PB94-964002
EPA/RQ0/R04-94/168
July 1994
EPA Superfund
Record of Decision:
Cedartown Municipal Landfill Site,
Cedartown, GA
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RECORD OF DECISION
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
CEDARTGWN UUNICSPAL LANDFILL SITE
CEDARTOWN, POLK COUNTY, GEORGIA
PREPARED BY
U. S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV
ATLANTA, GEORGIA
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DECLARATION
of the
RECORD OF DECISION
SITE NAME AND LOCATION
Cedartown Municipal Landfill Site
Cedartown, Polk County, Georgia
STATEMENT OF BASIS AND PURPOSE
This decision document (Record of Decision), presents the selected
remedy for the Cedartown Municipal Landfill Site, Cedartown, Georgia,
developed in accordance with the Comprehensive Environmental Response,
Compensation and Liability Act of 1980 (CERCLA), as amended by the
Superfund Amendments and Reauthorization Act of 1986 (SARA), 42 U.S.C.
§ 9601 et sea.. and to the extent practicable, the National
Contingency Plan (NCP), 40 CFR Part 300.
This decision is based on the administrative record for the Cedartown
Municipal Landfill Site.
T.TT *-Vi *-V»e» a e^ 1 tzr^t
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from the
Cedartown Municipal Landfill 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 THE SELECTED REMEDY
This action is the first and final action planned for the Site. This
alternative calls for the design and implementation of response
measures which will protect human health and the environment. The
action addresses the principal threat at the Site, the contaminant
sources in the wastes, as well as the ground water contamination at
the Site.
The major components of the selected remedy include:
cover maintenance and seep controls;
institutional controls, such as record notices and deed, zoning
and land-use restrictions;
ground/surface water monitoring program to insure natural
attenuation processes would be effective and that contaminants
would not migrate;
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a two year review during which EPA would determine whether ground
water performance standards continue to be appropriate and if
natural attenuation processes are effective. EPA shall consider
and at EPA's sole discretion implement an active ground water
remediation if ground water performance standards continue to be
appropriate and natural attenuation processes are not effective,
a contingency remedial action which includes ground water
extraction, on-site treatment, and discharge under National
Pollutant Discharge Elimination System (NPDES) to a nearby surface
water or POTW; and,
continued ground water monitoring upon attainment of the
performance standards at sampling intervals to be approved by EPA.
The ground water monitoring program would continue until EPA
approves a five-year review concluding that the alternative has
achieved continued attainment of the performance standards and
remains protective of human health and the environment.
STATUTORY DETERMINATIONS
The selected remedy with an active ground water treatment contingency
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 with contingency
satisfies the statutory preference for remedies that employ treatment
that reduces toxicity, mobility, or volume as a principal element.
Finally, it is determined that this remedy utilizes a permanent
solution and treatment technology to the maximum extent practicable.
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 continue to provide adequate
protection of human health and the environment.
PATRICK M. TOBIN, ACTING REGIONAL ADMINISTRATOR DATE
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TABLE OF CONTENTS
1.0 SITE LOCATION AND DESCRIPTION
2.0
3.0
4.0
5.0
6.0
7.0
SITE HISTORY AND ENFORCEMENT ACTIVITIES
HIGHLIGHTS OF COMMUNITY PARTICIPATION
SCOPE AND ROLE OF ACTION .
SUMMARY OF SITE CHARACTERISTICS
5 . 1 GEOLOGY AND SOILS
5.1.1 FILL MATERIALS
5.1.1.1 GEOTECHNICAL TESTS
5.1.2 RESIDUUM AND SAPROLITE
5.1.3 NEWALA LIMESTONE
5.2 SURFACE WATER /HYDROLOGY
5 . 3 HYDROGEOLOGY
5.4 SUMMARY OF SITE CONTAMINATION
5.4.1 GROUND WATER CHARACTERIZATION . . . .
5.4.2 SOIL CHARACTERIZATION
5.4.3 SURFACE WATER CHARACTERIZATION . . . .
5.4.3.1 EAST SEEP
5.4.4 SEDIMENTS CHARACTERIZATION
5.5.5 LEACHATE AND WASTE CONTAMINANTS . . .
5.5.5.1 WASTE/SOIL ANALYSES
5.5.5.2 LEACHATE SAMPLE ANALYSES ....
SUMMARY OF SITE RISK
6.1 HUMAN HEALTH RISKS
6.1.1 CONTAMINANTS OF CONCERN (COCs) . . . .
6.1.1.1 COCs IN GROUND WATER
6.1.2 EXPOSURE ASSESSMENT
6.1.2.1 CURRENT EXPOSURE
6.1.2.2 FUTURE EXPOSURE
6.1.3 TOXICITY ASSESSMENT
6.1.4 RISK CHARACTERIZATION
6.1.5 IDENTIFICATION OF UNCERTAINTIES . . .
6.2 ECOLOGICAL EVALUATION
6.2.1 TERRESTRIAL
6.2.2 AQUATIC
6.3 CONTAMINANTS OF CONCERN & PERFORMANCE STANDARDS
DESCRIPTION OF ALTERNATIVES
7 . 1 ALTERNATIVE 1 : NO ACTION
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7.2 ALTERNATIVE 2: INSTITUTIONAL CONTROLS. COVER
MAINTENANCE. SEEP CONTROL. AND GROUND WATER
MONITORING 44
7.3 ALTERNATIVE 3: GROUND WATER TREATMENT 45
7.4 APPLICABLE OR RELEVANT AND APPROPRIATE
REQUIREMENTS (ARARs) 47
8.0 SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES ... 52
8.1 THRESHOLD CRITERIA 54
8.1.1 OVERALL PROTECTION OF HUMAN HEALTH AND
THE ENVIRONMENT 54
8.1.2 COMPLIANCE WITH ARARS 55
8.2 PRIMARY BALANCING CRITERIA 55
8.2.1 LONG-TERM EFFECTIVENESS AND PERMANENCE . . 55
8.2.2 REDUCTION OF TOXICITY, MOBILITY, OR
VOLUME THROUGH TREATMENT 56
8.2.3 SHORT-TERM EFFECTIVENESS 56
8.2.4 IMPLEMENTABILITY 57
8.2.5 COST 57
8.3 MODIFYING CRITERIA 57
8.3.1 STATE ACCEPTANCE 57
8.3.2 COMMUNITY ACCEPTANCE 58
9.0 SUMMARY OF SELECTED REMEDY 58
10.0 STATUTORY DETERMINATION 64
10.1 PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT ... 64
10.2 ATTAINMENT OF THE APPLICABLE OR RELEVANT AND
APPROPRIATE REQUIREMENTS (ARARs) 65
10.3 COST EFFECTIVENESS 67
10.4 UTILIZATION OF PERMANENT SOLUTIONS TO THE MAXIMUM
EXTENT PRACTICABLE 67
10.5 PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT . . 67
11.0 DOCUMENTATION OF SIGNIFICANT CHANGES 67
A: PENDIX A: RESPONSIVENESS SUMMARY 68
APPENDIX B: STATE OF GEORGIA CONCURRENCE LETTER 78
11
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LIST OF TABLES
TABLE 5-1 SUMMARY OF SUBSTANCES DETECTED IN GROUND WATER .... 14
TABLE 5-2 SUMMARY OF SUBSTANCES DETECTED IN SOILS 18
TABLE 5-3 SUMMARY OF SUBSTANCES DETECTED IN SURFACE WATERS ... 20
TABLE 5-4 SUMMARY OF SUBSTANCES DETECTED IN SEDIMENTS 22
TABLE 5-5 SUMMARY OF SUBSTANCES DETECTED IN WASTE/SOILS 24
TABLE 5-6 SUMMARY OF SUBSTANCES DETECTED IN LEACHATE 27
TABLE 6-1 CONTAMINANTS OF CONCERN 28
TABLE 6-2 CONTAMINANTS OF CONCERN TOXICITY ASSESSMENT 34
TABLE 6-3 SUMMARY OF UNACCEPTABLE RISK -- GROUND WATER
INGESTION 37
TABLE 6-4 SUMMARY OF REMEDY PERFORMANCE STANDARDS (GROUND
WATER) 43
SiLE 7-1 POTENTIAL LOCATION SPECIFIC ARARs 48
TABLE 7-2 POTENTIAL ACTION-SPECIFIC ARARs FOR THE SELECTED
AND CONTINGENCY REMEDIES 49
TABLE 7-3 POTENTIAL CHEMICAL-SPECIFIC ARARS 51
TABLE 8-1 COMPARISON OF COSTS 58
TABLE 9-1 SUMMARY OF MONITORING PERFORMANCE STANDARDS
(GROUND WATER) 62
ill
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LIST OF FIGURES
FIGURE 1-1 Area Map 2
FIGURE 1-2 Local Map 3
FIGURE 1-3 Site Map 4
FIGURE 5-1 Site Sampling Plan 13
Figure 5-2 Ground Water Contour Map 16
IV
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Record of Decision
Cedartown Municipal Landfill Site
Pagel
Record of Decision
Cedartown Municipal Landfall Site
1.0 SITE LOCATION AND DESCRIPTION
The Site is located in Polk County on the outskirts of the City of Cedartown, Georgia,
approximately 62 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. A portion of the Site lies within the limits of
the City of Cedartown. (Note: The City is currently in the process of annexing all
portions of the Site not currently within the City limits.) The general location of the
Site is illustrated in Figure 1-1, Area Map and Figure 1-2, Local Map.
Property immediately east of the Site consists of an industrial complex, while land to
the north, south, and west is a mixture of residential, agricultural, and undeveloped
land.
The Site, which consists of land formerly used as part of the landfill operations,
occupies approximately 94 acres. The Site itself is well vegetated with 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 western 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. This area includes the pond situated directly behind the
former Rome Coca-Cola Bottling Company building (referred to herein as the "Coke
Pond") and the lands in and around the former Leary residence (formerly situated
immediately north of the Coke Pond). See Figure 1-3, 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 (9 percent slope). Minor
areas of surficial erosion were observed in the central, northwest and eastern portions
of the Site. No exposed refuse was observed in any of the erosion areas noted. A
leachate seep was observed on-site west of the Coke Pond.
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Cedartown Municipal Landfill Site
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S>£^
ALABAMA
; GEORGIA
iRpckmart
Figure 1-1 Area Map
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Record of Decision
Cedartown Municipal Landfill Site
Page3
Figure 1-2 Local Map
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Record of Decision
Cedartown Municipal Landfill Site
Page 4
FIGURE 1-3 Site Map
>>~Ti,. :=:: cr C;''AR??WW ; !
LEGEND
SITE BOUNDARY
(BASED ON 1991 Rl)
I I APPROXIMATE LIMITS OF
I I MINING ACTIVITY
"'- NON-EXCAVATION ACTIVITIES
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Record of Decision
Cedartown Municipal Landfill Site
PageS
Although the Site is not fenced, access is limited due to the dense vegetation which
occurs around the northern, 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 1880s as an iron ore strip mine. Mining
operations continued at the Site, with some interruptions, until the mid 1900s. 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 operations 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 day previously stockpiled from the mining operations prior to
placement of waste materials. Once waste was in place, the pits were covered and
graded.
This type of operation is significantly different from common landfill operations of
the period where wastes were placed in large common fill disposal cells with
occasional daily and/or interim cover material. The lack of on-going, irregular
settlement of the existing cap may be attributable to the shallow intermittent disposal
practices which occurred.
The outer limits of the area used for waste placement within on-site pits, as
determined during the Remedial Investigation (RI), are illustrated on Figure 1-3.
While the landfill received primarily municipal solid sanitary waste during its
operation, limited quantities of industrial waste were also reportedly disposed at the
Site. The industrial wastes disposed of at the Site include but is not limited to the
following:
i) sludge from an industrial waste water treatment system;
ii) animal fat and vegetable oil skimmings from a separation unit;
iii) liquid dye wastes;
iv) latex paint and paint sludges; and
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Cedartown Municipal Landfill Site
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v) 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 day soil varying in thickness from
one to 12 feet. A vegetative cover was then established over the soil layer to prevent
erosion.
On June 6, 1985, a representative of USEPA completed an initial Site inspection to
evaluate conditions at the Site and identify areas of potential investigation. In
October 1986, an initial reconnaissance of the Site was completed by representatives
of USEPA. Subsequently, during 1987 and 1988, an investigation of the Site was
conducted.
USEPA evaluated the Site using the Hazardous Ranking System (HRS). The aggregate
HRS score derived for the Site evaluated by USEPA was 33.62. The Site was
subsequently proposed for inclusion on the National Priorities List (NPL) in June
1988 and finalized in March 1989.
Cedartown Municipal Landfill Potentially Responsible Parties' (PRPs) committee
completed the Remedial Investigation (RI) and Feasibility Study (FS) in July 1993
under EPA oversight pursuant to EPA's 1990 Administrative Order of Consent
(AOC). Field work for the RI began in 1991 and was completed in 1993. The RI was
designed to determine the nature and extent of contamination in order for a remedy
selection to be made. Field work for the RI included installing monitoring wells and
sampling soils, sediments, leachate, landfill waste, surface water and ground water.
3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION
All basic requirements for public participation under CERCLA sections
113(k)(2)(B)(i-v) and 117, were met in the remedy selection process. Because the local
community has been interested and involved in the Cedartown Municipal Landfill
Site status during the remedial activities at this Site, community relations activities
remained an important aspect throughout the remedial process. The community
relations program at the Cedartown Municipal Landfill Site was designed to maintain
communication between the residents in the affected community and the government
agencies conducting remedial activities at the Cedartown Municipal Landfill Site.
Frequent communication with nearby residents and local officials has been
maintained as a priority. Special attention has been directed toward keeping the
community informed of all study results. Numerous meetings have been held with
Cedartown city officials. Prior to approval of the Remedial Investigation/Feasibility
Study (RI/FS) Workplan, EPA officials attended a local Chamber of Commerce public
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Cedartown Municipal Landfill Site
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forum and a Kiwanis Club meeting. In addition, a meeting was held with the
community at an availability session in the Winter of 1991 to inform residents of
EPA's intentions and to obtain input concerning sampling locations and health and
safety procedures.
On September 9, 1993, after the finalization of the Remedial Investigation (RI) Report
and the completion of the Feasibility Study (FS), EPA presented its preferred remedy
for the Cedartown Municipal Landfill Site during a public meeting at the Cedartown
Public Library, 245 East Avenue, Cedartown, Georgia. The 30-day public comment
period was held September 1 through September 30, 1993. A copy of the
Administrative Record, upon which the remedy was based, is located at the
Cedartown Public Library, 245 East Avenue, Cedartown, Georgia 31701. EPA's
responses to comments which were received during the comment period are
contained in Appendix A.
4.0 SCOPE AND ROLE OF ACTION
a. .nis S£i£ct£u. r£in£vj.y witii an active grcunu water treatment contingency is tu8 *irsi
and final remedial action for the Site. The function of this remedy is to reduce the
risks associated with exposure to contaminated ground water.
The selected remedial alternative will address conditions which pose a threat to
human health and the environment:
Contaminated ground water (may potentially impact drinking water supplies);
and,
contaminated landfill leachate (present a continuing source of contamination).
Pathways of exposure include:
Ingestion of contaminated ground water; and,
aquatic exposure to leachate migrating to surface waters
The major components of the remedy are:
cover maintenance and seep controls;
institutional controls, such as record notices and deed, zoning and land-use
restrictions;
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Cedartown Municipal Landfill Site
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ground water monitoring program to insure natural attenuation processes
would be effective and that contaminants would not migrate;
a two year review which EPA would determine whether ground water
performance standards continue to be appropriate and if natural attenuation
processes are effective. EPA shall consider and at EPA's sole discretion
implement an active ground water contingency remedial action if ground
water performance standards continue to be appropriate and natural
attenuation processes are not effective,
contingency remedial action to include ground water extraction, on-site
treatment, and discharge under National Pollutant Discharge Elimination
System (NPDES) to a nearby surface water or POTW; and,
continued ground water monitoring upon attainment of the performance
standards at sampling intervals to be approved by EPA. The ground water
monitoring program would continue until EPA approves a five-year review
concluding that the alternative has achieved continued attainment of the
performance standards and remains protective of human health and the
environment.
This remedy addresses the first and final cleanup action planned for the Site. The
ground water present beneath the Site contains elevated levels of contaminants
similar to that present in wastes and leachate at the Site. Although this water bearing
zone is affected, the contamination is not affecting the public drinking water supply
(Cedartown Springs). The purpose of this proposed action is to prevent current or
future exposure to the landfill wastes and contaminated ground water, and to reduce
the migration of contaminants.
5.0 SUMMARY OF SITE CHARACTERISTICS
5.1 GEOLOGY AND SOILS
The Site is bounded on the north by an undeveloped field, on the west by an
agricultural field, on the south by undeveloped land and a residential area, and on
the east by an industrial development. The Site is mound-shaped in nature with
gentle slopes on the south and east and steeper slopes on the north and west.
Densely wooded areas consisting of pine trees and thick viney underbrush border the
Site on the north, west and southern perimeters. The eastern edge of the Site is
generally wooded with pine trees and vegetated with thick grasses. The remainder
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Cedartown Municipal Landfill Site
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of the Site, specifically the crown of the landfill, is bare to grassy.
Minor areas of surficial erosion were observed in the central, northwest and eastern
portions of the Site. No exposed refuse was observed in any of the erosion areas
inspected.
The Cedartown Municipal Landfill Site is located in the Valley and Ridge
physiographic province of the Appalachian Region. The Valley and Ridge province is
characterized by lowlands and hilly areas that range in altitude from approximately
600 to 1,000 feet. A few isolated ridges occur but most have altitudes of less than
1,300 feet (Cressler, 1970).
5.1.1 FILL MATERIALS
Placement of waste materials was not uniform across the landfill. Only 11 of the 30
boreholes advanced within the six landfill cells encountered waste materials. When
encountered, waste materials typically consisted of municipal/industrial refuse
including plastic, cardboard, glass, v/cod, and metal. Waste materials, where
encountered, were found to range from one foot thick in borehole (leachate well)
LW-2A to 30 feet thick in LW-1 (see figure 5-1, Sampling Map). On the landfill
proper, the cover material and fill materials consisted of orange to red mottled day.
