
site areas, consolidation and containment of soil and sediment
on-site, and the implementation of on-site institutional
controls.
Removal of sediment from off-site Areas "A" and "E" and of soil
from portions of Areas "B" and "D" would be followed by the
consolidation of excavated material in the western corner of the
1C property (Area C) . A soil cover (Option A) or composite cap
(Option B) would then be placed over the consolidated material to
prevent direct contact and reduce infiltration. The portions of
Areas "B" and "D" requiring removal include the portions that lie
off site and a portion that lies on site, but too close to the
property boundaries to allow placement of the cover.
The estimated ranges of soil and sediment requiring excavation
under Alternative No. 3 are as follows:
Area A: 300 to 600 cubic yards
AreaB (a portion) : 275 to 525 cubic yards
AreaD (a portion) : 40 to 75 cubic yards
Area E: 1,900 to 3,700 cubic yards
This results in a combined estimated range of 2,515 to
4,900 cubic yards (in place) to be excavated and consolidated on-
site. This anticipated volume of excavated soil and sediment
will require placement of an approximately 2- to 3-foot thick
layer (excluding the cover) over 1 acre. The area proposed for
consolidation is primarily Area C, plus portions of Areas B and
D. This area of the Site is the most logical area to consolidate
excavated material since some of the underlying soil (Areas "B",
"C", and "D") exceeds RGOs. The consolidation area would require
only minimal site preparation such as clearing and grading.
Removal of off-site soil or sediment would be performed using
conventional construction equipment and methods such as an
excavator and bulldozer. Excavated material would be transported
by truck from Area "E" to the designated consolidation area.
Depending on Site conditions at the time of sediment removal
(i.e. precipitation, stormwater runoff, standing water, ability
of soil to support heavy equipment, etc.), more specialized
27
-------
excavation equipment may be necessary. A temporary access road
to and a soil berm around Area "A" may be necessary- These
contingencies are reflected in the cost estimate. Subsequent to
the completion of excavation, Areas "A" and "E" and the excavated
off-site portions of Areas "B" and "D" would be backfilled with a
clean fill from an off-site source, compacted, and then
revegetated to provide adequate cover and reduce erosion.
Engineering considerations for the Site, especially in Areas "A"
and "E", during removal operations include: protection of the
excavation area during removal operations from stormwater by
berming or shoring the area; maintenance of normal stormwater
conveyance in the east ditch by phasing removal activities at
Area "E" so that a limited portion is being excavated at any
given time, or stormwater diversion; dewatering excavation areas
by pumping incident precipitation entering the excavation into a
temporary staging area prior to its discharge into the on-site
sewer system; solids removal for stormwater which has entered the
excavation area; limiting the disturbance of surrounding areas
not designated for excavation which, in turn, would minimize
constituent mobility and transport and unnecessary damage to the
environment; and the conduct of ambient air monitoring during
construction activities.
Upon consolidation of soil and sediment in the western corner of
the 1C property, a soil cover (Option A) or a composite cap
(Option B) would be placed over the excavated material, then
graded and vegetated to promote positive drainage and reduce
infiltration. The area for consolidation and containment is
shown on Figure 4-1. The two cover options proposed in this
alternative consist of the following elements (from top to
bottom):
Option A - Soil Cover (see Figure 4-2):
• 6 inches of topsoil with vegetative cover
• 6 inches of clean fill material overlying impacted
soil and sediment
Option B - Composite Cover (see Figure 4-3):
• 6 inches of topsoil with vegetative cover
• 18 inches of fill
• geocomposite (geotextile and drainage layer (geonet)
overlying geomembrane)
• 18 inches of soil that has a permeability no greater
than 1 x 10"5 cm/s
Engineering controls common to both cover options include:
implementation and maintenance of erosion control measures by
grading (minimum 5 percent) and establishing a vegetative cover
(placement of an appropriate species of grass seed, fertilizer,
and mulch); watering and maintenance necessary such that
germination can reasonably be anticipated; and preventing run-on
28
-------
and runoff from eroding or damaging the final cover. Typical O&M
activities include periodic inspection of the cover for cracks,
adequate vegetative cover, integrity, and erosion; mowing;
fertilizing/reseeding; and repair of damaged areas, as needed.
Institutional controls, similar to those discussed in Alternative
No. 2, would be implemented for this alternative. Institutional
controls for off-site areas would not be necessary. In addition,
a six-foot high chain link security fence would be placed between
the consolidated area and the rear of the 1C building. This
fence would restrict vehicles from gaining access. Post-closure
land use of this area would not permit disturbance of the final
cover. Extraction of groundwater would continue to be conducted
in accordance with the groundwater remedial action. A review of
Site conditions would be performed at five-year intervals to
evaluate whether the remedy is still protective of public health
and the environment.
7.4 ALTERNATIVE NO. 4A/4B - REMOVAL, THERMAL TREATMENT, AND
REPLACEMENT
This alternative includes excavation from Areas "A", "B", "C",
"D", and "E", on-site treatment with low temperature thermal
desorption, and replacement of treated soil and sediment.
Treatment of sediment and soil would be conducted at a central
location from which equipment and material staging operations
would be based. Depending on the moisture and physical
characteristics of the soil and sediment, dewatering, mixing, and
material sizing operations may be necessary prior to treatment.
Low temperature thermal desorption utilizes heat to volatilize
constituents from soil, sediment, and sludge. Low temperature
thermal desorption differs from incineration in that the former
uses an indirect heat source and relatively small gas flows are
used to desorb constituents from the affected media to a
downstream unit for recovery or destruction, while the latter
places the affected media directly in the heat source where the
constituents are at least partially destroyed. The lower
temperatures, typically 600°F to 1,000°F for thermal desorption
compared to 1,500°F to 2,000°F for incineration, greatly reduce
the energy costs, while the smaller gas flows reduce the off-gas
treatment system costs.
Excavated soil is transferred from a stockpile to a feed system,
typically consisting of a shredder and conveyor belt leading to a
hopper, which delivers the soil to the thermal processor.
Typically, soil is moved through the thermal processor by means
of a heated screw through which hot oil circulates or, more
commonly, a rotating dryer is used. Volatilized compounds are
transported from the thermal unit to a gas treatment unit by a
relatively low flow of gas that may be an inert gas such as
nitrogen or partially deoxygenated air. Gas treatment may
29
-------
adsorption, or thermal oxidation. The soil is quenched in a
jacketed screw or a pug mill with water to permit further
handling.
Thermal desorption would involve on-site treatment of impacted
soil and sediment at elevated temperatures. Commercial low
temperature thermal desorption units are available from various
vendors in sizes ranging from 5 tons per hour to 45 tons per
hour.
Bench-scale treatability tests performed on impacted Site soil
showed that overall removal efficiencies of constituents at a
temperature of 800°F were good at 99.96 percent. The extent of
removal of volatiles was also to be determined, however, it was
realized that if performance with respect to pesticides was
satisfactory, volatile constituents would be removed well below
levels of potential interest. Upon treatment, excavated areas
would be backfilled with the treated material, compacted, and
revegetated. Post-treatment material handling (e.g., addition of
water) may be required. Residuals and off-gases generated during
treatment would be treated on site or condensed and transported
off site for appropriate treatment. Upgrades for existing
electric and natural gas connections may be required.
Volumes of soil and sediment potentially requiring excavation and
treatment are estimated below and are shown on Figure 3-2:
Area A: 300 to 600 cubic yards
Area B: 575 to 1,125 cubic yards
Area C: 150 to 300 cubic yards
Area D: 75 to 150 cubic yards
Area E: 1,900 to 3,675 cubic yards
This results in a combined volume estimate ranging from 3,000 to
5,850 cubic yards (in place) requiring excavation and treatment.
Processing requirements for the feed material may include
dewatering via air drying, bar screening to remove debris, and a
series of vibratory screening steps to reduce the material size.
Weather and soil conditions resulting in more aggressive
excavation and/or processing efforts will be reflected in the
cost.
Institutional controls would be implemented as described for
Alternative No. 2. The groundwater remedial action (OU1) and
associated Site monitoring would continue. A review of Site
conditions would'be performed at five-year intervals to evaluate
whether the remedy is still protective of public health and the
environment.
30
-------
7.5 ALTERNATE NO. 5A/5B - REMOVAL. BIOLOGICAL TREATMENT, AND
REPLACEMENT
This alternative includes excavation, consolidation, and on-site
biological treatment using an aerobic/anaerobic process followed
by replacement of treated soil and sediment. This particular
process was considered in a Treatability Study Evaluation Report.
This alternative considers ex-situ (Option A) and in-situ (Option
B) treatment applications. The areas/volumes of soil to be
treated are identical to that described in Alternative 4.
Factors and considerations relative to removal of soil and
sediment are also identical to those discussed for Alternative
No. 4. Additional considerations for the ex-situ application
include the immediate backfill and revegetation of areas to be
excavated due to the potential extended time the soil and
sediment would be undergoing treatment to meet Performance
Standards. Treated soil will be subsequently placed on-site,
graded, and revegetated to reduce erosion and infiltration.
The process under consideration alternately generates anaerobic
and aerobic conditions. The anaerobic conditions result in
dechlorination of the pesticides, while the aerobic conditions
result in further degradation of the dechlorinated intermediates.
The ex-situ process requires preparation of a reaction bed where
the cyclic process can be conducted. Soil and sediment may be
dewatered or mixed with a solid matrix that can support earth
moving equipment. The soil and sediment is then placed on a
lined and covered area to a depth of approximately two feet.
Amendments are applied using a tractor-mounted rotary tiller.
The tiller has an effective penetration of approximately two feet
and serves to homogenize the amended soil and aerate the soil
when aerobic or (oxic) conditions are required. When anaerobic
(also known as anoxic) conditions are required, additional
reagents and water are blended into the soil matrix and then a
cover is placed over the soil matrix to minimize aeration. The
amendments serve to reduce the oxidation/reduction potential and
consume available oxygen. The added moisture mitigates against
further intrusion of oxygen.
The in-situ process can also be conducted for the treatment of
surficial soil or sediment. For the in-situ process, debris,
rocks, etc. may require removal that is accomplished through the
use of a subsurface ripper and/or agriculture rock picker. Due
to the physical constraints, Areas "A" and "E" could be
consolidated on-site over the portion of the Site that includes
Areas "B", "C", and "D". The consolidated material would be
placed in no more than a 1 foot thickness and the entire area
would then be treated "in-situ".
Following each anaerobic/aerobic cycle, the effectiveness of the
treatment process will be monitored. Chloride content is
measured because it is a byproduct of dechlorination and can be
31
-------
utilized to confirm degradation is occurring. Moisture and pH
are also measured to determine if soil/sediment matrix conditions
are within acceptable limits. The process would continue until
Performance Standards are met.
Under this alternative, institutional controls would be
implemented as described for Alternative No. 2. Extraction and
off-site treatment of groundwater would continue to be conducted
in accordance with the groundwater remedial action for OU1. A
review of Site conditions would be performed at five-year
intervals to evaluate whether the remedy is still protective of
public health and the environment.
7.6 ALTERNATIVE NO. 6 - REMOVAL AND OFF-SITE DISPOSAL
This alternative includes excavation and off-site disposal of
impacted soil and sediment at a permitted waste facility. The
volume of soil and sediment applicable to this alternative is
identical to that presented for Alternative No. 3. Soil and
sediment from Areas A, B, C, D, and E would be excavated, hauled
to a central on-site location, dewatered (if necessary), and
placed into over-the-road trucks for off-site transport.
Excavated areas would be backfilled and revegetated to reduce
erosion and infiltration. The material would be properly shipped
in accordance with 29 CFR (Department of Transportation) shipping
regulations. Depending on the moisture and physical
characteristics of the soil and sediment, some additional
material handling (such as dewatering) may be required prior to
loading onto trucks for off-site transport. Dewatering
operations would likely include pumping prior to excavation,
followed by air drying, subsequent to excavation. Weather and
soil conditions resulting in more aggressive excavation and/or
dewatering efforts will be reflected in the cost.
The cost estimates for this alternative presume that
characterization of the material excavated, as determined by the
Toxicity Characteristic Leaching Procedure (TCLP), will show the
majority of the material to be non-hazardous. As such, it is
anticipated that most of the material would be sent to a Subtitle
D landfill, with the remainder (soils/sediments that are
characterized "hazardous waste" based on the TCLP test) being
sent to a permitted hazardous waste facility.
Discussion of the "likelihood" that the excavated material passes
or fails TCLP testing is somewhat premature and qualitative.
However, a qualitative evaluation of site soil and sediment data
has been performed, wherein the analytical database was queried
for sample results that might be expected to fail a TCLP test.
This data evaluation was based on levels detected, areal extent,
and the soil adsorption characteristics of the contaminants of
concern. The data evaluation showed that individual samples for
the various constituents with concentrations that appear likely
32
-------
to exceed TCLP criteria were only seen sporadically in Areas A,
B, C, D, and E, primarily in the surficial soil interval (0 to
1 feet) and in the sediment sampled within the storm sewer
(included with Area E). However, considering the fact that the
constituents evaluated strongly adsorb to soil and sediment, and
the fact that the sample locations were sporadic and spread out,
it is likely that most, if not all, of the soil would be
nonhazardous once it is excavated and characterized.
Institutional controls would be implemented as described for
Alternative No. 2. The groundwater remedial action (OU1) and
associated Site monitoring would continue. A review of Site
conditions would be performed at five-year intervals to evaluate
whether the remedy is still protective of public health and the
environment.
8.0 SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES FOR
SOILS/SEDIMENTS REMEDIATION
This section of the ROD provides the basis for determining which
alternative provides the best balance with respect to the
statutory balancing criteria in Section 121 of CERCLA and in
Section 300.430 of the NCP. The major objective of the
feasibility study was to develop, screen, and evaluate
alternatives for the remediation of OU2 at the THAN site. The
remedial alternatives selected from the screening process 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.
• Long-term effectiveness and permanence.
• Reduction of toxicity, mobility, or volume of hazardous
substances or contaminants.
• Short-term effectiveness, or the impacts a remedy might
have on the community, workers, or the environment during
the course of implementing it.
• Implementability, that is, the administrative or technical
capacity to carry out the alternative.
• 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.
33
-------
The NCP categorizes the nine criteria into three groups:
(1) Threshold Criteria - overall protection of human health
and the environment and compliance with ARARs (or
invoking a waiver) are threshold criteria that must be
satisfied in order for an alternative to be eligible for
selection;
(2) Primary 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.
The selected alternative must meet the threshold criteria and
comply with all ARARs or be granted a waiver for compliance with
ARARs. Any alternative that does not satisfy both of these
requirements is not eligible for selection. The Primary
Balancing Criteria are the technical criteria upon which the
detailed analysis is primarily based. The final two criteria,
known as Modifying Criteria, assess the public's and the state
agency's acceptance of the alternative. Based on these final two
criteria, EPA may modify aspects of a specific alternative.
The following sections provide a summary of the evaluation of
alternatives for remediating soils/sediments under OU2 at the
Site, for each of the criteria. A comparison is made between
each of the alternatives for achievement of a specific criterion.
8.1 OVERALL PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
Except for Alternative No. 1, each of the remedial alternatives
provides some degree of protection of human health and the
environment. However, Alternative No. 2 provides only a limited
amount of protection over Alternative No. 1, and neither of these
alternatives would satisfy this criteria for overall protection
of human health and the environment. Each of the remaining
alternatives would be adequate with respect to this criteria.
34
-------
TABLE 3 - DESCRIPTION OF CLEANUP ALTERNATIVES- SOILS/ SEDIMENTS
EPA evaluated six alternatives identified in the Feasibility Study (FS) for remediating contaminated soils and sediments related to the THAN Site. The following table lists each
alternative, along with a short description, total present worth cost, and implementation time required. See Sections 7.1 through 7.6 of the FS for a complete discussion of each
alternative. The only exception is Alternative 5, Option B: "Removal, Biological Treatment, and Replacement- Insitu". This alternative reflects a cost that was updated in June,
1998.
Alternative and Explanation
Totil Cost
$ Thominds
Implementation
Time
ALTERNATIVE No. 1. No Action
The National Oil and Hazardous Substances Pollution Contingency Plan (NCP) requires that a No Action alternative be evaluated as part of the screening process, in
order to provide a baseline for comparison to other alternatives. Under this alternative for OU2, no further actions would be taken to address the soil and sediment at
the Site.
• 0-
-0-
ALTERNATIVE No. 2 • Institutional Controls
This alternative consists of the use of institutional controls, including deed or use restrictions and fencing and gates, implemented for the portion of the Site in which
controls do not already exist and for areas off-site where soil and sediment concentrations exceed Performance Standards. Periodic site inspections and routine
maintenance would be performed.
