EPA/ROD/R04-93/143
1993
EPA Superfund
Record of Decision:
FIRESTONE TIRE & RUBBER CO. (ALBANY PLANT)
EPA ID: GAD990855074
OU01
ALBANY, GA
06/24/1993
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DECLARATION of the RECORD OF DECISION
SITE NAME AND LOCATION
Firestone Tire & Rubbery Company Site
Albany, Dougherty County, Georgia
STATEMENT OF BASIS AND PURPOSE
This decision document (Record of Decision), represents the selected remedial action for the
Firestone Tire & Rubber Company "Site", Albany, Dougherty County, Georgia, developed in
accordance with the reguirements of the Comprehensive Environmental Response, Compensation and
Liability Act of 1980 (CERCLA) , as amended by the Superfund Amendments and Reauthorization
act of 1986 (SARA) 42 U.S.C. Section 9601 et seg., and to the extent practicable, the National
Contingency Plan (NCP) 40 CFR Part 300.
This decision is based on the administrative record for the Site.
The State of Georgia concurs with the selected remedy.
ASSESSMENT OF THE SITE
Actual or threatened releases of hazardous substances from the 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.
DESCRIPTION OF SELECTED REMEDY
This final remedy addresses remediation of soils and groundwater contamination by eliminating or
reducing the risks posed by the Site, through treatment, engineering and institutional controls.
The major components of the selected remedy include:
Excavation of PCB-contaminated soils until established cleanup levels are reached with disposal
in an off-site permitted landfill.
Backfilling the excavated areas with clean fill material.
Extraction and treatment of contaminated groundwater using existing wells and supplemental wells
if necessary. The contaminated groundwater will be remediated using on-site air stripping.
Discharge of extracted groundwater after treatment to the Local Waste Water Treatment System
(Publicly Owned Treatment Works - POTW).
Periodic groundwater monitoring will be conducted to assess the effectiveness of the remedy.
Institutional controls will be placed on well construction and water use on the Site.
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STATUTORY DETERMINATIONS
The selected remedy is protective of human health and the environment, complies with federal and
state requirements that are legally applicable or relevant and appropriate, and is
cost-effective. This remedy utilizes permanent solutions and alternative treatment (or resource
recovery) technologies to the maximum extent practicable and satisfies the statutory preference
for remedies that employ treatment that reduces toxicity, mobility, or volume as a principal
element. Because this remedy will result in hazardous substances remaining on-site above
health-based levels, a review will be conducted at least every five years beginning no later
than five years from commencement of remedial action to ensure that the remedy continues to
provide adequate protection of human health and the environment. Reviews may be conducted on a
more frequent basis as EPA deems necessary.
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RECORD OF DECISION
SUMMARY OF REMEDIAL ALTERNATIVE SELECTION
FIRESTONE TIRE & RUBBER COMPANY SITE
ALBANY, GEORGIA
PREPARED BY:
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV
ATLANTA, GEORGIA
TABIiE OF CONTENTS
1.0 SITE LOCATION AND DESCRIPTION
1.2 SURFACE FEATURES
1.3 CLIMATE AND METEOROLOGY
1.4 SURFACE WATER HYDROLOGY
1.5 GEOLOGY
1.6 HYDROGEOLOGY
1.7 DEMOGRAPHY
1.8 ECOLOGY
2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES
3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION
4.0 SCOPE AND ROLE OF RESPONSE ACTION
5.0 SUMMARY OF SITE CHARACTERISTICS
5.1 NATURE AND EXTENT OF CONTAMINATION
5.1.1 CONFIRMATORY SAMPLING OF THE FORMER INTERIOR PCB TRANSFORMER LOCATIONS
5.1.2 GROUNDWATER SAMPLING
5.1.3 SURFACE WATER SAMPLING
5.1.4 SURFACE SOIL SAMPLING
5.1.5 SUBSURFACE SOIL SAMPLING
5.1.6 SEDIMENT SAMPLING
5.1.7 CONFIRMATORY SAMPLING OF FORMER COURTYARD PCB TRANSFORMERS
6.0 SUMMARY OF SITE RISKS
6.1 CONTAMINANTS OF CONCERN
6.2 EXPOSURE ASSESSMENT
6.3 TOXICITY ASSESSMENT
6.4 RISK CHARACTERIZATION
6.5 ENVIRONMENTAL RISK
7.0 DESCRIPTION OF CLEANUP ALTERNATIVES
7.1 ALTERNATIVES FOR GROUNDWATER REMEDIATION
7.2 ALTERNATIVES FOR SOIL REMEDIATION
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8.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
8.1 OVERALL PROTECTION OF HUMAN HEALTH & THE ENVIRONMENT
8.2 COMPLIANCE WITH ARARs
8.3 LONG-TERM EFFECTIVENESS & PERMANENCE
8.4 REDUCTION OF TOXICITY, MOBILITY OR VOLUME
8.5 SHORT-TERM EFFECTIVENESS
8.6 IMPLEMENTABILITY
8.7 COST
8.8 STATE ACCEPTANCE
8.9 COMMUNITY ACCEPTANCE
9.0 THE SELECTED REMEDY
9.1 PERFORMANCE STANDARDS
10.0 STATUTORY DETERMINATIONS
10.1 PROTECTION OF HUMAN HEALTH AND THE ENVIRONMENT
10.2 COMPLIANCE WITH ARARs
10.3 COST EFFECTIVENESS
10.4 UTILIZATION OF PERMANENT SOLUTIONS
10.5 PREFERENCE FOR TREATMENT AS A PRINCIPAL ELEMENT
APPENDIX A - RESPONSIVENESS SUMMARY
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LIST OF TABLES
TABLE 5-1 SUMMARY OF CONTAMINANTS FOUND IN GROUNDWATER
TABLE 5-2 CONTAMINANTS FOUND IN SURFACE AND SUBSURFACE SOILS
TABLE 5-3 CONTAMINANTS FOUND IN SEDIMENTS
TABLE 5-4 CONTAMINANTS FOUND IN SURFACE WATER
TABLE 6-1 CONCENTRATIONS OF CONTAMINANTS FOUND IN GROUNDWATER RESIDUUM WELLS
TABLE 6-2 CONCENTRATIONS OF CONTAMINANTS FOUND IN GROUNDWATER UPPER OCALA
TABLE 6-3 CONCENTRATIONS OF CONTAMINANTS FOUND IN GROUNDWATER LOWER OCALA
TABLE 6-4 CONCENTRATIONS OF CONTAMINANTS FOUND IN SOILS SURFACE SOILS (0-1 FT)
TABLE 6-5 CONCENTRATIONS OF CONTAMINANTS FOUND IN SOILS SUBSURFACE SOILS (0-1 FT)
TABLE 6-6 CONCENTRATIONS OF CONTAMINANTS FOUND IN SEDIMENTS SHALLOW SEDIMENTS (0-1 FT)
TABLE 6-7 CONCENTRATIONS OF CONTAMINANTS FOUND IN SEDIMENTS SUBSURFACE SEDIMENTS (2-3 FT)
TABLE 6-8 CONCENTRATIONS OF CONTAMINANTS FOUND IN SURFACE WATER
TABLE 6-9 EXPOSURE & INTAKE PARAMETERS ASSESSING INGESTION AND DERMAL EXPOSURE TO SOIL BY
WORKERS
