PB98-963138
EPA 541-R98-150
March 1999
EPA Superfund
Record of Decision Amendment:
Cedai town Municipal Landfill
Cedartown, GA
5/11/1998
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AMENDED RECORD OF DECISION
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
CEDARTOWN MUNICIPAL LANDFILL SITE
CEDARTOWN, POLK COUNTY, GEORGIA
PREPARED BY
U. S. ENVIRONMENTAL PROTECTION AGENCY
REG ION IV
ATLANTA, GEORGIA
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DECLARATION
of the
AMENDED RECORD OF DECISION
SITE NAME AND LOCATION
Cedartown Municipal Landfill Site,
Cedartown, Polk County, Georgia
STATEMENT OF BASIS AND PURPOSE
This decision document (Amended Record of Decision) presents an
amendment to the selected remedial action for the Cedartown
Municipal Landfill Site, Polk County, Georgia, developed in
accordance with the Comprehensive Environmental Response,
Compensation and Liability Act of 1980 (CERCLA), as" amended, 42
U.S.C. Section 9601 et seq., and in accordance with, the National
Contingency Plan (NCP) 40 CFR Part 300.
The original selected remedy was signed in November 1993. Based
on new information obtained during the Remedial Action, it was
determined that the remedy should be amended. This ROD Amendment
provides for necessary changes to the remedy based on information
obtained during the groundwater monitoring mandated by the
November 1993 ROD. This ROD amendment is consistent with the
Superfund Administrative Reforms Guidance.
This amended decision is based on the administrative record for
the Cedartown Municipal Landfill Site. In addition, this ROD
amendment will become a part of the Administrative Record for the
site. The Administrative Record for this site can be found at
the Information Repository located at the United States
Environmental Protection Agency, 61 Forsyth Street, Atlanta,
Georgia 30303 or the Cedartown Public Library, 245 East Avenue,
Cedartown, Georgia.
The State of Georgia has concurred on this amendment to the
selected remedy (Appendix A).
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from this'
site, if not addressed by implementing the response action
selected in this ROD amendment, may present an imminent and
substantial endangerment to public health, welfare or the
environment.
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DESCRIPTION OF SELECTED REMEDY
This document is an amendment to the remedial action described in
the Record of Decision (ROD) dated November 2, 1993 for the Site.
The function of the remedy, as described in the ROD as amended,
is to restrict access to contamination and to reduce
contamination to health based levels which are protective of
human health and the environment. Contaminated groundwater is the
principal threat at the site.
The major components of the amended groundwater remedy are:
Institutional controls to restrict groundwater use beneath and
immediately surrounding the Site, and
Maintenance of the landfill cover and seep controls.
The requirement for groundwater monitoring and the pump-and-treat
contingency have been removed from the remedy.
STATUTORY DETERMINATIONS
The selected remedy, as amended, is protective of human health
and the environment, complies with federal and state requirements
that are legally applicable or relevant and appropriate, and is
cost-effective. This remedy utilizes permanent solutions and
alternative treatment technology to the maximum extent
practicable, and considered the statutory preference for remedies
that employ treatment that reduces toxicity, mobility, or volume
as a principal element .
Because this remedy may result in hazardous substances remaining
on-site, a review will be conducted within five years after
commencement of the remedy to ensure that the remedy continues to
provide adequate protection of human health and the environment.
This review will include a groundwater sampling event to verify
that the selected remedy remains protective.