220
• 0-
ALTERNATTVE No. 3 - Onrite Consolidation and Containment
This alternative includes the excavation of sediment from off-site areas, consolidation and containment of soil and sediment on-site, and the implementation of on-site
institutional controls. Removal of sediment from off-site Areas "A" and "E" and of soil from portions of Areas "B" and "D" would be followed by the consolidation of
excavated material in the western corner of the 1C property (Area C). A soil cover (Option A) or composite cap (Option B) would then be placed over the consolidated
material to prevent direct contact and reduce infiltration.
A:
567-1,326
B:
795-1,554
9-18 months
ALTERNATIVE No. 4 • Removal, Thermal Treatment, and Replacement
This alternative includes excavation from Areas "A", "B", "C", "D", and "E", on-site treatment with low temperature thermal desorption, and replacement of treated soil
and sediment. Treatment of sediment and soil would be conducted at a central location from which equipment and material staging operations would be based.
Depending on the moisture and physical characteristics of the soil and sediment, dewatering, mixing, and material sizing operations may be necessary prior to
treatment.
1,911-
3,574
12-17
months
ALTERNATIVE No. 6 - Removal. Biological Treatment, and Replacement
This alternative includes excavation, consolidation, and on-site (in situ or ex situ) biological treatment using an aerobic/anaerobic process followed by replacement (for ex
situ option) of treated soil and sediment. This alternative considers ex-situ (Option A) and in-situ (Option B) treatment applications. The areas/volumes of soil to be
treated are identical to that described in Alternative 4, as are factors and considerations relative to removal of soil and sediment. Additional considerations for the
ex-situ application include the immediate backfill and revegetation of areas to be excavated due to the potential extended time the soil and sediment would be
undergoing treatment to meet RGOs. Treated soil will be subsequently placed on-site, graded, and revegetated to reduce erosion and infiltration.
A:
1,181-
2,637
B:
723-1,382
2-4 years
ALTERNATIVE No. 6 • Removal and Off-site Diapoaal
This alternative includes excavation and off-site disposal of impacted soils and sediments at a permitted waste facility (Subtitle D landfill for nonhazardous waste). The
volume of soil and sediment applicable to this alternative is identical to that presented for Alternative No. 4. Soil and sediment from Areas "A", "B", "C", "D", and "E"
would be excavated, hauled to a central on-site location, dewatered (if necessary), and placed into trucks for ofT-site transport. Excavated areas would be backfilled and
revegetated to reduce erosion and infiltration. Final cost would vary according to how much material would be require disposal at a permitted hazardous waste facility.
845-1,889
10-12
months
35
-------
8.2 COMPLIANCE WITH ARABS
Alternative Nos. 3, 4, and 5 would require designation of those
areas exceeding performance standards as a corrective action
management unit (CAMU), in order to comply with EPA's Resource
Conservation and Recovery Act (RCRA) regulations with respect to
land disposal restrictions (LDRs). Alternative No. 3B would meet
the Alabama solid waste requirements for cover design for a waste
characterized as non-hazardous; however, Option A would not.
Each of Alternatives No. 3 through 6 would meet location- and
action-specific ARARs such as meeting the substantive
requirements for soil erosion and sedimentation for disturbed
areas, stormwater discharge, applicable regulations for waste
handling, etc. Alternative Nos. 4 and 5 would comply with all
ARARs by reducing the levels of constituents of interest in soils
to or below the performance standards.
The only alternatives that would not be adequate with respect to
this criteria would be Alternatives No. 1, 2, and 3A.
8.3 LONG-TERM EFFECTIVENESS AND PERMANENCE
With the exception of Alternative Nos. I and 2, each of the
alternatives would provide good long-term effectiveness.
However, some long-term effectiveness is realized by Alternative
Nos. 1 and 2 due to natural attenuation and biodegradation.
Alternative No. 3B would provide for a slight increase in long-
term effectiveness over Option A since the benefits of synthetic
materials include long-life and reliability. Alternative Nos. 4
and 5 provide the greatest long-term effectiveness for the soil
and sediment which currently exceed performance standards.
However, Alternative No. 6 does provide an equivalent long-term
effectiveness relative to the site itself.
These comparisons of long-term effectiveness presume
institutional controls will maintain an industrial land use for
the Site.
8.4 REDUCTION OF TOXICITY. MOBILITY, OR VOLUME THROUGH TREATMENT
Based on treatability study results, Alternative No. 4 would
provide for the greatest reduction of mobility and toxicity of
impacted soils (followed closely by Alternative No. 5).
Following Alternative Nos. 4 and 5, Alternative No. 6 provides
the next best opportunity for reducing mobility, toxicity, and
volume on the site. Alternative No. 3 provides reduction in
mobility for all of the alternatives evaluated, but provides
little reduction of toxicity and volume. Comparing Options A and
B of Alternative No. 3, slightly higher levels of reduction of
mobility are provided by Option B because of the more stringent
containment components (i.e., synthetic liner). Alternative
Nos. 1 and 2 do not provide any reduction of mobility, toxicity,
36
-------
or volume.
8.5 SHORT-TERM EFFECTIVENESS
With the exception of the Alternative No. 1, protection of human
health and the environment would begin immediately upon
completion of each alternative. The most favorable alternatives
regarding short-term effectiveness are presented by Alternative
Nos. 1 and 2, which require the least amount of material
handling, can be implemented quickest, and result in the lowest
amount of potential human and environmental exposure to Site
constituents. The next most favorable situation is presented by
Alternative No. 3, which would require a marginal increase in
material handling and potential human and environmental exposure
to Site constituents. For Alternative No. 3, there would be a
noticeable difference between Option A and B, since the
implementation period for Option B would increase, as would the
potential for exposure. The next most favorable alternative
would be No. 6, which would result in offsite disposal but which
would entail excavation activities beforehand. The least
favorable situation with regard to short-term effectiveness is
created by Alternative No. 5 which provides the greatest amount
of material handling, requires the longest implementation time,
and therefore increases the potential human and environmental
exposure to Site constituents. However, engineering process
controls and on-site health and safety measures would be designed
to address these potential short-term exposures. Please see the
Responsiveness Summary for EPA responses to issues 12 and 16.
8.6 IMPLEMENTABILITY
Each of the six alternatives evaluated are considered readily
implementable. In order, Alternative Nos 1,2,6,3A,3B,4,5A, and
5B would provide, an increasing degree of difficulty in
implementation. The treatment alternatives. No. 4 and 5, will
require more advanced equipment, facilities, and specialists for
design, construction, and implementation. In addition,
Alternative No. 5 will require pilot scale testing prior to
implementation. The time required to implement each of the
alternatives is also reflected by the order presented here.
The cost estimate summary for the six alternatives is presented
in Table 3. Total costs for each alternative include estimated
capital costs, as well as associated O&M costs once the
alternative has been implemented. In order to compare
alternatives on an equal basis, the present worth of annual O&M
costs was calculated for a period of 30 years at a 7 percent
interest rate. All of the alternatives except for the No
Action alternative (No. 1) have capital costs associated with
implementation. Alternative 4 has the highest estimated capital
37
-------
cost range, while Alternative 2 has the lowest. Alternative 3B
has the highest O&M cost. Based on the present worth of O&M
costs, Alternative 4 is the most expensive while Alternative
No. 1 (No Action) is the least expensive.
All costs shown on Table 3 are taken from the Feasibility Study
for OU2, which was completed in 1996, except for Alternative 5,
Option B, in-situ biological treatment. The costs for this
option was updated in June, 1998, and reflected a lower cost due
to increased experience with the technology. The corresponding
costs for the ex-situ biological treatment, Option A, was not
updated, since the increased cost of the ex-situ option was not
considered justified (the original FS costs reflected a $619,000
dollar difference between ex-situ and in-situ treatment).
For the reader's reference, the following cost breakout is
provided for each alternative, as a supplement to Table 3, where
O&M represents annual operation and maintenance costs:
Alternative Capital Cost O&M Cost
No. / Description ($) ($/year)
1 - No Action 0 0
2 - Institutional Controls 55,000 13,300
3A - On-site Consolidation and 478,000 - 1,237,000 7,200
Containment - Soil Cover
3B - On-site Consolidation and 685,000 - 1,444,000 8,900
Containment - Composite Cover
4 - Removal, Thermal Treatment, 1,895,000 - 3,558,000 1,300
and Replacement
5A - Bioremediation (Ex-Situ) and 1,165,000 - 2,621,000 1,300
Replacement
5B - Bioremediation (In-Situ) and 706,900 - 1,365,900 1,300
Replacement
6 - Removal and Off-Site Disposal 829,000 - 1,873,000 1,300
Total Present Worth'
($)
0
220,000
567,000 - 1,326,000
795,000 - 1,554,000
1,911,000 - 3,574,000
1,181,000 - 2,637,000
723,000 - 1,382,000
845,000 - 1,889,000
• Present Worth = Capital Cost + (O & M x 12.409).
The cost ranges given for Alternatives 3-6 reflect the
uncertainty associated with the exact amount of soils to be
38
-------
remediated (see Section 5.3.6). The high range reflects an
assumed soil volume of 5,850 cubic yards to be treated.
It is noted here that the present worth cost for the groundwater
remedy was documented in the Record of Decision (ROD) for OU1.
The total cost for the groundwater remedy was $6,100,000, based
on a capital cost of $1,305,000 and an annual O&M cost of 511,000
(the Present Worth factor assumed at that time was 9.384, based
on a 10% interest rate, and has not been changed for purposes of
this OU2 ROD). The actual cost associated with the groundwater
remedy will depend on the number of years it takes to reach
groundwater performance standards (see Section 9.1.1).
Thus, the total present worth cost associated with remediating
both soils/sediments and groundwater is estimated at $7,482,000.
8.8 STATE ACCEPTANCE
The State of Alabama, as represented by the Alabama Department of
Environmental Management (ADEM), has assisted in the Superfund
process through the review of documents and submittal of
comments. The State has reviewed the Proposed Plan and OU2 ROD
and concurs with the selected remedy.
8.9 COMMUNITY ACCEPTANCE
Based on the comments expressed at the August 13, 1998 public
meeting and recorded in the transcript thereof (no written
comments were received during the comment period), the community
in the vicinity of the site does not oppose the biological
treatment of impacted soils and sediments, with a contingent
remedy in place to have these soils and sediments removed and
disposed off-site if necessary.
9.0 THE SELECTED REMEDY
Based upon CERCLA requirements, the NCP, the detailed analysis of
alternatives, and public and state comments, EPA has determined
that the activities as described in Alternative No. 4 (Removal,
Biological Treatment, and Replacement, Zn-situ Option) constitute
an appropriate remedial action for the Site. Alternative No. 6
(Removal and Off-site Disposal) will be the contingent remedy,
and will be invoked as necessary and as discussed below.
Institutional controls will be put in place that will limit the
future use of the Site to industrial purposes only. Designation
of the areal extent of contamination as a Corrective Action
Management Unit (CAMU) will be necessary to comply with Resource
Conservation and Recovery Act (RCRA) regulations with respect to
land disposal restrictions.
There are four specific areas in which the contingent remedy can
be invoked to help achieve an effective remediation for the Site.
39
-------
The first has to do with the performance milestones being set for
the biological treatment remedy. Although biological treatment
as a remediation technology has matured within the last decade,
there is still the risk that performance standards for soils and
sediments will not be achieved in a timely manner.
For that reason, the following milestones are being set as part
of this document so that EPA can invoke the contingent remedy, if
it appears that biological treatment will be unable to reach
performance standards:
Toxaphene: 50% destruction after 1 year
Performance Standard after two years
DDT: 50% destruction after 1 year
Performance Standard after two years
The times referenced above are understood to begin when the first
cycle of the biological treatment process begins, after the pilot
scale testing has ended. It is also understood that these
milestones are to be used only at EPA's discretion when invoking
the contingent remedy, and that operational factors will be
considered as necessary and if warranted. These milestones are
primarily in place to avoid a lengthy remedy taking years to
complete, if contaminant levels slowly drop to performance
standard levels. They are not intended to serve as a "trigger"
for the contingent remedy.
Second, the contingent remedy can be used to remove off-site the
most contaminated soils and sediments located within Areas A-E,
as shown on Figure 3-2. This can be beneficial if longer
treatment times can be avoided that would otherwise trigger the
milestone criteria shown above. This possibility will be
examined further during the design phase of the OU2 remedy and
will be utilized as necessary.
Third, there is one sewer culvert location documented during the
RI (sample location N010-E805) that showed high concentrations of
contaminants. Although these sediments do not present a current
risk to the surface soils (human health or ecological risks),
groundwater, or surface water, the contingent remedy will be
invoked to address these sediments, which are not part of Areas
A-E shown on Figure 3-2.
Fourth, the contingent remedy can be used to address inorganic
contamination at the Site. Arsenic and lead are inorganic
compounds and are thus not affected by biological treatment.
However, the N010-E805 sample location at the sewer culvert was
the only location where arsenic was found at levels above its
performance standard of 317 ppm. It is also the only location
where lead was found above a presumed industrial standard of 1300
ppm (see Table 2). Thus, the contingent remedy would address the
40
-------
inorganic contamination, and at the same time remove the other
highly elevated contaminants at the N010-E805 sample location.
The selected remedy also includes provision for continuing the
interim groundwater remedy until groundwater performance
standards are met.
As noted in Section 5.3.3.2, it was found during the off-facility
sediment sampling that contaminant levels fall off rapidly along
the drainage pathway leading south-southwest from the site.
Nonetheless, there is a potential off-facility ecological risk
along this drainage pathway (see Section 6.3), even though Catoma
Creek is not impacted. The selected remedy will address those
sediments adjacent to Area A shown on Figure 3-2 that are below
the performance standards based on human exposure under an
industrial land use, but yet still may present an unacceptable
ecological risk along the drainage pathway leading from the Site.
These sediments will be excavated and either consolidated into
the biological treatment cell, or graded onto the Site since they
will be beneath the performance standards for soils. The amount
of impacted soil is not extensive, as can be seen by examination
of Figure 4, Figure 3-2, and Table 2-2 in Appendix D. Although
the ecological risk to some receptors may still remain above an
acceptable Hazard Quotient after remediation based upon the soils
performance standards given here, it is not considered feasible
to remediate additional sediments along the drainage pathway,
based on ecological risk concerns. This decision is also
influenced by consideration of the habitat destruction that would
occur with any excavation activities associated with remediation.
Residual risks that remain after the biological treatment of the
soils and sediments can be re-evaluated, if warranted, during the
five-year review.
As noted in Section 8.7, the present worth cost for implementing
the biological treatment remedy for soils and sediment was
$1,382,000 assuming a soil volume of 5,850 cubic yards. The
groundwater remedy has an associated present worth cost of
$6,100,000. Total cost to implement both remedies is thus
$7,482,000. These costs assume a 30 year life for O&M costs.
9.1 GROUNDWATER PERFORMANCE STANDARDS
Groundwater performance standards are based on drinking water
standards, and include federal Maximum Contaminant Levels (MCLs)
and Applicable or Relevant and Appropriate Requirements (ARARs),
including State standards, and also may include risk-based
performance standards.
Table 1 shows those compounds that were detected above drinking
water standards during the January, 1996 sampling event.
Highlighted on Table 1 are those compounds that continued to
exceed drinking water standards during the October, 1997 sampling
41
-------
event. The MCLs and/or ARARs and/or risk-based performance
standards shown on Table 1 for these compounds are thus the
performance standards for groundwater. If future sampling
determines that drinking water standards have been exceeded for
other compounds besides, then they will also be added as a
performance standard for purposes of this groundwater remedy.
9.1.1 AQUIFER RESPONSE AND POMP TESTING
As discussed in the OU1 ROD, additional geological and
engineering data is to be collected regarding the hydrogeologic
properties of the surficial groundwater aquifer. Technical
difficulties have prevented that data from being obtained as of
August, 1998. However, it is noted that the construction of the
groundwater remedy was completed in February, 1998, and that the
pumping system itself is operational. The additional data will
help determine if the system in place is capable of establishing
hydraulic control to the point of compliance (POC), in addition
to confirming how well the conceptual model of the aquifer fits
the hydrogeological data,
Groundwater modeling has also been conducted in an attempt to
predict how the aquifer will respond to the pumping system, as
part of the Remedial Design for OU1. This groundwater modeling
predicted that carbon tetrachloride, trichloroethene, and endrin
would most likely drive the length of the cleanup action. It was
found that the groundwater cleanup could last as long as 30
years, based on carbon tetrachloride reaching its Maximum
Contaminant Level (MCL) in the lower portion of the surficial
aquifer. However, due to the intrinsic attenuation that appears
to be taking place due to biodegradation within the aquifer, it
is unlikely that the groundwater remedy will actually require
this long.
9.1.2 COMPLIANCE TESTING
As discussed in the ROD for OU1, groundwater monitoring shall be
conducted quarterly at this Site for the first year following
remedial action. After the first year of remedial action,
periodic monitoring will continue to be conducted at least twice
annually until the performance standards are met at the point of
compliance (POC). The POC is being set at the property boundary.