The Kaolinite-rich clay was likely obtained from on-Site stockpiles generated during
historical mining of iron deposits. This clayey mixture visually appears to be
consistent with the clays of the residuum/saprolite described below.
5.1.1.1 GEOTECHNICAL TESTS
Geotechnical data obtained from the Shelby tube samples collected from the base of
the waste materials indicate vertical hydraulic conductivity values from
3.08 x 1(T7 on/sec to 1.06 x 10'7.
5.1.2 RESIDUUM AND SAPROLITE
A residuum/saprolite unit was encountered on-site beneath the fill materials and at
the surface in off-site areas. The residuum consists of weathered in place bedrock
that displays no recognizable original bedrock structure. Saprolite is similar to
residuum in its formation but has been weathered to a lesser degree so that some
original bedrock structure is discernible. The residuum was described as stiff to very
stiff, Kaolinite-rich clay to sandy day. The unit also contained frequent iron nodules.
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Cedartown Municipal Landfill Site
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Near the base of the residuum more of the day mottling occurred indicating some
vestigial remains of the bedrock structure. The residuum/saprolite consists of 69 to
92 percent silt and day sized partides.
The total thidcness of this unit varied from 20 feet to 156 feet (OW-3). Beneath the
landfill, the total thidcness of residuum/saprolite was found to range from 20 to 80
feet.
5.1.3 NEW ALA LIMESTONE
The Ordovician age Newala Limestone was encountered below the
residuum/saprolite unit in each of the seven perimeter bedrock monitoring wells
completed as part of the RI. The Newala Limestone was investigated to depths
ranging from 9 to 60 feet from the top of the bedrock during the RI. This unit
consisted of a light to dark gray interbedded dolostone to limestone with cherty
zones. The bedrock exhibited slight to moderate weathering. Examination of the
bedrock cores provided evidence of bedding plane and higher angle fractures.
Post-depositional infilling of some fractures with caldte or quartz was also noted.
The primary post-depositional feature of the Newala Limestone is the presence of
karst features. These features range from small voids to large cavern-like openings.
The presence of void spaces in the bedrock was noted at wells OW-1, OW-2, OW-3
and OW-6B. The vertical extent of the voids ranged from seven feet (OW-1) to
greater than 60 feet (OW-6B).
The top of rock was encountered at elevations ranging from approximately 770 feet
AMSL to 785 feet AMSL. The minor changes in the elevation of the top of rock
indicate small undulations in the bedrock surface, but no significant trends across the
Site. The variation of the thickness of overburden across the Site is influenced by
previous mining operations and historical landfilling activities.
5.2 SURFACE WATER/HYDROLOGY
The hydrology on-site is controlled by the relief on the landfill site and the relatively
low permeability of the cover material. Precipitation falling on the landfill proper
will either infiltrate into the subsurface or run off following the topographic trends.
A northeast trending high exists across the central portions of the landfill. This
central elevated arch has an elevation of approximately 860 feet AMSL, which is as
much as 50 to 60 feet higher than lower areas to the east and west. Overland flow
along the west side of the landfill will move downslope towards relatively flat areas
bordering the landfill. Some of this overland flow may continue westward towards
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Cedartown Municipal Landfill Site
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an intermittent stream located west of the landfill.
This intermittent stream crosses Prior Station Road approximately one-half mile west
of the site and flows northeasterly to a pond (Cotton Pond) which is located
approximately 500 feet west of the central portion of the landfill perimeter. This
pond may receive overland discharge from the Site during rainfall events. This
intermittent stream continues along a northeasterly path away from the pond and
continues to diverge away from the Site.
The landfill cap is mounded resulting in sheet flow runoff extending radially
outward from the central portion of the landfill. No major drainage courses are
present on the Site itself. Along the south side of the Site overland flow moves off
the landfill toward a drainage ditch which runs east/west along Prior Station Road.
This drainage ditch flows west where it appears to be intercepted by a low area on
the west side of the Site immediately west of the perimeter access road. No surface
water was observed in this low area or in the ditch along Prior Station Road
throughout the field component of the RI. Overland flow along the southeast side of
the Site moves overland towards Tenth Street. Much of the overland flow across the
eastern central portion of the landfill moves toward a small pond located west of the
Coca Cola bottling plant (Coke Pond). Across the north and northeastern section of
the landfill Site, overland flow moves toward an area located north of the City
Garage. This area is drained by an overflow drainage ditch that directs drainage
northward away from the Site.
5.3 HYDROGEOLOGY
Seven (7) new bedrock monitoring wells (OW-1 to OW-5 inclusive plus OW-6A and
OW-6B) were installed around the perimeter of the landfill to supplement existing
perimeter bedrock wells previously installed by USEPA during the site investigation
(see figure 5-1). The seven new wells plus three existing wells (CL-03-WP,
CL-04-WP, CL-09-WP) were sampled on different occasions (October 1991, December
1991, and June 1993) to define the extent of ground water contamination.
5.4 SUMMARY OF SITE CONTAMINATION
5.4.1 GROUND WATER CHARACTERIZATION
Seven (7) new bedrock monitoring wells (OW-1 to OW-5 inclusive plus OW-6A and
OW-6B) were installed around the perimeter of the landfill to supplement existing
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Cedartown Municipal Landfill Site
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perimeter bedrock wells previously installed during the site investigation. The seven
new wells plus three existing NUS wells (CL-03-WP, CL-04-WP, CL-09-WP) were
sampled on three different occasions in October (event #1) and December 1991 (event
#2) and June 1993 (event #3).
Seven bedrock monitoring wells (OW-1 to OW-5 inclusive plus CL-03-WP and
CL-09-WP) were also sampled for analysis of chromium and manganese in June 1993.
Perimeter monitoring well locations are illustrated on Figure 5-1 and analytical data
are summarized in Table 5-1.
VOLATILE ORGANICS (VOCs)
Ace.tone was detected during the October and december sampling events at
concentrations ranging from 16 to 570 micrograms per liter (ug/1) or parts per billion
(ppb). 1,2-Dichloroethane was reported in monitoring well OW-2 at an estimated
concentration of 4 ppb.
PESTICIDES, BASIC/NEUTRAL ACID EXTRACTABLES (BNAs), AND
POLYCHLORINATED BIPHENYLS (PCBs)
Pesticides and PCBs were not detected in any wells during any sampling event.
Eight (8) BNAs were reported in OW-6B (including three estimated at less than
10 ppb) during the second sampling event. In addition, fluorene and pyrene were
both reported at an estimated concentration of 2 ppb in well OW-3 during the second
sampling event.
METALS
Metals were reported in all ground water samples collected during the first and
second sampling events.
Chromium was also detected in all cross- and down-gradient monitoring wells except
OW-3 and OW-4. Chromium ranged in concentration from 13 ug/L to 230 ug/L
(CL-03-WP). The values in most wells varied between events may be due to varying
sediment contents. While metal concentrations may have been impacted by sample
turbidity, using low flow sampling techniques and proper well construction may
produce a sample more representative of actual ground water quality.
In sampling events 1 and 2, Beryllium, Chromium, Cadmium, and Lead were
detected above their respective Safe Drinking Water Act (SDWA) Maximum
Contaminant Level (MCL). The results obtained from sampling event #3, using low
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Cedartown Municipal Landfill Site
Page 13
FIGURE 5-1
SITE SAMPLING PLAN
LEGEND
SITE BOUNDARY
(DEFINED BY NUS)
°*~* Rl OBSERVATION WELL
A L*~' LEACHATE WELL
£ L»-IA LEACHATE WELL PILOT BOREHOLE
0 o.-09-w NUS OBSERVATION WELL
B 0.-OJ-S* NUS 1987 SOIL SAMPLING LOCATIONS
@a-U-M> OBSERVATION WELL (NOT FOUND)
g SS-« SEDIMENT/SURFACE WATER
SAMPLE LOCATION
a
Q
CAST
SCIP
SAMPIX
SEDtUENT SAMPLE LOCATION
UNAFFECTED SOIL SAMPLE
STAINED SOIL SAMPLE
LEACHATE SEEP SAMPLE
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Record of Decision
Cedartown Municipal Landfill Site
Page 14
TABLE 5-1
. SUMMARY OF SUBSTANCES DETECTED IN GROUND WATER
Downgradient Wells (3) Background Wells (4)
Frequency of
Compound Detection
VOCs (u$/L)
Acetone
1 ,2-Dichloroe thane
Xylenes (Total)
Inorganics Cug/L)
Aluminum
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Toad
jnesium
Manganese
Mercury
Nickel
Potassium
Sodium
Vanadium
Zinc
General Chemistry (ug/L)
Alkalinity
Chloride
Hardness
Sulfate
3/14
1/14
1/14
14 / 14
5/14
14 / 14
6/14
4/14
14 / 14
9/20
7/14
13 / 14
14 / 14
8/14
12 / 14
19 / 20
3/14
12 / 14
11 / 14
11 / 14
5/14
12 / 14
14 / 14
13 / 14
14 / 14
9/14
Range of Detections
Minimum
ND(10)
ND(5)
ND(5)
525
ND(5)
55
ND(5)
ND(5)
51,000
ND(10)
ND(50)
ND(10)
3,600
ND(3)
ND(5,000)
ND(15)
ND(0.2)
ND(40)
ND(5,000)
ND(5,000)
ND(50)
ND(20)
86,000
ND(2,000)
140,000
ND(5,000)
Maximum
240
- 4J
- 2J
- 77,000
- 18
- 830
- 60
- 24
- 865,000
- 230
- 250
- 180
- 200,000
- 100
- 280,000
- 8,800
- 0.4
- 1,000
- 88,000
- 290,000
- 170
- 3,200
- 1,200,000
- 15,000
- 2,200,200
- 940,000
Average
Concentration
25
2.6 J
2.5 J
21,107
7.1
361
11.9
4.8 J
272,429
43
68
58
52,679
20
61,421
1,714
0.15 J
204
25,350
48,079
57
520
430,071
7,286
917,857
109,464
Range of Concentrations
Minimum
ND(10)
930
10
ND(5)
ND(5)
11,000
ND(10)
ND(50)
ND(10)
8,100
ND(5)
ND(5,000)
96
ND(02)
ND(40)
ND(5,000)
ND(5,000)
ND(50)
31
72,000
3,000
20,000
ND(5,000)
Maximum
- 570
-
-
- 40,000
-
- 475
- 50
- 8.5
- 61,000
- 185
- 335
- 370
- 125,000
- 308
- 24300
- 5,000
- 1.1
- 1,170
- 15,000
- 10,000
- 120
- 2,550
- 155,000
- 3,000
- 156,000
- 15,000
Average
Concentration
149
ND (5)
ND (5)
18,108
ND (5)
217
17
4J
40,250
48
136
138
50,250
83
11,125
1,487
0.6
405
8,250
5,783
56
937
114,250
3,000
109,000
10,188
Notes:
ND(5) - Not detected at detection limit presented in brakets.
\-y J - Indicates value is estimated.
(3) Samples from Site-Specific Background locations were not includec
(4) Background well locations include CL-09-WP and OW-6B.
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Record of Decision
Cedartown Municipal Landfill Site
Page 15
flow sampling techniques, indicates that chromium is not present above 10 ug/L.
This concentration is well below the SDWA MCL of 100 ug/1.
The manganese results obtained from ground water sampling event #3 are consistent
with sampling events 1 and 2. Therefore, sediment has had little or no impact on
these results. The manganese levels are similar to those determined during the RI
which are above the risk based performance standard of 175 ug/1. Monitoring wells
OW-6B and CL-09-WP provided the background ground water quality data.
BACKGROUND UNCERTAINTIES
Perimeter bedrock monitoring wells OW-6 and CL-09WP are upgradient of the Site
and provided the background ground water quality data. However, due to the
substantial analytical differences between background results from the two wells,
background concentration values will be confirmed during the first two years of
ground water sampling. Two background wells were established, OW-06 (installed
at EPA's direction), and CL-09WP (utilized by PRPs' contractor during the RI). OW-
06 is upgradient. CL-09 appears to be upgradient, however the North/Northeast
ground water flow from the landfill may have impacted this well as shown in Figure
5-2 and in the summarized data provided.
Beryllium, cadmium, chromium, and lead will remain Site Contaminants of Concern
and performance standards will be their respective SDWA MCL, due to significant
background analytical differences and the possible landfill contaminant impact on
background well CL-09-WP. Further background sampling and analysis will be
required to support modifying the SDWA MCL based performance standard due to
technical infeasibility or inability to attain the ARAR as justified by actual
background ground water quality.
The proposed remedy will require further sampling and analysis to further define
background ground water concentrations of inorganic contaminants. If this analysis
indicates that background ground water concentration for an inorganic constituent
exceeds the applicable performance standard, consideration to amending the
performance standards through an Explanation of Significant Differences (ESD) or
Record of Decision (ROD) Amendment including any applicable or relevant and
appropriate requirement (ARAR) waiver may be accomplished.
Proper well construction and development techniques along with a low flow
sampling method would be used during monitoring. While certain inorganic and
metals concentrations may have been impacted by sample turbidity, this impact may
be reduced or eliminated utilising low flow sampling techniques and proper well
construction. Therefore, metal concentrations in ground water will be confirmed
using low flow sampling techniques during post-ROD ground water monitoring.
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Record of Decision
Cedartown Municipal Landfill Site
Page 16
Figure 5-2 Ground Water Contour Map
*v~-l^-^V^i.";-: OW-4 >
SITE BOUNDARY
(DEFINED BY NUS)
Rl OBSERVATION WELL
<» NUS OBSERVATION WELL
780 BEDROCK GROUNDWATER CONTOUR
(774.54) GROUNDWATER ELEVATION
<*=! GROUNDWATER FLOW
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Record of Decision
Cedartown Municipal Landfill Site
Page 17
Sampling Event 1
OW-6B
CI-09WP*
Sampling event 2
OW-6B
CL-09WP
Sampling Event 3 **
CL-09WP
CONTAMINANT CONCENTRATIONS (ug/1)
Lead
ND(5)
ND(50)J
7
40
N/A
Cadmium
ND(5)
12J
ND(5)
ND(5)
N/A
Chromium
ND(ll)
230J
ND(10)
170
ND(10)
Beryllium
ND(5) .
61J
ND(5)
13
"*
N/A
Manganese
130
6200J
96
2200
<15
Arsenic
ND(5)J
ND(5)
ND(5)
ND(5)
N/A
NOTES
* CL-09WP results based on two samples (one is a duplicate). The higher of the two
results was utilized.
** Sampling Event #3 was only analyzed for Chromium and Manganese.
j Estimated values
5.4.2
SOIL CHARACTERIZATION
Soil samples were collected off Site at all perimeter bedrock monitoring well
locations. In addition/ soil samples were collected from the soil cover at select
locations within the limits of the landfill. Soil sample data are presented in Table 5-2.
VOCs
Several discrete detections of trace concentrations of several VOCs and phthalates
were reported in soil samples from the locations of monitoring wells OW-1, OW-3
and OW-6. No VOCs were reported in the on-site soil sample collected adjacent to
the seep on the east slope of the landfill.
PESTICIDES, BNAs, and PCBs
No PCBs, BNAs, or pesticides were reported in any of the off-site soil samples
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Record of Decision
Cedartown Municipal Landfill Site
Page 18
TABLE 5-2
SUMMARY OF SUBSTANCES DETECTED IN SOIT.S
Compound
VOCs u$/k$)
Acetone
Benzene
2-Butanone
Carbon Disulfide
Chlorobenzene
Ethylbenzene
Methylene Chloride
Toluene
Xylenes. (Total)
BNAs (uvfkv)
bis(2-Ethylhexyl)phthalate
2-Methylnaphthalene
Naphthalene
Inorganics (mgfkg)
Aluminum
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Sodium
Vanadium
Zinc
Frequency of
Detection
3/10
1 / 10
1 / 10
1/10
1/10
1 / 10
1 / 10
1 / 10
1 / 10
1 /9
1 /9
1 /9
9/9
9/9
9/9
9/9
5/9
6 /9
9/9
8/9
9/9
9/9
9/9
6 /9
9/9
3/9
9/9
9/9
1 /9
1 /9
9/9
9/9
Range of Detections (3)
Minimum
ND(12)
ND(6)
ND(ll)
ND(6)
ND(6)
ND(6)
ND(6)
ND(6)
ND(6)
ND(410)
ND(410)
ND(410)
4,700
4.6
49
0.7
ND(0.6)
ND(290)
19
ND(2.9)
13
21,000
6.4
ND(290)
33
ND(0.12)
11
370
ND(0.6)
ND(290)
16
38
Maximum
- 210J
- 8J
- 36J
- 8J
- 4J
- 190J
- 21J
- 5J
- 900J
- 230J
- 88J
- 210J
- 18,000
- 27
- 1,100
- 6.7
- 2.4
- 6,700
- 46
- 470
- 86
- 160,000
- 100
- 1,200
- 33,000
- 0.4J
- 340
- 4,000
- 3.1
- 16,000
- 59
- 650
Average (3)
Concentration
42
4.4 J
10.9 J
4.5 J
4.0 J
23
5.9 J
4-2 J
94
275 J
254 J
267 J
12,767
12.9
283
3.7
1.2
1,371
32
111
54
101,556
31
469
5,575
0.16
158
1,188
0.7 J
1,928
42
381
Background (4)
Soil
Concentration
111
3.3 J
ND (12)
ND (6)
ND (6)
ND (6)
ND (6)
ND (6)
ND (6)
218 J
208 J
218 J
14,000
17.7
113
2.6
0.6
2,484
31.6
40
42
69,720
49
593
1302
0.17
81
630
ND (0.6)
ND (320)
444
237
Notes:
(1) ND(5) - Not detected at detection limit presented in brakets.
(2) J - Indicates value is estimated.
(3) Samples from Site-Specific Background locations were not included.
(4) Background soil locations include OW-4, OW-5 and OW-6.
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Record of Decision
Cedartown Municipal Landfill Site
Page 19
collected. No VOCs, BNAs, PCBs, or pesticides were reported in the on-site soil
sample collected adjacent to the seep on the east slope of the landfill.