Richard D. Green Date
Director,
Waste Management Division
ii
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Table of Contents
Page
1.0 Site Name, Location, and Description .......... 1
2.0 Site History and Enforcement Activities ........ 2
3.0 Reasons for Issuing ROD Amendment ............ 6
4.0 Summary of Site Characteristics and Risks ........ 7
5.0 Description of Alternatives .............. 7
6.0 Summary of the Comparative Analysis of Alternatives . . 8
6.1 Overall Protection of Human Health and the
Environment ..................... 9
6.2 Compliance with ARARs .......... ' ..... 9
6.3 Long-Term Effectiveness and Permanence ...... 10
6.4 Reduction of Toxicity, Mobility or Volume
Through Treatment ................... 10
6.5 Short-Term Effectiveness ............. 10
6.6 Implement ability ................. 10
6.7 Cost ....................... 10
6.8 State Acceptance ................. 11
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7.0 Selected Remedy ..................... 11
8.0 Statutory Determination ................. 12
8.1 Protection of Human Health and the Environment . . 12
8.2 Attainment of the Applicable or Relevant and
Appropriate Requirements (ARARs) ............ 12
8.3 Cost Effectiveness ................ 13
8.4 Utilization of Permanent Solutions to the Maximum
Extent Practicable ................... 13
8.5 Preference for Treatment as a Principal Element . . 13
9.0 Documentation of Significant Changes .......... 14
iii
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List of Figures
Figure 1 - General Map 3
Figure 2 - Site Location Map 4
Figure 3 - Site Plan 5
List of Tables
Page
Table 1 - Chemical-Specific ARARs for Cedartown Site .... 15
Table 2 - Action-Specific ARARs for Cedartown Site 17
Table 3 - Location-Specific ARARs for Cedartown Site .... 19
Table 4 - To-Be-Considered Documents for Cedartown Site ... 19
IV
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AMENDED RECORD OF DECISION
The Decision Summary
Cedartown Municipal Landfill Site
1.0 Site Name, Location, and Description
The Cedartovm Municipal Landfill Site (hereinafter the Cedartown
Site or the Site) is located in Polk County on the outskirts of
the City of Cedartown, Georgia, approximately 60 miles northwest
of Atlanta, Georgia. The Site encompasses a former iron ore mine
which subsequently was used as a municipal landfill. The Site is
situated on the western edge of Cedartown and is bordered on the
east by Tenth Street/ the south by Route 100 (Prior Station
Road), and the north and west by undeveloped and/or agricultural
land. Property to the east of the Site consists of an industrial
complex. Land to the north, west and south of the Site is a
mixture of residential, agricultural, and undeveloped land. Only
a portion of the Site lies within the limits of the City of
Cedartown. The general location of the Site is illustrated in
Figure 1, General Location Map, and Figure 2, Local Map.
The Site, which consists of land formerly used as part of the
landfill operations,- occupies approximately 94 acres. The Site
itself has wooded areas along the north, south and west. A
seasonal stream and pond, which appear during periods of high
precipitation, exist approximately 700 feet west of the Site
perimeter. The eastern half of the Site is covered by thick
grasses. Approximately 10 acres of land, situated between the
eastern and western halves of the Site, were not used for
landfill operations. See.Figure 3, Site Map.
The surface of the Site is grassed with limited areas of mainly
exposed soil occurring northeast of the location of the former
Leary home. The crown of the Site is 872 feet above mean sea
level (AMSL) and gently slopes on all sides with the exception of
portions of the western perimeter which are relatively steep.
During the RI/FS,minor areas of surficial erosion were observed
in the central, northwest, and eastern portions of the Site.
Evidence of erosion has not been observed during recent
inspections by the City of Cedartown. No exposed refuse was
observed in any of the erosion areas. One leachate seep was
observed on-site. In regular inspections of the seep, no changes
have been observed.
Although the Site is not completely fenced, access is limited due
to the dense vegetation which occurs around the northern,
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western, and southern boundaries. The primary access route from
the east directs traffic past the City garage and is restricted
by a fence gate which limits vehicle access to the Site.
2.0 Site History and Enforcement Activities
The Site was originally developed in the 1880's as an iron ore
strip mine. Mining operations continued at the Site/ with some
interruptions/ until the mid 1900's. At that time/ portions of
the Site were leased and/or subsequently acquired by the City of
Cedartown for development as a municipal landfill.
Pits resulting from the strip mining operartions were utilized by
the City of Cedartown and Polk County as disposal areas for
municipal and, to a lesser extent/ industrial wastes. These pits
contained native clay or may have been partially backfilled with
clay previously stockpiled from the mining operations prior to
placement of waste materials. Once waste was in place, the pits
were covered and graded.
While the landfill received primarily municipal solid sanitary
waste during its operation/ quantities of industrial waste were
also reportedly disposed at the Site. The industrial wastes
disposed at the Site may have included the following:
sludge from an industrial waste water treatment system/
animal fat and vegatable oil skimmings from a separation unit,
liquid dye wastes,
latex paint and paint sludges, and
plant trash.
In 1979, in accordance with then applicable State regulations
pertaining to the closure of landfills, the Site was covered with
a layer of clay soil varying in thickness from one to 12 feet. A
vegetative cover was then planted over the soil layer to prevent
erosion.
From 1985 to 1987, EPA evaluated conditions at the Site and
identified areas of potential investigation. EPA then proposed
the Site for inclusion on the National Priorities List (NPL) in
June 1988 and finalized the listing in March 1989.