TABLE 6-10 EXPOSURE & INTAKE PARAMETERS ASSESSING INGESTION AND DERMAL EXPOSURE TO SEDIMENT AND
SURFACE WATER BY WORKERS
TABLE 6-11 EXPOSURE & INTAKE PARAMETERS ASSESSING INHALATION EXPOSURE TO PARTICLE AND VAPOR
PHASE CHEMICALS BY WORKERS
TABLE 6-12 EXPOSURE & INTAKE PARAMETERS ASSESSING INGESTION OF GROUNDWATER, INHALATION OF VOCs
IN THE GROUNDWATER AND DERMAL CONTACT WITH GROUNDWATER BY POTENTIAL FUTURE ON-SITE
RESIDENTS
TABLE 6-13 EXPOSURE & INTAKE PARAMETERS ASSESSING INGESTION DERMAL EXPOSURE TO SURFACE SOIL FOR
POTENTIAL FUTURE ON-SITE RESIDENTS
TABLE 6-14 EXPOSURE & INTAKE PARAMETERW ASSESSING INHALATION EXPOSURE TO VOLATIZED SOIL
CHEMICALS AND ENTRAINED SOIL PARTICLES FOR POTENTIAL FUTURE ON-SITE RESIDENTS
TABLE 6-15 CHRONIC REFERENCE DOSES AND CANCER SLOPE FACTORS FOR CONTAMINANTS OF CONCERN
TABLE 6-16 SUMMARY OF CANCER RISK AND NON-CARCINOGENIC HEALTH HAZARD ESTIMATES AND MEDIA FOR
WHICH REMEDIATION GOALS ARE DERIVED
LIST OF FIGURES
FIGURE 1-1 LOCATION MAP
FIGURE 1-2 FACILITY MAP (SITE FEATURES)
FIGURE 1-3 GEOHYDROGEOLOGY OF THE ALBANY, GEORGIA AREA
FIGURE 5-1 RI SAMPLING LOCATIONS
FIGURE 5-2 CONTAMINANTS IDENTIFIED IN THE RESIDUUM
FIGURE 5-3 CONTAMINANTS IDENTIFIED IN THE TRANSITION ZONE
FIGURE 5-4 CONTAMINANTS IDENTIFIED IN THE UPPER OCALA
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Decision Summary
Record of Decision
Firestone Tire & Rubber Company Site
ALbany, Georgia
1.0 SITE LOCATION AND DESCRIPTION
The Firestone Tire & Rubber Company Site ("Site") is located at 3300 Sylvester Road in Albany,
Dougherty County, Georgia. The City of Albany is located in Dougherty County in the southwest
portion of Georgia. The Site is located approximately one mile east of Albany city limits
(Figure 1-1). The Firestone facility was used for manufacturing tires from 1968 to 1986 within a
1,840,000 ft[2] on-site building. In October 1989, the facility was placed on the National
Priorities List ("NPL") as a result of environmental investigations conducted at the Site.
Except for cleanup activities, the Site remained inactive between 1986 and March 1990, at which
time Cooper Tire purchased the facility and began renovations for future operations.
Along the eastern property line of the Site lies vacant land, which was formerly used for
agricultural purposes. Immediately to the north of the Site is Sylvester Road, a four-lane
highway (U.S. Route 82). North of Sylvester Road are eight mobile home parks and three
commercial retail sites, including a flea market and a gas station. Along the western property
line are a church, a tree farm and vacant land. The southern property line lies along the
Seaboard Coastline railroad tracks. A railroad spur along the east side of the Site, which
served the facility's shipping and receiving operations, is connected to the Seaboard Coastline
railroad at the southeast corner of the Site. To the south of the Site, beyond the railroad
right-of-way, lies the U.S. Marine Corps Logistics Base which has also been identified as a
Superfund Site.
The facility is currently zoned as an industrial/commercial area, according to the Dougherty
County Planning Commission. The primary source Area of Contamination addressed in this Record
of Decision ("ROD") is located in the courtyard area (Figure 1-2). However, certain chemicals
have been dispersed throughout the Site.
1.2 SURFACE FEATURES
The Firestone Site is located in the Dougherty Plain district of the Coastal Plain physiographic
province. The land displays level or gently undulating topography, with measurements at the
Site indicating ground surface elevations ranging from approximately 200 to 220 ft above mean
sea level (MSL). The composition of the soils range from well-drained sands to poorly
drained soils in ponded depressional areas. Most of the surface soils at the Site are either
sandy loams or loamy sands.
The Dougherty Plain is characterized by Karst topography and contains numerous shallow
flat-bottomed or rounded sinkholes caused by solutioning and collapse of the underlying
limestone. Many of the sinkholes are filled with material of relatively low permeability and
some hold water year round. At the Site, the storm water detention pond is a natural pond
delineated as Wetland Area No. 3, and is likely to be the surface expression of a sinkhole
(Figure 12).
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1.3 CLIMATE AND METEOROLOGY
Southern Georgia has a warm temperate humid climate due to its latitude and proximity to the
Atlantic Ocean and the Gulf of Mexico. The mean total annual precipitation for Albany is about
50 in. The annual mean monthly temperature is about 66 F with mean daily minimum temperatures
ranging from approximately 37 F in January to 71 F in July and mean daily maximum temperatures
ranging from approximately 60 F in January to approximately 92 F in July and August.
According to data obtained from the National Climate Data Center, no predominant wind direction
exists in the Albany area. Winds in the area are calm approximately 23 percent of the time.
1.4 SURFACE WATER HYDROLOGY
The Firestone Site can be characterized as containing both well drained areas and poorly-drained
areas. The well-drained areas include the manufacturing plant area, where roof and parking lot
drains discharge storm water directly into ditches, and other areas where the slope is
significant to control surface water runoff. Poorly drained areas include some of the wetland
areas on the Site.
The ditches and ponds have been observed to completely dry up during periods without
precipitation, therefore the surface water hydrology at the Site is influenced mainly by storm
events. After a significant storm event, rain falling onto the north half of the Site
infiltrates into the ground and/or collects in two main ditches: the East Ditch and the West
Ditch. The East and West Ditches also receive storm water from areas north, east and west of the
Site. These off-site areas include Sylvester Road and nearby residential/ commercial areas.