METALS
Metal concentrations varied significantly between samples and ranged as follows:
arsenic (4.6 to 31 mg/kg); barium (43 to 1,100 mg/kg); beryllium (0.7 to 6.7 mg/kg);
cadmium (ND to 2.4 mg/kg); chromium (18 to 49 mg/kg); cobalt (ND to 470 mg/kg);
lead (6.4 to 100 mg/kg); and zinc (38 to 650 mg/kg). Cyanide was reported in one
surfirial soil sample at a concentration of 0.82 mg/kg.
Contamination of surficial soils appears to be limited to those soils/sediments
impacted by the seep.
5.4.3 SURFACE WATER CHARACTERIZATION
Surface water samples were collected from locations illustrated in Figure 5-1.
Surface water data are "resented in Table 5-3.
Two (2) surface water samples were collected from an intermittent drainage course
situated 300 to 700 feet west of the Site. One (1) of these two samples was situated
upgradient of the Site (SS-8) and a second sample was collected due west or
cross-gradient from the Site (SS-4). No water was present in this drainage course
downgradient of the Site.
VOCS, PESTICIDES, BNAs, and PCBs
VOCs were not reported in either of these samples. Trace concentrations of 10 BNAs
were reported in the surface water sample taken from the Cotton Pond. No
pesticides or PCBs were reported.
METALS
Metals were detected in all surface water samples collected, with the greatest number
of parameters and highest concentrations detected in sample SS-6 from the shallow
ponded area. The metals reported include: arsenic (9 ug/L); barium (1,200 ug/L);
chromium (62 ug/L); cobalt (50 ug/L); lead (20 ug/L); manganese (4,900 ug/L); and
zinc (540 ug/L). Most of the metals detected in this sample were not detected in the
other three surface water samples. Metals detected in the surface water sample from
the cotton pond were generally consistent with the sample collected upgradient of
this location (SS-8) with the exception of higher levels of aluminum, iron and
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Record of Decision
Cedartown Municipal Landfill Site
Page 20
Compound
VOCs
Acetone
2-Butanone
BNAs
Acenaphthene
Anthracene
Benzo(a)anthracene
Dibenzofuran
Di-n-butyl phthalate
Fluorene
2-Methylnapthalene
Naphthalene
Phenanthrene
Pyrene
Inorganics
Aluminum
Arsenic
Barium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Nickel
Sodium
Vanadium
Zinc
TABLE 5-3
SUMMARY OF SUBSTANCES DETECTED IN SURFACE WATERS
Background (4)
Frequency of Range of Detections (3) Average (3) Surf ace Water
Detection Minimum Maximum Concentration Concentration
2/3
1 /3
ND(10) - 100
ND(10) - 6J
54
5.3 J
1 /3
1 /3
1 /3
1 /3
1 /3
1 /3
1 /3
1 /3
1 /3
1 /3
ND(10)
ND(10)
ND(10)
ND(10)
ND(10)
ND(10)
ND(10)
ND(10)
ND(10)
ND(10)
- 11
- 4J
- 3J
- 9J
- 6J
- 15
- 190
- 47
- 42
- 6J
ND (10)
ND (10)
7.0 J
4-7 J
4.3 J
6.3 J
5.3 J
8.3 J
67
19
17.3
5.3 J
ND (10)
ND (10)
ND (10)
ND (10)
ND (10)
ND (10)
ND (10)
ND (10)
ND (10)
ND (10)
2 /3
1 /3
2 /3
3 /3
1 /3
1 /3
1 /3
3 /3
1 /3
2 /3
3 /3
1 /3
1 /3
1 /3
2/3
ND(200)
ND(5)
ND(200)
5,400
ND(10)
ND(50)
ND(10)
510
ND(5)
ND(5,000)
82
ND(40)
ND(5,000)
ND(50)
ND(50)
- 19,000
- 9
- 1,200
- 140,000
- 62
- 50
- 49
- 190,000
- 20
- 55,000
- 4,900
- 55
- 290,000
- 110
- 540
6,467
4.7 J
438
55,800
26
33
22
63,743
8.3
22,833
1,701
32
98333
53
199
ND (200)
ND (5)
ND (200)
26,000
ND (10)
ND (50)
ND (25)
160
ND (5)
13,000
19
ND (40)
ND (5000)
ND (50)
33
(1) ND(5) - Not detected at detection limit presented in brakets.
(2) J - Indicates value is estimated.
(3) Samples from Site-Specific Background locations were not included.
(4) Background concentrations
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Record of Decision
Cedartown Municipal Landfill Site
Page 21
manganese.
5.4.3.1 EAST SEEP
Surface water samples were also collected from two locations on the east side of the
Site. One surface water sample (sample SS-6) was collected from a shallow ponded
area apparently fed by the seep noted on the east slope of the landfill. An additional
surface water sample (sample SS-5) was collected from the Coke Pond which appears
to be further downgradient of the seep and the ponded seep area (sample SS-6).
Acetone was detected in the ponded area and Coke Pond at concentrations of
100 ppb and 58 ppb, respectively. 2-Butanone was reported at an estimated
concentration of 6 ppb. No BNAs, pesticides or PCBs were reported in either sample.
VOCS, BNAS, and metals reported in the leachate seep (east seep) were generally
consistent with those reported in the nearby leachate well (CL-08-WT).
These concentrations suggest the Site has minimally impacted off-site surface water.
5.4.4 SEDIMENTS CHARACTERIZATION
Sediment samples were collected at all surface water sampling locations in addition
to selected dry locations in intermittent stream beds. Results are shown in Table 5-4.
VOCS, PESTICIDES, and BNAs
Sediment samples collected from the "Dry Pond" (SS-3) and upgradient stream
location (SS-4 in the Cotton Pond) contained no reported VOCs, one BNA (960 ug/kg
of diethylphthalate at SS-3), no reported pesticides or PCBs, and metals consistent
with background.
Sediment samples collected from the shallow ponded area and Coke Pond also had
reported detections of acetone (380 ug/kg and 1500J ug/kg, respectively), and
2-butanone (76 ug/kg and 650J ug/kg, respectively), in addition to several other trace
detections of other VOCs. One BNA was detected in Coke Pond sediment
(bis(2-ethylhexyl)) phthalate at 220J ug/kg), no other BNAs or pesticides or PCBs
were reported.
METALS
Metals were reported in all sediment samples collected at varying concentrations.
Concentrations of the inorganic constituents reported in the sediment samples
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Record of Decision
Cedartown Municipal Landfill Site
Page 22
TABLE 5-4
SUMMARY OF SUBSTANCES DETECTED IN SEDIMENTS
Compound
VOCs (fjff/kv)
Acetone
Benzene
2-Butanone
Ethylbenzene
Methylene Chloride
Toluene
BNAs fug/Kg)
bis(2-Ethylhexyl)phthalate
Diethylphthalate
Inorganics (mg/kg)
Aluminum
senic
ijarium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Sodium
Vanadium
Zinc
frequency of
Detection
2/4
1 /4
2/4
1 /4
1 /4
1 /4
1 /4
1 /4
4/4
4/4
4/4
4/4
1 /4
4/4
4/4
4/4
4/4
4/4
4/4
3 /4
4/4
1 /4
4/4
2 /4
1 /4
4/4
4/4
Range of Detections (3)
Minimum
ND(13)
ND(7)
ND(13)
ND(7)
ND(7)
ND(7)
ND(440)
ND(520)
7,700
5
67
0.62
ND(0.8)
880
16
6.2
7
16,000
13.9
ND(830)
330
ND(0.17)
8.4
ND(390)
ND(330)
25
55
Maximum
- 1,500}
- 6J
- 650J
- 4.2J
- 23
- 8.5
- 220J
- 960
- 17,000
- 13
- 170
- 2.8
- 0.7
- 12,550
- 28
- 28
- 29
- 48,000
- 47
- 1,040
- 1300
- 0.2
- 89
- 2,050
- 715
- 39
- 400
Average (3)
Concentration
467
7.5 J
184
7.1 J
11.8
8.1
244 J
512 J
12300
8.2
116
1.3
0.6 J
5,808
21
14.4
19.6
30,250
35
711
721
0.14 J
36
910
373
30
.197
Background (4)
Sediment
Concentration
70
3.4 J
ND(12)
ND(6)
6.3 J
ND(6)
373 J
ND(500)
10,933
11.5
85
1.3
0.4 J
1397
22
21
20
37,573
47
493
804
0.10 J
35
323
ND(320)
31
117
Notes:
(1) ND(5) - Not detected at detection limit presented in brakets.
'">) J-Indicates value is estimated.
) Samples from Site-Specific Background locations were not included.
(4) Background sediment locations indu*!*- OW-4, OW-5, OW-6 and SS-8.
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Record of Decision
Cedartown Municipal Landfill Site
Page 23
collected from the intermittent drainage course situated west of the Site were, in
general, consistent between upgradient and cross/downgradient sample locations.
Levels of metals reported in the sediment sample collected from the dry pond (SS-3),
downgradient of the Cotton Pond include: arsenic (13 mg/kg); barium (170 mg/kg);
beryllium (2.8 mg/kg); mercury (0.2 mg/kg); nickel (89 mg/kg); and zinc
(240 mg/kg). Samples collected from the seep and downstream location exhibited
different characteristics, consistent with the impact of a municipal landfill (e.g. high
calcium and sodium concentrations).
These concentrations further suggest the Site has minimally impacted off-site
sediment quality.
5.5.5 LEACHATE AND WASTE CONTAMINANTS
A total of 30 boreholes were specifically targeted in an effort to locate subsurface
waste materials for the purpose of installing leachate wells during this phase of the
work. No waste materials were encountered in 19 of the boreholes while waste
»-*» ** 4-sf*»i -*!*« ftv*->.* n 9ft s« *£> C+ f-isl «* tV* ^ 1 1 */!*»« «%i«*«*%sv V-*/-k«»/^V» rtl f\f* T?ivrs\ 1 /\*^ /-»V» ** ±s\ T*T/%11r* I T TA7_1
xxi.aLCAi.ctxo rv ex c XU.CXLLXXXCU. XXL LAIC x x x cxxicixxuxtg LSV/A cxiwxch?. x x »t xcuvxiutc TT tr**-r* \i^ v T */
LW-2, LW-3, LW-4 and LW-6) were installed within the identified waste deposits
immediately adjacent to five boreholes exhibiting waste. Leachate well LW-6 was
installed approximately 75 feet from borehole LW-6A (see figure 5-1).
Soil/waste samples were collected during advancement of the boreholes. Samples
were collected near the base of the waste in boreholes where waste was encountered.
In addition, samples were collected from any unique zones/conditions encountered.
One round of leachate samples were collected from the five newly installed leachate
wells and one existing leachate well (CL-08-WT).
5.5.5.1 WASTE/SOIL ANALYSES
Soil/waste samples include all subsurface solid samples collected on Site from
identified waste disposal areas. Data obtained from the analyses of waste/soil
samples are presented in Table 5-5.
VOCs
Detections of volatile organic compounds in the waste materials were variable. In
general, trace concentrations (i.e. less than 100 ppb) of several common VOCs were
detected in the waste/soil samples including: acetone, ethylbenzene, methylene
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Record of Decision
Cedartown Municipal Landfill Site
Page 24
TABLE 5-5
SUMMARY OF SUBSTANCES DETECTED IN WASTE/SOILS
Compound
VOCs (uv/kv)
Acetone
Benzene
Carbon Disulfide
Chlorobenzene
1 ,2-Dichloroethane
Ethylbenzene
Merhylene Chloride
Toluene
Xylenes (Total)
EN As (uv/kv)
bis(2-Ethylhexyl)phthalate
Di-n-butyl phthalate
2-Methylnaphthalene
Naphthalene
Phenol
*
Inorganics (mv/kv)
Aluminum
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel -
Potassium
Selenium
Sodium
Vanadium
Zinc
Cyanide
Frequency of
Detection
9/10
1/10
1/10
1/10
2/10
2/10
2/10
2/10
4/10
3/9
2/9
1 /9
3/9
1 /9
9/9
9/9
9/9
7/9
5/9
7/9
9/9
7 /9
9/9
9/9
9/9
6 /9
9/9
5/9
7/9
9/9
4/9
3/9
8/9
9/9
1 / 9
Range of Detections (3)
Minimum
ND(19)
ND(6)
ND(6)
ND(6)
ND(6)
ND(6)
ND(6)
ND(6)
ND(6)
ND(410)
ND(410)
ND(410)
ND(410)
ND(410)
1,700
6.6
18
ND(031)
ND(0.6)
ND(310)
8.5
ND(3.1)
12
12,000
8
ND(310)
4.2
ND(O.l)
ND(25)
370
ND(O.T)
ND(310)
ND(3.5)
3.3
ND(03)
Maximum
- 120J
- 4J
- 4J
- 12J
- 180,000
- 15J
- 17
- 11
- 50J
- 27,000
- 1300
- 120,000
- 95,000
- 75,000
- 14,000
- 23
- 680
- 9.4
- 21
- 120,000
- 300
- 140
- 120
- 180,000
- 2,100
- 970
- 2,900
- 0.2
- 350
- 1,900
- 8.4
- 3,000
- 37
- 1300
- 0.56
Average (3)
Concentration
56
35]
35]
43 J
18,010
4.7 J
55 J
4.1 J
11.9
3315
483
13,554
10,740
8554
6,867
10.1
207
3.1
3.9
14,244
48
49
54
59,778
258
500
1,202
0.15 J
122
1,054
1.8
560
18.3
345
0.20 J
Background (4)
Soil
Concentration
111
33 J
ND (6)
ND (6)
ND (6)
ND (6)
ND (6)
ND (6)
ND (6)
218 J
300 J
268 I
218 J
ND (500)
14,000
17.7
113
2.6
0.6
2,484
31.6
40
42
69,720
49
593
1,502
0.17
81
630
ND (0.6)
ND (320)
444
237
0.29 ]
(1) ND(5) - Not detected at detection limit presented in brakets.
(2) J - Indicates value is estimated.
(3) Samples from Site-Specific Background locations were not included.
(4) Background soil sample locations include OW-4, OW-5 and OW-6.
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Cedartown Municipal Landfill Site
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chloride, toluene, and xylene.
1,2-Dichloroethane (1,2-DCA) was detected in one subsurface soil sample from a
depth of 4 to 6 feet at a concentration of 180 ppm in borehole LW-3. The only other
reported detection of 1,2-DCA in soil occurred at borehole LW-1 from a depth of 38
to 40 feet at a concentration of 0.079 ppm. No waste material was noted at this
location. This sample was taken from a discrete discolored soil seam and was not
representative of typical conditions noted in this or any other borehole.
PESTICIDES, BNAs, and PCBs
The same sample contained reported concentrations of various BNAs including
bis(2-ethylhexyl)phthalate (27 ppm); 2-methylnaphthalene (120 ppm); napthalene
(95 ppm); and phenol (75 ppm). Trace concentrations of other BNAs reported
include Di-n-butyl phthalate in sample S-3482-10 (1.3 ppm) and
bis(2-ethylhexyl)phthalate in sample S-3482-38 (0.77 ppm).
No other significant concentrations of BNAs were reported in the waste/soil samples.
No pesticides or PCBs were detected in any waste/soil samples submitted for
analyses. Cyanide was detected in one waste/soil sample collected for analyses from
borehole LW-6 at a concentration of 0.56 ppm.
METALS
Several metals were detected above non-waste soil levels in samples collected from
borehole LW-6. The sample collected at a depth of 18 to 20 feet contained reported
concentrations of various metals including: barium (390 ppm); beryllium (9.4 ppm);
cadmium (21 ppm); copper (120 ppm); manganese (2,100 ppm); nickel (350 ppm); and
zinc (1,300 ppm). Lead was reported at a concentration of 2,100 ppm in the sample
collected from 6 to 10 feet in the same borehole.
The highest level of manganese was reported in the sample collected at a depth of 18
to 20 feet in borehole LW-4 at a concentration of 2,900 ppm. The highest level of
chromium was found in borehole LW-3 at a depth of 4 to 6 feet. This sample
contained chromium at a concentration of 300 ppm. No other significant
concentrations of metals were reported in the waste/soil samples.
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Cedartown Municipal Landfill Site
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5.5.5.2 LEACHATE SAMPLE ANALYSES
Leachate analytical data are summarized in Table 5-6.
VOCs, PESTICIDES, BNAs, and PCBs
In general, only trace concentrations of a limited number of VOCs and BNAs were
reported in the leachate samples collected. The most common compounds reported
include: acetone (ND to 55 ug/L); benzene (ND to 37J ug/L); chlorobenzene (ND
to 14 ug/L); ethylbenzene (ND to 290 ug/L); toluene (ND to 47 ug/L); and total
xylenes (ND to 1600 ug/L). The highest reported BNA compound in leachate was
naphthalene at a concentration of 125 ug/L. Remaining BNA compounds were less
than 10 ug/L with the exception of several isolated and sporadic detections. No
PCBs or pesticides were reported in any of the leachate samples.
METALS
Metals were reported at varying concentrations in all leachate samples collected, with
the highest concentrations of metals generally reported in samples collected from
leachate wells LW-4 and LW-6. Select metals were also detected in leachate well
LW-2. Of these three wells, detected metals concentrations reported included:
arsenic (ND to 19 ug/L); barium (3.5 to 12 mg/L); cadmium (5 to 55 ug/L);
chromium (190 to 700 ug/L); lead (110 to 1,700 ug/L); manganese (3.9 to 180 mg/L);
and zinc (12 to 17,000 ug/L). Arsenic, barium, and lead were also reported in the
sample from well CL-08-WT at respective levels of 8,1600 and 92 ug/L. Levels of
barium (1,300 ug/L) and lead (31 ug/L) were found in the sample collected from
leachate well LW-1. Select metals reported in the sample collected from the east seep
included: arsenic (7 ug/L); barium (1,100 ug/L); manganese (3,200 ;ig/L); and lead
(26 ug/L).