In November 1993, EPA issued a Record of Decision (ROD) for the
Site. The ROD selected a remedy consisting of the following:
cover maintainance and seep controls,
institutional controls to minimize land use and prevent
groundwater use,
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Figure 2
Local Map
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LEGEND
--- LIMITS OF THE LANOflU.
(BASED ON 1991 Rl)
Rl OBSERVATION WELL
* LEACHATE WEU
« NUS OBSERVATION WEU
^ FENCE/GATE
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Figure 3
Site Map
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surface water monitoring to ensure leachate contaminants do not
migrate from the seep,
groundwater monitoring to ensure that the contaminants are
reduced by natural attenuation and contaminants do not move,
implementation of a pump and treat sytem if groundwater
performance standards have not been met, and
continued groundwater monitoring after groundwater performance
standards were achieved.
3.0 Reasons for Issuing ROD Amendment
This ROD Amendment does not modify the results of the risk
assessment or change the cleanup goals/action levels documented
in the ROD dated November 1993 and the May 1996 Explanation of
Significant Differences Fact Sheet. The purpose of this Amended
ROD is to consider new information regarding the most effective
groundwater remedy.
The major components of the amended groundwater remedy are:
Institutional controls to restrict groundwater use beneath and
immediately surrounding the Site,
Maintenance of the landfill cover, and
Removal of the requirement for groundwater monitoring and the
pump-and-treat contingency.
EPA's rationale for modifying the remedy selected in the original
ROD is based on new information obtained during the Remedial
Action phase. In the original ROD, EPA selected groundwater
monitoring to ensure that the contaminants were reduced by
natural attenuation and did not migrate away from the site,
implementation of a pump and treat sytem if groundwater
performance standards were not met, and continued groundwater
monitoring until EPA approves a five-year review concluding that
the alternative had achieved continued attainment of the
performance standards. Groundwater monitoring for two and one-
half years has demonstrated that groundwater contamination levels
for all contaminants of concern, except manganese, are below
performance standards. Groundwater concentrations of manganese
have remained stable in the wells which are contaminated.
Manganese contamination has not moved to more distant wells. In
addition, EPA analysis of groundwater data demonstrates that
manganese contamination in the wells exceeding the groundwater
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performance standard does not appear to be related to landfill
impacts.
4.0 Summary of Site Characteristics and Risks
Site characteristics and risks remain as described in the ROD
dated November 1993 and the May 1996 Explanation of Significant
Differences Fact Sheet.
5.0 Description of the Alternatives
EPA re-evaluated three alternatives developed as modifications of
the Feasibility Study (FS) alternatives.
Alternative 1; Current Remedy with Continued Monitoring
This alternative would include all items selected in the ROD
dated November 1993, except the pump and treat contingency.
Under this alternative/ groundwater monitoring would continue
until EPA approves a five-year review concluding that the
alternative has achieved continued attainment of the performance
standards. Groundwater monitoring is estimated to continue for a
minimum of ten years to demonstrate reduction of groundwater
contamination. Landfill cover maintenance and seep controls
would be a part of this alternative. The estimated'cost of this
alternative is $320,275.
Alternative 2; Current Remedy with Pump and Treat Contingency
This alternative would include all items selected in the original
ROD, including the pump and treat contingency. A pump and treat
remedy would involve installation of wells to remove contaminated
groundwater from below the.Site. The contaminated groundwater
would be treated to remove manganese and the treated groundwater
would be discharged to a nearby stream. Landfill cover
maintenance and seep controls would be a part of this
alternative. The estimated cost of this alternative is
$8,631,000.
Alternative 3: Institutional and Engineering Controls
This new alternative would include implementation of
institutional controls to prevent groundwater use in the areas
where performance standards are exceeded. Groundwater monitoring
would not be continued since existing data has demonstrated that
contamination is not moving away from the Site. Landfill cover
maintenance and seep controls would be a part of this
alternative. EPA would conduct a five-year review to determine if
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the remedy remained protective of human health and the
environment. The estimated cost of this alternative is $5/000.
6.0 Summary of the Comparative Analysis of Alternatives
This section of the ROD amendment provides the basis for
determining which alternative provides the best balance with
respect to the statutory balancing criteria in Section 121 of
CERCLA and in Section 300.430 of the NCP. The major objective of
the original Feasibility Study was to develop, screen/ and
evaluate alternatives for the remediation at the Cedartown Site.