If performance standards beyond the POC have not been met at that
time, then it will be necessary to establish that natural
attenuation, or intrinsic biodegradation, will be capable of
reaching the performance standards beyond the POC. If this is
not possible, then the groundwater remedial design will have to
be altered in order to do so.
9.2 SOILS/SEDIMENTS PERFORMANCE STANDARDS
Performance standards for both soils and sediments are shown on
42
-------
Table 4 below. Both the soils and the sediments will be treated
as one unit after excavation. These performance standards are
based upon a 10-5 risk level for carcinogenic compounds, and
assume an industrial land use. The only exception is arsenic
which assumes a 10-4 carcinogenic risk level based on non-cancer
endpoints, bioavailability, and other uncertainties.
Table 4
Performance Standards for Soils/Sediments
Const itutent
DDT
ODD
DDE
Arsenic
Toxaphene
Performance Standard
94
132
94
317
29
Note: All values shown above are in mg/kg (or parts per million)
Arsenic is a natural occurring mineral that is considered by EPA
to be a systemic (non-carcinogenic) toxicant and a human
carcinogen. However, there is considerable uncertainty
concerning its ability to cause cancer at low exposure levels,
especially the less soluble form that occurs in contaminated
soil. The Superfund program of EPA's Region 4 regulates arsenic
in soil as a systemic toxicant for the purpose of deriving
protective clean up levels. To be consistent with the NCP, EPA
also requires soil clean up levels to fall within the protective
cancer risk range of 10-6 to 10-4 for the most sensitive, likely
receptor even though the calculated risk may be an overestimate.
317 mg/kg was chosen as the Remedial Goal for arsenic because it
is within EPA's acceptable risk range and does not exceed a
Hazard Quotient of 1.0 based on a worker exposure scenario."
Table 2 shows sampling results for each of the DDT, DDE, and DDD
congeners, as was presented in the RI. However, it is noted here
that the Table 4 performance standards represent total DDT, total
DDE, and total DDD, i.e., there is no provision for separate
congeners, since toxicological data would not support such a
provision.
10.0 STATUTORY DETERMINATION
Under Section 121 of CERCLA, 42 U.S.C. § 9621, EPA must select
remedies that are protective of human health and the environment,
comply with applicable or relevant and appropriate requirements
(unless a statutory waiver is justified), are cost effective, and
utilize permanent solutions and alternative treatment
technologies or resource recovery technologies to the maximum
extent practicable. In addition, CERCLA includes a preference
43
-------
for remedies that employ treatment that permanently and
significantly reduce the volume, toxicity, or mobility of
hazardous wastes as their principal element. The following
sections discuss how the selected remedy meets these statutory
requirements.
10.1 PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
The selected remedy provides protection of human health and the
environment by: eliminating, reducing, and controlling risk
through engineering controls and/or institutional controls; and
via soil/sediment and ground water treatment as delineated
through the performance standards described in Section 9.0 - The
Selected Remedy. The residual risk due to individual
contaminants will be reduced to a probability of IxlO"5 for
carcinogens. The residual carcinogenic risk at the Site will be
reduced to acceptable levels (i.e., cancer risk between IxlCT6
and IxlO"4) once performance standards are achieved.
Implementation of this remedy will not pose unacceptable short-
term risks or cross media impact.
10.2 ATTAINMENT OF THE APPLICABLE OR RELEVANT AND APPROPRIATE
REQUIREMENTS (ARARs)
The selected remedy will comply with the substantive requirements
of federal and state laws and regulations that have been
determined to constitute applicable or relevant and appropriate
requirements (ARARS).
Applicable requirements are those cleanup standards, control
standards, and other .substantive environmental protection
requirements, criteria, or limitations promulgated under federal
or state law that specifically address a hazardous substance,
pollutant, contaminant, remedial action, location, or other
circumstance at a Superfund site. Relevant and appropriate
requirements are those cleanup standards, control standards, and
other substantive environmental protection requirements,
criteria, or limitations promulgated under federal or state law
that, while not applicable, address problems or situations
sufficiently similar (relevant) to those encountered and are
well-suited (appropriate) to circumstances at the particular
site.
Safe Drinking Water Act, MCLs and MCLGs; Alabama's Primary.
Drinking Water Standards. The following is taken from the OUl
ROD, page 21 and 22, and applies equally here for purposes for
OU2:
"Maximum contaminant levels (MCLs) and Maximum Contaminant
Level Goals (MCLGs) promulgated under the authority of the
44
-------
Safe Drinking Water Act (SDWA) are specifically identified in
Section 121 of CERCLA as well as the NCP as remedial action
objectives for groundwater that is a current or potential
source of drinking water supply. The groundwater underlying
the THAN Site is classified as Class II A groundwater (i.e.,
potential sources of drinking water) under EPA's Guidelines
for Ground-Water Classification. MCLs and non-zero MCLGs are
therefore relevant and appropriate as final remedial action
objectives for groundwater cleanup. Alabama's primary
drinking water standards are also relevant and appropriate as
final remedial action objectives for groundwater cleanup
because they set standards for potential sources of drinking
water."
Resource Conservation and Recovery Act (RCRA); ADEM Hazardous
Waste Regulations; ADEM Solid Waste Regulations. The following
discussion is taken from the OU1 ROD, and applies equally here
for purposes of OU2, with respect to groundwater:
"The selected groundwater remedy involves the short term
storage of contaminated groundwater before it is sent to the
POTW for treatment and disposal. If the contaminated
groundwater is RCRA characteristic hazardous waste, hazardous
waste regulations which address storage units are applicable.
If the contingent remedy for contaminated groundwater is
implemented, which involves extraction, treatment and
discharge at the Site by reinjection or infiltration,
hazardous waste regulations which involve treatment and
storage units may likewise be applicable. Land disposal
restrictions establish treatment standards which must be met
before hazardous wastes may be land disposed. Land disposal
restrictions are applicable if the contingent remedy for
contaminated groundwater is implemented, the contaminated
groundwater is RCRA characteristic hazardous waste, and
treated groundwater is discharged at the Site by reinjection
or infiltration. In such an event, the land disposal
restrictions must be met before treated groundwater may be
discharged. .Any waste generated by the treatment process,
such as sludges and filters, are subject to the waste
characterization and disposal provisions of RCRA."
The selected remedy also involves the excavation, treatment, and
replacement of contaminated soils and sediments. As such, the
land disposal restrictions and other provisions of RCRA, as
discussed above, are also applicable, and will require the
designation of a Corrective Action Management Unit (CAMU).
Clean Water Act, Pretreatment Standards. The following
discussion is taken from the OU1 ROD, and applies equally here
for purposes of OU2, with respect to groundwater:
"The general pretreatment regulations set forth in 40 C.F.R
45
-------
Part 403 addresses the introduction of pollutants into POTWs
and are applicable to the selected interim remedy."
Safe Drinking Water Act, Underground Injection Control
Regulations, as delegated to the State of Alabama. The following
discussion is taken from the OU1 ROD, and applies equally here
for purposes of OU2, with respect to groundwater:
"If the contingent remedy for contaminated groundwater is
implemented (as set forth in the OU1 ROD), and treated
groundwater is discharged at the Site by reinjection or
infiltration, the substantive requirements of the UIC program
are applicable. See 40 CFR 147.50."
Alabama Regulations Governing Emissions of Pollutants to Air;
Ambient Air Quality Standards. If the contingent remedy for
groundwater is invoked (see OU1 ROD) and on-site treatment
occurs, these standards are applicable because there will be
emissions of air pollutants from the air stripper in ambient air.
This applies also to the biological treatment remedy for soils
and sediments.
Department of Transportation (DOT) Regulations and Occupational
Safety and Health Administration (OSHA) Regulations. While DOT
and OSHA regulations do not fall within the technical definition
of ARARs because they are not environmentally based, they are
nonetheless directly applicable to the extent they address
activities associated with the cleanup such as the transportation
of hazardous materials and health and safety requirements for
workers at the Site.
Waivers
Waivers are not anticipated at this Site at this time.
Other Guidance To Be Considered
Other Guidance To Be Considered (TBCs) include health-based
advisories and guidance. TBCs have been utilized in estimating
incremental cancer risk numbers for remedial activities at the
Site and in determining RCRA applications to contaminated media.
10.3 COST EFFECTIVENESS
After evaluating all of the alternatives which satisfy the two
threshold criteria (protection of human health and the
environment, and attainment of ARARs), EPA has concluded that the
selected remedy, Alternative 5B, affords the highest level of
overall effectiveness proportional to its cost. Section
300.430(f)(1)(ii)(D) of the NCP also requires EPA to evaluate
three out of five balancing criteria to determine overall
effectiveness: long-term effectiveness and permanence; reduction
of toxicity, mobility, or volume through treatment; and short-
46
-------
term effectiveness. Overall effectiveness is then compared to
cost to ensure that the remedy is cost-effective. The selected
remedy provides for overall effectiveness in proportion to its
cost.
The selected remedy is, with the exception of Alternative 1 (No
Action), Alternative 2 (Institutional Controls), and Alternative
3A (Onsite Consolidation and Containment, Option A), the least
expensive of the alternatives for this Site. Alternatives 1 and
2 do not satisfy the primary criteria. The selected remedy
provides much better overall effectiveness than either
Alternative 3A or 3B, for roughly the same cost. Although
Alternative 4 does provide the highest degree of overall
effectiveness, its much higher cost is not considered justified.
The same applies to Alternative 5A, where a potentially modest
increase in overall effectiveness does not justify its increased
cost. The selected remedy will also reduce toxicity, mobility,
or volume through treatment at a lower cost than Alternative 6,
which provides no reductions in same.
The estimated present worth costs for the selected remedy is
$7,482,000.
10.4 UTILIZATION OF PERMANENT SOLUTIONS TO THE MAXIMUM EXTENT
PRACTICABLE
EPA has determined that the selected remedy represents the
maximum extent to which permanent solutions and treatment
technologies can be utilized in a cost-effective manner for the
final remediation at the Site. Of those alternatives that are
protective of human health and the environment and comply with
ARARs, EPA has determined that Alternative 5B provides the best
balance of trade-offs in terms of long-term effectiveness and
permanence, reduction in toxicity, mobility, or volume achieved
through treatment, short-term effectiveness, implementability,
and cost, while also considering the statutory preference for
treatment as a principal element and consideration of state and
community acceptance.
The selected remedy represents a permanent solution with respect
to the principal threats posed by the Site.
10.5 PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT
The selected remedy does utilize treatment as a principal
element, for both groundwater and soils/sediments.
11.0 EXPLANATION OF SIGNIFICANT CHANGES
There have been no significant changes in the selected remedy
from the preferred interim remedy described in the Proposed Plan,
47
-------
APPENDIX A:
RESPONSIVENESS SUMMARY - T H AGRICULTURE & NUTRITION SITE
The Responsiveness Summary shows how EPA considered public
comments made on the Final Remedial Action summarized herein as
Operable Unit Two (OU2) for this Site. For additional reference,
a transcript of the public meeting held August 13, 1998 is part
of the Administrative Record for OU2. A copy of both the OU1 and
OU2 Administrative Records is available for review at the
information repository, which has been set up at the Montgomery
County Library- Rufus Lewis Branch. No written comments were
received during the public comment period for the OU2 Final
Remedial Action. All issues identified were taken from the
transcript referenced above.
1. Is the company that did the dumping being held accountable
for the cost? Who's paying for it?
EPA Response:
Yes. Elf Atochem is the owner of the former Pennwalt
facility, which is adjacent to the THAN facility.
Prior to the Remedial Investigation (RI), Elf Atochem
entered into an agreement with EPA to take the lead on
the RI and Feasibility Study (RI/FS), and all RI/FS
activities have been completed to date. The Site is
thus referred to as a Potentially Responsible Parties
lead, or PRP-lead site, as opposed to a Fund-lead site,
where EPA would perform the work and seek reimbursement
afterwards.
A separate Consent Decree will be negotiated with the
Responsible Parties prior to enacting the Remedial
Design and Remedial Action (RD/RA) for OU2.
2. Why are they taking so long to clean up?
EPA Response:
This Site was discovered on the CERCLIS database in
1986. A Preliminary Assessment was done in 1987 and
the Site Inspection was done in 1987 (PA/SI). Using
information from the PA and SI, the Site was then
placed on the National Priorities List (NPL) in 1990.
A Consent Decree was negotiated with the PRPs prior to
the Remedial Investigation (RI), which was finalized in
1993. Using data from the RI, a focused Feasibility
48
-------
APPENDIX A (con'd):
RESPONSIVENESS SUMMARY - T H AGRICULTURE & NUTRITION SITE
Study was performed to support the first remedial
action, Operable Unit One (OU1), which was put in place
to address the groundwater contamination. The Record
of Decision (ROD) for OU1 was signed in 1995.
Construction was completed on the OU1 remedy in
January/ 1998. The final remedial action for the Site,
or OU2, will begin Remedial Design after the ROD is
signed.
It should be recognized that EPA does not exercise its
remedial authority under CERCLA unless the site has
been placed on the NPL.
In order to make an informed decision on the cleanup,
studies to determine the nature and extent of
contamination are necessary to ensure selection of the
appropriate remedy for protection of human health and
the environment.
3. There was a break in the water line in front of one of those
plants up there a few years ago. And has the drinking water
and/or water lines been tested?
EPA Response:
No. The Montgomery Water Works and Sanitary Sewer Board
(MWWSSB) has been contacted regarding this issue. It
was learned that a break in the water line did occur in
1990. The location of the break was about 200 feet
north of the northeast corner of the THAN property, up
in the woods. The line was plugged at the time near
the THAN site, and service was restored from an
alternate branch line. The section of line near the
Site has not been used since.
However, there is little likelihood that residents' tap
water has been contaminated by Site soils, for several
reasons: first, the break did not occur in the vicinity
of soil contamination at the Site (see Issue 20 also).
Second, the water break results in water flowing
outward and does not pull outside soils into the pipe.
Third, it is not uncommon for sand and grit to
accumulate in water lines and settle. When a break in
the water line occurs, the suddenly increased water
flow will disturb the sand and grit inside the line,
49
-------
APPENDIX A (con'd):
RESPONSIVENESS SUMMARY - T H AGRICULTURE & NUTRITION SITE
which will then show up initially in the tap water
after service is resumed. . Last, the water line with
the break has not been repaired to date, and service
since the break has been provided from another water
line branch.
However, EPA understands the concerns that the
community may have with respect to their drinking
water. Accordingly, at the community's request, plans
have been made for EPA's field operations personnel to
conduct testing of the drinking water, with samples to
be taken at the tap from 2-3 homes. Plans are to have
water samples taken on October 2. The Reverend Leon
Henderson will be notified prior to field activities.
4. Have you found contamination on the ground and in the
groundwater at the Site? Have you found whether the
contaminated water is moving, and if so, where? Is it going
to the river? Is it affecting inhabitants in the
neighborhood?
EPA Response:
Contamination has been found in site soils, sediments,
and groundwater. The remedial action undertaken as
part of Operable Unit One (OUl) installed a pumping
system that will keep contaminated groundwater from
moving further off-site. However, Catoma Creek and the
Alabama River are too far away to be impacted by
groundwater from the Site. The community is not
affected by the contaminated groundwater since their
water is supplied by the City of Montgomery.
5. Where are we now? Are we going through the paperwork getting
prepared for this, or are we in the process now of cleaning
it up, and you're trying to determine how to clean it up?
EPA Response:
The proposed plan represents what EPA considers to be
.the best of the six remedies identified in the
Feasibility Study for addressing soils and sediments.
The preferred remedy is presented to the public in a
public meeting in order to solicit comments from the
50
-------
APPENDIX A (con'd):
RESPONSIVENESS SUMMARY - T H AGRICULTURE & NUTRITION SITE
public regarding the proposed remedy. This Record of
Decision for OU2 was finalized only after the comments
from the community were considered. Cleanup of the
soils will begin after the Remedial Design and Remedial
Action workplan are finished.
On those dots shown on your map, I assume those are testing
areas that you have all around the area. You have some over
on Hunter Loop Road and down by the trailer park. Do each
one of those black dots show one of those testing spots where
you're monitoring groundwater?
EPA Response:
No. The map presumably referred to is Figure 3-2 from
the Feasibility Study, which was included in both the
proposed plan and this Record of Decision. The black
dots represent sample locations for soils and sediments
that were used to define Areas A-E shown. These areas
will be excavated and treated via the remedy set forth
in this document. The groundwater monitoring consists
of over 50 wells, and were not included on Figure 3-2.
7. You're saying you did pick up some (contamination) across
Highway 31, and back toward old Maxwell field, but you didn't
find any (contamination) coming down towards the trailer
park? What about the runoff?
EPA Responset
There is no risk to the residents currently living in
the vicinity of the Site via contamination from the
Site.