6.0 SUMMARY OF SITE RISK
CERCLA directs EPA to conduct a Baseline Risk Assessment (BRA) to determine
whether a Superfund Site poses a current or potential threat to human health and the
environment in the absence of any remedial action. The baseline risk assessment
provides the basis for determining whether or not remedial action is necessary and
the justification for performing remedial action.
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Cedartown Municipal Landfill Site
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TABLE 5-6
SUMMARY OF SUBSTANCES DETECTED IN LEACHATE
Compound
VOCs (ng/L)
. Acetone
Benzene
Chlorobenzene
Ethylbenzene
Toluene
Xylenes (Total)
BNAs (ug/L)
Acenaphthene
Benzoic Acid
bis(2-Ethylhexyl)phthalatc
Dibenzofuran
2,4-Dimethylphenol
. Di-n-butyl phthalate
1 ,4-Dichlorobenzene
Fluorene
2-Methylnapthalene
4-Methylphenol
Naphthalene
N-nitrosodimethylamine
Phenanthrene
Phenol
Innrvanic^ (/j?fL)
Aluminum
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Sodium
Vanadium
Zinc
Cyanide
General Chemistry (fjt$/L)
Alkalinity
£ Chloride
Hardness
Sulfate
Frequency of
Detection
5 11
5/7
3/7
3/7
2/7
5/7
1 /7
1 /7
3/7
1 /7
3 11
1 /7
i n
2 /7
2/7
1 /7
4 / '/
i n
i n
2 n
7/7
4/7
7 17
3 17
3 17
7/7
7/7
4 / 7
7/7
7/7
6/7
6/7
7/7
4/7
6/7
6/7
7/7
5/7
7/7
5/7
7/7
7/7
7/7
7/7
Range of Detections
Minimum
ND(10)
ND{5)
ND(5)
Nt>(6)
ND(6)
ND(5)
' ND(10)
ND(10)
ND(10)
ND(10)
ND(10)
ND(10)
ND(10)
ND(10)
ND(10)
ND(10)
iND(iG)
ND(10)
ND(10)
ND(10)
1,300
ND(5)
82
ND(5)
ND(5)
8,200
15
ND(50)
12
4,900
ND(5)
ND(5,000)
1,200
ND(0.2)
ND(40)
ND(5,000)
3,200
ND(50)
12
ND(5)
40 £00
19,000
26,000
8,000
Maximum
- 55
- 37]
- 14
- 290
- 47
- 1,600
- 6]
- 31]
- 15
- 3J
- 16
- 3J
- 4J
- 4J
- 36
- 27
- 125
- 5]
- 5J
- 3]
- 390,000
- 19
- 12,000
- 220
- 55
- 170,000
- 700
- 5,100
- 1,800
- 2,400,000
- 1,700
- 60,000
- 180,000
- 6.7
- 8,300
- 100,000
- 280,000
- 670
- 17,000
- 80
- 1,100,000
- 330,000
- 820,000
- 46,000
Average
Concentration
25
17.6 .
9.6
67
10.3
372
8.1 J
26 J
8.6 1
7.7 j
10.1 J
7.7 J ..
7.9 J lii;
7.6 J
13.3
11.1
it
8.0 J
8.0 J
7.4 J
112,386
8.7
3,312
37 .
16.1 :
108,886
212
846
545
554,700
509
38,929
29,000
1.5 J
1,451
59,500
168,743
240
3,026
17.9
734,285
179,714 i
438,000
16,429
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Cedartown Municipal Landfill Site
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6.1
HUMAN HEALTH RISKS
The human health risk assessment evaluated the nature and extent of the threat to
public health caused by the release or threatened release of hazardous substances
from the Site.
6.1.1
CONTAMINANTS OF CONCERN (COCs)
Chemicals were included in the Summary of Site Risk Section if the results of the risk
assessment indicate that a contaminant might pose a significant current or future risk.
The criteria for determining the contaminants of concern are those contaminants that
contributed to a pathway which exceeds a 1E-4 risk or HI of 1; chemicals contributing
risk to these pathways need not be included if their individual carcinogenic risk is
less than 1E-6 or their noncarcinogenic risk is less than 1.0, the only pathway meeting
this criteria is the Future Residential Ingestion of Ground Water Route and Table 6-1
summarizes the COCs for this pathway.
TABLE 6-1 CONTAMINANTS OF CONCERN
Media and Chemical
Exposure Point Concentrations
Frequency
of Detection
RME l
Background
GROUND WATER mg/l mg/l mg/l
Dichloroethane, 1,2-
Arsenic
Barium
Beryllium
Cadmium
Manganese
Nickel
Vanadium
Zinc
1/14
5/14
14/14
6/14
4/14
19/20
12/14
5/14
12/14
0.0029
0.01
0.52
0.023
0.008
2.747
0.368
0.086
1.017
ND
ND
0.217
0.017
0.004
1.487
0.405
0.056
0.937
1 Reasonable Maximum Exposure defined as the 95% upper confidence limit
chemical concentration (UCL) on the arithmetic mean (or maximum
concentration when the UCL exceeds the maximum).
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6.1.1.1 COCs IN GROUND WATER
Monitoring wells OW-6 and CL-09WP are upgradient of the Site and provided
background ground water quality data. However, due to the substantial analytical
differences between background results from the two wells, the utilization of CL-
09WP will be confirmed during future ground water monitoring.
While certain inorganic and metals concentrations may have been impacted by
turbidity, this impact may be reduced or eliminated utilizing low flow sampling
techniques and proper well construction. Therefore, metal concentrations in
background ground water will be confirmed using low flow sampling techniques
during future ground water sampling.
Nine chemicals reported in the downgradient and cross-gradient monitoring wells
meet the COC criteria: 1,2-dichloroethane, arsenic, barium, beryllium, cadmium,
manganese, nickel, vanadium and zinc.
trvnr^cT roc A cccccx>ri7Tvrr
-
Whether a chemical is actually a concern to human health depends upon the
likelihood of exposure, i.e. whether the exposure pathway is currently complete or
could be complete in the future. A complete exposure pathway (a sequence of events
leading to contact with a chemical) is defined by the following four elements:
Source and mechanism of release;
a transport medium (e.g., surface water, air) and mechanisms of
migration through the medium;
the presence or potential presence of a receptor at the exposure point;
and
a route of exposure (ingestion, inhalation, dermal absorption).
If all four elements are present, the pathway is considered complete.
The two major constituent release and transport mechanisms potentially associated
with the Site are as follows:
Infiltration of precipitation through the affected waste/soils and the
percolation of the resulting leachate into the ground water; and,
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release of affected waste/soil by seeps/leachate run-off to surface
waters, sediments, and soils.
Because of the present landfill cover, wide and dispersed waste disposal practices,
and the minimal presence of VOCs, exposure to constituents in air transport is not
considered significant at the Site.
An evaluation was undertaken of all potential exposure pathways which could
connect chemical sources at the Site with potential receptors. All possible pathways
were first hypothesized and evaluated for completeness using the above criteria. The
current pathways represent exposure pathways which could exist under current Site
conditions while the future pathways represent exposure pathways which could exist,
in the future, if the current exposure conditions change.
6.1.2.1 CURRENT EXPOSURE
Under present conditions, the eastern perimeter of the Site is bordered by light
industrial operations. These operations involve limited outdoor activity; therefore,
outdoor exposures to ambient air, surface soil, and surface water could involve work
populations.
The remainder of the Site and surrounding area is primarily undeveloped and is
covered by a dense growth of trees, brush and mixed vegetation. This area,
therefore, has limited accessibility to the public from the nearby roads and other
properties. Vehicle trails enter the Site across private land in several locations. This
situation allows potential on-site exposure to site-related chemicals in surface soil,
sediment, and surface water.
The receptor populations would be trespassers such as fishermen, hunters, older
children, or hikers. New fencing and gates provide additional security for the Site
and decrease the potential for trespassers and worker exposure.
GROUND WATER
Under current conditions there are no on-site ground water wells so there is no
on-site exposure to ground water or leachate. Nearby residences are on the
municipal water supply and generally, do not have private wells. Two private wells
are known to exist within a 1 mile radius of the Site. One is located downgradient of
the Site and one is cross gradient. Neither well is used for potable purposes. The
down gradient well is over 200 feet in-depth in the Knox group and used for
irrigation use only. The cross gradient well is of unknown depth and is used for
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irrigation use. Neither of these wells would likely be impacted by the Site. Potential
exposures under present land use conditions are summarized as follows:
Media
On-Site
Surface Water
Surface Soil
Surface Sediment
Off-Site
Surface Water
(Coke Pond)
Ground water
Potential Exposure Scenarios - Current Conditions
Exposure Pathway Receptor Populations
Direct Contact
Incidental Ingestion
Recreational use (fish, swim)
Direct contact; ingestion
Household Water
On-Site Workers and Trespassers
Area residents using ponds
and downgrade creek areas
Area residents on private wells
6.1.2.2
FUTURE EXPOSURE
Under potential alternate future land use, the type of potential receptor populations
would not change although the populations could increase in size due to expansion
of the industrial park (more workers) and additional residential development (more
convenient for older children to play on Site) in undeveloped areas close to the Site.
One population, namely hunters, would probably decrease if the area around the Site
becomes more developed.
From the information available (multiple ownership, limited zoning, and general
accessibility of the area), future development of the Site, although possible, will be
limited. The City of Cedartown has initiated action to acquire direct control of the
property. Once acquired, the City may implement restrictions not allowing any
future use of this Site. Without strict zoning, the development in the areas around
the Site could be either commercial or residential. The area to the north and east of
the Site is expected to be developed commercial to light industrial.
In the absence of strict regulations in the State or the county that require use of
municipal water, new development within the County could involve either the use of
County water or the development of private wells to utilize ground water for
residential or industrial purposes. In the event a private well is developed, exposure
from drinking and bathing in potentially contaminated water could occur.
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If the City implements a formal maintenance program to ensure the integrity of the
Site cover and prevent minor illegal waste disposal, workers involved in maintenance
activities could be exposed to contaminated surface soils, sediment and surface water.
Exposure pathways and receptor populations under future alternate land use
conditions are similar to present land use conditions. Future complete exposure
points can be summarized as follows:
Media
On-Site
Potential Exposure Scenarios - Future Conditions
Exposure Pathway Receptor Populations
Surface Water Direct Contact Residents near the Site - Trespassers
Incidental Ingestion
Surface Soils Direct Contact &
& Sediments Ingestion
On-site Maintenance Workers &
Trespassers
Off-Site
Surface Water Recreational Use
Direct Contact
Area Residents using ponds
Ground water Drinking & Bathing Nearby Residents with Private wells 0>
0)
Only two private wells were noted to currently exist within a one mile radius of the Site. The
City of Cedartown prohibits development of new wells within the City limits.
The exposure point concentrations for each of the chemicals of concern and the
exposure assumptions for each pathway were used to estimate the chronic daily
intakes for the potentially complete pathways. The chronic daily intakes were then
used in conjunction with cancer potency factors and non-carcinogenic reference doses
to evaluate risk.
The 95th percentile for reported concentrations of chemicals of concern in each-media
evaluated were calculated as the exposure point concentrations for the reasonable
maximum exposure (RME) in each of the exposure scenarios. Exposures point
concentrations are summarized in Section 6.1.1, Table 6-1.
Potential future exposure scenarios included all the exposures examined under
current conditions. Exposure assumptions were considered the same in evaluating
future conditions as were used in evaluating current conditions.
The future residential ingestion of ground water exposure scenario assumed a 30 year
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duration (5 years as a child). The assumed ingestion rates for an adult and a child
were 2 liters and 1 liter, respectively. Body weights were 70 kg for adults and 15 kg
for a child.
6.1.3 TOXICITY ASSESSMENT
A cancer slope factor (CSF) and a reference dose (RfD) are applied to estimate the
potential risk of cancer from an exposure and the potential for non-carcinogenic
effects to occur from the exposure.
CSFs have been developed by EPA's Carcinogenic Assessment Group for estimating
excess lifetime cancer risks associated with exposure to potentially carcinogenic
contaminants of concern. CSFs which are expressed in units of (mg/kg/day)"1, are
multiplied by the estimated intake of a potential carcinogen in mg/kg/day, to
provide an upper-bound estimate of the excess lifetime cancer risk associated with
exposure at that intake level. The term "upper-bound" reflects the conservative
estimate of risks calculated from the CSF. Use of this approach makes
underestimation of the actual cancer risk highly unlikely. CSF are derived from the
results of human epidemiological studies or chronic animal bioassays to which
animal-to-human extrapolation and uncertainty factors have been applied.
This increased cancer risk is expressed by terms such as 1E-6. To state that a
chemical exposure causes a 1E-6 added upper limit risk of cancer means that if
1,000,000 people are exposed, one additional incident of cancer is expected to occur.
The calculations and assumptions yield an upper limit estimate which assures that no
more than one case is expected and, in fact, there may be no additional cases of
cancer. USEPA policy has established that an upper limit cancer risk falling below or
within the range of 1E-6 to 1E-4 is acceptable.
RfDs have been developed by EPA for indicating the potential for adverse health
effects from exposure to COCs exhibiting noncarcinogenic effects. RfDs which are
expressed in units of mg/kg/day, are estimates of lifetime daily exposure levels for
humans, including sensitive individuals, that are likely to be without risk of an
adverse affect. Estimated intakes of COCs from environmental media (e.g. amount of
COCs ingested from contaminated ground water) can be compared to the RfD. RfDs
are derived from the results of human epidemiological studies or chronic animal
bioassays to which animal-to-human extrapolation and uncertainty factors have been
applied (e.g. to account for the use of animal data to predict effects on humans). If
the estimated exposure to a chemical expressed as mg/kg/day is less than the RfD,
the exposure is not expected to cause any non-carcinogenic effects, even if the
exposure is continued for a lifetime. In other words, if the estimated dose divided by
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the RfD is less than 1.0, there is no concern for adverse non-carcinogenic effects.
Exposure Point Concentrations, and Toxicity Potency Factors used to calculate
Human Health Risks are summarized in Table 6-2.
TABLE 6-2 CONTAMINANTS OF CONCERN TOXICITY ASSESSMENT
Media and Chemical
Toxicity
CSF2
l/(mg/kg/day)
RfD l
mg/kg/day
GROUND WATER
Dichloroethane, 1,2-
Arsenic
Barium
Beryllium
Cadmium
Manganese
Nickel
Vanadium
Zinc
.091
1.75
N/A
4.3
N/A
N/A
N/A
N/A
N/A
N/A
.0003
.07
.005
.001
.005
.02
.3
.02
1 Reference doses (RfDs) have been developed by EPA for indicating the potential for adverse
health effects from exposure to chemicals exhibiting non-carcinogenic effects. Adapted from
USEPA IRIS, July 92 and USEPA Health Effects Summary Table, OERR 9200.6-303 (1992).
Cancer potency factors (CPFs) have been developed for estimating excess lifetime cancer
risks associated with exposure to potentially carcinogenic chemicals. Adapted from USEPA
IRIS, July 92 and USEPA Health Effects Summary Table, OERR 9200.6-303 (1992). unless
otherwise noted.
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6.1.4 RISK CHARACTERIZATION
For carcinogens, risks are estimated as the incremental probability of an individual
developing cancer over a life-time as a result of exposure to the carcinogen. Excess
life-time cancer risk is calculated from the following equation:
RISK = CDI X CSF
where:
risk = a unit less probability (e.g., 2 X 10~5) of an individual developing cancer;
CDI = chronic daily intake averaged over 70 years (mg/kg-day); and,
CSF = slope-factor, expressed as (mg/kg-day)"1
These risks are probabilities that are generally expressed in scientific notation (e.g.,
1X10"6 or IE"*). An excess lifetime cancer risk of 1 X 10* indicates that, as a
reasonable maximum estimate, an individual has a 1 in 1,000,000 chance of
developing cancer as a result of site-related exposure to a carcinogen over a 70-year
lifetime under the specific exposure conditions at the Site.
The potential for noncarcinogenic effects is evaluated by comparing an exposure level
over a specified time period (e.g., lifetime) with a reference dose derived for a similar
exposure period. The ratio of exposure to toxicity is called a hazard quotient (HQ).
By adding the HQ's for all COCs that affects the same target organ within a medium
or across all media to which a given population may reasonably be exposed, the
Hazard Index (HI) can be generated.
The HQ is calculated as follows:
Non-cancer HQ = CDI/RfD
where:
CDI = Chronic Daily intake
RfD = Reference Dose; and,
CDI and RfD are expressed in the same units and represent the same exposure
period (i.g., chronic, subchronic, or short-term).
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To evaluate the estimated cancer risks, a risk level lower than 1x10"* is considered a
minimal or de minimis risk. The risk range of 1x10"* to 1x10"* is an acceptable risk
range and would not be expected to require a response action. A risk level greater
than 1x10"4 would be evaluated further, and a remedial action to decrease the
estimated risk considered.
A hazard index (HI) of less than unity (1.0) indicates that the exposures are not
expected to cause adverse health effects. An HI greater than one (1.0) requires
further evaluation. For example, although the hazard quotients of the several
chemicals present are added and exceed 1.0, further evaluation may show that their
toxicities are not additive because each chemical affects different target organs. When
total affects are evaluated on an effect and target organic basis, the hazard index of
the separate chemicals may be at acceptable levels.
Carcinogenic risks and non-carcinogenic hazards were evaluated for potential
exposures to media-specific chemicals of concern in surface soil, surface water,
surface sediment and ground water. Receptor populations were potentially exposed
workers, trespassers and area residents that could, theoretically, use ground water for
a household water source.
Estimated potential exposure to chemicals of concern in surface water, surface soil
and surface sediments did not result in unacceptable carcinogenic risk or
non-carcinogenic hazard.
Estimated potential added cancer risks and non-carcinogenic hazards from the use of
contaminated ground water for household use are in an unacceptable range. The
estimated cancer risk exceedances are related to arsenic and beryllium concentrations
reported. The arsenic concentration is well below the MCL. The maximum
beryllium concentration in downgradient wells is below the maximum background
concentrations reported, and elevated levels of certain metals may be related to the
presence of sediment in the ground water samples. Background and COC's
concentrations will be confirmed during future ground water monitoring.