Three alternatives were re-evaluated using the following nine
evaluation criteria:
Overall protection of human health and the environment.
Compliance with applicable and/or relevant Federal or
State public health or environmental standards.
Long-term effectiveness and permanence.
Reduction of toxicity/ mobility, or volume of hazardous
substances or contaminants through treatment.
Short-term effectiveness, i.e., the impacts a remedy might
have on the community, workers, or the environment during the
course of implementing it.
Implementability, i.e., the administrative or technical
capacity to carry out the alternative.
Cost-effectiveness considering costs for construction,
operation/ and maintenance of the alternative over the life of
the project, including additional costs should it fail.
Acceptance by the State.
Acceptance by the Community.
The NCP categorizes the nine criteria into three groups:
(1)Threshold Criteria - overall protection of human health and
the environment and compliance with ARARs (or invoking a
waiver) are threshold criteria that must by satisfied in order
for an alternative to be eligible for selection;
(2)Primary Balancing Criteria - long-term effectiveness and
permanence; reduction of toxicity, mobility, or volume through
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treatment; short-term effectiveness; implementability, and
cost are primary balancing factors used to weigh major trade-
offs among alternative hazardous waste management strategies;
and
(3)Modifying Criteria - state and community acceptance are
modifying criteria that are formally taken into account after
public comment is received on the proposed plan and
incorporated in the ROD amendment.
The selected alternative must meet the threshold criteria
including compliance with all ARARs or be granted a waiver for
compliance with ARARs. Any alternative that does not satisfy
both of these requirements is not eligible for selection. The
Primary Balancing Criteria are the technical criteria upon which
the detailed analysis is primarily based. The final two
criteria, known as Modifying Criteria, assess the public's and
the state agency's acceptance of the alternative. 'Based on these
final two criteria, EPA may modify the remedial action.
The following analysis is a summary of the evaluation of
alternatives considered for remediating groundwater for the
Cedartown Site under each of the criteria.
Threshold Criteria
6.1 Overall Protection of Human Health and the Environment
All alternatives would provide overall protection of human health
and the environment. Alternative 2 would be most protective, if
groundwater could be effectively pumped and treated.
Alternatives 1 and 3 would be equally protective; however,
alternative 1 would provide additional sampling data to
demonstrate that contamination is not migrating. For alternative
3, groundwater areas which exceed the performance standard would
be restricted from use as drinking water by deed restrictions.
Groundwater beyond this affected area would meet performance
standards and would be safe for human use.
6.2 Compliance with ARARs
Alternative 2 could be implemented to comply with all ARARs
described in the original ROD. For the ARARs related to the Safe
Drinking Water Act and the Lead and Copper Rule, Alternatives 1
and 3 would comply with drinking water maximum contaminant levels
(MCLs) or action levels for all contaminants of concern, except
manganese. For manganese, Alternatives 1 and 3 would utilize
institutional controls to restrict use of groundwater which
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exceeded the health-based performance standard for manganese.
Alternatives 1 and 3 could be implemented to comply with all
other ARARs.
Primary Balancing Criteria
6.3 Long-Term Effectiveness and Permanence
All alternatives would provide long-term effectiveness and
permanence through the landfill cover maintenance and seep
controls. Alternatives 1 and 3 would provide additional long-term
effectiveness and permanence by utilizing institutional controls
to ensure that groundwater with elevated levels of manganese is
not used for human consumption. Alternative 2 would provide
additional long-term effectiveness and permanence by actively
treating contaminated groundwater.
6.4 Reduction of Toxicity, Mobility or Volume Through Treatment
Since existing data has demonstrated that contaminant levels are
not migrating further from the Site, treatment to reduce
toxicity, mobility or volume is not included in Alternatives 1
and 3. Only alternative 2 would provide treatment to reduce
toxicity, mobility, or volume of contamination through the pump
and treat system.
6.5 Short-Term Effectiveness
Alternative 1 would include continued groundwater monitoring
which presents minimal risk to workers, community or the
environment. Alternative 2 would involve construction of a pump
and treat system. Such construction activities may produce short-
term impacts from dust and noise. Impacts from these activities
could be reduced by normal dust and noise controls. Alternative
3 is highly effective in.the short term. This alternative would
involve no construction activities, which could present a risk to
workers, community, or the environment. The implementation of
institutional controls will provide protection of human health
from remaining groundwater contamination.