Surface water runoff from the Site flows southwest over
a relatively poorly defined drainage pathway. This
drainage pathway runs towards Catoma Creek and not
Maxwell Air Force Base. Residents of the Lakewood
community live to the northwest of the Site, off of
the drainage pathway leading from the Site. In
addition, contaminant levels fall off rapidly away from
the Site and are not impacting Catoma Creek. This is
51
-------
APPENDIX A (con'd):
RESPONSIVENESS SUMMARY - T H AGRICULTURE & NUTRITION SITE
in large part due to the nature of the contaminants
themselves, as pesticides tend to bind tightly to
soils, as discussed on page 7 of the Proposed Plan
factsheet that was mailed to the public.
8. Why don't we close down the Site until we we can get some
(idea) of how long it will take to fix it and what (should be
done)?
EPA Response:
Operable Unit Two (OU2) represents the final remedial
action for the Site, and represents the selection of
biological treatment as the preferred remedy for the
soils and sediments; in addition, the groundwater
remedy begun with OU1 will be continued until
performance standards are met for groundwater. Both
the THAN and Elf Atochem properties are inactive at
this time.
9 . How long do you need?
EPA Response:
The implementation time for the preferred remedy of
biological treatment is two to four years. This
includes the time required for remedial design, during
which pilot scale testing will be conducted (a bench
scale treatability study has already been conducted as
part of the Feasibility Study).
10. I was curious about how these places got to be called
Superfund.
EPA Response:
The transcript shows the verbal response given at the
public meetiing, and provides an overview of the
remedial process included as part of the Comprehensive
Environmental Response, Compensation, and Liability Act
(CERCLA), more commonly known as Superfund. CERCLA's
remedial authority is used on sites placed on the
National Priorities List (NPL). The THAN site was
52
-------
APPENDIX A (con'd):
RESPONSIVENESS SUMMARY - T H AGRICULTURE & NUTRITION SITE
placed on the NPL in 1990.
Generally, CERCLA's remedial authority addresses long-
term threats to the public health and the environment,
such as contaminated groundwater. In addition, CERCLA
provides EPA with removal authority, which can be used
to address sites at which an imminent threat to the
public health and the environment exists, such as
leaking drums. Listing on the NPL is not required for
EPA to exercise its remedial authority.
CERCLA was passed in 1980, in large part as a response
to such sites as Love Canal in New York. It was
intended to address abandoned hazardous waste sites
across the nation, and the Fund set up by CERCLA to pay
for the cleanups (with cost reimbursement sought
afterward).became commonly known as Superfund.
11. What is involved in the biological treatment of the soil?
What guarantee would we have that this biological treatment
is not going to be hazardous in itself? Can you offer us
any guarantee or warranty on the fact that this won't be
worse than the problem that exists already? Will the
treatment be hazardous to the residents?
EPA Response:
The biological treatment remedy will consist of soil
amendments that will be added to the excavated soils
and sediments, that will encourage the bacterial
breakdown of the chlorinated contaminants in the soil.
These soil amendments will include nutrients for the
microorganisms. The process itself will involve a
cycling procedure where each successive cycle will
alternate between aerobic conditions (somewhat
analogous to composting, requiring oxygen to be
supplied via aeration) and anaerobic conditions. The
aerobic cycles will break the chlorinated compounds,
while the anaerobic cycles will further degrade the
non-chlorinated intermediate breakdwon products.
As part of the remedial design phase, pilot scale
testing will be conducted on part of the excavated
soils and sediments. These pilot tests will provide
assurance that the biological treatment will be
53
-------
. APPENDIX A (con'd):
RESPONSIVENESS SUMMARY - T H AGRICULTURE & NUTRITION SITE
feasible (if pilot testing is not successful, the
contingent remedy will be invoked).
Process controls will be put in place to control such
factors as dust and surface water runoff, and will be
explicitly included as part of the Remedial Design.
The chlorines that are part of the contaminants of
concern will be released as non-toxic chloride gas as
the biological degradation occurs. In fact, chloride
gas will be monitored as an indicator that the
degradation is occurring. Although the intermediate
breakdown products of DDT (DDD and DDE) are also
hazardous, DDD and DDE are included as part of the
performance standards for the remedy.
Given all these factors, and given the case histories
provided on previous sites on which this technology has
been used, 'EPA feels that adequate safeguards will be
part of this remedy, and that the contaminated soils
and sediments can be treated successfully. If for
whatever reason, these safeguards or performance
standards cannot be met, then the contingent remedy of
offsite disposal will be invoked.
12. How are you going to cover it? What type of material are
you going to cover it with?
EPA Response:
During the anaerobic cycles of the biological treatment
process, the soils and sediments being treated will be
covered to reduce the amount of oxygen available to the
microorganisms. During the aerobic cycles of the
process, dust control may be achieved by either
controlling the moisture content of the soils and
sediments (i.e., wetting it down), or with a cover.
These engineering controls have not been determined at
this time,-but will be explicitly included as part of
the Remedial Design to ensure that contamination will
not migrate from the Site during implementation of the
biological treatment remedy.
54
-------
APPENDIX A (con'd):
RESPONSIVENESS SUMMARY - T H AGRICULTURE & NUTRITION SITE
14. But the number one issue is that we shouldn't let them keep
putting landfills in the community like this. We should
have a law for that.
EPA Response:
There is no landfill located on the Site. Municipal
landfills are regulated by local and State authorities,
and are not addressed by the CERCLA program, unless
they present an imminent and/or longterm threat to the
public or the environment.
15. Where is it in writing as to what you're going to do?
EPA Response:
This Record of Decision represents the selection of the
preferred remedy for final remedial action at the Site,
and will become part of the Administrative Record (AR)
for Operable Unit Two. The AR is available for public
review at the Montgomery County Library, Rufus Lewis
Branch.
16. How do you contain water?
EPA Response:
Operable Unit One (OU1) consisted of an interim remedy
that was put in place to contain the groundwater plume
existing under the site. It consists of a pumping
system that pumps the groundwater and discharges it to
the sewer line adjacent to the Site. This groundwater
is then sent to the Public Owned Treatment Works
(POTW), or sewage plant, for treatment. Pumping the
groundwater out of the aquifer helps keep the
contamination from moving underground away from the
Site.
Containing the surface water runoff after the soils and
sediments are excavated can be done by covering the
treated area. This should be adequate during the
anaerobic cycles of the biological treatment, since the
soils must be covered during these cycles. For the
aerobic cycles, a cover may still be feasible, or
55
-------
APPENDIX A (con'd):
RESPONSIVENESS SUMMARY - T H AGRICULTURE & NUTRITION SITE
perhaps a berm could be built to contain the runoff
water. These engineering controls have not been
determined at this time, but will be included as part
of the Remedial Design.
17. Who's to say that (contamination) has not exceeded that
point during the 12 years that you've been out there trying
to contain and eliminate this same problem?
EPA Response:
The Remedial Investigation (RI) was finalized in 1993.
To some extent, it does represent a snapshot of site
conditions, and it is possible that conditions have
since changed. However, confirmatory sampling will be
conducted as part of the excavation activities in the
field. It'is not expected that Areas A-E will have
changed much since RI sampling was conducted (due to
the binding characteristics of the contaminants,
discussed earlier); however, the confirmatory sampling
will ensure that all contaminated soils and sediments
above performance standards will be collected and
treated.
18. To what extent has the amount of chemical waste that was
dumped in this area not been deteriorated by these
microorganisms up there? Have you been able to measure how
much of this chemical still remain in the soil, in and
around this site in the hot spots?
EPA Response:
It is not thought that natural attenuation is occurring
within the Site soils and sediments. Therefore, as
discussed in the previous Response to Issue 17, the
Remedial Investigation represents the last snapshot of
Site conditions.
However, there is thought to be natural attenuation
occurring in the groundwater, as evidenced by the
declining levels of contaminants detected during
previous groundwater sampling activities (see Table 1
of this Record of Decision).
56
-------
APPENDIX A (con'd):
RESPONSIVENESS SUMMARY - T H AGRICULTURE & NUTRITION SITE
19. According to the newspaper, it can only be used for
industrialization purposes. Define "clean".
EPA Response:
The Remedy set forth in this Record of Decision (ROD)
for Operable Unit 2 takes into account the industrial
zoning of the Site, as designated by local planning
authorities (see Section 6.2 of the ROD for more
information on this issue).
•.
The human health risk posed by any site is dependent
upon exposure to hazardous constituents, and exposure
is determined by assumptions based in part on a given
land use. A residential exposure scenario would
require a more protective standard than an industrial
exposure scenario. However, it is important to
recognize that the performance standards for soils and
sediments, as set forth in this ROD, are still fully
protective for the onsite worker under an industrial
exposure scenario.
It is also important that the groundwater remediation
is independent of these land use issues. The
groundwater performance standards are based on drinking
water standards, and are independent of anticipated
land use.
20. Where is the water line, and is it situated anywhere in an
area where you plan on digging?
EPA Response:
The water line runs parallel to U.S. Highway 31-82,
approximately north-south. The location of the break
in the water line, discussed earlier, was 200 feet
north of the northeast corner of the THAN property.
That location is not near the Areas A-E on Figure 3-2
that will be excavated. However, the water line does
run adjacent to Area E that will be excavated.
It has come to EPA's understanding, after the public
meeting was held, that this water line has not been in
service since the break occurred in 1990. The
57
-------
APPENDIX A (con'd):
RESPONSIVENESS SUMMARY - T H AGRICULTURE & NUTRITION SITE
Montgomery Water Works and Sanitary Board does plan to
re-connect this line, but has no immediate plans to do
so.
21. Now that you propose to clean it up, what are the news media
going to do to help this community say "It's safe now. You
can make a loan, etc"?
EPA Response:
EPA will continue issue factsheets to the mailing list
set up for the Site. This mailing list includes
members of the community and the news media. These
factsheets will keep the public informed of progress
made regarding cleaning up the Site.
22. And who's monitoring this cleanup and where is it being
kept?
EPA Response:
The Site is being cleaned up by the companies that own
the two adjacent properties. EPA has its own
contractor that provides oversight for the activities
undertaken by these companies, and that contractor was
present at the public meeting August 13, 1998. In
addition, EPA can use its own field operations
personnel, located in EPA's Science and Ecosystem
Support Division (SESD), to split samples and provide
quality control support during future sampling
activities .-
The Administrative Record for both Operable Unit One
and Operable Unit Two (OU1, OU2) are kept at the
Montgomery County Library, Rufus Lewis Branch, and are
available for public review. These Administrative
Records include all documents and information that EPA
used to select the preferred remedy for OU1 and OU2.
58
-------
APPENDIX A (con'd):
RESPONSIVENESS SUMMARY - T H AGRICULTURE & NUTRITION SITE
23. Eight months ago, I bought 15 acres of residential and
commercial property and I just got my property tax in the
mail, and all of a sudden it's worth $75,000 more than what
I paid for it, and I haven't done anything to it.
EPA Response:
Property tax assessments are the jurisdiction of the
local tax assessor, and are not addressed by EPA.
59
-------
APPENDIX B
CONCURRENCE LETTERS
60
-------
ADEM
JAMES W.WARR
DIRECTOR
ALABAMA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT
POST OFFICE Box 301463 « 1751 CONG. W. L. DICKINSON DRIVE 36109-2608
MONTGOMERY, ALABAMA 36130-1463
(334)271-7700
FOB JAMES, JR.
GOVERNOR
o i- -»o no
September 28, 1998
Facsimiles. (334)
Adm,n,51rat,on 271.7950
Air 279-3044
Land 279-3050
Water 279-3051
Groundwaler 270-5631
Field Operations 272-8131
Laboratory 277-6718
Education/Outreach 213-4399
Mr. Richard D. Green, Director
Waste Management Division
U.S. EPA, Region 4
Atlanta Federal Center
61 Forsyth Street, SW
Atlanta, Georgia 30303-3104
Re: THAN Record of Decision
Dear Mr. Green:
The Department has reviewed the Proposed Plan and Draft Record of Decision for the
Thompson-Hayward Agriculture and Nutrition (THAN) Superfund site in Montgomery,
Alabama. Your staff has provided us with timely drafts of these documents, and has
accepted our comments and suggestions. Based on our review, the proposed remedy,
consisting of excavation, bioremediation of soils on-site, and replacement of treated
soils, is acceptable to the Department. We therefore concur with the selected remedy.
If you have questions or comments regarding this matter, please contact Mr. Fred
Barnes at 334-270-5646.
Sincerely,
James W. Wan-
Director
JWW/lb
1 10 Vulcan Road
Birmingham. Alabama 35209-4702
(205)942-6168
(205) 941-1603 [Fax|
400 Well Street. N.E • P 0 Box 953
Decatur. Alabama 35602-0953
(205)353-1713
(205) 340-9359 [Fax]
2204 Perimeter Road
Mobile. Alabama 36615-1131
(334)450-3400
(334) 479-2593 [Fax]
Printed on Recycled Paper ~.
-------
APPENDIX C
SELECTED TABLES FROM THE BASELINE RISK ASSESSMENT
The following1 tables are
provided without page
numbers, and were taken
from the Baseline Risk
Assessment, consisting of
the final document dated
July 29, 1994 and as
amended by subsequent
addendums dated November
14, 1994 and September 5,
1995. Revised tables
incorporated slow purge
data for inorganic
compounds :
Table 3
Table 5
Table 6
Table 7 (revised)
Table 8
Table 9
Table 10
Table 11
Table 12 (revised)
Table 13 (revised)
Table 14
Table 15 (revised)
Table 17 (revised)
61
-------
Tables
Reasonable Maximum Exposure Concentrations for
Chemicals of Potential Concern in Soil
T.H. Agriculture & Nutrition Site
Montgomery. Montgomery County. A
- '" „ - ; * •- ~, >
'// dhemJQ^d^/jKP
'', !,"'
' , P^cr^T'Cfefwenn \\',-
Aluminum
Antimony
Arsenic
Barium
Beryllium
Chromium
Lead
Manganese
Vanadium
Benzo(a)anthracene
Benzo(a)pyrene
bis(2-ethylhexyl)phthalate
Dibenzo(a,h)anthracene
Hexachlorobenzene
lndeno(1 ,2,3)pyrene
2,3.7,8-TCDD-EQ
alpha-BHC
beta-BHC
delta-BHC
namma-BHC (lindane)
ralpha-Chlordane
gamma-Chlordane
2.4'-DDD
2.4--DDE
2.4'-DDT
4.4'-DDD
4.4'-DDE
4,4'-DDT
Dieldrin
Endrin
Endrin aldehyde
Endrin ketone
Heptachlor epoxide
Toxaphene
' "'
/, M0a»dk, ,
Transformed
""'"DMT,*,'
9.9
0.7
1.6
4.8
0.0
3.4
2.9
6.5
3.4
0.01
-0.1
-0.3
-0.02
0.02
-0.04
1.4
2.1
3.5
3.1
3.1
2.2
2.2
4.1
3.3
3.8
4.5
4.8
5.1
3.6
3.3
3.6
2.6
3.2
7.2
;StajKlarcl '
" ''Deviation
/ \ of stela
, ' ' '
0.49
0.27
0.88
0.59
0.54
0.46
0.57
0.98
0.38
0.28
0.46
0.95
0.37
0.21
0.45
2.00
1.86
2.52
1.79
1.78
1.80
1.87
2.76
2.52
2.43
2.93
2.85
3.33
1.82
2.24
1.37
1.55
1.49
1.52
, , ' /* $ ;
H {Statistic j
ffwh-
s !«**»}/ :
1.830
1.733
2.117
1.891
1.830
1.830
1.891
2.205
1.777
.733
.830
2.205
.777
.697
.830
26.140
2.997
3.920
2.997
2.997
2.997
2.997
4.569
3.920
3.920
4.569
4.569
5.233
2.997
3.295
2.447
2.713
2.713
2.713
abama
Sample ;
Siz»,(1) ;,
143
143
143
143
143
143
143
143
143
124
124
118
124
124
124
2
143
143
143
143
143
143
99
99
99
143
143
142
143
143
143
143
143
143
UGL !
tfngfea) j
24200
2.3
8.7
164
1.3
36
22.9
1331
34
1.1
1.1
1.4
1.1
1.1
1.1
2E+024
0.1
1.7
0.2
0.2
0.1
0.1
9.5
1.7
2.4
20.1
21.7
179.5
0.3
0.6
0.1
0.1
0.1
6.0
Maximum
59900
10
115
1480
2.3
173
98
13200
66
2.8
3.9
91
0.5
0.9
2.6
0.00002
23
40
200
52
5.3
8
190
41
280
680
160
2700
59
60
3
14
4.6
4400
RME
,A«}&*8)
24200
2.3
8.7
164
1.3
36
22.9
1331
34
1.1
1.1
1.4
0.5
0.9
1.1
0.00002
0.1
1.7
0.2
0.2
0.1
0.1
9.5
1.7
2.4
20.1
21.7
179.5
0.3
0.6
0.1
0.1
0.1
6.0
(1). Sample size based on number of usable results. Invalid results were not counted.