These ditches flow from north to south and empty into a storm water detention pond (Wetland Area
No. 3). The water then flows through the pond to the only outlet located at the west end of the
pond. From the pond, the storm water flows through underground storm water pipes, ditches and
canals and ultimately discharges to the Flint River. The Flint River converges with the
Apalachicola River, which discharges to the Gulf of Mexico.
Rain falling on the southern half of the Site basically flows to one of several wetland areas
present in the south. The railroad bed of the Seaboard Coastal Railroad acts as a barrier for
surface water entering or leaving the Site from the south. The bed is elevated above normal
ground surface and two drainage ditches parallel each side of the railroad bed. Figure 1-2 shows
the surface water hydrology of the Site.
1.5 GEOLOGY
The Firestone Site is underlain by Coastal Plain sedimentary strata of pre-Cretaceous to
Quaternary age. In general, the strata consist of alternating units of sand, clay, sandstone,
dolomite, and limestone that dip gently and thicken in a southeastern direction. The site
specific geologic units of interest consist of the Residuum, the Upper Ocala Limestone, and the
Lower Ocala Limestone.
The lithology of the Residuum varies across the Site, but can generally be described as sandy
clay to clayey sand. Colors also vary and have been identified to include red, brown, yellow,
gray, purple, and white. The base of the Residuum unit gradates into the underlying Ocala
Limestone and a distinct contact is not present between the two formations. Varying guantities
of clay and weathered limestone fragments with traces of dolomitic rocks have been identified
near the base of the Residuum.
The Residuum is underlain by the Ocala Limestone which is typically white to tan and grades from
a highly weathered, fine to coarse grained, fossiliferous, soft limestone into a less weathered,
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finer grained, less fossiliferous, more indurated limestone at depths ranging from approximately
130 to 150 ft bgs. The soft, more weathered limestone is referred to as the Upper Ocala and the
more indurated limestone is considered to represent the Lower Ocala.
The contact between the Residuum and the Upper Ocala, often described as the Transition Zone, is
usually very weathered. Relatively significant void spaces (4 to 10 ft thick) have been
identified in the Lower Ocala just below the contact with the Upper Ocala. These void spaces
are underlain by a clay filled layer, which is typical of Karst features. The clays are
considered to restrict the downward flow of water and subseguently create solution cavities.
1.6 HYDROGEOLOGY
Aguifer Testing Program
An Aguifer Test Program consisting of three separate tests was performed in the Floridan Aguifer
by Firestone as a part of the Remedial Investigation/Feasibility Study ("RI/FS"). Specifically,
the tests were performed in the Ocala Limestone and overlying Residuum which comprise the Upper
Floridan Aguifer at the Site. These test were intended to characterize the conditions and
properties of the formations and are listed as:
(1) Single borehole (double-packer) test;
(2) Multi-well aguifer test; and
(3) Production well monitoring tests.
The purpose of the Aguifer Testing Program was to evaluate the hydrogeologic properties of the
Ocala Formation and overlying Residuum and to assess the hydraulic connection between the
Residuum, Upper and Lower Ocala Formations.
The objectives of the Aguifer Testing Program were to:
Gather additional data to assess the rate and direction of groundwater flow in the
water-bearing zones underlying the Site,
Investigate the hydrological continuity between the permeable zones of the Ocala Formation
and the overlying water-bearing zones of Residuum; and
Gather additional data on the hydrogeologic properties(hydraulic conductivity,
transmissivity, and yield) of the Ocala Formation underneath the Site.
The Aguifer Testing Program results were also used to evaluate the groundwater flow velocity and
chemical migration, and to assess potential groundwater remedial alternatives during the
Feasibility Study.
The two hydrogeologic water bearing units of interest at the Site consist of the Residuum and
the underlying Floridian Aguifer, and have been referred to as the Residuum, Transition Zone,
Upper and Lower Ocala Limestone at the Firestone Site (Figure 1-3). Hydrogeologic
characterization was performed at the Site through evaluation of data generated from monitoring
well installation in both units and aguifer testing performed in the Ocala Limestone.
Groundwater elevation measurements were used to assess the
groundwater flow trends and gradients beneath the Site. The aguifer testing was performed to
determine the hydraulic properties of the Ocala Limestone in the vicinity of the courtyard.
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The uppermost hydrostratigraphic unit is the Residuum. Water saturated zones have not been
encountered in the Residuum at the Site which indicates that the Residuum is not continuously
saturated and the groundwater is confined in isolated permeable zones. The horizontal hydraulic
conductivity was determined to have an average rate of 4x10[-5] cm/sec. The Residuum has been
observed to possess strong downward vertical gradients with a rate ranging from approximately
0.7 to 1.9 ft/ft. It is likely that the strong vertical gradients are due to the unsaturated
nature of the Residuum, continuous drainage and recharge of isolated zones, and regional
downward flow components. Horizontal movement of groundwater within the Residuum is limited by
the lack of continuous water-bearing zones and low horizontal hydraulic conductivity.
It was found that there is hydraulic heterogeneity in the Upper Ocala with calculated hydraulic
conductivity values in the vicinity of 1x10[5] cm/sec. The relatively low hydraulic conductivity
of the Upper Ocala verifies its classification as a regional semi-confining unit for the Lower
Ocala. The vertical gradients measured in the Upper Ocala across the Site were fairly constant
and average 0.06 ft/ft. This information suggests that the downward movement of groundwater
within the Upper Ocala is a result of regional stresses and natural recharge-discharge
relationships. The average horizontal gradient was found to be approximately 0.002 ft/ft. The
horizontal groundwater flow directions are somewhat variable; southwest-west flow directions are
evident in the northeast corner of the Site, but are reversed in the southwest corner. Local
variations in groundwater flow directions that are not consistent with regional directions are
common in the upper portions of the Ocala. Undulations and depressions that have been identified
at the bedrock surface of the Ocala, localized permeability changes, and water table mounding in
the vicinity of the storm water detention pond may influence the groundwater flow patterns in
the Upper Ocala at the Site.
The hydraulic conductivity of the Lower Ocala is estimated to be on the order of 3x10[-1]
cm/sec. This estimate is consistent with published literature describing prolific zones and
potable water supplies within the lower portions of Ocala Limestone and is considerably greater
than the range established for the overlying weathered materials characteristic of the Upper
Ocala. The increased conductivity may be attributed to fracturing and more extensive
dissolution in the Lower Ocala. The primary component of flow is horizontal with gradient of
approximately 0.001 ft/ft for the southwest portion of the Site. A relatively flat
potentiometric surface has been identified across the remainder of the Site.
Recharge to the Residuum and the Ocala Limestone is primarily by infiltration of precipitation
and flows vertically downward. The Residuum is leaky and provides recharge to the underlying
Upper Ocala but at a limited rate. Horizontal movement in the Residuum is limited by the lack of
continuous water bearing zones and low hydraulic conductivity.