6.6 Implementability
Alternative 1 involves a continuation of groundwater monitoring
and is easily implemented with utilization of readily available
sampling and analytical services. Alternative 2 involves
construction activities and methods which are easily aquired.
Alternative 3 is easily implemented, since it involves only
periodic maintenance of the cover and implementation of
institutional controls.
6.7 Cost
The estimated cost for Alternative 1 is relatively low at
$320,275. Alternative 2 has the highest estimated cost at
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$8,631,000. The .cost for Alternative 3 is minimal, since it
involves only periodic maintenance of the cover and
implementation of institutional controls. The estimated cost is
$5,000.
Modifying Criteria
6.8 State Acceptance
The State of Georgia has concurred on this amendment to the
selected remedy (Appendix A).
6.9 Community Acceptance
EPA has selected institutional controls and landfill cover
maintenance as the remedy for the Site. EPA received only one
comment on the proposed plan which supported selection of
Alternative 3 - Institutional and Engineering Controls.
7.0 Selected Remedy
Based upon the Administrative Record, consideration of the
requirements of CERCLA, the NCP, the detailed analysis of
alternatives and public and state comments, EPA has selected an
amended remedy for this site. The selected cleanup alternative
to reduce to levels protective of human health and the
environment risks posed by contamination found at the Cedartown
Site is Alternative 3 - Institutional and Engineering Controls.
This remedy involves implementation of institutional controls to
restrict groundwater use in the areas where performance standards
are exceeded. Groundwater monitoring would not be continued,
since existing data has demonstrated that contamination is not
migrating away from the site. EPA would conduct a five-year
review to determine if the remedy remained protective of human
health and the environment. The estimated cost of this remedy is
$5,000.
This remedy will protect human health and the environment by
restricting groundwater use in areas where performance standards
are exceeded. ARARs can be easily met. Although this remedy
will not reduce toxicity and volume through treatment, mobility
appears to be reduced, as indicated by groundwater monitoring
results. The selected remedy is easily implemented and is cost
effective.
Performance Standards
The selected remedy will achieve the performance standards
specified in the original ROD, with the exception of the area
beneath and immediately surrounding the landfill. All activities
shall comply with ARARs, and state standards.
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8.0 Statutory Determination
Under its legal authorities, EPA's primary responsibility at
Superfund sites is to undertake remedial actions.that achieve
adequate protection of human health and the environment. In
addition, Section 121 of CERCLA establishes several other
statutory requirements and preferences. These specify that, when
complete, the selected remedy must meet appropriate environmental
standards established under Federal and State environmental laws
unless a statutory waiver is justified. The selected remedy also
must be cost-effective and utilize permanent solutions and
alternative treatment technologies or resource recovery
technologies to the maximum extent practicable. Finally, the
statute includes a preference for remedies that employ treatment
that permanently and significantly reduce the volume, toxicity,
or mobility of hazardous wastes as their principal element. The
amended remedy meets the statutory requirements and preferences
of Section 121 of CERCLA as further explained below.
8.1 Protection of Human Health and the Environment
The selected remedy protects human health and the environment
through restricting the use of groundwater beneath and
immediately surrounding the landfill and through landfill cover
maintenance. The selected remedy provides protection of human
health and the environment by eliminating, reducing, and
controlling risk through engineering controls and/or
institutional controls. Institutional and engineering controls
will prevent exposure to contaminants while natural attenuation
occurs over time.
8.2 Attainment of the Applicable or Relevant and Appropriate
Requirements (ARARs)
Remedial actions performed under CERCLA, as amended by SARA, must
comply with all applicable or relevant and appropriate
requirements (ARARs) unless a waiver is justified. All
alternatives considered for the site were evaluated on the basis
of the degree to which they complied with these requirements.
The selected alternative was found to attain ARARs.
ARARs for the Cedartown Site are found in Tables 1, 2, and 3 and
are discussed below.
Chemical-Specific ARARs
Groundwater performance standards which are maximum contaminant
levels (MCLs) under the Safe Drinking Water Act have been met at
the site. The performance standard for manganese was developed
using EPA's risk assessment guidelines. The manganese
performance standard will be met by restricting use of
groundwater which exceeds the manganese performance standard.
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The selected remedy will comply with all other relevant and
appropriate regulations.
Action-Specific ARARs
Because actions required by the selected remedy are limited to
institutional and engineering controls, the only action-specific
ARAR for the remedy is the Georgia Water Well Standards Act.