2.3.7.8-TCDD-EQ: Combined toxicity of all dibenzodioxin and dibenzofuran congeners
UCL: Upper Confidence Limit
SQL: Sample Quantitation Limit
Maximum: The highest detected concentration.
RME: Reasonable Maximum Exposure (UCL or maximum when UCL is greater than maximum)
-------
Tables
Reasonable Maximum Exposure Concentrations for
Chemicals of Potential Concern in Surface Water
T.H. Agriculture & Nutrition Site
Montgomery. Montgomery County. Alabama
'T^'y^'IS^^^^^f^^
'? '' ''''A',^',.,?"'' :';,^'}ffs?f'?s'?;'&';''<''i
,$.S ;•" ',''%'/''/ 4's^S'''//v/S'/£tJ£f%'-s!&'/ft$%
f '•' PoJentfeTGoftciiHTJ- ^^;:" ^
* x's,' '', ' t •*'••* ';• ' ''^//ty*:'.
-,' ' , , ,' S',,""^' ,' A ,' , ',<,''' '
Aluminum
Arsenic
Barium
Beryllium
Cadmium
Chromium
Lead
Manganese
Thallium
Vanadium
Benzene
Carbon Disulfide
1 ,4-Dichlorobenzene
Toluene
Benzo(b)fluoranthene
Bis(2-ethylhexyl)phthalate
4-Methylphenol
Nitrobenzene
alpha-BHC
beta-BHC
delta-BHC
gamma-BHC (lindane)
alpha-Clordane
gamma-Clordane
2.4-D
2.4'-DDD
2.4'-DDE
4.4'-DDD
4.4'-DDE
4.4'-DDT
Dieldrin
Heptachlor
'^liaiiiiolf'' ^
.,,s ,',' ~ '> ,*,[,
^TJ^anorOflxMml
'?"" Ojtfa ' ' ''
"' - ,' f ,' 5
",- ', , „ y- "
8.8
2.2
4.7
-0.6
0.5
3.4
2.2
6.5
-0.2
2.0
-0.7
0.6
-0.7
0.7
-0.1
0.3
2.0
0.0
-4.1
-2.7
-2.9
-3.2
-4.4
-4.4
1.8
-2.9
-4.1
-1.4
-2.3
-2.5
-3.0
-3.7
w/' '••''''', - '' ,'
' '*2.^'i'!f~~'± •'
'• ' iiL^j *J»6s«. '' ' ''
' f''f$*$*7~^r?Wf"',-
'. ' f'tfljfafai' , ,'
','•' , " ' '"*'"/'
''-'"'" -" '-'""•
1.12
1.04
0.76
0.36
0.54
0.92
1.48
1.70
0.78
1.09
0.16
1.25
0.21
2.26
0.52
0.77
0.93
0.08
1.48
2.12
1.69
1.22
1.18
1.25
0.16
1.42
0.81
2.54
2.27
1.76
1.34
1.30
K^H {Sta^c -
;J-*j '*;inuiMl '' >t/'
', '*', '*?/' >;*»y»*f.>^ '* ^ '
"'',"'' T^jlei * ''
\ ''/*', ',,','',
•?' '• • ' ,: '"A—
2.423
2.423
2.202
1.856
1.928
2.432
3.077
3.437
2.202
2.423
1.742
2.737
1.742
5.013
1.928
3.155
2.310
1.701
3.077
3.812
3.437
2.737
2.737
2.737
1.771
3.077
2.202
4.588
4.588
3.437
2.737
2.737
•:'SarhbM;
4&M #« 1'
;'&H3» \\) i
f ', ' ' '•
; ' 1
' ' *
35
39
38
39
38
18
31
37
33
39
39
39
39
25
38
9
39
39
39
39
39
39
39
39
23
28
28
39
39
39
39
39
f'' ''f''\JG&{''''-
'y » 4
f {Uypl^ fi
* ', '-,' ''
f * *
' - •
19416
23
187
0.7
2.2
82
63
7153
1.6
21
0.55
6.7
0.56
247
1.2
4.1
16.3
1.0
0.10
2.3
0.6
0.15
0.04
0.05
6.7
0.4
0.03
40.5
7.3
1.1
0.2
0.10
,- -. s s \
Maximum
% f ^UJ£fl»J _, \
; ;
,* ' '':
' ' "" :
63200
68
754
2.0
42
130
137
6100
3.9
77
1
51
1.8
190
0.1
10
210
1.6
0.45
9.4
4.5
0.35
0.13
0.18
13
1.3
0.15
180
14
5.5
1.2
0.84
'flME-V
Amd V
tug/Lj ,f
'f
19416
23
187
0.7
2.2
82
63
6100
1.6
21
0.55
6.7
0.56
190
0.1
4.1
16.3
1.0
0.10
2.3
0.6
0.15
0.04
0.05
6.7
0.4
0.03
40.5
7.3
1.1
0.2
0.10
(1). Sample size based on number of usable results. Invalid results were not counted.
UCL: Upper Confidence Limit
SQL: Sample Quantitation Limit
Maximum: The highest detected concentration.
RME: Reasonable Maximum Exposure (UCL or maximum when UCL is greater than maximum)
-------
Table 6
Reasonable Maximum Exposure Concentrations for
Chemicals of Potential Concern in Sediment
T.H. Agriculture & Nutrition Site
Montgomery, Montgomery County, Alabama
;,> "" .Ol»mfcai'<* "V '"
"< V:,'," •'/, , ,.; f ',', *f ,',/,!,
'••',,' "', ," ' '.'"•. ' *i ', , f Y, ',
:'/,- ' -PotWidaf Cortcwft. ' •• ' >y
Aluminum
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
Lead
Manganese
Mercury
Thallium
Vanadium
Benzo(a)anthracene
Benzo(a)pyrene
Bis(2-ethylhexyl)phthalate
Dibenzo(a,h)anthracene
Hexachlorobenzene
Hexachlorobutadiene
2,3.7.8-TCDD-EQ
1 ,2,4-Trichlorobenzene
alpha-BHC
beta-BHC
delta-BHC
gamma-BHC (lindane)
alpha-Chlordane
gamma-Chlordane
2,4'-DDD
2.4'-DDE
2.4'-DDT
4,4'-DDD
4,4'-DDE
4.4'-DDT
Dieldrin
Endrin
Heptachlor epoxide
Toxaphene
'"'jWeaft«t /
Transforcrwd
:Data ',; i
9.8
0.9
2.0
-0.0
-0.1
3.5
3.0
3.6
6.0
-2.9
1.2
3.3
0.0
-0.0
-0.1
0.0
0.0
0.0
NA
0.1
2.0
2.9
3.1
3.1
2.6
2.6
4.3
3.1
3.7
5.0
5.3
4.4
3.4
2.8
3.3
7.4
\ Standard
Qevfatfon
'' ^ofdttte 1
1.35
0.75
1.27
0.72
0.59
1.08
1.0
1.02
1.42
0.58
0.21
0.9
0.32
0.56
0.92
0.38
0.37
0.27
NA
0.73
2.23
2.41
2.16
2.26
2.31
2.31
3.01
2.78
2.63
3.42
3.07
3.22
1.86
2.25
1.92
2.01
H (Statistic
;-', -from
- 'Table)
2.447
2.035
2.447
1.960
1.891
2.205
2.205
2.205
2.713
1.891
1.697
2.117
1.733
1.891
2.117
1.777
1.777
1.793
NA
1.96
3.295
3.920
3.295
3.920
3.920
3.920
4.569
4.569
3.920
5.233
4.569
4.569
2.997
3.920
3.295
3.295
Sample
S*»{1* /
85
85
85
85
85
85
85
85
85
85
85
85
85
85
85
85
85
85
1
85
86
86
86
86
86
86
63
63
63
86
86
86
86
86
86
86
VGL
63140
3.9
24.3
1.5
0.5
80.4
41
76.0
1650
0.1
3
50
1.0
1.3
1.6
1.1
1.2
1.1
NA
1.7
0.2
0.9
0.5
0.7
0.5
0.5
38.3
5.4
5.0
375.0
107.8
76.1
0.3
0.5
0.3
24.2
Maximum
-------
Table 7-Revlsed
Reasonable Maximum Exposure Concentrations for
Chemicals of Potential Concern In Groundwater
T.H. Agriculture & Nutrition Site
Montgomery, Montgomery County, Alabama
M^^SSSSM^^^ii^^^^^^^^i^
ICS8e]^^L«rt«»«3BiSB^HKBtSjff~£«ji i™ V lafcv-«»k.>'-'t- -33 :
JiaiSgfflByB^^
P """"i "I"1'1 • UUiLH^naw*'^'"
Aluminum
Barium
Cadmium
Chromium
Manganese
Thallium
Vanadium
Benzene
Carbon Disulfide
Carbon Tetrachlorkte
Chloroform
0 ibromochloroiwthane
1 5-Dichloroethane
1.1-Dichloroethene
15-Dichtoroethene
1 5-Dichloropropane
Ethyl benzene
Methytene Chloride
Tetrachtoroethene
1.1.1-Trichloroethane
Trichteroethene
Xylenes
bls(2-Ethylhexyl)phthalate
2,4-Dichtorophenol
Nitrobenzene
1 5.4-Trichlorobenzene
2,4,6-Trichtorophenol
alpha-BHC
beta-BHC
delta-BHC
gamma-BHC (lindane)
alpha-Chlordane
gamma-Chlordane
2.4'-DDD
2.4--DDE
2.4--DDT
4,4'-DDD
4.4'-DDE
4.4f-DDT
Dtekttn
Dinoseb
Endrin
HeptachlorepoxJde
SSESlslSfi Srjft°f7i
83
43
0.7
2.8
5.1
•05
1.6
-0.0
-0.4
0.1
0.3
-0.5
-0.3
0.8
0.5
-0.5
-0.4
02
0.4
0.4
1.2
0.5
0.6
0.1
-0.0
-0.0
0.1
-3.8
-3.1
-2.5
-3.4
-5.5
-5.5
-4.1
•4.4
-4.1
-3.4
-4.7
-4.0
-3.7
0.1
-4.3
-4.2
TgSHg%3tSgjgiii8
OJ2
OA3
0.47
0.73
130
0.51
033
1.76
1.18
1.72
1.83
1.01
1.35
1.56
2.01
1.06
1.50
1.07
1.73
1.86
225
1.74
1.34
0.35
0.36
0.15
0.40
2.88
2.72
3.01
2.42
1.46
1.34
1.55
1.92
1.55
2.27
1.70
1.83
1.74
0.49
224
1.31
afefesaalEERgBis
2002
2.710
2220
2.532
3.639
2220
Z902
2.997
2.447
2.997
2.997
2505
2.447
2.713
3595
2505
2.713
2505
2.997
2.997
3595
2.997
2.580
1.777
1.777
1.697
1.777
4.569
3.920
4.569
3.920
2.713
2.447
2.713
3595
2.713
3.920
2.997
2.997
2.997
1.830
3595
2.447
^nsj^rig
s
9
9
9
9
9
9
91
91
91
91
91
91
91
91
91
91
88
91
91
91
91
42
91
88
91
91
91
91
91
91
91
91
91
91
91
91
91
91
91
91
91
91
|i||i||§£
15368
198
33
41
2051
1.0
20
7.9
1.8
8.6
12.7
1.3
2.7
12
2B2
1.4
32
2.8
11.8
155
89.5
12.7
7.8
1.2
1.1
1.0
1.3
5.8
5.7
32.9
1.7
0.02
0.01
0.1
02
0.1
1.1
0.1
02
02
1.3
0.4
0.05
ii^i
•UAV|WU|,
^csbs*???1
29300
315
4.0
45
4060
23
35
3100
86
170
400
1.9
100
250
570
10
8300
2200
79
320
260
70000
59
12.0
8.5
22
19
19
3.8
17
42
026
0.05
4.3
3.8
7.7
22
11
38
0.8
25
9.4
0.09
iOtf.TX. V.-Jtt
^raiE/
ife
k&aZ-'A.',*- u
:»-«*•;- ••' «
15368
198
3.3
41
2051
1.0
20
7.9
1.8
8.6
12.7
1.3
2.7
12
262
1.4
32
2.8
11.8
155
89.5
12.7
7.8
1.2
1.1
1.0
1.3
5.8
3.8
17
1.7
0.02
0.01
0.1
02
0.1
1.1
0.1
02
02
1.3
0.4
0.05
Bold, JMfcfeMf flgunf npntant data that wv/» nvtsed to Jhcoipontf* »tow purge,
rota/ Inorganic*, groundwmtor data.
(1). Sample size based on number of usable results. Invalid results were not counted.
UCL: Upper Confidence Umrt
SQL: Sample Quantitatton Unit
Maximum: The highest detected concentration.
RME: Reasonable Maximum Exposure (UCL or maximum when UCL is greater than maximum)
-------
Table 8
Intake Factors for Onsite Worker
T.H. Agriculture & Nutrition Site
Montgomery, Montgomery County, Alabama
PARAMETER
BODY WEIGHT
EXPOSURE FREQUENCY
EXPOSURE DURATION
INHALATION RATE
SOILS INGESTION RATE
SKIN SURFACE AREA cnrVday
SOIL/SKIN ADHERENCE FACTOR
ABSORPTION FACTOR
UNITS
kg
days/year
years
mVday
mg/day
2,000
mg/cm2
unitless
NONCARCINOGENIC AVERAGING TIME days
CARCINOGENIC AVERAGING TIME
4
CONVERSION FACTOR
days
kg/mg
1 . Human Health Evaluation Manual, Supplemental Guidance: "
2. Exposure Factors Handbook (EPA, 1 989b)
3 . Region IV Guidance (EPA, 1 99 1 a)
4. Risk Assessment Guidance for Superftind (RAGS), Volume I,
VALUE
70
250
25
20
50
2
1.0
0.01 (organic compounds)
0.001 (inorganic compounds)
9,125
25,550
1/1,000,000
Standard Default Exposure Factors" (EPA, 1991b)
Human Health Evaluation Manual (Part A), Interim Final (EP
SOURCE
1,2
1
1
1
1
3
3
4
'A, 1989a)
43
-------
Table 9
Intake Factors for Site Visitor
T.H. Agriculture & Nutrition Site
Montgomery, Montgomery County. Alabama
PARAMETER
BODY WEIGHT
EXPOSURE FREQUENCY ONSITE
EXPOSURE FREQUENCY CREEK
EXPOSURE DURATION
INHALATION RATE
SOILS INGESTION RATE
SEDIMENT INGESTION RATE
SURFACE WATER INGESTION RATE
EXPOSURE TIME IN SURFACE WATER
SKIN SURFACE AREA
SOIL/SKIN ADHERENCE FACTOR
ABSORPTION FACTOR
UNITS
kg
visits/year
visits/year
years
mVday
ing/day
mg/day
L/hr
hours/visit
cmVvisit
mg/cm2
unitless
VALUE
45
78
15
10
20
100
100
0.05
2
5,300
1.0
0.01 (for organics)
SOURCE
4
4
4
4
3
4
4
2
4
4
1
1
0.001 (for inorganics)
44
-------
Table 9 (continued)
Intake Factors for Site Visitor
T.H. Agriculture & Nutrition Site
Montgomery, Montgomery County, Alabama
PARAMETER
UNITS
VALUE
SOURCE
PERMEABILITY CONSTANT cm2/hr
NONCARCINOGENIC AVERAGING TIME days
CARCINOGENIC AVERAGING TIME days
CONVERSION FACTOR kg/mg
CONVERSION FACTOR - LIQUID L/cm3
CONVERSION FACTOR mg///g
chemical specific
3,650
25,550
1/1,000,000
0.001
1/1,000
5
2
2
1. Region IV Guidance (EPA, 1991 a)
2. Risk Assessment Guidance for Superfund (RAGS), Volume I, Human Health Evaluation Manual (Part A), Interim Final (EPA, 1989a)