1.7 DEMOGRAPHY
There are eight residential mobile home parks located directly north of the Site. Reportedly,
there are a total of 250 units within these parks. Approximately, 956 people live directly north
of the Site in Census Block 207 which includes, but is not limited to, these trailer parks.
Additionally, within one mile of the Site, 70 people live north of Census Block 207. A large
flea market is also located directly north of the Site which is open to the general public on
Friday through Sunday.
Approximately 735 people live west of the Site and south of Sylvester Road within a one mile
radius of the Site and approximately 340 people live west of Pine Bluff Road within one mile
radius northwest of the Site.
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Another residential area, north of Sylvester Road, is located approximately three miles east of
the Site. There are approximately 140 residents in this area according to the 1990 Census. A
mobile home park is located approximately one mile east of the Site, on Sylvester Road.
According to the 1990 Census, 27 people live in ten housing units within this mobile home park.
Commercial businesses east of the Site on Sylvester Road include two transportation and
distribution companies. There is also a residential area less that a mile east of the Site.
According to the 1990 Census, there are approximately 600 residents that live within this area.
The seaboard Coastline Railroad separates the Site from the U.S. Marine Corps Logistics Base
which is the largest industrial and residential complex located south of the Site. The Base
employs approximately 2,700 civilians and provides housing for approximately 600 Marine
families.
Sylvester Road Elementary School (408 students) is located approximately one mile west of the
Site. In addition, two more elementary schools (1,145 students), a middle school (951 students),
and a high school (1,034 students) are located approximately three miles west of the Site.
The Albany city hospital is located west of the Flint River more than three miles from the Site.
1.8 ECOLOGY
There are two distinct vegetation zones at the Site: a grassy area located on the northern half
of the Site, and a wooded and wetland area located on the southern half of the Site.
The main grassy area that lies within the fenced area of the manufacturing plant and on the
northern half of the Site is periodically mowed and predominantly contains Bahia grass. Some
commonly occurring hydrophytic vegetation scattered throughout other grassy areas include reed
grass, vasey grass, maidencane, sedges, rushes and mild water pepper.
The southern half of the Site consists of a mixed southern pine/hardwood forest and large
wetland areas. The upland areas of the pine/hardwood forest consist mostly of young slash pine
and live oak. Some sections of the upland area are barren or covered only with herbaceous
plants including golden aster, honeysuckle, black raspberry and goldenrods. The wetland areas of
the southern half contain such species as black willow, water oak, southern bayberry and
cattail.
The fauna on and around the Site observed in August 1991 include, but is not limited to, mammals
such as the white-tailed deer, raccoon, gray fox, gray sguirrel and eastern cottontail rabbit;
birds such as the common crow,mourning dove, bobwhite guail, turkey vulture, killdeer, cattle
egret, blue jay and mockingbird; reptiles such as the gopher tortoise; amphibians such as the
green frog; and pond macro-invertebrates such as water boatmen, water striders and dragonflies.
Four rare species believed to inhabit Dougherty County by the Georgia Department of Natural
Resources were not observed at the Site: the spotted bullhead, bluestripe shiner, hooded
pitcher plant, and chafseed. However, the gopher tortoise, believed to be rare in some parts of
southwestern Georgia, was spotted on the Site.
2.0 SITE HISTORY AND ENFORCEMENT ACTIVITIES
The Site is owned by the Albany-Dougherty Payroll Development Authority. Under lease, the sole
use of this Site by the former Firestone Tire & Rubber Company was the manufacture of pneumatic
tires. Bridgestone/Firestone, Inc. ("Bridgestone/Firestone") is the successor to Firestone Tire
& Rubber Company (The names are used interchangeably throughout this ROD). Manufacturing at the
facility was carried out from 1968 to 1986 within a 1,840,000 ft[2] building. Construction of
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the complex commenced in 1967 and several additions were built over the years. Bridgestone/
Firestone, Inc. ceased operations at the Site in 1986. The Site was proposed for the NPL in
June of 1988 and was finally included in October of 1989. EPA issued a Special Notice Letter to
Bridgestone/Firestone in March of 1990, giving them an opportunity to conduct the RI/FS at the
Site. The company entered into an Administrative Order on Consent (AOC) with EPA in 1990 to
study the Site further and to evaluate possible actions to address any contamination found.
Except for remedial activities discussed below, the Site remained inactive until March 1990, at
which time Cooper Tire Company purchased the Bridgestone/Firestone, Inc. leasehold and began
renovations for future operations.
In 1985, Bridgestone/Firestone, Inc., as a part of facility closure voluntarily initiated a
study of possible contamination in soil, groundwater, and surface water. Based on the results
of this assessment, a scope of work for further studies was defined. The study identified the
courtyard and the burn pit as two major Areas of Contamination (AOCs). These areas are presented
on Figure 1-2.
The area referred to as the courtyard is located on the eastern side of the plant and is
enclosed by the manufacturing buildings on three sides. The courtyard was designed for shipping
and material handling operations. Materials used in the manufacturing processes and general
facility operations were delivered to the courtyard by both rail and roadway. Underground
storage tanks, which were removed in interim cleanup actions in 1986, were formerly located in
two areas of the courtyard. Transformers mounted on concrete pads were located in the
Courtyard. Four above-ground fuel oil storage tanks remain on-site.
The second area of concern, the burn pit area, covers about 3,000 sguare feet near the
intersection of the east drainage ditch and the storm water retention pond. The burn pit seems
to have been built to collect runoff from a 6,000 gallon spill of anti-oxidant (Santoflex 13) in
1980. The fluid was later pumped into 55-gallon drums and stored adjacent to the pit. Later
in 1980 this material and 65 partially rifled drums of liguid waste cement were burned as a fire
training exercise.
Bridgestone/Firestone, Inc. took a series of interim cleanup measures, including additional
groundwater monitoring to better define concerns identified in the 1985 study. The company
presented descriptions of their past investigations to EPA in a Scoping Document submitted on
October 7, 1990 as a preliminary remedial investigation report under the Administrative Order.
The cleanup actions and studies which Firestone conducted at the
Site consisted mainly of the following activities:
• Identified and analyzed soil and debris piles, and removed and disposed contaminated
materials. Approximately 441 cubic yards (c.y.) of rubbish and debris and 105 c.y.
of soil were taken to the Oxford Solid Waste Landfill in Albany during these general
cleanup activities). Empty 5-gallon containers and a few 55gallon drums were
disposed at a regulated facility in Alabama.
• Studied PCB transformer leaks in interior of building, on the building, and in the
courtyard; removed transformers, roof materials, and concrete pads; cleaned up areas
surrounding former transformers and placed in a permitted facility.