Location-Specific ARARs
The selected remedy will not impact critical habitats for
threatened or endangered species. Neither will it impact wild or
scenic rivers or any other sensitive habitat.
Other Guidance To Be Considered
Other guidance to be considered (TBCs) include the Georgia
Hazardous Site Response Act.
8.3 Cost Effectiveness
Cost effectiveness is determined by comparing the cost of all
alternatives being considered with their overall effectiveness to
determine whether the costs are proportional to the effectiveness
achieved. The selected remedy (Alternative 3) will reduce or
eliminate risks to human health at an estimated cost of $5,000.
It is expected to achieve an effectiveness comparable to
Alternatives 1 and 2 at a substantially lower cost (although over
a longer time period than Alternative 2).
8.4 Utilization of Permanent Solutions to the Maximum Extent
Practicable
EPA has determined that the selected remedy represents the
maximum extent to which permanent solutions can be utilized in a
cost-effective manner at the Cedartown Municipal Landfill Site.
Of those alternatives which meet the threshhold criteria, EPA has
determined that the selected remedy provides the best balance
between long-term effectiveness and permanence, short-term
effectiveness, and implementability, while also considering the
statutory preference for treatment and state and community
acceptance.
8.5 Preference for Treatment as a Principal Element
EPA believes that the selected remedy provides that best balance
of all of the evaluation criteria. However, the statutory
preference for treatment will not be met by this selected remedy
for the above stated reasons. Existing data have demonstrated
that contaminant levels are not migrating from the Site.
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9.0 Documentation of Significant Changes
None identified.
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POTENTIAL CHEMICAL SPECIFIC ARARs
CLEAN WATER ACT - 33 U.S.C. 1251-1376
R&A
R&A
Description
Provides for the establishment of water
quality criteria based on toxicity to
aquatic organisms and human health.
Sets standards to control pollutants which
pass through or interfere with treatment
processes in publicly-owned treatment
works or which may contaminate sewage
sludge.
Citation
40 CFR Part 131
Ambient Water Quality Criteria
Requirements
40 CFR Part 403 - National
Pretreatment Standards
SAFE DRINKING WATER ACT - 40 U.S.C. 300
A
A
Establishes primary drinking water
regulations pursuant to Section 1412 of
the Public Health Service Act, as amended
by the Safe Drinking Water Act; and
related regulations applicable to public
water systems.
Establishes National Secondary Drinking
Water Regulations pursuant to Section 1412
of the Safe Drinking Water Act, as amended
(42 U.S.C. 300g-l); and control
contaminants in drinking water that
primarily affect the aesthetic qualities
relating to the public acceptance of
drinking water.
40 CFR Part 141
National Primary Drinking Water
Regulations
40 CFR Part 143
National Secondary Drinking Water
Regulations
RESOURCE CONSERVATION AND RECOVERY ACT - 42 U..S.C. 6901-6987
R&A
R&A
Identifies those solid wastes which are
subject to regulation as hazardous wastes.
Defines the term "solid waste" and
"hazardous waste".
Establishes standards for generators of
hazardous waste.
.40 CFR Part 261
Identification and Listing of
Hazardous Waste
40 CFR Part 262
Standards Applicable to Generators
of Hazardous Waste
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CLEAN AIR ACT -
R&A
STATE OF GEORGI/
R&A
A
R&A
42 U.S.C. 7401-7642 .
Establishes standards for ambient air
quality to protect public health and
welfare.
^ REGULATIONS
Establishes rules and regulations for
Georgia drinking water standards and
addresses wellhead protection zones.
Establishes Georgia surface water quality
criteria.
Establishes standards for ambient air
quality to protect public health and
welfare.
40 CFR Part 50 - National Primary
and Secondary Ambient Air Quality
Standards
Georgia Drinking Water
Regulations, Chapter 391-3-5
Georgia Water Quality Control
Regulations and Standards
Georgia Air Quality Act, Chapter
391-3-1
SUBSTANCE, POLLUTANT, CONTAMINANT, REMEDIAL ACTION LOCATION OR OTHER CIRCUMSTANCE AT THE CEDARTOWN SITE.
R & A RELEVANT AND APPROPRIATE REQUIREMENTS WHICH WHILE THEY ARE NOT "APPLICABLE" TO A HAZARDOUS SUBSTANCE,
POLLUTANT, CONTAMINANT, REMEDIAL ACTION, LOCATION, OR OTHER CIRCUMSTANCE AT THE CEDARTOWN SITE, ADDRESS PROBLEMS
OR SITUATIONS SUFFICIENTLY SIMILAR TO THOSE ENCOUNTERED AT THE CEDARTOWN SITE THAT THEIR USE IS WELL SUITED TO
THE SITE.