Similarly, exceedances of a hazard index of 1.0 may be related to high concentrations
of metals resulting from turbidity in ground water samples.
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TABLE 6-3: SUMMARY OF UNACCEPTABLE RISK - GROUND WATER
INGESTION a
Chemical
Dichloroethane, 1,2-
Arsenic
Barium
Beryllium
Cadmium
Manganese
Nickel
Vanadium
Zinc
TOTAL
Lifetime Excess Cancer Risk
4.0 X KT06
2.6 X lO"04
N/A
1.5 X KT03
N/A
N/A
N/A
N/A
N/A
2.0 X 10-03
Hazard Quotient
NV
2.2
0.5
0.3
0.5
36.6
1.2
0.8
0.2
42.3
£&fl£g&tr£iio&$
6.1.5
IDENTIFICATION OF UNCERTAINTIES
The following areas of uncertainty were associated with the estimation of chemical
uptake from exposure to ground water:
1. Exposure scenarios based on USEPA Guidance utilize conservative
assumptions which means the actual risk will not be greater than the estimate
and may be lower. For this reason, the estimated cancer risks based on
USEPA Guidance such as are presented in this document may not represent
actual risks to the population. The function of these risk estimates is to assist
in evaluating: which chemicals may be responsible for the major risk, if any,
associated with the Site; which media and exposures present the greatest
potential problems; what remediation, if any, is needed; and how effective any
selected remediation will be in decreasing the estimated risk.
2. Exposures related to drinking and bathing are theoretical because ground
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Cedartown Municipal Landfill Site
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water in the area is not presently used for drinking water or for other
household water needs, and it is unlawful at this time for residents to bore a
new well within the city limits.
3. Because of the limitations of a data set, the 95th percentile may exceed the
maximum concentration reported in some evaluations. This may occur when
there are a large number of non-detects and the detection limits are unusually
high due to interferences in the analyses (e.g., BNAs in surface soil). In these
cases, consistent with USEPA Region IV guidance, the maximum reported
values were used as exposure point concentrations to estimate human
exposures. Although the use of maximum values is generally recognized as an
appropriate screening approach, it should be recognized that this procedure
may over estimate the actual exposure.
4. This is also the case for the use of detection limits as the non-detect values
when a chemical has been reported as not detected in the majority of the
samples collected and analyzed. Since some of the non-detects may be zero,
assuming that a concentration equal to half the detection limit is present
instead of zero may over-estimate the actual chemical concentrations at the
Site. This is particularly true if interfering chemicals affect the analyses and
the non-detect value is elevated.
5. Environmental sampling and analysis can contain significant errors and
artifacts. At this Site, the data are believed to adequately and accurately
represent the existing conditions.
6. When the long-term health effects are evaluated, it is assumed that the
chemical concentrations are constant for the exposure period being evaluated.
This may not be accurate since the reported chemical concentrations are
changing due to various degradation processes (i.e. dilution by
uncontaminated water, sorption, dispersion of contaminated ground water,
volatilization, biodegradation, chemical degradation and photo degradation).
The use of steady state conditions will likely over-estimate the exposure.
7. The exposures to vapors and dust at the Site, dermal contact with ground
water from household uses other than bathing (i.e. laundry, washing dishes),
and other possible exposures to surface soil and surface water were not
evaluated. Although these and other potential exposures could occur, the
magnitudes of these exposures are expected to be much lower than the
exposures evaluated, and would not quantitatively affect the total health
impact from the Site.
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Cedartown Municipal Landfill Site
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8. Since ground water in the surrounding area is not presently used for
drinking water or for other household water needs, the exposures related to
drinking and bathing are theoretical and relate to potential future exposures
should a new house or an existing house develop a well for a household
potable water supply. This is unlikely since public water is available in the
area and would be the preferred source for residential water. The City of
Cedartown has in effect an ordinance (City Code Section 11-117) which makes
it unlawful to bore any well in the City limits. This ordinance applies to both
individuals and corporations.
The following are uncertainties associated with estimation of risks:
1. In the hazard and risk evaluations, the risks or hazards presented by
several chemicals reported for the same exposure have been added to provide
a sum of estimated total risk or hazard for that particular exposure. This is a
conservative assumption and is scientifically accurate only in those instances
where the health effects of individual chemicals are directed at the same effect
and same target organ. The effects may be additive, synergistic or
antagonistic. Since a large number of chemicals have no similarity as to their
non-carcinogenic action or the target of their action, this approach may
over-estimate risk.
2. Risks calculated from slope factors are derived using a linearized multistage
procedure; therefore, are likely to be conservative upper bound estimates. The
actual risks may be much lower.
3. There is a degree of uncertainty regarding the RfD for manganese in the
ground water ingestion scenario. There is currently a debate whether it is
appropriate to separate the exposures from food and water as currently done
by IRIS for some chemicals, and whether it is appropriate to separate the
exposure from food and water as presently done for manganese (and some
other inorganics) by IRIS. Due to the high degree of uncertainty associated
with the present RfD of 0.005 mg/kg/day for manganese, the RfD
determination is scheduled for EPA review. The current EPA RfD for
manganese in water of 0.005 mg/kg/day was used to evaluate risks
concerning manganese drinking water intake.
6.2 ECOLOGICAL EVALUATION
An assessment of the nature of the Cedartown Municipal Landfill Site supports a
conclusion that an in-depth ecological and environmental evaluation is not warranted.
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Cedartown Municipal Landfill Site
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6.2.1 TERRESTRIAL
The Site was dosed in 1979 and has been covered with dean soil of 1 to 10 feet in
depth and graded to match its original high mounded terrain. When grading was
completed, each area was vegetated with grasses, various herbaceous growth, trees,
and shrubs. The result is a sloping terrain which is covered by some open grassy
areas, some areas of brushy volunteer tree and shrub growth and some areas of
reforestation (pine trees). Some areas are minimally vegetated, possibly due to the
day nature of the cover. The ultimate result appears to be a reasonably well
balanced wildlife habitat providing food and cover which is suitable for a wide
variety of terrestrial wildlife.
The Georgia Fish and Wildlife Service provided the following list of federally
endangered spedes which may inhabit the area:
Picoides borealis Red-Cockaded Woodpecker
Haliaeetus leucocephalus Bald Eagle
Felis concolor cougar Eastern Cougar
Myotis grisescens Gray Bat
The Georgia Department of Natural Resources indicated the red-cockaded
woodpecker would not locate near the Site because pine trees are relatively young,
and this bird inhabits old growth pines. The bald eagle and eastern cougar would
not be found in this area due to urbanization/industrialization. The nearest cave
which hosts the gray bat is over 30 miles from the Site. Since the typical range of the
gray bat is a few miles, it is unlikely that the Site would impact this spedes.
The U.S. Fish and Wildlife indicated the following protected plants which may be
present in the area:
Yellow Lady's Slipper
False Hellebore
While both species are native to Northwest Georgia, they are only found in
undisturbed, old growth forests. This habitat does not exist on or near the Site.
Because the surface soil is non-contaminated, there is no risk of chemical exposure
from contaminated soil for animal and bird populations which may inhabit the area.
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Cedartown Municipal Landfill Site
Page 41
6.2.2 AQUATIC
Surface Waters
There are several areas of surface water near the Site. A comparison of chemical
concentrations reported in all the surface water bodies with criteria to protect aquatic
organisms was accomplished. A comparison of the maximum surface water
concentrations with the Federal Ambient Water Quality Criteria (AWQC) and the
Georgia Surface Water Quality Standards indicates exceedances were found in the
East Seep Pond, which likely reflects leachate seepage from the landfill.
Metals found in the East Seep Pond were above the maximum (acute) surface water
concentrations criteria and standards for aluminum and chromium (based upon Cr
VI). Copper and zinc exceed both the acute and chronic AWQC and iron and lead
exceed the chronic AWQC. These values are referenced in the RI and FS (Table 1.7).
The East Seep Pond is a small depression which collects water during precipitation.
Because of limited area, water depth and a susceptibility to dryness during the
summer months, the East Seep Pond does not provide a suitable habitat for aquatic
biota. Therefore, exposure of aquatic biota to contaminants in this pond would not
be a concern.
Inorganic surface water concentrations in the downgradient Coke Pond do not exceed
the AWQC, thus indicating that Site-related inorganic contaminants are not currently
impacting the surface water in Coke Pond at levels that might cause adverse effects
on aquatic biota living in the pond. However, given the levels of contaminants of
ecological concern in the East Seep Pond, the future potential migration of surface
water contaminants (runoff) from the East Seep Pond into the Coke Pond, down
gradient of the East Seep Pond, is a concern.
Sediments
A comparison of chemical concentrations in sediments of the Cotton Pond, East Seep
Pond and Coke Pond to USEPA Region IV Screening Values adopted from the
National Oceanic and Atmospheric Administration (NOAA) was accomplished in the
RI.
NOAA developed these screening values through evaluation of biological effect data
for aquatic (marine and freshwater) organisms, obtained through equilibrium
partitioning calculations, spiked-sediment bioassays, and concurrent biological and
chemical field surveys. For each constituent having sufficient data available, the
concentrations causing adverse biological effects were arrayed, and the lower 10
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Record of Decision
Cedartown Municipal Landfill Site
Page 42
percentile (called an Effects Range-Low, or ER-L) and the median (called an Effects
Range-Median, or ER-M) were determined.
If sediment contaminant concentrations are above the ER-M, adverse effects on the
biota are considered probable. If contaminant concentrations are between the ER-L
and the ER-M, adverse effects are considered possible. If contaminant concentrations
are below the ER-L, adverse effects are considered unlikely.
There are no available sediment screening values for the VOCs and BNAS. For the
inorganics with available sediment screening values, corresponding maximum
reported values are below the ER-L values, with the exception of lead, nickel and
zinc. The maximum lead concentration reported in the Cotton Pond exceeded the
ER.-L value, but it did not exceed the ER-M value. In addition, the background lead
concentration exceeded the ER-L value. The maximum reported concentration of
nickel exceeded the ER-M value only in the Dry Pond, while the maximum zinc
concentration exceeded the ER-M value only in the Coke Pond. It should also be
noted that even background sediment concentrations of lead and nickel exceed the
ER-L values, while background zinc concentrations in sediments are similar to the
ER-L value. Therefore, this indicates limited potential for effects on the bottom
dwelling aquatic biota in these ponds.
An ecological and environmental evaluation of the Site leads to a conclusion that the
Site currently provides a habitat for a variety of wildlife and that chemical exposures
on the Site do not represent a threat to wildlife which may inhabit the area. The
Coke Pond currently does not appear to contain surface water and sediment
contaminants at levels that would adversely affect aquatic biota living in this habitat.
However, it is possible that contaminants form the East Seep/Pond may potentially
migrate into Coke Pond in the future.
6.3 CONTAMINANTS OF CONCERN & PERFORMANCE STANDARDS
Estimated potential exposure to site chemicals in surface water, surface soil, and
surface sediments do not result in unacceptable cancer or non cancer risks at the
Cedartown Landfill Site. However, the estimated potential cancer and non-cancer
risks from future exposure to ground water exceed EPA's cleanup target risk range
and an HQ of 1. Therefore, EPA established performance standards for chemicals in
ground water at levels above EPA's target risk range or Safe Drinking Water Act
MCL to ensure that any future ground water users would not be exposed to unsafe
levels of site-related contaminants. Performance standards for the remediation of
ground water are shown in Table 6-4.
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Cedartown Municipal Landfill Site
Page 43
In the area of the Site, background concentrations (in ground water not contaminated
by the site) of some chemicals may actually be higher than MCLs. Since remediation
below background levels is not technically feasible, additional sampling will be
conducted to confirm if data is indicative of background conditions.
Actual and threatened releases of hazardous substances from this Site, if not
addressed by implementing the response action selected in this ROD, may present an
imminent and substantial endangerment to public health, welfare, or the
environment.
TABLE 6-4
SUMMARY OF REMEDY PERFORMANCE STANDARDS (GROUND WATER)
f*f}f|tS.flitnmit
Manganese
Beryllium
Cadmium
Chromium
Lead0
a - Calculated value b
Hazard Quotient (1
are a 2 liter per da
body weight.
b - Safe Drinking Wat<
Level (MCL).
c - Included due to co
frequency of detec
Concentrations Detected (ug/1)
Mean
1,714
11.9
4.8
43
20
Max
8.8OO
60
24
230
100
ased on an acceptable risk or a
y ingestion rate ai
er Act Maximum C
ntaminant concei
tion.
ad a 7O kilogram
'ontaminant
itration* and
Background (ug/1)
1,487
17
4
48
83
Performance Standard
(ug/1)
175 a
*b
5b
100 b
15 e
d - While chromium was below detection during
third sampling round, it was detected above
standards in previous rounds. Therefore, it was
retained for determining performance
standards.
e - EPA Action Level from Lead and Copper Rule,
56 FR. June 7, 1991.
7.0
DESCRIPTION OF ALTERNATIVES
The Feasibility Study Report evaluated possible alternatives for remediation of
conditions at the Cedartown Municipal Landfill Site. A total of three (3) alternatives
have been established for detailed analysis consideration. These alternatives were
selected to provide a range of remedial actions for the Site. The table below
summarizes the alternatives and estimated cost of each alternative.
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Cedartown Municipal Landfill Site
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1.
2.
3.
No Action
Institutional Controls, Cover Maintenance, Seep Control, and
Ground water Monitoring
Ground Water Extraction and Treatment
$0
$ 625,000
$ 5,225,000 - 8,631,000
7.1 ALTERNATIVE 1: NO ACTION
EPA is required to consider the no action alternative by the National Oil and
Hazardous Substances Pollution Contingency Plan (NCP), the regulation
implementing the Superfund law. It is used as a baseline for comparing other
alternatives. Under mis alternative, EPA would take no action to minimize the
impact ground water contamination has on the area. There is no cost associated with
this alternative since no additional activities would be conducted.
7.2 ALTERNATIVE 2: INSTITUTIONAL CONTROLS. COVER
MAINTENANCE. SEEP CONTROL, AND GROUND WATER
MONITORING
This alternative would include:
Cover maintenance and seep controls;
institutional controls, such as record notices and deed, zoning and land-
use restrictions;
ground/surface water monitoring program to insure natural attenuation
processes would be effective and that contaminants would not migrate;
a two year review during which EPA would determine whether ground
water performance standards continue to be appropriate and if natural
attenuation processes are effective. EPA would consider requiring the
implementation of a contingency ground water remedial action as
discussed in Alternative 3, if ground water performance standards
continue to be appropriate and natural attenuation processes are not
effective; and,
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Cedartown Municipal Landfill Site
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continued ground water monitoring upon attainment of the performance
standards at sampling intervals to be approved by EPA. The ground
water monitoring program would continue until EPA approves a five-
year review concluding that the alternative has achieved continued
attainment of the performance standards and remains protective of
human health and the environment.
The ground water monitoring program would require further sampling and analysis
to further define background ground water concentrations of inorganic contaminants
and would, at EPA's discretion, require the installation of additional wells. If, based
on that information, the background concentration for an inorganic exceeds the MCL
or acceptable risk based standards, EPA, at its sole discretion, would consider
amending the performance standards through an ESD or ROD Amendment. Ground
water samples would be collected on a quarterly basis for two years upon
implementation of the ground water monitoring program. Proper well construction
and development techniques along with a low flow sampling method would be used
during the monitoring. EPA, at its sole discretion, may approve revising the
sampling intervals of the ground water monitoring program.
Surface water sampling of the Coke Pond would be collected at sampling intervals to
be approved by EPA and at the Five-Year review to ensure contaminants do not
migrate from the East Seep. EPA would evaluate and at EPA's sole discretion
discontinue sampling based on the results of the five year review.
The present worth cost of this alternative is estimated at $459,000 (semi-annual
sampling) to $723,000 (quarterly sampling) consisting of 30 years of Operation and
Maintenance (O&M) costs. An estimate of $625,000 was used for cost comparison
purposes based on quarterly sampling for 5 years and semi-amual for the remaining
25 years.
7.3 ALTERNATIVE 3: GROUND WATER TREATMENT
This alternative would include:
Cover maintenance and seep controls;
institutional controls, such as record notices and deed, zoning and land-
use restrictions;
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Cedartown Municipal Landfill Site
Page 46
a ground/surface water monitoring program to insure the ground water
treatment system would be effective and that contaminants would not
migrate;
active remediation of ground water. Ground water would be extracted,
treated and discharged until all performance standards are met for two
consecutive sampling events; and,
continued ground water monitoring upon attainment of the performance
standards at sampling intervals to be approved by EPA. The ground
water monitoring program would continue until EPA approves a five-
year review concluding that the alternative has achieved continued
attainment of the performance standards and remains protective of
human health and the environment.
Contaminated ground water would be extracted, treated and discharged through a
National Pollutant Discharge Elimination System (NPDES). If NPDES is not viable,
other discharge alternatives such as discharge to the local wastewater treatment plant
would be considered. On-site treatment would likely be required. The treated water
would meet permit requirements for discharge to a nearby surface water body.
During pump and treat operations, the withdrawn ground water would be stored in
an equalization tank from which it would be pumped to a treatment system. The
equalization tank would provide storage during times when a downstream treatment
system might be shut down.
During the remedial design for this project, bench scale treatability studies would be
conducted to determine the effectiveness of chemical, ion exchange, and physical
treatment or a combination there of. The treatment determined to be the most
effective would be used. Other treatment technologies for ground water might be
found to be effective and could be implemented if the time frame for cleanup would
be retained. Final methods would be determined during design of the cleanup
remedy. Any spent materials would be disposed of at a regulated facility. The
number of extraction wells and pumping rates would be determined during the
design.
Additionally, during the design, this remedy would require additional ground water
sampling and analysis to verify background ground water concentrations of inorganic
contaminants.
If EPA were to determine that ground water performance standards continue to be
appropriate, the implementation of the ground water treatment remedy would be
required.
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Cedartown Municipal Landfill Site
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The present worth cost of this alternative is estimated at a range from $5,225,000 with
a capital cost of $1,394,500 and $3,830,500 for 30 years O&M for a 50 gallon per
minute (gpm) to $8,631,000 with a capital cost of $1,539,000 and $7,092,000 for 30
years O&M for the 100 (gpm) treatment system.