3. Human Health Evaluation Manual, Supplemental Guidance: "Standard Default Exposure Factors" (EPA, 1991b)
4. Professional Judgment
5. Dermal Exposure Assessment: Principles and Applications, Office of Research and Development. January. (EPA, 1992b).
45
-------
Table 10
Intake Factors for Child Hypothetical Future Resident
T.H. Agriculture & Nutrition Site
Montgomery. Montgomery County, Alabama
PARAMETER
BODY WEIGHT
EXPOSURE FREQUENCY (CREEK)
EXPOSURE FREQUENCY
EXPOSURE DURATION
INHALATION RATE
SOILS INGESTION RATE
SEDIMENT INGESTION RATE
SURFACE WATER INGESTION RATE
EXPOSURE TIME (SURFACE WATER)
SKIN SURFACE AREA
SOIL/SKIN ADHERENCE FACTOR
ABSORPTION FACTOR unitless
UNITS
kg
visits/year
days/year
years
mVday
rag/day
nig/day
L/hour
hours
crrf/day
rag/cm2
VALUE
15
90
350
6
16
200
100
0.05
2
5,000
1.0
0.01 (organic compounds)
SOURCE
1
5
1
2
1
1
5
4
5
3
1
4
GROUNDWATER INGESTION RATE L/day
0.001 (inorganic compounds)
1
-------
Table 10 (continued)
Intake Factors for Child Hypothetical Future Resident
T.H. Agriculture & Nutrition Site
Montgomery, Montgomery County. Alabama
PARAMETER UNITS VALUE SOURCE
PERMEABILITY CONSTANT cm/hour chemical specific 6
NONCARCINOGENIC AVERAGING TIME days 2,190 2
CARCINOGENIC AVERAGING TIME days 25,550 2
CONVERSION FACTOR kg/mg 1/1,000,000
CONVERSION FACTOR - LIQUID L/cm3 0.001
1. Human Health Evaluation Manual, Supplemental Guidance: "Standard Default Exposure Factors" (EPA, 1991b)
2. Risk Assessment Guidance for Superfund (RAGS), Volume I, Human Health Evaluation Manual (Part A), Interim Final (EPA, 1989a)
3. Exposure Factors Handbook (EPA, 1989b)
4. Region IV Guidance (EPA, 1991 a)
5. Professional Judgment
6. Dermal Exposure Assessment: Principles and Applications, Office of Research and Development. January. (EPA, 1992b).
49
-------
Table 11
Intake Factors for Adult Hypothetical Future Resident
T.H. Agriculture & Nutrition Site
Montgomery. Montgomery County. Alabama
PARAMETER
BODY WEIGHT
EXPOSURE FREQUENCY (CREEK)
EXPOSURE FREQUENCY
EXPOSURE DURATION
INHALATION RATE
SOILS INGESTION RATE
SEDIMENT INGESTION RATE
SURFACE WATER INGESTION RATE
EXPOSURE TIME IN SURFACE WATER
SKIN SURFACE AREA
SOIL/SKIN ADHERENCE FACTOR
ABSORPTION FACTOR
UNITS
kg
visits/year
days/year
years
mVday
ing/day
nig/day
L/hour
hours
cmVday
mg/cm2
unitless
VALUE
70
90
350
24
20
100
100
0.05
2
5,300
1.0
0.01 (organic compounds)
SOURCE
1
5
1
2
1
1
5
4
5
3
1
4
0.001 (inorganic compounds)
-------
Table 11 (continued)
Intake Factors for Adult Hypothetical Future Resident
T.H. Agriculture & Nutrition Site
Montgomery. Montgomery County, Alabama
PARAMETER
PERMEABILITY CONSTANT
GROUNDWATER INGESTION RATE
NONCARCINOGENIC AVERAGING TIME
CARCINOGENIC AVERAGING TIME
UNITS
cm/hour
L/day
days
days
VALUE
chemical specific
2
8,760
25,550
SOURCE
6
1
2
2
CONVERSION FACTOR kg/mg 1/1,000,000
CONVERSION FACTOR - LIQUID L/cm3 0.001
1. Human Health Evaluation Manual, Supplemental Guidance: "Standard Default Exposure Factors" (EPA, 1991b)
2. Risk Assessment Guidance for Superfund (RAGS), Volume I, Human Health Evaluation Manual (Part A), Interim Final (EPA, 1989a)
3. Exposure Factors Handbook (EPA, 1989b)
4. Region IV Guidance (EPA, 1991 a)
5. Professional Judgment
6. Dermal Exposure Assessment: Principles and Applications, Office of Research and Development. January. (EPA, 1992b).
51
-------
Table 12-flevtaed
Cancer Stop* Factor*. Tumor Sftaa tad EPA Cancer Clesslflcation* for
Chemfcaki of Potential Concern
T.H. Agriculture ft Nutrition Site
Itontgornery. Montgomery County, Alabami
{fMatWITflBBB
tHaBBBiBSaiiBBBBBBB
Bm^BBmBapBBSBBflaBfc^BaBaail
p5@i8BwrSwBMBmBtug^B6^
(Aluminum
1 Antimony
4/aanfe
Barium
Benzene
Benzo(a)anthracene
Ben2o(b)fluoranthene
B«nzo(i)pyrona
Beryllium
alpha-BHC
beta-BHC
delta-BHC
jamma-BHC (lindane)
Bis(2-«hylhaxyl)prithalate
Cadmium
Carbon dtsuffide
Carbon tatrachlorlda
alpha-Chlordans
jamma-Chlordane
Shloroform
Chromium VI
Copper
2.4-D
2.4' ODD
2.4--DDE
2.4--DDT
4,4'-DOO
4.4--OOE
4.4'-OOT
Diben2D(a.rOanthracene
Dibromochloromethane
1 .4-Dtchtorobenzene
1.2-Dichtoroethane
1.1-Dichtoroethene
1.2-Dichk>roethene (mixed)
2.4-Dichlorophanol
1,2-Dichtoropropane
DieWrin
Dinoseb
Endrin
Ethylbenzene
Hopatchtor
Hepatchtor epoxlde
Hexachtorobenzene
Haxachlorobutadiena
lrKtono((1.2.3)pyrana
Laad
Manganese (water/rood)
Mercury
Methylena chloride
4-Methylphenol
Nickel
Nitrobenzene
2,3.7.8-TetrachlorodibenzDdioxln
Tetrachloroethene
Thallium carbonate
Toluene
Toxaphene
1 ,2.4-Trichtorobenzane
1.1.1-TrtcMoroethane
Trichloroethene
2.4.6-Trichlorophenol
vanadium
Xylenes
Zinc
jatUt&faaHtt
EBBftHB^Q
^^^2S88Bi9
IBHMMBI
cfifcSSteSE
SS^I^^^n^^l^r^
iMaffllc^^'^^^iSfflatTO
^^^^^•^^aa^^^^^dajatimMe^flBaM^^^^M
S^iVlV:XBBt*M&~l*JiUlm^^S8XSSt
NA NA
NA
1JOE+OOO (i)
NA
2.9E-002 (i)
7.3E+000 ;IV)
7.3E+000 IIV)
7.3E+000 (i)
4.3E+000 (i)
6.3E+OOO (i)
1.8E+OOO (i)
1.3E+000 IIV)
1.3E+000 (h)
1.4E-002 (i)
NA
NA
1.3E-001 (i)
1.3E+000 (i)
1.3E+000 (i)
6.1E-003 (i)
NA
NA
NA
2.46-001 |IV)
3.4E-001 |IV)
3.4E-001 |IV)
2.4E-001 (i)
3.4E-O01 (i)
3.4E-001 (i)
7.3E+000 |IV)
8.4E-002 (i)
2.4E-002 (h)
9.1E-002 (i)
6E-001 (i)
NA
NA
6.8E-002 (h)
1.6E+C01 (i)
NA
NA
NA
4.5E+000 (i)
9.1E+OOO (i)
1.6E+000 (i)
7.8E-002 (i)
7.3E+000 ;(V)
NA
NA
NA
7.5E-003 (i)
NA
NA
NA
1.5E+OOS (h)
5.2E-002 (e)
NA
NA
1.1E+000 (i)
NA
NA
1.1E-002 (e)
1.1E-002 (i)
NA
NA
NA
NA
4.3E-003 (i)
NA
8.3E-006 (i)
NA
NA
NA
2.4E-003 (i)
1.8E-003 (i)
S.3E-004 (i)
NA
NA
NA
1.8E-003 (i)
NA
1.5E-005
3.7E-004 (i)
3.7E-004 (I)
2.3E-005 (i)
1.2E-002 (1)
NA
NA
NA
NA
9.7E-005 (IV)
NA
NA
9.7E-OOS (i)
NA
NA
NA
2.6E-005 (1)
S.OE-005 (i)
NA
NA
NA
4.6E-003 (i)
NA
NA
NA
1.3E-003 (i)
2.6E-003 (i)
4.6E-004 (i)
NA
NA
NA
NA
NA
4.7E-007 (i)
NA
NA
NA
3.3E-005 (h)
5.8E-M7 (e)
NA
NA
3.2E-004 (i)
NA
NA
1.7E-006 (e)
3.1E-006 (i)
NA
NA
NA
NA
NA
1.5E+001 (i)
NA
2.9E-002 (i)
NA
NA
6.1E+000 (IV)
8.4E+000 (i)
6.3E+000 (i)
1.8E+OOO (i)
NA
NA
NA
6.3E+000 (i)
NA
5.3E-002 (i)
1.3E+000 (i)
1.3E+OOO (i)
B.lE-002 (i)
4.2E+O01 (i)
NA
NA
NA
NA
3.4E-001 (IV)
NA
NA
3.4E-001 (i)
NA
NA
NA
9.1E-002 (i)
1.8E-001 (i)
NA
NA
NA
1.6E+001 (i)
NA
NA
NA
4.6E+000 (i)
9.1E+000 (1)
1.6E+000 (i)
7.7E-002 (i)
NA
NA
NA
NA
1.6E-003 (i)
NA
NA
NA
1.5E+005 (h)
2.0E-003 (e)
NA
NA
1.1E+000 (i)
NA
NA
6.0E-003 (e)
1.1E-002 (i)
NA
NA
NA
NA
NA
7_3£*0»
NA
3.6E-002
1.5E+001
1.5E*001
1.5E+001
2.2E+001
1.3E+001
3.6E+000
2.6E+000
2.6E+000
2.8E-002
NA
NA
1.6E-001
2.6E-KKM
2.6E+000
7.6E-003
NA
NA
NA
4.8E-001
6.8E-001
6.8E-001
4.8E-001
6.8E-001
6.8E-001
1.5E+001
1.1E-001
4.8E-002
1.1E-001
7.5E-001
NA
NA
8.5E-002
3.2E+O01
NA
NA
NA
9.0E+000
1.8E+O01
3.2E+000
1.6E-001
1.5E+001
NA
NA
NA
9.4E-003
NA
NA
NA
3E4005
6.5E-002
NA
NA
2.2E+000
NA
NA
1.4E-002
2.2E-002
NA
NA
NA
^tL7i- 't^-'"" -'•"^^Kw'^i
%iit!j$5jaj5si
Lw^^Jj^ffs^iJQiS
NA
NA
Skin
NA
Leukemia
Forestomach
Forestomach
Fotastomach
All sites
Liver
Liver
NA
Liver
Liver
NA
NA
Liver
Liver
Liver
Several cites
NA
NA
NA
(jver
Liver
Liver
Liver
Liver
Liver
Forestomach
Liver
Liver
Several sites
Kidney
NA
NA
Liver
Liver
NA
NA
NA
Liver
Liver
Liver, thyroid
Liver
Forestomach
Kidney
NA
NA
Liver
NA
NA
NA
Liver
Liver
NA
NA
Liver
NA
NA
L/ver
Leukemia
NA
NA
NA
&«ffg|ja?^
Pi^^
^^v.'WJJ'SrtB:
NA
NA
Lung
NA
Leukemia
NA
NA
Respiratory tract
Lung
Liver
Liver
NA
NA
NA
Lung, trachea
NA
Liver
Liver
Liver
Several sites
Lung
NA
NA
NA
NA
Liver
NA
NA
Liver
NA
NA
NA
Several sites
Kidney
NA
NA
NA
Liver
NA
NA
NA
Liver
Uver
Liver, thyroid
Uver
NA
NA
NA
NA
Liver
NA
NA
NA
Resp. system
Liver
NA
NA
Liver
NA
NA
Liver
Leukemia
NA
NA
NA
•m
wy.-rara
•m&
0
D
A
D
A
B2
B2
B2
B2
B2
C
O
D
B2
B1
D
B2
B2
B2
B2
A
D
O
82
B2
B2
B2
B2
B2
B2
C
B2
B2
C
0
D
62
B2
D
D
D
B2
B2
B2
B2
B2
B2
D
D
B2
0
D
D
82
NA
D
D
B2
D
0
NA
B2
D
D
O
(1) Absorption factors: 20% inorganics. 50% semMolatiles, 80% volatile*
(i) IRIS
(h) HEAST
(e) ECAO
(IV) EPA Region IV Guidance
CSFo • Cancer Slope Factor (oral), (mg/kg/dayr-1
Unit Risk (inhalation)- (ug/cu m)-1
CSFi • Cancer Slope Factor (inhalation), (mg/Xg/dayH
NA • Not Applicable (no data)
EPA Classification:
A • Human carcinogen
B - Probable human carcinogen
C • Possible human carcinogen
D - Not classifiable as a human carcinogen
-------
Tabtoia-Revtead
Reference DIMM and Target Stta* for
Chemlcars of Potential Concent
TJ4. Agriculture ft Nutrition Site
Montgomery, Montgomery County, Alabama
^A^^M^iilMM^S^^^^^S^^^^^
SmSmi^^mSmiaSS^^S^K^
^^Hffl^^^^^M^H^8[^^KMpKBII|K^|
KJ^^BUHj^f^^^^^^^^^^^E^H&fff^ff^ESaSS^Mff^Ka&K
Aluminum
Antimony
Arsenic
Barium
Benzene
Benzo(a)anrriracane
Berao(b)fluoranthene
Benzo(a)pyrene
Beryllium
afcha-BHC
beta-BHC
detta-BHC
gamma-BHC (llndane)
9ls(2-«thy1hexyl)phthalate
Cadmium (water)
Cadmium (food)
Carbon dHutflde
Carbon tetrachlorlde
aJpha-Chtordane
gamma-Chlordane
Chloroform
Chromium VI
Copper
2.4-D
2.4--DDD
2.4--DDE
2.4--DDT
M'-DOD
M'-DDE
4.4--DDT
3l>enzo(a,h)anthracene
Dfcromcchloromettiane
1.4-Dlchlorobenzene
1.2-Dlchloroethane
1.1-Dlchloroettiene
1,2-Dlchloroetnena (mixed)
2.4-Dlehlorophenol
1,2-Dlchloropropane
Dltldrln
Dlnoseb
Endrln
EthyTbenzene
Haptachlor
Heptacnlor epoxlde
hlaxachlorobenzene
Hexachiorobutadient
hdeno((1.2.3)pyrene
Lead
Manganese (water)
Manganese (food)
Mercury
4 M^ttivtohainol
Nickel
Nitrobenzene
? 1 7.0 TeliarhlijuMHiemocllojdM
Tetfechloroetriene
Thallium carbonate
Toluene
Toxaphene
1 ,2.4-Trichlorobenzene
1.1.1-Trlcnloroethane
TVteMorMthtnt
2,4,6-Trtcfitorophenol
Vanadium
Xytenea
Zinc
1A&400 (•)
4E-004 (1)
3E-004 (1)
7E-002 (1)
NA
NA
NA
NA
5E-003 (I)
NA
NA
NA
3E-004 (1)
2E-002 (1)
SE-004 (1)
1E-003 (I)
1E-001 (1)
7E-004 (1)
6E-005 (1)
6E-005 (1)
1E-002 (I)
SE-003 (I)
3.7E-002 (h)
1E-002 (1)
5E-004 (IV)
SE-004 (IV)
SE-004 (IV)
SE-004 (IV)
SE-004 (IV)
SE-004 (1)
NA
2E-002 (I)
NA
NA
96-003 (1)
96-003 (h)
3E-O03 (1)
NA
SE-005 (1)
1E-003 (I)
3E-004 (I)
1E-001 (1)
SE-004 (1)
1.3E-005 (I)
8E-004 (1)
2E-004 (1)
NA
NA
SE-003 (1)
1.4E-001 (1)
3E-004 (h)
ce *!vv> /u\
9C-OU3 (h)
2E-002 (1)
SE-004 (1)
NA
1E-002 (I)
8E-005 (I)
2E-001 (1)
NA
1E-002 (I)
9E-002 (w)
6E-003 (e)
NA
7E-003 (h)
2E«000 (I)
3E-001 (1)
NA
NA
NA
SE-004 (h)
SE-004 (e)
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
1E-002 (h)
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
4E-003 (1)
NA
NA
NA
1E*000 (1)
NA
NA
NA
NA
NA
NA
NA
NA
3E-004 (h)
3E+000 (h)
NA
2E-003 (h)
NA
NA
NA
NA
NA
96-003 (h)
NA
NA
NA
NA
NA
NA
NA
NA
NA
1.4E-004 (h)
1.4E-004 (e)
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
5.7E-004 (e)
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
2.3E-001
2.96-003 (e)
NA
NA
NA
1.1E-003 (1)
NA
NA
NA
3E-001 (1)
NA
NA
NA
NA
NA
NA
NA
NA
9E-005 (h)
9E-001 (h)
NA
SE-004 (h)
NA
NA
NA
1.1E-001 (w)
NA
3E-003 (h)
NA
NA
NA
NA
NA
NA
IfflBH
pRj^pwWc?