• Installed monitoring wells in surficial aguifer and Upper Floridan Aguifer and
collected soil samples in the courtyard to determine if the source area of the
contamination would affect groundwater.
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• Removed underground storage tanks (USTs).
• Studied burn pit/buried drum area, excavated the burn pit; removed and disposed of
approximately 160 drums, which contained material similar to waste rubber cement and
Banbury Sludge (material used to make tires/all material passed TCLP test), and
contaminated soil and water; and collected samples to determine the adeguacy of the
cleanup.
• Identified areas of potential subsurface drum disposal which were evaluated by a
magnetic survey, but no additional buried drums or waste material were identified.
• Sampled surface water and sediments in the storm water retention pond and drainage
ditches flowing into the pond.
3.0 HIGHLIGHTS OF COMMUNITY PARTICIPATION
Public participation reguirements in CERCLA Section 117 were met in the remedy selection
process. The Community Relations Plan was finalized in 1991 for the Firestone Tire and Rubber
Superfund Site. This document list contacts and interested parties throughout the government
and the local community. The plan also establishes communication pathways to assure timely
dissemination of pertinent information.
On August 1, 1991, EPA held a public information session to announce the start of the Firestone
Site RI/FS. The RI/FS Workplan, Risk Assessment, Technical Memorandums, RI/FS Reports, Proposed
Plan and any other documents EPA used to prepare a preferred remedy were released to the public
on December 30, 1992. The documents were made available to the public in both the administrative
record docket and the information repository maintained at the EPA docket room at Region IV
Headguarters in Atlanta, Georgia and at the Dougherty Public Library, 300 Pine Avenue in Albany,
Georgia. A public comment period was held from December 30, 1992 to January 29, 1993.
Notices were placed in the Albany Herald newspaper on December 28, 1992, January 5 and 11, 1993
announcing the comment period. In addition to the public comment period and the administrative
record files, a public meeting was held on January 12, 1993 at the Albany City Hall. At this
meeting representatives from EPA and Georgia Environmental Protection Division answered
guestions and addressed community concerns.
A response to all significant comments received during the public comment periods is included in
the Responsiveness Summary (Appendix A), which is a part of this Record of Decision.
This decision document presents the selected remedial action for the Firestone Tire and Rubber
Site, chosen in accordance with CERCLA, as amended by SARA and to the maximum extent
practicable, the NCP. The decision for this Site is based on the administrative record. The
reguirements under Section 117 of CERCLA/SARA for public and state participation have been met
for this remedy selection.
4.0 SCOPE AND ROLE OF RESPONSE ACTION
This ROD addresses contamination remaining in approximately 20 cubic yards of PCB contaminated
soil and Volatile Organic Compounds (VOCs) in shallow groundwater (Residuum, Transition Zone and
Upper Ocala) beneath the Firestone Site. The contaminated soils pose a threat to human health
and the environment from possible ingestion (eating or drinking), inhalation (breathing) or
dermal contact (through the skin). Also, the groundwater could pose a threat if it were to
migrate off-site or be used as a water source in the future. The purpose of the selected remedy
is to prevent current and future exposure to the contamination by treating the soil and
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groundwater to reduce movement of contaminants. This is the only ROD contemplated for the Site.
5.0 SUMMARY OF SITE CHARACTERISTICS
5.1 Nature and Extent of Contamination
The following section provides a description of the nature and extent of the contamination found
in each media during the RI.
5.1.1. Confirmatory Sampling of the Former Interior PCB Transformer Locations
A total of 10 floor wipe samples were collected from interior transformer locations to verify
that previous remedial activities had achieved the PCB target cleanup level of 10 ug/cm[2]. The
samples were collected in accordance with the FSAP and analyzed for PCBs. Sample results
indicated that PCB concentrations for all areas were below detection limits.
5.1.2 Groundwater Sampling
A total of 17 groundwater wells and one piezometer were installed at depths ranging from 32-190
ft. A total of 46 groundwater samples were collected from the monitoring wells located
throughout the Site, between August 14, through October 3, (Phase I), and December 9, through
December 12 (Phase II), 1991. In addition to the groundwater samples, 9 duplicates, 4 matrix
spikes and matrix spike duplicates (MS/MSD), 27 field blanks, 22 trip blanks and 2 equipment
rinsate samples were collected as per FSAP and Quality Assurance Project Plan (QAPP). All of
the groundwater samples were analyzed for the Contract Laboratory Program's (CLP) Target
Compound List/Target Analyte List (TCL/TAL) parameters. Contaminants found in the groundwater
at concentrations that exceed a Hazard Quotient of 1 or an upper bound cancer Risk of 1x10[-6]
include Antimony, Carbon-Disulfide, 1,1-Dichloroethene Beryllium, Benzene,
1,1,1-Trichloroethane, PCBs Lead, Chromium and Bis (2-Ethylhexyl) phthalate (DEHP). Groundwater
sampling locations are provided in Figure 5-1. Figures 5-2 thru 5-4 provide the monitoring well
locations screened in the contaminated aguifers and indicator contaminants identified during the
RI activities. A summary of the contaminants detected during groundwater sampling activities is
presented in Table 5-1.
5.1.3. Surface Water Sampling
Six surface water samples were collected after storm events to characterize on-site water
guality conditions. These six samples were analyzed for TCL/TAL parameters. Four additional
surface water samples were collected on December 12, 1991 to compare on-site water guality to
state and federal water guality criteria. Three samples were collected from the storm water
detention pond and field tested for water hardness, one sample was collected from the East
Ditch, located just upstream from the area where development water was discharged. This sample
was analyzed for TCL VOCs. No contaminants were found in the surface water at concentrations
that exceed a Hazrd Quotient of 1 or an upper bound cancer risk of 1x10[-6]. Surface water
sampling locations are provided in Figure 5-1. A summary of the contaminants detected during
surface water sampling activities is presented in table 5-4.
5.1.4 Surface Soil Sampling
A total of 22 surface soil samples were collected throughout the Site. The purpose of this
sampling effort was to characterize surface soil at the Site and to obtain chemical data for use
in the baseline risk assessment. The surface samples were collected in accordance with the Field
Sampling and Analysis Plan and were analyzed for all TCL/TAL parameters. No contaminants were
found in the surface soil at concentrations that exceed a Hazard Quotient of 1 or an upper bound
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cancer risk of 1x10[-6]. Surface soil sampling locations are provided in Figure 5-1. A summary
of the contaminants detected during surface soil sampling activities is presented in table 5-2.