7.4 APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
(ARARs)
The remedial action for the Cedartown Municipal Landfill Site, under CERCLA
Section 121 (d), must comply with federal and state environmental laws that are either
applicable or relevant and appropriate (ARARs). Applicable requirements are those
standards, 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 CERCLA Site. Relevant and appropriate
requirements are those that, while not applicable, still address problems or situations
sufficiently similar to those encountered at the Site that their use is well suited to the
particular Site. To-Be-Considered Criteria (TBCs) are non-promulgated advisories
and guidance that are not legally binding, but should be considered in determining
the necessary level of cleanup for protection of health or the environment.
The affected ground water in the aquifer beneath the Cedartown Municipal Landfill
Site has been classified by EPA as Class HA. Class IIA ground water is a source of
drinking water. It is EPA's policy that ground water resources be protected and
restored to their beneficial uses. A complete definition for ground water classification
is provided in the Guidelines for Ground water Classification under the EPA Ground
water Protection Strategy. Final Draft, December 1986.
While TBCs do not have the status of ARARS, EPA's approach to determining if a
remedial action is protective of human health and the environment involves
consideration of TBCs along with ARARs.
Location-specific ARARs are restrictions placed on the concentration of hazardous
substances or the conduct of activities solely on the basis of location. Examples of
location-specific ARARs include state and federal requirements to protect floodplains,
critical habitats, and wetlands, and solid and hazardous waste facility siting criteria.
Table 7-1 summarizes the potential location-specific ARARs for the Cedartown
Municipal Landfill Site.
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Cedarto-wirMuniripal Landfill Site
Page 48
TABLE 7-1
POTENTIAL LOCATION SPECIFIC ARARs
Location
Citation
R&A
Critical habitat upon
which endangered
or threatened
species depends
Endangered Species Act of 1973
50 CFR Parts 200 and 402
Fish and Wildlife Coordination Act
33 CFR Parts 320-330
R&A
Area affecting
stream or river
Wild and Scenic River Act
40 CFR Part 6.302(e)
R&A
Within area affecting
wild, scenic or
recreational river
Wild and Scenic River Act
40 CFR Part 6.302(e)
STATE OF GEORGIA REGULATIONS
R&A
Establishes facility
location standards
Georgia Comprehensive Solid Waste Management
Act, O.C.G.A. § 12-8-20 et sea, and Rules, Chapter
391-3^.
R&A
Critical habitat upon
which endangered
or threatened
species depends
Endangered Wildlife and Wildflower Preservation Act
of 1973 O.C.G.A. § 12-6-172 et sea, and Rules,
Chapter 391-4-10.
R&A
APPLICABLE REQUIREMENTS WHICH WERE PROMULGATED UNDER FEDERAL LAW
TO SPECIFICALLY ADDRESS A HAZARDOUS SUBSTANCE, POLLUTANT,
CONTAMINANT, REMEDIAL ACTION LOCATION OR OTHER CIRCUMSTANCE AT THE
CEDARTOWN MUNICIPAL LANDFILL SITE.
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
MUNICIPAL LANDFILL SITE, ADDRESS PROBLEMS OR SITUATIONS SUFFICIENTLY
SIMILAR TO THOSE ENCOUNTERED AT THIS SITE THAT THEIR USE IS WELL SUITED.
Action-specific ARARs are technology- or activity-based requirements or limitations
on actions taken with respect to hazardous wastes. These requirements are triggered
by the particular remedial activities that are selected to accomplish a remedy. Since
there are usually several alternative actions for any remedial Site, various
requirements can be ARARs. Table 7-2 lists potential action-specific ARARs and
TBCs for the selected and contingency ground water remedy for the Cedartown
Municipal Landfill Site.
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Cedartown Municipal Landfill Site
Page 49
TABLE 7-2
POTENTIAL ACTION-SPECIFIC ARARs FOR THE SELECTED REMEDY AND
CONTINGENT REMEDIAL ACTION
CLEAN WATER ACT - 33 U. S. C. §§ 1251-1376
R&A
40 CFR Part 131 - Ambient
Water Quality Criteria
Ambient Water Quality Criteria: Ambient
water standards for the protection of
human health and aquatic life.
R&A
40 CFR Part 122, 125 -
National Pollutant Discharge
Elimination System, 40 CFR
Part 125, 40 CFR Part 131,
and 40 CFR Part 136.1
Requires permits for the discharge of
pollutants for any point source into waters
of the United States.
R&A
40 CFR Part 144 -
Underground Injection
Program
Requirements limiting injection of fluids
containing chemical concentrations
exceeding NPDES into underground
sources of drinking water.
R&A
40 CFR Part 141 - National
Primary Drinking Water
Standards
Specifies sampling, analytical and
monitoring requirements for public water
systems.
R&A
40 CFR Part 403 - National
Pretreatment Standards
Sets standards to control pollutants which
pass through, interfere, or contaminate
treatment processes in public treatment
works.
RESOURCE CONSERVATION AND RECOVERY ACT - 42 U.S.C. §§ 6901-6987
R&A
40 CFR 257 - 258 - Solid
Waste Management
Regulations
Establishes minimum levels of
performance required of any solid waste
land disposal Site operation and including
operation and maintenance.
R&A
40 CFR Part 261 -
Identification & Listing of
Hazardous Wastes
Characterizations of Treatment Facility
Generated Sludges.
R&A
40 CFR Part 262 -
Standards Applicable to
Generators of Hazardous
Waste
General requirements for identifying and
managing hazardous wastes and manifest
requirements for hazardous wastes
R&A
40 CFR Part 263 -
Standards Applicable to
Transporters of Hazardous
Waste
Establishes standards which apply to
transporting hazardous waste within the
U.S., if required under 40 CFR 262.
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Cedartown Municipal Landfill Site
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TABLE 7-2
POTENTIAL ACTION-SPECIFIC ARARs FOR THE SELECTED REMEDY AND
CONTINGENT REMEDIAL ACTION
R&A
40 CFR Part 264 -
Standards for Owners and
Operators of Hazardous
Waste Treatment, Storage
and Disposal (TSD)
Facilities
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.
CLEAN AIR ACT - 42 U.S.C. §§ 7401-7642
R&A
40 CFR Part 61 - National
Emission Standards for
Hazardous Air Pollutants
Addresses hazardous air pollutants at
their point of emission from specific
sources
STATE OF GEORGIA REGULATIONS
Georgia Hazardous Site
Response Act § O.C.G.A.
12-8-90 et sea.
Requires corrective action for releases of
hazardous waste, constituents, and
substances.
R&A
Georgia Comprehensive
Solid Waste Management
Act § O.C.G.A. 12-8-20 et
seq. and Rules, Chapter
391-3-4.
Establishes minimum levels of
performance required of any solid waste
land disposal Site operation and includes
operation and maintenance.
R&A
Georgia Hazardous Waste
Management Act O.C.G.A. §
12-8-60 et sea, and Rules,
Chapter 391-3-11.
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 wastes in the State
of Georgia.
R&A
Georgia Water Quality
Control Act O.C.G.A. § 12-
5-20 and Rules, Chapter
391-3-6.
Pre-treatment standards and permit
requirements for Publicly Owned
Treatment Works, criteria and standards
for injection wells, and authorizes DNR to
issue discharge permits.
R & A -
APPLICABLE REQUIREMENTS WHICH WERE PROMULGATED UNDER FEDERAL
LAW TO SPECIFICALLY ADDRESS A HAZARDOUS SUBSTANCE, POLLUTANT,
CONTAMINANT, REMEDIAL ACTION LOCATION OR OTHER CIRCUMSTANCE AT
THE CEDARTOWN MUNICIPAL LANDFILL SITE.
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
MUNICIPAL LANDFILL SITE, ADDRESS PROBLEMS OR SITUATIONS SUFFICIENTLY
SIMILAR TO THOSE ENCOUNTERED AT THE CEDARTOWN Municipal Landfill SITE
THAT THEIR USE IS WELL SUITED TO THE SITE.
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Chemical-specific ARARs are specific numerical quantity restrictions on individually-
listed chemicals in specific media. Examples of chemical-specific ARARs include the
MCLs specified under the Safe Drinking Water Act as well as the ambient water
quality criteria that are enumerated under the Clean Water Act. Since there are
usually numerous chemicals of concern for any remedial Site, various numerical
quantity requirements can be ARARs. Table 7-3 lists potential chemical-specific
ARARs for the Cedartown Municipal Landfill Site.
TABLE 7-3
POTENTIAL CHEMICAL-SPECIFIC ARARS
CLEAN WATER ACT - 33 U.S.C. §§ 1251-1376
A
R&A
40 CFR Part 131 - Ambient
Water Quality Criteria
40 CFR Part 403 - National
Pretreatment Standards
Suggested ambient standards for the
protection of human health and
aquatic life.
Sets standards to control pollutants
which pass through or interfere with
treatment processes in publicly-
owned treatment works or which may
contaminate sewage sludge.
RESOURCE CONSERVATION AND RECOVERY ACT - 42 U.S.C. §§ 6901-6987
R&A
R&A
40 CFR Part 261 - Identification
and Listing of Hazardous
Wastes
40 CFR Part 262 - Standards
Applicable to Generators of
Hazardous Waste
Defines those solid wastes which are
subject to regulation as hazardous
wastes under 40 CFR Parts 263-265
and Parts 124, 270, and 271.
Establishes standards for generators
of hazardous waste.
CLEAN AIR ACT - 42 U.S.C. §§ 7401-7642
R&A
40 CFR Part 50 - National
Primary and Secondary
Ambient Air Quality Standards
Establishes standards for ambient air
quality to protect public health and
welfare.
SAFE DRINKING WATER ACT - 40 U.S.C. §§ 300
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Cedartowrf Municipal Landfill Site
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TABLE 7-3
POTENTIAL CHEMICAL-SPECIFIC ARARS
R&A
40 CFR Part 141 - National
Primary Drinking Water
Standards
Establishes maximum contaminant
levels (MCLs) which are health-
based standards for public water
systems.
PL No. 99-339 100 Stat. 462
(1986) - Maximum Contaminant
Level Goals (MCLGs)
Establishes drinking water quality
goals set at levels of no known or
anticipated adverse hearth effects
with an adequate margin of safety.
STATE OF GEORGIA REGULATIONS
R&A
Air Quality Act of 1978 O.C.G.A.
§ 12-9-1 et sea, and Rules,
Chapter 391-3-1.
Establishes standards for ambient air
quality to protect public health and
welfare.
R&A
Safe Drinking Water Act
O.C.G.A. § 12-5-170 et sea.
and Rules, Chapter 391-3-5.
Establishes maximum contaminant
levels (MCLs) which are health-
based standards for public water
systems.
R&A
Georgia Water Quality Control
Act O.C.G.A. § 12-5-20 et sea.
and Rules, Chapter 391-3-6.
Establishes treatment standards for
public water systems.
R&A
APPLICABLE REQUIREMENTS WHICH WERE PROMULGATED UNDER FEDERAL
LAW TO SPECIFICALLY ADDRESS A HAZARDOUS SUBSTANCE, POLLUTANT,
CONTAMINANT, REMEDIAL ACTION LOCATION OR OTHER CIRCUMSTANCE AT
THE CEDARTOWN MUNICIPAL LANDFILL SITE.
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
MUNICIPAL LANDFILL SITE, ADDRESS PROBLEMS OR SITUATIONS SUFFICIENTLY
SIMILAR TO THOSE ENCOUNTERED AT THE CEDARTOWN Municipal Landfill SITE
THAT THEIR USE IS WELL SUITED TO THE SITE.
8.0
SUMMARY OF THE COMPARATIVE ANALYSIS OF ALTERNATIVES
This section of the ROD provides the basis for determining which alternative
provides the best balance with respect to the statutory balancing criteria in Section
121 of CERCLA, 42 U.S.C. Section 9621, and in the NCP, 40 CFR, Section 300.430.
The major objective of the FS was to develop, screen, and evaluate alternatives for the
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remediation of the Cedartown Municipal Landfill Site. A wide variety of alternatives
and technologies were identified as candidates to remediate the contamination at the
Cedartown Municipal Landfill Site. These were screened based on their feasibility
with respect to the contaminants present and Site characteristics. After the initial
screening, the remaining alternatives/technologies were combined into potential
remedial alternatives and evaluated in detail. The remedial alternative was selected
from the screening process 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 implementation;
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; and,
acceptance by the Community.
The NCP categorizes the nine criteria into three groups:
(1) Threshold Criteria - overall protection of human health and the environment
and compliance with ARARs (or invoking a waiver) are threshold criteria that
must be satisfied in order for an alternative to be eligible for selection;
(2) Primary 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
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(3) Modifying Criteria - state and community acceptance are modifying criteria
that are formally taken into account after public comments are 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 of alternatives is
primarily based. The final two criteria, known as Modifying Criteria, assess the
public's and the state agency's acceptance of the alternative. Based on these final two
criteria, EPA may modify aspects of a specific alternative.
The following analysis is a summary of the evaluation of alternatives for remediating
the Cedartown Municipal Landfill Superfund Site under each of the criteria. A
comparison is made between each of the alternatives for achievement of a specific
criterion.
8.1 THRESHOLD CRITERIA
8.1.1 OVERALL PROTECTION OF HUMAN HEALTH AND THE
ENVIRONMENT
The No-Action Alternative will not mitigate the risks associated with contamination
at or originating from the Cedartown Municipal Landfill Site. Therefore, this
alternative is not protective of human health and the environment and will no longer
be considered in this discussion.
Alternative 2 would use ground water monitoring and applies natural attenuation
processes to meet ground water performance standards. If natural processes are not
effective, EPA at its sole discretion may implement a contingency ground remedial
action. Alternative 3 would provide for active restoration of the ground water.
Alternative 3 would provide the best and most immediate protection of human health
and the environment.
Alternatives 2 and 3 treat the metals contamination, thereby allowing the ground
water to attain the COCs MCL through natural attenuation or by extraction and
treatment. These alternatives protect human health and the environment through
restoring the Class HA aquifer and preventing any potential migration of the
contaminated plume. Since there is not a current direct exposure route to ground
water, natural attenuation of the ground water contamination is protective. A
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contingency ground water remedial action of extraction and treatment of ground
water, if natural attenuation is determined ineffective, would be most protective.
8.1.2 COMPLIANCE WITH ARARS
Alternatives 2 and 3, will meet all of their respective ARARs.
Ground water ARARs include Maximum Contaminant Levels (MCLs) that establish
chemical-specific limits on certain contaminants in community water systems. Long-
term monitoring is included in Alternatives 2 and 3. Additional statistical analysis of
data will further substantiate the presence/absence of a ground water plume. This
long-term monitoring will provide the data necessary for a statistical determination of
constituent concentrations in groundwater. If, in EPA's sole discretion, it becomes
apparent that MCLs will not be met through attenuation, a contingency pump and
treat remedial action as described in alternative 3 will be considered and at EPA's
sole determination be implemented.
For Alternative 2, remedial action would include further sampling and analysis of
ground water to assure that ground water beneath the Site will meet ARARs through
attenuation in a reasonable time-frame. Surface water on-site currently meets
ARARs.
Alternatives 2 and 3 would be able to meet all Federal and State standards for
contaminants and proposed actions. Alternative 1, no action, would not be able to
meet ARARs.
8.2 PRIMARY BALANCING CRITERIA
8.2.1 LONG-TERM EFFECTIVENESS AND PERMANENCE
Both Alternatives 2 and 3 would provide long-term effectiveness and permanence.
Alternative 2 would use controls, which would be reevaluated two years after
implementation of the monitoring program and again at the five-year review.
Although this alternative would require additional time to meet the performance
standards, it would likely be as effective from a long-term standpoint. Alternative 3
would use treatment technologies to reduce hazards posed by the contaminants in
the ground water at the Landfill Site.
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Alternatives 2 and 3 would require long-term cover maintenance and seep control
and monitoring for at least 5 years after performance standards were met to ensure
continued effectiveness. Five-year reviews would be needed to verify that the
cleanup remained protective for both alternatives.
Alternative 3 would present long-term liabilities associated with disposal of treatment
sludges in a secure landfill or treatment facility.
8.2.2 REDUCTION OF TOXICITY. MOBILITY. OR VOLUME THROUGH
TREATMENT
Alternative 3 would provide for active ground water remediation and treatment.
Alternative 2 would not provide for ground water treatment, but would likely reduce
contaminants over time. Toxicity, volume, and mobility of ground water would be
reduced through active restoration in Alternative 3.
Therefore, Alternative 3 (and Alternative 2 if the contingency ground water remedial
action is implemented) would best satisfy CERCLA's statutory preference for
treatment and use of treatment to reduce toxicity, mobility, and volume of
contaminants.
8.2.3 SHORT-TERM EFFECTIVENESS
Alternative 2 is expected to have the least short-term risk because its implementation
presents no risk to workers, community, and the environment. Its effectiveness
would be achieved over a longer period of time, although it is expected to achieve a
comparable reduction in toxicity. The contingent remedial action with Alternative 2
would ensure that if results were not achieved by attenuation, the effectiveness of
Alternative 3 would be achieved.
Alternative 3 would also be effective in the short-term. Alternative 3 (ground water
treatment) would need additional studies to determine ground water treatment
design specifications. However, Alternative 3 would more quickly remediate ground
water contamination through extraction and treatment. The installation of ground
water wells may impose risks by disturbing the contamination in the soil or ground
water; however, it is not expected to pose unacceptable short-term environmental or
health hazards, which could not be controlled.
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8.2.4 IMPLEMENTABILITY
Alternative 2 would be the simplest to implement and operate. Materials, services,
capabilities, and specialists would be readily available for cover maintenance and
seep control. Periodic maintenance of the cover would provide reliability in the
future. The ground water monitoring program would determine the effectiveness of
attenuation of the contaminated ground water.
Alternative 3 would be the most technically difficult to implement and would require
complex treatability studies and testing to define the design parameters for these
processes. Alternative 3 would also likely require off-site disposal of treatment
sludges at regulated off-site facilities.