2E-001
8E-OOS
8E-005
1E-O02
NA
NA
NA
NA
tE-003
NA
NA
NA
2E-004
1E-002
1E-004
26-004
8E-002
6E-004
3E-OOS
36-005
8E-003
1E-003
7E-003
5E-003
3E-004
3E-004
36-004
3E-004
3E-004
3E-004
NA
26-002
NA
NA
76-003
7E-003
26-003
NA
36-005
SE-004
2E-004
86-002
3E-004
7E-006
4E-004
1E-004
NA
NA
1E-003
3E-002
6E-005
SE-002
tf fWl
JC-UUU
46-003
4E-004
86-003
2E-OOS
26-001
NA
86-003
76-002
SE-003
NA
16-003
26*000
66-002
Unknown
Longevity, blood glucose
Skin, blood vessels
Increased blood pressure
NA
NA
NA
NA
NOAEL
NA
NA
NA
Uver. kidney
Uver
Proteinuria
NOAEL
Fetal taxi city
Uver
Uver
Uver
Uver
NOAEL
NA
NA
NA
NA
Uver
NA
NA
Uver
NA
Uver
Unknown
NA
Uver
Uver
Deer, hypersens. response
NA
Uver
Decreased fetal weight
Uver
Uver. kidney
Uver
Uver
Liver
Uver
NA
CNS •fleets, blood
CNS effects
NOAEL
Kidney
Uver
Decreased weight
Uver, adrenals
MA
nn
Uver
her. SOOT and LDH
Unknown
NA
Adrenal gland
Uver
NA
NA
None observed
Hyperactlvlty
Decreased ESOD cone.
aBgsgai!^.£giEB
NA
NA
NA
Fetal foxfdty
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Fetal toxiclty
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA '
NA
NA
NA
NA
NA
NA
Nasal mucosa
NA
NA
NA
Developmental toxiclty
NA
NA
NA
NA
NA
CNS effects, blood
NA
NA
Neurotoxldty
Liver
MA
NA
Blood
NA
NA
NA
NA
Uver
NA
NA
NA
NA
NA
NA
(1) Absorption factors: 20% Inorganics. 50% semtvlalatlles. 80% volatile*
(ORB
(h)HEAST
(e) ECAO
(IV) EPA Region IV Guidance
(w) Withdrawn from RBor HEAST
RfDo Reference Dose (oral). (mg/kg/Uay)
RfC Reference Concentrsflon, (mg/cu m)
RfDI Reference DOM (Inhalation), (mg/kg/day)
NA Not Applicable (no data)
-------
Table 14
Summary of Cancer and Noncancer Risks by Exposure Route
Current Use Scenario
T.H. Agriculture & Nutrition Site
Montgomery, Montgomery County, Alabama
Btte Visitor;
Cancer
Inadvertent Ingestion of Soil
Dermal Contact with Soil
Inhalation of Dust
Inadvertent Ingestion of Surface Water
Dermal Contact with Surface Water
Inadvertent Ingestion of Sediment
Dermal Contact with Sediment
2E-005
2E-005
3E-008
NA
NA
NA
NA
0.3
0.2
0.00005
NA
NA
NA
NA
9E-006
8E-006
5E-009
9E-007
1E-005
3E-006
3E-006
0.3
0.2
0.00002
0.1
0.5
0.1
0.1
TOTAL CURRENT RISK
4E-005
0.5
3E-005
1.3
HI Hazard Index (noncancer risk)
NA Not Applicable
-------
Table 15-Revlsed
Summary of Cancer and Noncancer Risks by Exposure Pathway
Future Use Scenario
T.H. Agriculture & Nutrition SHe
Montgomery, Montgomery County, Alabama
Inadvertent Ingestbn of Soil
Dermal Contact with Soil
Inhalation of Dust
Inadvertent Ingestion of Surface Water
Dermal Contact with Surface Water
Inadvertent Ingestion of Sediment
Dermal Contact with Sediment
Ingestbn of Groundwater (1)
Inhalation of VOCs
1E-004
6E-005
3E-008
9E-006
1E-004
4E-005
3E-005
5E-004
NA
7
3
0.0003
2
8
2
2
33
NA
6E-005
6E-005
4E-008
8E-006
1E-004
3E-005
3E-005
8E-004
4E-005
0.8
0.6
0.0001
0.5
1.8
0.5
0.4
14
2.1
2E-004
1E-004
7E-008
2E-005
2E-004
7E-005
6E-005
1E-003
4E-005
7.9
3.3
0.0004
3
10
3
2
47
2E-005
2E-005
3E-008
NA
NA
NA
NA
NA
NA
0.3
0.2
0.00005
NA
NA
NA
NA
NA
NA
9E-006
8E-006
5E-009
9E-007
1E-005
3E-006
3E-006
NA
NA
0.3
0.2
0.00002
0.1
0.5
0.1
0.1
NA
NA
TOTAL FUTURE RISK
8E-004
57
1E-003
21
2E-003
78
4E-005
0.5
3E-005
1.3
(1) Revised to Incorporate slow purge, total Inorganics groundwater data.
HI Hazard Index (noncancer risk)
NA Not Applicable
VOCs Volatile Organic Compounds
-------
TaMa 17-ftevbed
Chemicals of Concern
TK. Agriculture 4 NutrtUon She
Montgomery. Montgomery County. Alabama
^^B^t^SS^StSSSBSK&^^^StSS^Et
^F^&j^SEESfg^^ESSSSSC&iSSSi
i^niBHHflBUMfiBSfflttfll
tnBdvwtom
L— —--
-------
Tabte 17-Revteed
Chemicals of Concern
T.H. Agriculture * Nutrition Sit*
Montgomery. Montgomery County. Alabama
jjSSSS&S3&£$ll
Dermal
Contact
hadvertent
Ingeston
Dermal
Contact
Ingeston
Surface
Water
Sediment
Sediment
Ground
Water
4.4--DDO ] She Visitor
4.4--DDE
Manganese
Benzo(b)fluoran1hene
beta-BHC
2,4'-DDD
4.4'-DDD
4.4--DOE
4,4'-DDT
Dieldrin
Benzo(b)lluoranthene
beta-BHC
4.4--DDD
4.4--DDE
4.4--DDT
Dieldrin
4,4'-DDD
Arsenic
Thallium
Benzo(a)pyrene
2.4'-DDD
4.4--DOD
4.4'-DDE
4.4--DDT
Toxaphene
Arsenic
2.4--DDD
4.4--DDD
4,4'-DDE
4,4'-DDT
Toxaphene
4.4--DDD
Arsenic
Benzo(a)pyrene
2.4--DDD
4,4'-DDD
4.4'-DDE
4.4--DDT
Toxaphene
Arsenic
Benzo(a)pyrene
2,4'-DDD
4,4'-DDD
4,4'-DDE
4.4--DDT
Toxaphene
Aluminum
Barium
Cadmium
Chromium
Manganese
Thallium
Vanadium
Benzene
Carbon Tetrachtoride
Chloroform
1.2-Dlchloroathane
1,1-Dicnloroetnene
1.2-Dlchloroethene
v_. . |.| •Iliaiin
Tetracntoioeihene
bte(2-Elhy1r»exyl)ph1halate
Nitrobenzene
alpha-BHC
beta-BHC
delta-BHC
gamma-BHC
4.4'-DDD
Dieldrin
Dinosab
Endrin
HeptacrilorepoMde
Child
Resident
Adult
Resident
Site Visitor
Child
Resident
Adult
Resident
Site Visitor
Child
Resident
Adult
Resident
Child
Resident
8E-006
2E-006
NA
3E-006
2E-006
7E-007
8E-005
2E-005
4E-006
2E-006
2E-006
1E-006
7E-005
2E-005
4E-006
1E-006
1E-006
6E-006
NA
1E-006
1E-006
1E-005
5E-006
4E-006
4E-006
5E-006
1E-006
1E-005
4E-006
3E-006
3E-006
1E-006
2E-006
1E-006
1E-006
1E-005
5E-006
4E-006
4E-006
1E-006
1E-006
1E-006
1E-005
5E-006
3E-006
3E-006
NA
NA
NA
NA
NA
NA
NA
1E-006
6E-006
4E-007
1E-006
4E-005
NA
3E-006
5E-006
6E-007
NA
2E-004
4E-005
1E-004
1E-005
2E-006
2E-005
NA
NA
3E-006
.HtiWanrt^
l-^JuoBenl'fi
0.4
0.1
0.2
NA
NA
0.1
6.2
1.0
0.3
0.02
NA
NA
1.4
02
0.1
0.005
0.1
0.1
0.1
NA
0.1
12
0.4
0.3
NA
0.03
0.03
0.3
0.1
0.1
NA
0.1
0.03
NA
0.1
1.0
0.3
02
NA
0.01
NA
0.02
02.
0.1
0.05
NA
1
03
0.4
0.5
26
0.8
03
NA
0.8
0.1
NA
0.1
02
0.1
1.0
0.02
0.1
NA
NA
NA
0.4
0.1
02
0.1
0.1
0.3
-------
Table 17-Revteed
Chemicals of Concern
TJt Agriculture * Nutrition Site
MontgonMiy, MontgonMry County. Alabama
Ground
Water
Aluminum
Barium
Cadmium
Chromium
Manganese
Thallium
Vanadium
Benzene
Cartoon Tetrachtorlda
Dibromochloromelhane
1,2-Dichkxoelhane
1.1-0ichloro0lhene
1.2-DichloroBlnene
Telrachloroethene
Trichloroethene
bis(2-Elhy1hexyl)ph1halale
Nitrobenzene
alpha-BHC
beta-BHC
deha-BHC
gamma-BHC
4.4'-DDD
Oieldrin
Heptachlof epoxkte
Adult
Resident
MA
NA
NA
NA
NA
NA
NA
2E-006
1E-005
1E-006
2E-006
7E-005
NA
6E-006
9E-006
1E-006
NA
3E-004
6E-005
2E-O04
2E-005
3E-006
3E-005
4E-006
0.4
0.1
OS
OS
11
0.3
0.1
NA
0.3
0.002
NA|
0.04
0.1
0.03
0.4
0.01
0.1
NA
NA
NA
0.2
0.1
0.1
0.1
Inhalation
Votedlles
Ground
Water
Benzene
Carbon Tetrachloride
Chloroform
1,2-DJctiloroalhane
1,1-Dichloroettiene
Trichloroethene
Nitrobenzene
Adult
Resident
2E-006
4E-006
IE-DOS
2E-006
2E-005
5E-006
NA
1.5
0.4
NA|
0.03
NA
NA
0.1
BoH. ltmllclz»d figum npnsent OfU Out IMA* rmvttud to Incorporate slow purge,
total InofpmJe*. groundwater dtta.
-------
APPENDIX D
SELECTED TABLES FROM THE ECOLOGICAL RISK ASSESSMENT
SELECTED HAP, TABLE FROM THE SUPPLEMENTAL RI
The following tables are
provided without page
numbers, and were taken
from the Revised Ecological
Risk Assessment, dated May
1995:
Table 3-2
Table 4-2
Table 4-6
Table 5-1
The following map and table
are taken from the Draft
Supplemental Remedial
Investigation, dated June
1994:
Figure 2-1
Table 2-2
62
-------
TABLE 3-2
REFERENCE AREAS SEDIMENT SAMPLE RESULTS*
THAN SITE
MONTGOMERY, ALABAMA
Reference Area 1
Constituent of
Intercut
Pesticide* (/>g/kg)
•Iph.-BHC
beU-BHC
gamma-BHC
delU-BHC
4,4'-DDD
4,4'-DDE
4,4'-DDT
2,4'-DDD
2.4--DDE
2,4'-DDT
alpha-Chlordane
ganuna-CbJordane
TOC (rag/kg)
ftSollda
Sediment Texture
% Gravel
%Sand
%Silt
% Clay
6216
R1A
0.33 U
0.67 U
1.0 U
1.0 U
4.4
26
4.4
1.3 U
0.67 U
1.3 U
0.40 U
0.40 U
13,000
71.9
0.0
11.2
66.3
32.5
6216
R1B«
0.33 U
0.67 U
1.0 U
1.0 U
75
32
1.3 U
1.3 U
0.67 U
1.3 U
2.0 U
2.0 U
78,000
395
0.0
12.3
27.6
605
6217
R1C
0.33 U
0.67 U
1.0 U
1.0 U
1.6
85
1.3 U
1.3 U
0.67 U
1.3 U
0.40 U
0.40 U
22,000
61.1
0.0
85
46.0
463
6218
RID
0.33 U
0.67 U
1.0 U
1.0 U
3.4
12
1.3 O
1.3 U
0.67 U
1.3 U
0.40 U
0.40 U
24,000
66.7
0.0
7.3
44.3
48.4
Arithmetic
Meanb-e
_d
—
-
_
3.1
16.3
15
—
-
—
—
-
20,000
625
0.0
85
48.6
42.6
6212
R2A
0.33 U
0.67 U
1.0 U
1.0 U
1.7
16
1.3 U
1.3 U
0.67 U
1.3 U
0.40 U
0.40 U
78,000
46.4
0.0
6.4
43.3
60.3
Reference Area 2
6213
R2B
0.33 U
0.67 U
1.0 U
1.0 U
35
6.4
1.3 U
1.3 U
0.67 U
1.3 U
0.40 U
0.40 U
38,000
64.4
0.0
3.9
61.4
34.7
6214
R2C
0.33 U
0.67 U
1.0 U
1.0 U
1.3U
3.6
1.3 U
1.3 U
0.67 U
1.3 U
0.40 U
0.40 U
16,000
72.4
1.4
16.7
67.6
24.4
Arithmetic
Mean*
M
_
_
—
15
8.3
—
_
-
_
_
-
44,000
60.7
0.6
9.0
64.1
36.6
6219
R3A
0.33 U
0.67 U
1.0 U
1.0 U
2.3
1.6
1.3 U
1.3 U
0.67 U
1.3 U
0.40 U
0.40 U
23,000
66.9
0.0
6.1
49.6
44.4
Reference Area 3
6220
R3B
0.33 U
0.67 U
1.0 U
1.0 U
1.3 U
2.1
1.3 U
1.3 U
0.67 U
1.3 U
0.40 U
0.40 U
33,000
66.6
05
73
34.6
663
6221
R3C
0.33 U
0.67 U
1.0 U
1.0 U
7.4
9.6
2.6
1.3 U
0.67 U
1.3 U
0.40 U
0.40 U
37,000
643
0.0
4.1
31.3
64.6
Arithmetic
Mean*
_
_
-
_
3.6
4.4
1.3
_
-
_
_
-
31,000
69.3
0.3
6.0
38.4
66.3
Reference
East Ditch
6222
RED
0.33 U
0.67 U
1.0 U
1.0 U
1.3 U
0.67 U
1.3 U
1.3 U
0.67 U
1.3 U
0.40 U
0.40 U
2,600
66.4
0.0
19.8
43.6
36.6
•The preeence of a *U* qualifier indicate! that the compound waa analyxed for but not detected. The detection limit was assigned as the concentration for 'U* qualified data.
bD«U for sample location RIB were not included in the calculation of the arithmetic meana for Area 1. The USEPA concurred with the exclusion of RIB ae a reference location baaed on the
analytical results.
cWhile the table presents detection limits for nondetect data, for the purposes of calculating the arithmetic mean, one-half of the detection limit waa used for all non-detecte (NDe); duplicate
samples were considered individual samples in the calculation of the arithmetic mean. Arithmetic means are rounded to the number of significant digits to which the data were reported.
d Dashes (-) indicate that all values for a constituent were non-detecta (NDs), and no arithmetic mean was calculated.
Q:\95I8\ERATO302.DOC
Pigolofl
-------
TABLE 4-2
CHEMICAL RESULTS FOR TISSUE SAMPLES COLLECTED FOR THE BIOACCUMULATION ASSESSMENT
THAN SITE
MONTGOMERY, ALABAMA
East Ditch Referent*
Constituent
Peettcide* (pg/k«)
alpha-BHC
beta-BHC
gamma-BHC
de!U-BHC
4.4'-DDD
4,4'-DDE
4,4t-DDT
2,4'-DDD
2,4'-DDE
^•-DDT
alpba-Chlordane
gamma-Chlordam
W0t Weight (g)
6603
T-ED-R
(Tadpole.)