5.1.5 Subsurface Soil Sampling
A total of 37 subsurface soil samples were collected at 12 soil boring locations and 6 well
cluster locations. The purpose of this soil sampling effort was to develop a more complete soil
profile characterization of the Site and to evaluate the potential for contamination to migrate
from the soil to the groundwater. The subsurface samples were collected in accordance with the
Field Sampling and Analysis Plan (FSAP) and were analyzed for all TCL/TAL parameters. PCBs were
found at concentrations greater than the Toxic Substances Control Act (TSCA) - reguired cleanup
level of 10 ppm in four subsurface soil samples collected in a former transformer location of
the courtyard area. The estimated volume of contamination that exceeds 10 ppm is 20 cubic yards.
No other contaminants were found in the subsurface soil at concentrations that exceed a Hazrd
Quotient of 1 or an upper bound cancer risk of 1x10[-6]. Subsurface soil sampling locations are
provided in Figure 5-1. A summary of the contaminants detected during subsurface soil sampling
activities is presented in table 5-2.
5.1.6 Sediment Sampling
A total of 16 grab sediment samples from ten locations and 2 composite samples from four
locations were collected to characterize the on-site sediment guality. Samples were collected at
0 to 0.5 ft. and 1.5 to 3 ft intervals in accordance with the FSAP. With the exception of the
composite samples, all of the samples reguired by the workplan were analyzed for all TCL/TAL
parameters. The composite samples were analyzed for TCL semivolatile organic compound (SVOC),
PCBs and pesticide parameters, and TAL parameters. Four additional sediment samples, not
described in the RI/FS Workplan were collected and analyzed for Total Organic Carbon (TOG). The
TOG results were used in the baseline risk assessment. No contaminants were found in the
sediments at concentrations that exceed a Hazrd Quotient of 1 or an upper bound cancer risk of
1x10[-6]. Sediment sampling locations are provided in Figure 5-1. A summary of the contaminants
detected during sediment sampling activities is presented in table 5-3.
5.1.7 Confirmatory Sampling of Former Courtyard PCB Transformers
Twenty-three soil samples from 13 locations were collected during the RI. These samples were
collected to verify that remedial measures to remove courtyard transformers and surrounding soil
containing PCBs had achieved the PCB target cleanup level of 10 mg/kg. The samples were
collected in accordance with the FSAP and were analyzed for PCBs. Sample locations are provided
in Figure 5-1.
6.0 SUMMARY OF SITE RISKS
CERCLA directs the Agency to conduct a baseline risk assessment 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.
EPA's cleanup goals for contaminated soils are based on potential for cancer risk range of
1x10[-4] to 1x10[-6] (no more than an increased chance of one additional case in ten thousand to
one million) or a non-cancer Hazardous Index above 1.0 (or possible exposure to total
contaminants exceeding doses known not to cause harmful effects). The baseline risk assessment
indicates that current Site risk from soil contamination exceeds action or cleanup levels only
for polychlorinated biphenyls (PCBs).
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Past removal activities in the courtyard area have already removed PCB transformers, concrete
pads, and PCBs from the soil to 10 milligrams per kilogram (mg/kg) or parts per million (ppm),
which is eguivalent to the Toxic Substances Control Act (TSCA) -reguired cleanup level for the
smallvolume and low concentration of PCBs present at the Site. However, 4 samples near the
former PCB transformers were found to exceed 10 mg/kg (10 ppm). Concentrations varying from 17.0
to 230.0 mg/kg were identified in these samples at depths ranging from 4 to 5.5 ft. The current
estimate of PCB contaminated soil remaining on-site is 20 cubic yards (c.y.). Therefore, soil
cleanup will be reguired in this area to reduce the threat posed by the PCB contamination.
The major risk at the Site, however, is contamination in the shallow groundwater exceeding
Maximum Contaminant Levels (MCLS) or other cleanup levels. The RI data indicate that several
VOCs were identified in shallow wells primarily located in the courtyard area at levels
exceeding MCLs or action levels. The specific VOCs are 1,1,1-trichloroethane (TCA) , 1,1-
dichloroethylene (DCE), Bis (2-Ethylhexyl) Phthalate (DEHP) and Benzene. In addition to the
VOCS, beryllium, antimony, lead, carbon disulfide, Chromium and PCBs (PCBs only in one well)
above the MCL were found in the groundwater at levels that exceed cleanup standards. Sample
results from the Lower Ocala did not indicate the presence of of any hazardous constituents at
levels above MCLs or any other cleanup levels.
The baseline risk assessment also evaluated the health impacts associated with potential future
residential development of the manufacturing area and southern portions of the Site. When EPA
assumes residents (children and adults) are living on the Site property itself and depend
exclusively on local groundwater from the Upper Ocala/Transition Zone as a water source, both
upper bound cancer risk (greater than 1x10[-4] or an increased chance of one additional case in
ten thousand) and non-cancer hazard estimate (greater than 1.0) do exceed established acceptable
risk levels. In all cases unacceptable risks and hazards were a result of drinking contaminated
groundwater and breathing volatile groundwater chemicals during showering. In addition, the
shallowwater-bearing zone does not produce an adeguate water supply. However, even if the
southern portions of the property were converted to residential, local shallow groundwater would
probably not be used because connections to the municipal system are already available. The
plant itself is already served by city water and city sewer. The total lifetime cancer risk for
potential onsite residents in the southern portions of the Site would be 7x10[-4] (a chance of 7
additional cancer cases in 10,000 people) which exceeds EPA's target range. The Hazard Index for
substances causing harmful effects other than cancer would be 17 for this area, which greatly
exceeds acceptable exposure and warrants cleanup.
Contaminants of concern (COCs) were chosen based on concentration, toxicity, mobility, and
freguency of detection for the contaminants present. EPA expects that meeting cleanup goals for
these will result in sufficiently reducing risks posed by less harmful contaminants as well.
6.1 CONTAMINANTS OF CONCERN
The majority of the wastes and residues generated by production operations at the facility have
been managed, treated, and disposed of on-site throughout the Site's history. The significant
contaminated areas of concern are the courtyard area where shipping, handling, and temporary
storage of materials including hazardous substances occurred and the burn pit where liguid waste
was burned and partially-filled 55-gal drums containing waste materials characteristic of waste
rubber cement and Banbury sludge were buried. The chemicals measured in the various
environmental media in the Remedial Investigation were evaluated for inclusion as chemicals of
potential concern in the risk assessment by application of screening criteria. The criteria
used to select the contaminants of concern included:
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1. a general review of the Site data,
2. a review of designations to the data,
3. a comparison of the detects with that of the blanks,
4. a review of the sample guantitation limits,
5. a review of the tentatively identified compounds,
6. an evaluation of the apparent statistical distribution of the data,
7. an examination of the Freguency of detection,
8. an evaluation of the contaminants verses essential nutrient trace levels elements, and;
9. a comparison of the appropriate health-based criteria.