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TABLE 2
POTENTIAL ACTION-SPECIFIC ARARs
CLEAN WATER ACT - 33 U.S.C. 1251-1376
A
R&A
R&A
R&A
R&A
Provides for the establishment of water
quality criteria based on toxicity to
aquatic organisms and human health.
Sets standards to control pollutants which
pass through or interfere with treatment
processes in publicly-owned treatment
works or which may contaminate sewage
sludge.
Requirements limiting injection of fluids
into underground sources of drinking water
Specifies sampling, analytical and
monitoring requirements for public water
systems
Sets standards to control pollutants which
pass through, interfere with, and
contaminate treatment processes in public
treatment works.
40 CFR Part 131
Ambient Water Quality Criteria
Requirements
40 CFR Part 403 - National
Pretreatment Standards
40 CFR Part 144- Underground
Injection Program
40 CFR Part 141 - Nation Primary
Drinking Water Standards
40 CFR Part 403 - National
Pretreatment Standards
RESOURCE CONSERVATION AND RECOVERY ACT - 42 U.S.C. 6901-6987
R&A
R&A
R&A
R&A
Established minimum levels of performance
required of any solid waste land disposal
site operation including operation and
maintenance.
Characterizations of treatment facility
generated sludges
General requirements for identifying and
managing hazardous wastes and manifest
requirements for hazardous wastes
Establishes standards which apply to
transporting hazardous waste within the
U.S., if required under 40 CFR Part 262.
40 CFR 257-258 - Solid Waste
Management Regulations
40 CFR Part 261 - Identification and
Listing of Hazardous Wastes
40 CFR Part 262 - Standards .
Applicable to Generators of Hazardous
Waste
40 CFR Part 263 - Standards
Applicable to Transporters of
Hazardous Waste
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R&A
CLEAN AIR ACT -
R&A
STATE OF GEORGI/
R&A
R&A
R&A
R&A
Establishes minimum national standards
which define the acceptable management of
hazardous wastes for owners and operators
of facilities which treat, store, or
dispose of hazardous wastes.
42 U.S.C. 7401-7624
Addresses hazardous air pollutants at
their point of emission from specific
sources
^ REGULATIONS
Establishes minimum state standards for
the siting, construction, operation,
maintenance, and abandonment of wells and
boreholes.
Establishes minimum state standards which
define the acceptable management of
hazardous wastes for owners and operators
of facilities which treat, store or
dispose of hazardous waste.
Establishes minimum levels of performance
required of any solid waste land disposal
site operation.
Establishes pretreatment standards and
permit requirements for publicly-owned
treatment works, criteria and standards
for injection wells, and authorizes DNR to
issue discharge permits.
40 CFR Part 264 - Standards for
Owners and Operators of Hazardous
Waste Treatment, Storage, and
Disposal (TSD) Facilities
40 CFR Part 61 - National Emission
Standards for Hazardous Air
Pollutants
Georgia Water Well Standards Act,
Chapter 12-5-120 through 138.
Georgia Hazardous Waste Management
Act, Chapter 391-3-11.
Georgia Comprehensive Solid Waste
Management Act, Chapter 391-3-4.
Georgia Water Quality Control Act,
Chapter
391-3-6
SUBSTANCE, POLLUTANT, CONTAMINANT, REMEDIAL ACTION LOCATION OR OTHER CIRCUMSTANCE AT THE CEDARTOWN SITE.
R & A RELEVANT AND APPROPRIATE REQUIREMENTS WHICH WHILE THEY ARE NOT "APPLICABLE" TO A HAZARDOUS SUBSTANCE,
POLLUTANT, CONTAMINANT, REMEDIAL ACTION, LOCATION, OR OTHER CIRCUMSTANCE AT THE CEDARTOWN SITE, ADDRESS PROBLEMS OR
SITUATIONS SUFFICIENTLY SIMILAR TO THOSE ENCOUNTERED AT THE CEDARTOWN SITE THAT THEIR USE IS WELL SUITED TO THE SITE.
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TABLE 3
POTENTIAL LOCATION SPECIFIC ARARs
R&A
R&A
Description
Regulate activities in critical habitats
in which endangered or threatened species
are found.
Regulates activities in areas designated
as wild, scenic, or recreational rivers.