0.60 Uk
1.0 U
1.6 U
1.6 U
2.0 U
13
2.0 U
2.0 U
1.0 U
2.0 U
0.60 U
0.60 U
21
6604
T-ED-R
(Snails)
0.60 U
1.0 U
1.6 U
1.6 U
2.0 U
1.0 U
2.0 U
2.0 U
1.0 U
2.0 U
0.60 U
0.60 U
30
6749
T-ED-1
(Snails)
lOUDe
SOD
30 UD
30 UD
810 D
840 D
73 D
390 D
39D
40 UD
13 D
22D
16.6
East Ditch-Location 1
6760
T-ED-1
(Moequitofuh) (
6.90^
240 D
16 UD
16 UD
6,9000
6.800 D
93 D
700 D
170 D
20 UD
6.0 UD
49 D
28.7
6761
T-ED-1
Dragonfly larvae)
1.2 D
17 D
3.0 UD
3.0 UD
120 D
230 D
4.0 UD
43 D
4.2 D
4.0 UD
2.4 D
3.1 D
20.3
6762
T-ED-1
(Tadpole*)
6.0 UD
SOD
16 UD
16 UD
870 D
730 D
33D
280 D
62 D
20 UD
6.4 D
16 D
14j6
6868
T-l-R
2.6 U
6.0 U
7.6 U
7.6 U
10 U
18
10 U
10 U
6.0 U
10 U
3.0 U
3.0 U
3.6
Area 1 Reference
6606
T-l-R
(Worms)
0.60 U
1.0 U
1.6 U
1.6 U
2.0 U
14
2.0 U
2.0 U
1.0 U
2.0 U
0.60 U
0.60 U
33
6506
T-I.R
(Crayfish)
0.60 U
1.0 U
1.6 U
1.6 U
2.0 U
1.0 U
2.0 U
2.0 U
1.0 U
2.0 U
0.60 U
0.60 U
26
•
-------
TABLE 4-2 (Continued)
CHEMICAL RESULTS FOR TISSUE SAMPLES COLLECTED FOR THE BIOACCUMULATION ASSESSMENT
THAN SITE
MONTGOMERY, ALABAMA
Area 1— Location 1
Conatituent
PeiUetdM (pg/kg)
aJpba-BHC
beta-BHC
gajnma-BHC
delU-BHC
4,4'-DDD
4.4--DDE
4.4--DDT
2,4'-DDD
2,4'-DDE
2.4'-DDT
alpha -Chlordaae
gararaa-Chlordana
Wet Weight (g)
6607
T-l-1
(Worm*)
26 UO
60 UD
76 UD
76 UD
1,600 D
2^00 D
100 UD
1,100 D
170 D
100 UD
83 D
60 D
192
6608
T-l-1
(Crayfuh)
6.0 UD
19 D
16 UD
16 UD
78 D
830 D
20 UD
31 D
7.9 D
20 UD
9.3 D
6.0 UD
4
6609
T-l-1
(Moaquitofiah)
26 UD
MUD
76 UD
76 UD
3,900 D
2,600 D
100 UD
610 D
89D
100 UD
33 D
36D
33.7
6610
T-l-1
(Tadpole.)
12.6 UD
26 UD
37.6 UD
37.6 UD
670 D
770 D
MUD
320 D
66D
MUD
30 D
23D
24.0
6766
T-l-2
(Moequitofuh)
2.6 UD
7.7 D
7.6 UD
7.6 UD .
130 D
330 D
10 UD
42 D
6.0 UD
10 UD
3.1 D
3.0 UD
26.7
Area 1 -Location 2
6766
T-l-2
(Tadpoke)
2.0 UD
7.6 D
6.0 UD
6.0 UD
89D
HOD
8.0 UD
47 D
7.0 D
8.0 UD
2.4 UD
3.0 D
20.1
6767
T-l-2
(Wonna)
6.0 UD
10 UD
16 UD
16 UD
180 D
370 D
20 UD
1MD
26D
20 UD
9.2 D
7.6 D
24.7
6767 DUP
T-l-2
(Wonna;
DuplicaU)
6.0 UD
10 UD
16 UD
16 UD
170 D
380 D
20 UD
130 D
20 D
20 UD
8.1 D
6.0 UD
24.7
Q:\9218\ERAT040I.DOC
P(fRlof)
-------
TABLE 4-2 (Continued)
CHEMICAL RESULTS FOR TISSUE SAMPLES COLLECTED FOR THE BIOACCUMULATION ASSESSMENT
THAN SITE
MONTGOMERY, ALABAMA
Area 2-Location 1
Constituent
alpha-BHC
bete-BHC
gamma-BHC
delta-BHC
4,4'-DDD
4,4'-DDE
4,4I-DDT
2,4'-DDD
2,4'-DDE
^'-DDT
alpha -Chlordane
gamma -Chlordane
Wet Weight (g)
6764
T-2-1
(Orube)
6.0 UD
10 UD
16 UD
16 UD
68D
270 D
20 UD
SOD
24D
20 UD
11 D
6.0 UD
26.6
6763
T-2-1
(Worms)
0.60 U
1.0 U
1.6 U
1.6 U
12
110
2.0 U
8.7
34
2.0 U
2.6
0.60 U
17.0
6743
T-3-1
(Worms)
0.60 U
1.0 U
1.6 U
1.6 U
2.0 U
7.3
2.0 U
2.0 U
1.0 U
2.0 U
0.60 U
0.60 U
22.0
6744
T-3-1
(Crayfish)
0.60 U
1.0 U
1.6 U
1.6 U
2.0 U
2.7
2.0 U
2.0 U
1.0 U
2.0 U
0.60 U
0.60 U
223
Area 3-Location 1
6746
T-3-1
(Snails)
2.0 U
4.0 U
6.0 U
6.0 U
8.0 U
3.6
8.0 U
8.0 U
4.0 U
8.0 U
2.4 U
2.4 U
6.2
6746
T-3-1
(Tadpoles)
1.6 U
3.0 U
4.6 U
4.6 U
6.0 U
43
6.0 U
6.0 U
3.0 U
6.0 U
1.8 U
1.8 U
12
6747
T-3-1
(Sunfish)
0.60 U
1.0 U
1.6 U
1.6 U
2.0 U
23
2.0 U
2.0 U
1.0 U
2.0 U
0.61
0.60 U
26.2
6747 DUP
T-3-1
(Sunfish;
Duplicate)
0.60 U
1.0 U
1.6 U
1.6 U
2.0 U
14
2.0 U
2.0 U
1.0 U
2.0 U
0.60 U
0.60 U
26.2
Area 3-Location 2
6748
T-3-2
(Worms)
0.60 U
1.0 U
1.6 U
1.6 U
2.0 U
16
2.0 U
2.0 U
1.0 U
2.0 U
0.60 U
0.60 U
26.7
•The number associated with each sample IB the analytical laboratory identification number (see Appendix G).
•The presence of a *U* qualifier indicates that the compound was anatyted for but not detected. The detection limit was assigned as the concentration for 'U* qualified data.
"The presence of a "UD' qualifier indicates that the value was obtained by multiplying the detection limit by the dilution factor.
*The presence of a "D" qualifier indicates that a sample waa reanalyzed using a dilution because one of the compound concentrations exceeded the highest concentration range for the standard
curve.
q:\tHia\BRATO40J.DOC
1*3
-------
TABLE 4-6
DETERMINISTIC FOOD WEB MODEL RESULTS SUMMARY'
THAN SITE
MONTGOMERY. ALABAMA
Area of Interest
Raccoon
Mockingbird
Total Hazard Index
(% highest chemical)2
Total Hazard Index
(% highest chemical)2
Green Heron
Total Hazard Index
(% highest chemical)2
East Ditch Reference
East Ditch
Area 1 Reference
Area 1
Area 2
Area 3
1.83E-06
(35% delta-BHC)
3.14E-03
(43% 4,4'-DDD)
4.74E-06
(96% 4,4'-DDE)
1.04E-03
(60% 4,4'-DDE)
1.7SE-04
(35% delta-BHC)
1.18E-OS
(79% 4,4'-DDE)
8.99E-03
(65% 4,4'- ODD)
15.4
(46% 4,4'- DDE)
0.0682
(97% 4,4'- DDE)
12.3
(62% 4,4'. DDE)
5.77
(67% 4,4'- DDE)
0.0854
(86% 4,4'- DDE)
0.0128
(47% 4,4'-DDD)
40.0
(48% 4,4'-DDD)
0.0486
(96% 4,4'-DDE)
8.46
(57% 4,4'-DDE)
2.66
(67% 4,4'-DDE)
0.0792
(89% 4,4'-DDE)
Detailed calculations are provided in Appendix H.
Constituents of interest in parentheses are those which contributed most to the respective total
hazard index. The percentages presented reflect the percentage of the toatl hzard index for which
the highest constituent contributed.
-------
TABLE 6-1
PRELIMINARY ECOLOGICAL SEDIMENT VALUES
BASED ON THE FOOD WEB MODEL&
THAN SITE
MONTGOMERY, ALABAMA
Location
East Ditch
Area 1
Area 2
Constituent
4,4'-DDD
4,4'-DDE
2,4'-DDD
4,4'-DDD
4,4'-DDE
2,4'-DDD
4,4'-DDE
Model
CSb
(mg/kg)
0.43
2.2
1.1
0.50
0.72
..d
0.38
Green
Chemical
Specific
HQc
(unitless)
19.0
17.3
2.85
2.62
4.83
«
1.79
Heron
PESVb
(HQ = 1.0)
(mg/kg)
0.023
0.13
0.39
0.19
0.15
-
0.21
Mockingbird
PESVb
(HQ = 10.0)
(mg/kg)
0.23
1.3
3.9
1.9
1.5
«
2.1
Model
CSb
(mg/kg)
0.43
2.2
1.1
0.50
0.72
0.34
0.38
Chemical
Specific
HQc
(unitless)
4.72
7.01
3.03
2.54
7.68
1.75
3.88
PESVb
(HQ - 1.0)
(mg/kg)
0.091
0.31
0.36
0.20
0.094
0.19
0.098
PESVb
(HQ = 10.0)
(mg/kg)
0.91
3.1
3.6
2.0
0.94
1.9
0.98
aThese values are not intended as final site cleanup levels.
t>CS stands for concentration in sediment; preliminary ecological sediment value (PESV).
CHQ stands for hazard quotient.
^Dashes (-•) indicate that a PESV was not calculated because the food web model did not generate a hazard quotient that exceeded 1.0 for
the referenced constituent.
Q:\91l8\ERAT030t.DOC
-------
AREA 1
NOT TO SCALE
AREA
LEGEND
RELATIVELY WELL DEFINED DRAINAGE DITCH
POORLY DEFINED DRAINAGE PATH
Rl SEDIMENT SAMPLE (MAY 1992)
SUPPLEMENTAL SEDIMENT SAMPLE (AUGUST 1993)
ADDITIONAL SEDIMENT SAMPLE (OCTOBER 1993)
FIGURE 2-1
SOUTHWEST DRAINAGE AREAS
MO APPROXIMATE LOCATION OF
SUPPLEMENTAL SAMPLES
THAN SITE MONTGOMERY. ALABAMA
PATE »/l/»4 1110
ECKENFELDER.
INC.*
Ikknk. Kn J
-------
TABLE 2-2
PESTICIDE ANALYTICAL RESULTS FOR OFF SITE SEDIMENT SAMPLES*
So tuple ID
IA
III
1C
II)
IK
IF
10
2A
211
2C
21)
2K
2F
2<>
211
21
3A
311
3C
3D
3F.
.IF
so
4A
411
4C
41)
4K
4F
4(5
411
41
4.1
.niic
II
3.7
II
tl
U
U
II
U
II
II
II
II
II
II
II
u
II
u
II
II
II
II
u
II
II
u
II
u
II
II
II
II
II
MIIIC
200
200
9.9
9.5
U
I)
10
13
0
1.4
1)
14
II
5.1
U
2.6
0
V
tl
II
II
tl
0
II
II
0
II
U
u
11
u
II
u
rmic
ti
u
V
u
u
u
4.0
U
U
u
u
u
u
u
11
u
u
II
u
1)
u
u
u
II
u
II
II
tl
u
u
II
u
u
dnnc
u
u
II
u
u
u
u
u
(1
3.2
4.0
u
2.7
u
u
1.4
II
II
u
u
II
u
u
u
II
II
II
u
II
II
II
V
11
4.41-DDD
3.300
2.300
80
56
4.3
3.9
58
ino
88
87
46
210
.17
1.10
27
39
B.O
19
16
8.7
2.4
67
11
U
22
II
.11
80
e.9
u
2.4
U
5.0
4.4'-DDB
5.000
4.400
250
200
36
23
270
4K>
420
300
460
570
160
720
140
240
48
100
91
22
6.3
92
05
tl
IP
II
51
17
13
11
5.2
V
5.3
4.4'-DDT
U
210
11
U
II
II
21
tl
U
1)
6.4
U
0
140
II
U
11
1)
11
U
11
U
U
20
.in
u
n
10
7.0
11
3.0
u
u
F.ndrin
U
U
U
U
U
tl
V
U
U
II
V
tl
23
170
II
11
U
U
II
II
II
U
U
U
U
II
11
II
II
U
U
tl
0
llrpUrhlor
Eporlde
11
U
11
U
U
U
U
U
U
II
U
11
U
24
U
U
11
u
u
u
u
u
u
II
11
II
11
II
II
u
II
u
u
• Chlonbne
180
100
5.3
tl
U
U
U
10
19
U
U
17
U
II
U
U
tl
II
U
tl
U
2.7
U
2,1
7.1
II
5.1
2.6
1.5
U
II
11
1.8
,«^
220
93
6.3
U
1)
U
U
16
14
U
V
16
U
U
U
U
U
U
U
0.50
U
3.0
U
1.1
17
1)
3.9
2.0
2.4
II
U
U
1.4
14 ODD
5.000
2.400
120
52
U
3.3
53
410
210
no
57
450
57
240
26
59
II
9.2
10
4.3
11
31
14
II
t)
U
11
U
tl
tl
1!
U
V
2.4 DDE
640
220
16
12
11
0.85
12
57
50
34
35
62
19
65
9.4
26
4.1
5.5
4.7
1.0
U
6.6
5.8
tl
U
U
U
11
U
U
U
U
u
S^'-DDT
240
ICO
6.8
6.4
1.4
U
6.7
17
0
15
19
20
II
U
7.8
19
11
7.8
II
U
U
3.7
U
U
11
II
3.1
1.4
U
U
II
U
0
TOT
78.0HO
36.VK)
27.100
34.000
3R.40Q
17.000
27.900
M.ono
31.700
I6JOO
45.500
22.400
30.200
23.5(10
3I.8DO
63.300
1 1 .500
3 1. 500
34.800
33.200
22 .500
55.800
15,000
40«
I4.(xyi
I.IOO
n.cno
12.000
I5,«O
7,VK)
30.000
9.200
11.700
"Concentration in |ig/kg unless otherwise noted.
•"U: The presence of a "U" indieatea that the compound was analyzed for but wns not detected.
Q:\9I IO\8UH>2< IJII.DOC
rune t or i
-------
APPENDIX E
EXPLANATION OF DATA QUALIFIERS
The following explanation o£ the data qualifiers shown on Table 1 is provided
for the reader's benefit, and are excerpted from Chapter 11 (pages 11-5 and
11-6) of the Remedial Investigation (RI) dated June, 1993. Citations refer
to the RI, not the ROD.
• U-qualified data: The presence of a "U" indicated that the constituent was analyzed for but not
detected. Therefore, U-qualified data were not included in the total number of samples with reported
concentrations above detection limits.
• UD-qualified data: The presence of "UD" indicated that the constituent was analyzed for but not
detected and the sample was diluted for re-analysis because one or more of the constituent
concentrations exceeded the highest concentration range for the standard curve. UD-qualified data
were not included in the total number of samples with reported concentrations above detection limits.
• J-qualified data: The presence of a" J" indicated that the mass spectral data passed the identification
criteria showing that the constituent was present, but the calculated result was less than the practical
quantitation limit (PQL), the lowest level that can be reliably achieved within specified limits of
precision and accuracy during routine laboratory operating conditions. Although the analytical result
is considered to be estimated, J-qualified data were included in the total number of samples with
reported concentrations above detection limits.
• B-qualified data: The presence of a "B" indicated that the constituent was also detected in the method
blank. Unless the data point was further qualified with an "X" per the procedures described in
Section 5.1, B-qualified data were included in the total number of samples with reported
concentrations above detection limits.
• D-qualified data: The presence of a "D" indicated that the sample was diluted and re-analyzed
because one or more of the constituent concentrations exceeded the highest concentration range for
the standard curve. D-qualified data were included in the total number of samples with reported
concentrations above detection limits.
• E-qualified data: The concentration for any constituent that exceeded the highest concentration level
on the standard curve for that constituent was flagged with an "E". E-qualified data were included
in the total number of samples with reported concentrations above detection limits.
• X-qualified data: As discussed in Section 5.1, data were qualified with an "X" as a result of a
comparison of sample analytical results with analytical results for field blanks, equipment blanks, and
laboratory blanks. X-qualified data are considered as nondetect data, and therefore, were not included
in the total number of samples with reported concentrations above detection limits.
63
------- |