Separate lists of chemicals of potential concern were identified for each of the past waste
management areas. The contaminants of concern for the Site area include Antimony, Beryllium,
Benzene, Carbon Bisulfide, Chromium, 1,1-DCE, PCBs, 1,1,1-Trichloroethane, 1,1-Dichloroethylene,
Chloroform, Tetrachloroethylene, Toluene, Bis(2ethylhexy)phthalate, Di-n-butylphthalate,
1,IDichloroethane, Acetone, Carbon Bisulfide, Ethylbenzene, Trichloroethylene, Xylenes,
2-Methyl-2-pentanone, Polychlorinated Biphenyls, 2-Butanone, 1,2-Dichloroethylene, 2-Hexanone,
Pyrene, Magnesium, Selenium, and Zinc.
The arithmetic average concentrations, 95% upper confidence levels, and freguency of detections
of contaminants found in the various media tested are contained in Tables 6-1 through 6-8. The
exposure concentrations represent a 95% upper confidence limit on the mean of data collected
from both surface and subsurface samples and therefore, the data in the Table does not
necessarily reflect land surface concentrations.
6.2 EXPOSURE ASSESSMENT
Whether a chemical is actually a concern to human health and the environment 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 seguence of events leading to contact
with a chemical) is defined by the following four elements:
a source and mechanism of release from the source,
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.
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 EPA's criteria. Three current potentially complete exposure
pathways and four future exposure pathways remained after screening. The current pathways
represent exposure pathways which could or do exist under current Site conditions while the
future pathways represent exposure pathways which could exist, in the future, if the current
exposure conditions change.
According to the Dougherty County Planning Commission, residential use of this land is possible.
In addition, industrial operation to the east would not serve as an absolute obstruction to
residential development in the southern portion of the Site and to the west. As a result, a
future potential residential scenario for residents living on the southern portions of the
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facility property was developed and evaluated.
The exposure and intake parameters used in generating risk caused by current and future
scenarios are presented in Tables 6-9 through 6-14. Exposure by each of these pathways was
mathematically modeled using generally conservative assumptions and is further discussed in
Section 6.5.
The current pathways are:
on-site worker
off-site residential populations
trespassers
The future pathways are:
on-site worker
off-site residential populations
trespassers
residents living on the southern portion of the Site
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, with the exception of the groundwater pathway. The chronic daily intakes
were then used in conjunction with cancer potency factors and noncarcinogenic reference doses
to evaluate risk. No current sensitive subpopulations were localized to the Site's area during
the exposure assessment.
6.3. TOXICITY ASSESSMENT
Toxicity values are used in conjunction with the results of the exposure assessment to
characterize Site risk. EPA has developed critical toxicity values for carcinogens and
noncarcinogens. Cancer Slope Factors (CSFs) have been developed by EPA's Carcinogenic
Assessment Group for estimating excess lifetime cancer risks associated with exposure to
potentially carcinogenic chemicals. 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 the risks calculated from
the CSF. Use of this conservative approach makes underestimation of the actual cancer risk
highly unlikely. Cancer Slope Factors 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. The CSFs for oral ingestion and inhalation exposure to the
contaminants of concern at the Site are contained in Table 6-15.
Reference doses (RfDs) have been developed by EPA for indicating the potential for adverse
health effects from exposure to chemicals exhibiting noncarcinogenic effects. RfDs, which are
expressed in units of mg/kg/day, are estimates of lifetime daily exposure levels for humans,
including sensitive individuals. Estimated intakes of chemicals from environmental media can be
compared to the RfD. RfDs are derived from human epidemiological studies or animal studies to
which uncertainty factors have been applied (e.g., to account for the use of animal data to
predict effects on humans). These uncertainty factors help ensure that the RfDs will not
underestimate the potential for adverse noncarcinogenic effects to occur. The RfDs for oral
ingestion and inhalation exposure to the contaminants of concern at the Site are contained in
Table 6-15. The following information corresponds with the alphabets located in the "Weight of
Evidence Category" column of the table.
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Group A - Human Carcinogen; Group B - Probable Human Carcinogen (Bl - limited evidence from
epidemiologic studies; B2 - Sufficient evidence from animal studies and inadeguate or no data
from epidemiologic studies); Group C - Possible Human Carcinogen; Group D - Not Classifiable as
to Human Carcinogenicity and Group NE - Evidence of Non-Carcinogenicity for humans.
6.4 RISK CHARACTERIZATION
Human health risks are characterized for potential carcinogenic and noncarcinogenic effects by
combining exposure and toxicity information. Excessive lifetime cancer risks are determined by
multiplying the estimated daily intake level with the cancer potency factor. These risks are
probabilities that are generally expressed in scientific notation (e.g., lxlO[-6]). An excess
lifetime cancer risk of 1x10[-6] indicates that, as a plausible upper bound, an individual has a
one in one million additional (above their normal risk) chance of developing cancer as a result
of site related exposure to a carcinogen over a 70-year lifetime under the assumed specific
exposure conditions at a Site.
The Agency considers individual excess cancer risks in the range of 1x10[-4] to 1x10[-6] as
protective; however the 1x10[-6] risk level is generally used as the point of departure for
setting cleanup levels at Superfund Sites. The point of departure risk actions that result in
risks at the more protective end of the risk range.
Potential concern for noncarcinogenic effects of a single contaminant in a single medium is
expressed as the hazard guotient (HQ) (or the ratio of the estimated intake derived from the
contaminant concentration in a given medium to the contaminant's reference dose). A HQ which
exceeds one (1) indicates that the daily intake from a scenario exceeds the chemical's reference
dose. By adding the HQs for all contaminants within a medium or across all media to which a
given population may reasonably be exposed, the Hazard Index (HI) can be generated. The HI
provides a useful reference point for gauging the potential significance of multiple contaminant
exposures within a single medium or across media. An HI which exceeds unity indicates that
there may be a concern for potential health effects resulting from the cumulative exposure to
multiple contaminants within a single medium or across media.
The health risks resulting from exposure to the current pathways are as follows:
Overall, the baseline risk assessment indicates the unacceptable health hazards and risks are
not posed to humans currently having access to the Site. The summed upper bound cancer risks
for reasonable maximum exposures to current workers at the Site is within the acceptable risk
range and the non-carcinogenic Hazard Index is below the comparison Hazard Index threshold value
of 1.0. The overall upper bound cancer risks for reasonable maximum exposures to trespassers,
both youths and adults, is at or below the lower end of the risk range (1x10[-6]), and
noncarcinogenic Hazard Indices are below 1.0.