Citation
Endangered Species Act of 1973 (50
CFR Parts 200 and 402) and Fish
and Wildlife Coordination (33 CFR
Parts 320-330)
Wild and Scenic River Act (40 CFR
Part 6.302(e) )
STATE OF GEORGIA REGULATIONS
R&A
R&A
SUBSTANCE , POLLUTAN
R £ A RELEVANT f
POLLUTANT, CONTAMIN
OR SITUATIONS SUFFI
THE SITE.
Establishes minimum levels of performance
required of any solid waste Icind disposal
site operation.
Regulates activities in critical habitats
upon which endangered or threatened
species depend.
Georgia Comprehensive Solid Waste
Management Act, Chapter 391-3-4.
Endangered Wildlife and Wildflower
Preservation Act of 1973, Chapter
391-4-10.
REQUIREMENTS WHICH WERE PROMULGATED UNDER FEDERAL LAW TO SPECIFICALLY ADDRESS A HAZARDOUS
IT, CONTAMINANT, REMEDIAL ACTION LOCATION OR OTHER CIRCUMSTANCE AT THE CEDARTOWN SITE.
LND APPROPRIATE REQUIREMENTS WHICH WHILE THEY ARE NOT "APPLICABLE" TO A HAZARDOUS SUBSTANCE,
ANT, REMEDIAL ACTION, LOCATION, OR OTHER CIRCUMSTANCE AT THE CEDARTOWN SITE, ADDRESS PROBLEMS
CIENTLY SIMILAR TO THOSE ENCOUNTERED AT THE CEDARTOWN SITE THAT THEIR USE IS WELL SUITED TO
TABLE 4
TO-BE-CONSIDERED (TBC) DOCUMENTS
TBC
Description
Establishes State hazardous substance
cleanup activities and requirements
Citation
Georgia Hazardous Site Response
(HSRA) , Chapter 391-3-19
Act
TBCs - To-be-considered criteria are documents which are not legally binding, but should be
considered in determining the necessary level of cleanup for protection of human health or the
environment.
19
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APPENDIX A
STATE CONCURRENCE LETTER
19
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Georgia Department of Natural Resources
205 Butler Street, S.E., Suite 116^, Atlanta, Georgia 30334
Lonice C. Barrett, Commissioner
Environmental Protection Division
Harold F. Reheis. Director
404/656-2833
April 10, 1998
Mr. Richard D. Green
Acting Director CERTIFIED MAIL
Waste Management Division RETURN RECEIPT REQUESTED
U.S. Environmental Protection Agency
Region IV - Atlanta Federal Center rr
61 Forsyth Street, SW "-
Atlanta, Georgia 30303-8909
RE: Amended Record of Decision"^. .-__
Cedartown Municipal Landfill Site ^ £
Cedartown, Georgia
Dear Mr. Green:
The Georgia Environmental Protection Division (EPD) has reviewed the draft
Record of Decision (ROD) amendment for the Cedartown Municipal Landfill Site
(Cedartown Site) in Cedartown, Georgia. The original ROD, signed in November of 1993,
called for monitoring and institutional controls to address potential risks to human health
and the environment resulting from possible releases to groundwater of chromium and
manganese. The original ROD called for groundwater and surface water monitoring,
landfill cover maintenance and seep controls, and land-use restrictions. The original ROD
also contained a pump-and-treat contingency in case the groundwater performance
standard could not be met.
This ROD amendment is based on new information collected during the remedial
action. Groundwater data collected during the previous two and one-half years has
shown that no constituents, except manganese, remain above performance standards.
Additional data from the site indicate that the source of the manganese is not the result
of waste disposal.
*
The major components of this amendment are:
institutional controls to restrict groundwater use beneath and immediately
surrounding the Cedartown Site,
maintenance of the landfill cover, and
removal of the requirement for groundwater monitoring and the pump-and-
treat contingency.
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Mr. Richard D. Green
April 10, 1998
Page 2
Because there is the possibility that hazardous constituents may remain on site,
a five-year review will be conducted, and it will include another groundwater sampling
event. Georgia EPD hereby concurs with the selected remedy.
Sincerely,
Harold F. Reheis
Director
Georgia Environmental Protection Division
c. Ms. Annie Godfrey, U.S. EPA
Mr. David Johnson, City of Cedartown
File: Cedartown Municipal Landfill (B)
R.AMADELEINE\Cdartown\flOOCONC.LTR
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