8.2.5 COST
Cost details are provided in the FS and are summarized below in Table 8-1.
Alternative 2, institutional controls/monitoring, has the lowest present worth cost
and Alternative 3, ground water treatment, is the highest. Alternatives 3 is
significantly more expensive to construct and operate because of the ground water
extraction and treatment component. The contingent remedial action in Alternative 2
would include the treatment costs associated with Alternative 3, however, it is
expected that the attenuation processes will be effective. Alternative 2 provides for
the best ratio of costs to benefit received through the permanent reduction of risks to
human health and the environment.
8.3 MODIFYING CRITERIA
8.3.1 STATE ACCEPTANCE
The State of Georgia has concurred with the selection of Alternative 2 to remediate
the Cedartown Municipal Landfill Site.
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Alternative
1. No-Action
2. Institutional Controls,
Cover & Seep
Maintenance, and
Ground water Monitoring
3. Ground water Treatment
TABLE 8-1
COMPARISON OF
30 Year
Present-worth Cost
$0
$ 625,000
2 $ 5,225,000 -
3 8,631,000
COSTS
Capital Cost
NONE
$10,000
$ 1,394,350
- 1,539,450
Monitoring and
Maintenance Cost
(30-yr)
$0
$ 615,000
$ 5,225,000 -
7,091,500
1 If the ground water contingency remedy is implemented, the estimated total cost of $4,923,700
as indicated in alternative 3 would apply.
2 Based on a SO gallon per minute (gpm) treatment system
3 Based on a 100 gallon per minute (gpm) treatment system
8.3.2
COMMUNITY ACCEPTANCE
Based on comments expressed at the September 9, 1993, public meeting and receipt of
written comments during the comment period, it appears that the Cedartown
community generally agrees with the selected remedy; however, various comments
received during the meeting and comment period did indicate a preference for
Alternative 1, No-Action. Specific responses to issues raised by the community can
be found in Appendix A, The Responsiveness Summary.
9.0
SUMMARY OF SELECTED REMEDY
Based upon consideration of the requirements of CERCLA, the NCP, the detailed
analysis of alternatives and public and state comments, EPA has selected Alternative
2, institutional controls, ground water monitoring, and a ground water treatment
contingent remedial action for this Site. At the completion of this remedy, the risk
associated with this Site will be protective of human health and the environment.
The selected alternative for the Cedartown Municipal Landfill Site is consistent with
the requirements of Section 121 of CERCLA and the National Contingency Plan. The
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selected alternative will reduce the mobility, toxicity, and volume of contaminated
ground water at the Site. In addition, the selected alternative is protective of human
health and the environment, will attain all Federal and State applicable or relevant
and appropriate requirements, is cost-effective and utilizes permanent solutions to the
maximum extent practicable.
Based on the information available at this time, the selected alternative represents the
best balance among the criteria used to evaluate remedies. Alternative No. 2 is
believed to be protective of human health and the environment, will attain ARARs,
will be cost effective, and will utilize permanent solutions and alternative treatment
technologies or resource recovery technologies to the maximum extent practicable.
A. SOURCE CONTROL
Since the Baseline Risk Assessment indicates no unacceptable risk to exposure to
soils, source control remediation will address restricting exposure to contaminated
wastes and subsurface soils at the Site, prevent potential migration of landfill leachate
to surface waters, and ensure cover integrity to minimize ground water
contamination. Source control shall include landfill cover maintenance, seep controls,
and land use restrictions.
A.I. The major components of source control to be implemented include:
Cover maintenance and seep controls;
Institutional controls implemented as follows to minimize land use:
1) Deed or Record Notices would be placed on the landfill property and
those properties affected by contaminated ground water;
2) Municipal ordinances concerning permitting the installation of wells
would be applied to prevent ground water well installation on the Site
and/or affected properties, and;
3) The Municipalities (City of Cedartown and/or Polk County) would
annex all site properties and implement zoning restrictions that prevent
development that would disturb or adversely change existing Site
conditions of the Site and prevent ground water use of properties
affected by the Site.
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If these mechanisms (well permitting, annexation, and/or zoning mechanisms)
fail to restrict usage, cannot be implemented, and/or ordinances and municipal
regulations are changed and are no longer restrictive, deed restrictions or
restrictive covenants would be implemented.
Coke Pond surface water samples will be collected at sampling intervals to be
approved by EPA to ensure leachate contaminants do not migrate from the
East Seep. EPA will re-evaluate whether the potential migration from Landfill
seep(s) to the Coke Pond still exists during the Five-Year Review. EPA may at
its sole discretion discontinue sampling. Surface water sampling results shall
be compared to the appropriate Federal Ambient Water Quality Criteria or
more stringent Georgia Surface Water Quality Standard for aluminum,
chromium, copper, lead, nickel, and zinc to ensure the contaminants do not
migrate from the East Seep to the Coke Pond.
B. GROUND WATER MONITORING/RESTORATION
Ground water monitoring will be implemented at this Site to assess the movement of
contamination through ground water. If ground water contaminants of concern do
not meet monitoring performance standards, a contingency pump and treat system
described in Alternative #3 shall be considered and at EPA's sole determination be
implemented.
B.I. The major components of ground water monitoring/restoration to be
implemented include:
Long-term monitoring of ground water to consist of the following:
1 Ground water monitoring program to insure that natural
attenuation works and contaminants do not move.
2 Two-year review during which EPA would determine whether
ground water performance standards continue to be appropriate
and would determine the effectiveness of natural attenuation.
3 The ground water monitoring program would require further
sampling and analysis to further define background ground water
concentrations of inorganic contaminants and the effectiveness of
natural attenuation. This remedy could require the installation of
additional well(s). If, based on mat information, the background
concentration for an inorganic exceeded the MCL or acceptable
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risk-based standards, EPA, at its sole discretion, would consider
amending the performance standards through an Explanation of
Significant Differences (ESD) or Record of Decision (ROD)
Amendment. Ground water samples would be collected on a
quarterly basis for two years upon implementation of the
monitoring program. Proper well construction and development
techniques along with a low-flow sampling method would be
used during the monitoring to determine whether inorganic
substances continue to be a problem. EPA, at its sole discretion,
could revise sampling intervals of the ground water monitoring
program.
4 EPA shall consider and at EPA's sole discretion require the
implementation of a contingency ground water treatment
remedial action, as discussed in Alternative 3, if ground water
performance standards listed in Table 9-1 continue to be
appropriate and natural attenuation processes are not effective as
listed below:
COCs concentration levels listed in the table below
substantially increase during two consecutive sampling events;
and/or,
if natural attenuation has failed to demonstrate during the two-
year review that the performance standards listed in Table 9-1 are
likely attainable within 5 years of completion of the two year
review.
5 Continued ground water monitoring upon attainment of the
performance standards at sampling intervals approved by EPA.
The ground water monitoring program would continue until EPA
approves a five-year review concluding that the alternative has
achieved continued attainment of the performance standards and
remains protective of human health and the environment.
Placement of institutional controls as described in section 9.0 A to
preclude usage of ground water; and
Implementation of a pump and treat system as a contingency action
would be at EPA's sole determination that performance standards
described in B.I have not been met. The contaminated ground water
will be pumped to the surface and treated in accordance with
performance standards established in B.2.
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TABLE 9-1
SUMMARY OF MONITORING PERFORMANCE STANDARDS
(GROUND WATER)
Contaminant
Manganese
Beryllium
Cadmium c
Chromium "
Lead c
Performance Standard
(ug/1)
175 a
4b
5b
100 b
15 e
a - Calculated value based on an acceptable risk or a Hazard Quotient (HQ) of 1.
Exposure assumptions are a 2 liter per day ingestion rate and a 70 kilogram
body weight.
b - Safe Drinking Water Act Maximum Contaminant Level (MCL).
c - Included due to contaminant concentrations and frequency of detection.
d - While Chromium was below detection during third sampling round, it was
detected above standards in previous rounds. Therefore, it was retained for
determining performance standards.
e - EPA Action Level from Lead and Copper Rule, 56 FR, June 7, 1991.
B.2. Extraction, Treatment, and Discharge of Contaminated Ground Water.
Contingency Remedial Action
If implemented, the ground water extraction system shall consist of a group of
wells located within the estimated area of the plume. The pumping system
shall be designed to provide a capture zone sufficient to intercept the
delineated plume targeted for extraction.
The effectiveness of the ground water extraction system is dependent upon the
aquifer characteristics, transmissivity and storativity. Typically, these design
criteria are developed by aquifer testing based on constant discharge pumping
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and/or recovery tests. Pump tests and modeling shall be required prior to
extraction. The number of wells and system extraction rate, estimated at 50 -
100 gpm will be determined during RD, if implemented.
Ground water will be treated and discharged to an off-site surface water body.
NPDES standards shall be met for ground water discharge. Any required
ground water treatment shall be accomplished by Ion, Chemical, and/or
Physical or combination treatment train. Treatability studies shall be done at
implementation of this contingency remedy to determine design parameters
and procedures. The treated effluent would be discharged to the surface water
and the system will be designed to meet Federal and State NPDES limitations
for discharge to the surface water.
If NPDES requirements are not viable, other discharge mechanisms, such as
discharge to the local wastewater treatment plant, would be considered. While
extracted ground water concentrations may be lower than the limits set for
discharges to the public sewer system (Cedartown Code 22-64), the discharge
volume and flow may be a prohibitive factor in POTW acceptance of discharge
due to limited treatment plant capacity.
B.3. Performance Standards for Ground Water
a. Treatment Standards
Ground water shall be treated until the following maximum
concentration level is attained at the wells designated during the design
and approved by the EPA as compliance points.
Beryllium 4 ug/1
Cadmium 5 ug/1
Chromium 100 ug/1
Lead 15 ug/1
Manganese 175 ug/1
b. Discharge Standards
Discharges from the ground water treatment system shall comply with
all substantive requirements of the NPDES permitting program under
the Clean Water Act, 33 U.S.C. 1251 et secj., and all effluent limits
established by EPA and the State of Georgia.
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c. Design Standards
The design, construction, and operation of any ground water treatment
system shall be conducted in accordance with all Performance
Standards, including the RCRA requirements set forth in 40 CFR Part
264 (Subpart F).
C. Compliance Testing
Ground water monitoring shall be conducted at this Site. After demonstration of
compliance with all Performance Standards for 2 consecutive sampling events and
continued attainment through the five-year review at the wells approved by the EPA
as compliance points, sampling and monitoring may be discontinued at the discretion
of EPA. If ground water sampling or monitoring indicates that the Performance
Standards set forth in paragraphs B.I and B.3 are being exceeded at any time after
monitoring and/or pumping has been discontinued, extraction and treatment and/or
sampling of the ground water may recommence until the performance standards are
once again achieved.
10.0 STATUTORY DETERMINATION
Under CERCLA Section 121, 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 for remedies that employ treatment that permanently
and significantly reduce the volume, toxitity, 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 ground water treatment, if required as delineated through
performance standards described in Section 9.0 - SUMMARY OF SELECTED
REMEDY, subsections A (Source Control) and B (Ground water Restoration). Ground
water monitoring will be implemented in accordance with performance standards
described in Section 9.0 - SUMMARY OF SELECTED REMEDY, subsection B.I
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(Ground water Monitoring) to ensure that no exposure through ingestion of
contaminated ground water occurs. Institutional controls and ground water
monitoring will prevent exposure to contaminants while natural attenuation occurs
over time. Active remediation will not be immediately implemented for ground
water.
However, if contamination in the ground water does not attenuate to below
performance standards described in Section 9.0 - SUMMARY OF SELECTED
REMEDY, subsections B.I (Ground Water Monitoring); the performance standards
described in Section 9.0 - SUMMARY OF SELECTED REMEDY. B.2 (Extraction,
Treatment, and Discharge of Contaminated Ground Water, Contingency Remedial
Action) and B.3 (Performance Standards For Ground Water) shall apply and the
aquifer shall be actively restored through treatment.
10.2 ATTAINMENT OF THE APPLICABLE OR RELEVANT AND
APPROPRIATE REQUIREMENTS (ARARs)
Remedial actions performed under CERCLA, Section 121, 42 U.S.C. § 9621 must
comply with all applicable or relevant and appropriate requirements (ARARs). All
alternatives considered for the Site were evaluated on the basis of the degree to
which they complied with these requirements. The selected remedy with contingent
remedial action was found to meet or exceed ARARs identified in Tables 7-1, 2, 3 and
4. The following is a short narrative in support of attainment of the pertinent
ARARs.
Chemical-Specific ARARs
Ground water restoration performance standards are consistent with RCRA ARARs
identified in Table 7-4 concerning Identification and Listing of Hazardous Wastes and
Standards Applicable to Generators of Hazardous Waste.
Ground water restoration performance standards identified as MCLs are the Ground
water Protection Standards set out in this ROD as performance standards for
remedial action. If it becomes apparent that MCLs will not be met by means of
attenuation, a contingency pump and treat system will be implemented in accordance
with performance standards identified in the selected remedy section to insure that
MCLs are met.
Action-Specific ARARs
Performance and treatment standards are consistent with RCRA ARARs identified in
Tables 7-2 and 7-3, and these regulations will be incorporated into the design and
implementation of this remedy. If a pump and treat system becomes necessary, all
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groundwater treatment standards will be met prior to discharge of effluent to a U.S.
water under an NPDES permit, or all National Pretreatment Standards will be met
before off-site discharge of treated ground water to a POTW.
Location-Specific ARARs
Performance standards are consistent with ARARs identified in Tables 7-1.
The recommended remedial alternative is protective of species listed as endangered
or threatened under the Endangered Species Act. Requirements of che Interagency
Section 7 Consultation Process, 50 CFR Part 402, will be met. The Department of the
Interior, Fish & Wildlife Service, will be consulted during remedial design to assure
that endangered or threatened species are not adversely impacted by implementation
of this remedy.
Waivers
Section 121 (d)(4)(C) of CERCLA, 42 U.S.C. § 9621(d)(4)(c), provides that an ARAR
may be waived when compliance with an ARAR is technically impracticable from an
engineering perspective. While waivers are not anticipated to be invoked at this Site,
significant analytical differences between background wells will require further
analysis for verification that background average values are valid. However, it is
anticipated the contaminated ground water will meet all ARARs through the use of
proper low flow sampling and well construction techniques.
The selected remedy will require further sampling and analysis to further define
background ground water concentrations of inorganic contaminants. If background
analysis indicates that concentration for an inorganic exceeds the MCL or acceptable
risk based standards, EPA would consider amending the performance standards
through an BSD or ROD Amendment. A technical infeasibility or inability to attain
the ARAR as caused by existing background ground water conditions as supported
by further background sampling and analysis support may be evaluated as part of an
amended performance standard.
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 Sites and in determining RCRA applications to contaminated
media. TBCs for this Site include Guidelines for Groundwater Classification under
the EPA Groundwater Protection Strategy. Final Draft, December 1986, Lead and
Copper Rule, 56 FR, June 7,1991, and EPA memorandum dated June 21,1990 entitled
"Cleanup Level for Lead in Ground Water".
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10.3 COST EFFECTIVENESS
EPA believes the selected remedy, Alternative 2 will eliminate the risks to human
health at an estimated cost of $625,000. In the event that natural processes does not
achieve the ground water performance standards, the ground water treatment costs
will be comparable to Alternative 3. However, Alternative 2 may and is expected to
achieve a comparable effectiveness at a substantially lower cost (although over a
longer period of time). Alternative 2 provides an overall effectiveness proportionate
to its costs, such that it represents a reasonable value achieved for the investment.
10.4 UTILIZATION OF PERMANENT SOLUTIONS TO THE MAXIMUM
EXTENT PRACTICABLE
EPA and the State of Georgia have 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 Cedartown
Municipal Landfill Site. Of those alternatives that are protective of human health and
the environment and comply with ARARs, EPA and the State have determined that
this selected remedy 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 will satisfy
the statutory preference for treatment if the contingency remedial action is
implemented. The selected remedy provides for long-term effectiveness and
permanence, is easily implemented, reduces toxicity, mobility or volume, and is cost
effective.
10.5 PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT
The selected remedy with contingency utilizes treatment technologies to the extent
practicable. The statutory preference for remedies that employ treatment as a
principal element is satisfied.
11.0 DOCUMENTATION OF SIGNIFICANT CHANGES
There have been no significant changes in the selected remedy, Alternative 2, from
the preferred remedy described in the proposed plan.
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APPENDIX A;
RESPONSIVENESS SUMMARY - CEDARTQWN
MUNICIPAL LANDFILL
RECORD OF DECISION
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SUMMARY OF MAJOR QUESTIONS AND COMMENTS RECEIVED DURING THE PUBLIC
COMMENT PERIOD AND EPA's RESPONSES
ISSUE
EPA RESPONSE
3.
The effects of ore mining and published
literature values for natural occurring ground
water chemistry for metals were not discussed
in the Rl, but site history indicates that the
landfill was an iron mine previous to
development as a landfill.
The data does not support that the presence of metals are a
logical result of iron mining. Chromium and Iron are different
metals with different modes of occurrence. The iron ore in Polk
county is composed of minerals that are not sources of
chromium. Furthermore, the parent rocks containing iron ore are
carbonate rocks, which are not chromium sources.
Secondly, samples taken from the landfill leachate/wastes indicate
that the contaminants in the groundwater have a relationship to
wastes disposed of in the landfill.
Lastly, site specific background samples were collected from
areas that were believed not to be affected by landfill wastes.
Since site specific data is more representative of actual conditions
at the Site, this data was appropriately used to determine human
health and environmental effects, to establish applicable clean-up
standards, and to determine if contaminants were site related or
were from non-site related sources.
How valid is the data used for the Site
Investigation?
The data collected by NUS, an EPA contractor, during the initial
Site Investigation was valid for determining if a potential human
health and environmental risk was present and supported
calculations required for the hazardous ranking which led to
proposing the Site to the National Priority Listing authorizing
Superfund clean-up.
The Remedial Investigation completed in August of 1993 was an
extensive study with a high level of validity and data quality, to
determine the levels and extent of contaminants along with the
associated risk to people and the environment related to the Site.
What is the cost of the remedy on a yearly
basis?
A estimated cost for implementing the selected remedy is
$625,000. This is based on a 30 year period for landfill
maintenance and ground water monitoring (quarterly sampling
years 1-5, and semi-annual years 6-30).
On an annual basis, an estimated cost of $40,000 to $60,000
would be expected.
Is the U.S. Geological Survey (USGS) to
perform an intense analysis of the geology of
this area.
USGS has considered performing an area wide geological survey.
However, funding has not been available to conduct the survey
and the study would likely take many years to conduct The study
may be accomplished at a future date.
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Responsiveness Summary
Cedartown Municipal LandfiU Site
Page iii
SUMMARY OF MAJOR QUESTIONS AND COMMENTS RECEIVED DURING THE PUBLIC
COMMENT PERIOD AND EPA's RESPONSES
ISSUE
EPA RESPONSE
7.
The oral reference dose (RfD) for manganese
used to determine the amount of manganese
that can be ingested without an adverse affect
is flawed and not valid.
EPA recognizes that uncertainties exist regarding the amount of
manganese that can be ingested in water without an adverse
affect. Due to the uncertainties associated with the present RfD
for manganese, the amount of manganese that can be ingested
in water without an adverse effect is scheduled to be reviewed by
EPA experts in the near future.
EPA required that the current RfD for manganese be used to
evaluate health risks concerning manganese in water and
determine clean-up goals to ensure ingestion of ground water is
protective of human health. However, as referenced in the
proposed plan fact sheet, since there are uncertainties, EPA
made a risk management decision to propose ground water
monitoring versus active remediation as the appropriate response
action.
Lastly, as discussed in the proposed plan fact sheet, if the RfD for
manganese is revised, EPA will evaluate an amendment to the
Record of Decision revising the manganese clean-up standard in
ground water.
8.
The correct clean-up standard for lead should
be SO ug/l (regulated drinking water standard)
not the 15 ug/l stated in the proposed plan fact
sheet.
SO parts per billion or micrograms per liter (ug/l) is not the
regulated drinking water standard for lead. A regulated drinking
water standard for lead in water has not been established.
However, EPA has adopted the lead concentration of IS ug/l as
the appropriate ground water protection standard or action level
for the protection of human health.
The clean-up standard is based on an EPA memorandum dated
June 21,1990 entitled "Cleanup Level for Lead in Ground Water
and memorandum from EPA's Office of Drinking Water which set
IS ug/l as the drinking water action level. This action level is
based preventing unsafe exposure of lead contaminated drinking
water to young children. Since this level prevents exposure to
unsafe concentrations of lead, it is appropriate to use this
standard for Superfund cleanup and has been consistently used
by EPA Region IV as a ground water clean-up standard to
ensure drinking water is protective.
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Responsiveness Summary
Cedartown -Municipal Landfill Site
Page iv
SUMMARY OF MAJOR QUESTIONS AND COMMENTS RECEIVED DURING THE PUBLIC
COMMENT PERIOD AND EPA's RESPONSES
ISSUE
EPA RESPONSE
9.
Since the East Pond seep has not impacted the
coke pond in the 12 years since the landfill was
closed, the determination that the seep has a
future potential to impact the coke pond is not
correct and was included in the FS only to
support the requirement for cover and seep
maintenance.
1) Contaminant concentrations found in the Coke Pond indicates
that Site-related contaminants are not currently adversely
impacting the surface water in Coke Pond. However, given the
levels of contaminants of ecological concern in the east seep
pond, and the down stream location of the Coke Pond, a potential
for future migration of contaminants into the Coke Pond does
exist and was addressed as part of the proposed remedy to
protect this environment.
2) The requirement for cover and seep maintenance would be a
requirement of the selected remedy regardless of the potential
impact on the coke pond. Due to the existing ground water
contamination, cover maintenance is an important mechanism to
reduce the leaching of contaminants to ground water and in
ensuring that landfill contaminants do not have a pathway of
exposure for the protection of human health.
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CedartowiV Municipal Landfill Site
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SUMMARY OF MAJOR QUESTIONS AND COMMENTS RECEIVED DURING THE PUBLIC
COMMENT PERIOD AND EPA's RESPONSES
ISSUE
EPA RESPONSE
10.
The pump and treat remedy described in
alternative 3 is not technically feasible (will not
obtain hydraulic containment in a karst
topography) and will likely require pump rates
of 500 gpm with a cost of $40,000,000.
1) Since the affected aquifer is a class HA or current source of
drinking water and must be restored to its full beneficial use, a
contingency remedy is necessary. This contingency remedy will
extract and treat contaminated ground water if attenuation is
determined not to be effective.
However, EPA does agree that uncertainties do exist in the
hydrogeotogic characteristics beneath the Site due to the karst
setting or geology which will need to be resolved during the
remedial design through treatability studies and performance tests
to ensure contaminated ground water is extracted and treated if
the contingency remedy is implemented. That characterization
can be in the form of another dye-tracer analysis and/or a WADI
survey. The WADI is a Very Low Frequency (VLF) or passive
survey that uses an instrument that measures subsurface
responses to military transmitters. The WADI has been used
successfully by EPA to identify natural conduits at karst sites in
TN and KY.
Ground water extraction systems in karst settings are both being
effectively operated at the Gulfcoast Lead RCRA she in Tampa,
Florida and the Wolverine Tube RCRA site in Decatur, Alabama.
2) According to the Rl, 18% of wells installed in the Newala
Aquifer would be expected to pump over 20 gallons per minute
(gpm) and 60% over 10 gpm. Cedartown spring itself pumps 2-4
millions gallons per day (mgd). A review of similar current pump
and treat systems indicate an average pumping rate of SO - ISO
gpm. Therefore, a realistic pumping rate would likely be in the
range of 50-100 gpm (5 wells).
Additionally, if the implemented remedy costs exceeds + 50%
above the Record of Decision's cost estimate, per the NCP, an
Explanation of Significant Differences (ESD) or amendment to the
Record of Decision would be evaluated to consider
implementability of the remedy.
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Responsiveness Summary
CedartcJwif Municipal Landfill Site
Pagei
APPENDIX A:
RESPONSIVENESS SUMMARY - CEDARTOWN MUNICIPAL LANDFILL
RECORD OF DECISION
The U.S. Environmental Protection Agency (EPA) held a 30-day public comment period from
September 1,1993, through September 30,1993 for interested parties to give input on EPA's
Proposed Plan for Remedial Action at the Cedartown Municipal Landfill Superfund Site in
Cedartown, Georgia. A public meeting was conducted on September 9,1993, at the Cedartown
Public Library, 245 East Avenue, Cedartown, Georgia. At the meeting, EPA staff presented the
results of the Remedial Investigation and Feasibility Study (RI/FS) and explained EPA's preferred
remedy for the Site.
A responsiveness summary is required to document how EPA addressed citizen comments and
concerns, as raised during the public comment period. All comments summarized in this
appendix have been factored into the final decision of the remedial action for the Cedartown
Municipal Landfill Site.
SUMMARY OF MAJOR QUESTIONS AND COMMENTS RECEIVED DURING THE PUBLIC
COMMENT PERIOD AND EPA's RESPONSES
ISSUE EPA RESPONSE
1. What are the exposure assumptions used to The assumed drinking or ingestion rates for an adult and a child
determine Human Health effects in the Risk were 2 liters and 1 liter, respectively. Body weights were 70 kg
Assessment for drinking ground water? (154 Ib) for adults and IS kg (33 Ib) for a child. The ingestion of
ground water was assumed to occur over a 30 year duration (5
years as a child).
2. Has ground water been analyzed for Coliform Not by EPA. Under Superfund, the Remedial Investigation
Bacteria since sewage sludges may have been determines the presence and concentrations of hazardous
disposed at the landfill? substances for cleanup. These hazardous substances are
typically chemicals or substances that have been determined to
cause an adverse affect to human health. However, the
municipal public water authority and/or public health organization
monitors public drinking for adverse biological affects. A typical
water treatment plant removes bacteria threats from drinking
water prior to distribution to the public. A citizen using a private
well can request the local public health or water authority test
their well for bacterium.
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Cedartewir Municipal Landfill Site
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SUMMARY OF MAJOR QUESTIONS AND COMMENTS RECEIVED DURING THE PUBLIC
COMMENT PERIOD AND EPA's RESPONSES
ISSUE
EPA RESPONSE
11.
That EPA's directive for performing an RI/FS
investigation states that ground water extraction
is not feasible for extracting contaminants in
fractured bedrock.
The section of EPA's RI/FS guidance document titled by the
commenter as "EPA's Guidance on Pump and Treat Technology"
was improperly referenced and used.
EPA directive number OWSER 9355.3-01 titled "Guidance for
Conducting Remedial Investigations and Feasibility Studies Under
CERCLA" is not EPA's guidance for Pump and Treat Technology.
The commenter referenced figure 4-4, on page 4-17 titled "An
Example of initial screening technologies and process options" as
evidence that ground water extraction is not feasible. The use of
figure 4-4 in this EPA Guidance was an illustration and example
of how the process of selecting and screening technologies is
approached, not whether a particular technology is effective on a
particular or Site specific basis. As discussed in the previous
response, EPA has effectively used ground water extraction
systems in karst settings for ground water treatment and believes
would be an effective treatment technology for this Site if the
contingency remedy is required to be implemented.
12.
The No Action alternative is protective of
human health and the environment.
The results of the Remedial Investigation, Risk Assessment, and
Feasibility Study indicates that beryllium, cadmium, lead, and
manganese are present in concentrations in the ground water
that are not protective of human health and the environment. The
east seep does contain contaminants that may move and
adversely impact the Coke Pond.
The no-action remedy will not provide for cover maintenance and
seep controls which will provide continued containment of landfill
waste and assist in reducing leaching of the wastes to ground
and surface waters. Secondly, the No-Action alternative does not
provide a mechanism to determine if attenuation of the
contaminated ground water is effective or not (no ground water
monitoring). Thirdly, the No-Action alternative will not protect
against exposure to ground water through ingestion.
Since constituents are in the ground water are above health
based and/or regulatory levels, the No-Action alternative is not
protective of human health and the environment, therefore,
response actions were considered and proposed.
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CedartSwn Municipal Landfill Site
Page vii
SUMMARY OF MAJOR QUESTIONS AND COMMENTS RECEIVED DURING THE PUBLIC
COMMENT PERIOD AND EPA's RESPONSES
ISSUE
EPA RESPONSE
13. None of the alternatives meet ARARs due to
naturally occurring background levels of
manganese, lead, and beryllium.
Data indicates uncertainties in background results which were
recognized in the proposed plan fact sheet and the Record of
Decision and was a factor in selecting alternative #2. The
indications are that monitor well MW-09-WP used as a
background ground water well may have been impacted by the
Cedartown Municipal Landfill. Therefore, requiring a waiver of a
regulated drinking standard due to technical impractabilrty (i.e.
inability to clean-up to below background) would not be protective
of human health until further background analysis as described in
the Record of Decision is completed. If background ground water
concentrations are determined by EPA to be greater than the
clean-up or performance standard for a contaminant of concern,
EPA shall consider an amendment to the record of decision,
issuance of a drinking water standard waiver, if required, and
modification of the clean-up standard.
14.
Why is background incremental risk discussion
and evaluation not in the FS reports, and why
hasn't the Songterm effectiveness evaiuaticri
not considered risk due to background
conditions?
Due to methods used in establishing risk-based performance
standards and uncertainties in background analysis, the
comparison of risk associated with inyestion of site-contarriiriatcd
ground water with background ground water is not appropriate.
In the risk assessment process, background concentrations are
used as a screening mechanism to determine if further
contaminant risk calculations are required. Manganese met this
criteria which dictated that risk calculations be accomplished and
appropriate clean-up standards be determined.
Additionally, as stated in the previous comment, the final
determination of manganese background concentrations is to be
confirmed. If background analysis results are greater than the
clean-up standard, EPA shall consider amending the clean-up
standard.
15.
No-Action alternative is equally as effective as
alternative 2 in the reduction of toxicity, mobility,
and volume.
Since the NoAction alternative was determined not to be
protective of human health and the environment and would not
meet regulations, the comparison of long term effectiveness to
other remedies is not an appropriate comparison. If a remedy
does not meet the threshold criterium (i.e. protective and meets
regulations), the alternative is deemed unacceptable for further
comparison.
However, the No-Action alternative is not as effective as the
proposed remedy. The No-Action remedy will not provide for
cover maintenance and seep controls. The No-Action alternative
does not have a mechanism to determine if attenuation of the
contaminated ground water is effective or not. Since constituents
in the ground water are above health-based and/or regulatory
levels, the No-Action alternative is not an effective remedy.
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Cedartown Municipal Landfill Site
Pageviii
SUMMARY OF MAJOR QUESTIONS AND COMMENTS RECEIVED DURING THE PUBLIC
COMMENT PERIOD AND EPA's RESPONSES
ISSUE
EPA RESPONSE
16.
Pre-specifying alternative #3, pump and treat,
as a contingency remedy prevents the
opportunity of evaluating future alternative
technologies.
A record of decision is issued based on the most appropriate
technology available which best satisfies the criteria for selecting
a remedy and allows prompt clean-up of the Site. This Record of
Decision represents best current technologies for this Site.
However, EPA recognizes that best technologies used for
remediation at Superfund sites are evolving and may change.
EPA will consider issuing an amendment to the Record of
Decision refining the remedial technologies and treatment
processes, if a future technology becomes available which shows
an improved benefit in implementability, effectiveness, and cost.
17.
Alternative 3 would involve exposure to workers
to metal sludges and which was not considered
in its evaluation.
The potential risk to workers was considered in the evaluation to
alternative 3. EPA's decision to propose alternative 2 with
alternative 3 as a contingency reflects this factor among others in
determining the appropriate remedy.
However, alternative 3, through engineered controls would be
protective to workers and prevent exposure to metal sludges.
18.
Since the City of Cedartown is in the process of
acquiring lands associated with the landfill, the
City can enforce existing ordinances which
prevents the drilling of private water supply
wells. Therefore, institutional controls are not
required in the Record of Decision.
The proposed remedy allows the City of Cedartown to implement
land and/or ground water restrictions through zoning, annexing
and well restrictions. Deed or other legal restrictions will be
required if the City cannot implement restrictions which prevents
access or exposure to contaminated ground water and landfill
wastes.
Since future changes to municipal laws and zoning is possible,
and for the institutional controls to be effective, the possible
implementation of deed restrictions is required to be protective in
the long-term and shall remain an integral part of the remedy.
19.
Since there is no current or future risk
attributable to the landfill and the level of
contaminants found is what would normally be
expected at a municipal landfill site of this type,
the Site should be treated no differently than
any other closed landfill site in Georgia, and
should be delisted from the NPL
Site was listed in part due to the close proximity to Cedartown's
drinking water source. The Remedial Investigation and Risk
Assessment using site-specific sampling data indicates this Site
presents an unacceptable health risk from the ingestion of ground
water. Comparison to other municipal landfills would be of benefit
if site specific sampling data was not available. However, site
specific data was collected and was available for determining the
extent of contamination. Since the data analysis resulted in an
unacceptable risk to human health and the environment, this Site
cannot be deleted until all clean-up performance standards are
achieved for the protection for human health and the
environment
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Responsiveness Summary
Cedartown Municipal Landfill Site
Pageix
SUMMARY OF MAJOR QUESTIONS AND COMMENTS RECEIVED DURING THE PUBLIC
COMMENT PERIOD AND EPA's RESPONSES
ISSUE
EPA RESPONSE
20.
Chromium in the ground water as determined
by modeling and the June 1993, ground water
sampling results, and in the Baseline risk
assessment indicates it is not a contaminant of
concern in ground water.
The first two rounds of ground water samples contained elevated
levels of chromium (maximum 230 ug/l) that were over its drinking
water standard. However, the June 1993 ground water sampling,
using the tow flow purging and sampling techniques, indicated
chromium concentrations that were below detection limits. Since
the old style high pump rate/high bailing rate purging and
sampling techniques were used for the first two sampling events,
a comparison of analytical results to this new procedure is not an
appropriate evaluation. It is not appropriate to conclude that the
ground water would have contained no detections of chromium in
past sampling rounds if slow pump rate purging and sampling
had been done.
Therefore, neither the recent ground water sampling event (using
low flow techniques) nor past contaminant distribution patterns
di3CJuSufy thS SaPidm! UWIM aoSuimTig rSSpOnSibiiit/ fOr trie 6JVai6u
chromium soil and ground water concentrations at the site.
Chromium, based on previous sampling results, will continue to
be a contaminant of concern for ground water monitoring and the
ground water concentrations established in sampling round #3 will
be verified during future sampling. If the ground water monitoring
program confirms that chromium levels are below the drinking
water standard of 100 ug/l for two consecutive EPA verified
sampling events, chromium will have attained the clean-up
performance standard.
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Record of Decision
Cedartown Municipal Landfill Site
Page 78
APPENDIX B:
STATE OF GEORGIA CONCURRENCE LETTER
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Georgia Department of Natural Resources
205 Butler Street, S.E., Suite J 154 Atlanta, Georgia 30334
Joe D. Tanner, Commissioner
Environmental Protection Division
Harold F. Reheis, Director
404/656-2833 404/656-7802
September 21, 1993
Mr. Richard Green
Associate Division Director
Office of Superfund
U.S. EPA, Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
RE: Record of Decision
Cedartown Municipal Landfill
Dear Mr. Green:
The Georgia Environmental Protection Division (EPD) has reviewed the Record of
Decision, Summary of Remedial Alternative Selection for the Cedartown Municipal Landfill
NPL Site, Polk County, Georgia. The remedial alternative calls for cover maintenance
and seep controls, institutional controls, a groundwater/surface water monitoring program
to ensure natural attenuation, and a pump-and-treat contingency plan if groundwater
standards are not attained. EPD concurs with the selected remedy.
If you have any questions or need further assistance, please contact Madeleine
Kellam at (404) 657-8683.
Sincerely,
Harold F. Reheis
Director
HFR/mfk
c: Jay Bassett
file: Cedartown Municipal Landfill (B)
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