The health risk resulting from exposure potential future pathway are as follows:
The baseline risk assessment also evaluated the health impacts associated with potential future
residential development of the manufacturing area and southern portions of the Site. When EPA
assumes residents (children and adults) are living on the Site property itself and depend
exclusively on local groundwater from the Upper Ocala/Transition Zone as a water source, both
upper bound cancer risk (greater than 1x10[-4] or an increased chance of one additional case in
ten thousand) and non-cancer hazard estimate (greater than 1.0) do exceed established acceptable
risk levels. In all cases unacceptable risks and hazards were a result of drinking contaminated
groundwater and breathing volatile groundwater chemicals during showering. However, even if the
property were converted to residential, local shallow groundwater would not be used because
connections to the municipal system are already available. In addition, the shallow
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water-bearing zone does not produce an adequate water supply. The plant itself is already
served by city water and city sewer. The total lifetime cancer risk for potential on-site
residents in the southern portions of the Site would be 7x10[-4] (a chance of 7 additional
cancer cases in 10,000 people) which exceeds EPA's target range. The Hazard Index for
substances causing harmful effects other than cancer would be 17 for this area, which greatly
exceeds acceptable exposure and warrants cleanup. A summary of cancer risk and non-carcinogenic
health hazard estimates for all scenarios considered at the Site and designation of chemicals
and media for which remediation levels were derived are presented in Table 6-16. A potential
on-site resident in the manufacturing area scenario was presented in the FS. After review, EPA
has determined that the scenario is not a probable land use for that portion of the Site.
However, "potential on-site residents in the southern portions of the Site" scenario shall be
included with the factors used to develop the contaminants of concern for this Site. The
following table presents each chemical that poses unacceptable risks for all scenario
considered.
6.5 ENVIRONMENTAL RISK
There are two distinct vegetation zones at the site: a maintained grassy area on the north half
of the Site and a natural-type area on the south half. The grassy area lies to the west of the
manufacturing plant, and is periodically mowed in certain areas. This area contains scattered
areas of some hydrophytic vegetation. Most of the hydrophytic vegetation is in a small wetland
area along Sylvester Road.
The grassy area contains mainly Bahia grass and some hydrophytic vegetation, including reed
grass, maidencane, sedges, rushes and mild water pepper. The wetland areas of the southern half
contain such species as black willow, water oak, southern bayberry and cattail. The other large
wetland area in the southeastern section of the Site contains the largest and most mature trees
on the Site. Trees in this area include slash pine, water oak, laurel oak and black oak.
The fauna on and around the Site observed during the RI/FS include, but are not limited to,
mammals such as the white-tailed deer, raccoon, gray fox, gray sguirrel and eastern cottontail
rabbit; birds such as the common crow, mourning dove, bobwhite guail, turkey vulture, killdeer,
cattle egret, blue jay and marking bird; reptiles such as the gopher tortise; amphibians such
as the green frog; and pond macroinvertebrates such as water boatmen, water striders and
dragonflies. Faunal observations at the Site included visual observations of the animal, or any
signs of the animal such as tracks, nests or song.
In general, adverse impacts to aguatic, avian and mammalian environmental receptors are
unlikely. Surface water and sediment chemical concentrations are generally below comparison
values and concentrations of chemicals in soils were unlikely to pose a significant food chain
impact under current Site conditions. Although some isolated elevated concentrations of zinc and
chromium were detected in sediments, the lack of sustained bodies of water and, therefore, the
lack of widespread aguatic receptors suggests that the impact of these concentrations is likely
to be limited.
7.0 DESCRIPTION OF CLEANUP ALTERNATIVES
The cleanup alternatives considered for both soil and groundwater in the Feasibility Study (FS)
are discussed below, and the criteria EPA uses to evaluate the options are discussed in Section
7.1 Alternatives for Groundwater Remediation
Groundwater Alternative A: No Action
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In this groundwater alternative, no further cleanup action would be taken. EPA is required by
the National Oil and Hazardous Substances Pollution Contingency Plan (NCP) to use this option as
the baseline against which others are compared. This alternative is not protective of the
groundwater and will not achieve ARARs. There would be no cost for this alternative.
Groundwater Alternative B: Institutional Controls
Alterative B would consist of institutional controls, such as deed restrictions or well drilling
bans, in combination with groundwater monitoring. This alternative would reduce any potential
health risks associated with contaminated groundwater. Deed restrictions would be placed on the
contaminated area to prohibit the installation of new water supply wells. The potential for
cross-contaminating of the lower groundwater zones and increasing the hydraulic gradient would
be prevented by prohibiting the installation of new wells. This alternative would provide for
natural attenuation of contaminants to restore groundwater quality. Groundwater sampling and
analysis for identified contaminants of concern would be performed quarterly in the courtyard
area and at the boundary of the contaminated area. The results from the groundwater monitoring
would be used to determine the effectiveness of natural attenuation as a remedial option and to
assess potential contaminant migration. A review of the groundwater data collected at the Site
would be evaluated quarterly until contaminant concentrations in the groundwater no longer
exceed groundwater cleanup levels for three consecutive sampling events. The total cost to
implement this remedy is estimated at $334,500.
Groundwater Alternative C: Institutional Controls/Containment
Groundwater Alternative C would consist of the same controls and monitoring as B with
containment. This would involve installing an asphalt cap over portions of the courtyard area
and any necessary drainage controls. Drainage controls would provide additional protection from
infiltration and damage to the cap. Deed restrictions and groundwater monitoring would be
implemented as described for Alterative B to monitor movement and the effectiveness of natural
attenuation of groundwater. Groundwater sampling and analysis for identified contaminants of
concern would be performed quarterly in the courtyard area and at the boundary of the
contaminated area. The results from the groundwater monitoring would be used to determine the
effectiveness of natural attenuation and containment as a remedial option and to assess
potential contaminant migration. A review of the groundwater data collected at the Site would
be evaluated quarterly until contaminant concentrations in the groundwater no longer exceed
groundwater cleanup levels for three consecutive sampling events. The estimated cost is
$611,500 for this alternative.
Groundwater Alternative D: Controls, Pump & On-site Treatment with Discharge to POTW
This alternative would include the same controls and monitoring as Alterative B in addition to
pumping contaminated groundwater and treating it using air stripping on-site. Extraction of
groundwater would be accomplished by installing pumps in the courtyard area monitoring wells in
which contaminants have been detected above the cleanup levels. The installation of additional
wells may be required to adequately extract the contaminated groundwater. The location and
number of wells in the manufacturing area depends on the areal extent of contamination, area of
influence produced by each well, and the variability in pneumatic permeability around the
manufacturing area. Some pilot-scale treatability work would likely be required to complete the
design of the air stripping system. The extracted groundwater would be pumped through any
necessary solids removal system to remove suspended and/or dissolved solids (including metals)
and through the air stripping system to remove VOC's. The treated groundwater would be
discharged through the existing sewer system to the local Publicly Owned Treatment Works (POTW)
after all discharge requirements are met. Groundwater sampling and analysis for identified
contaminants of concern would be performed quarterly in the courtyard area and at the boundary
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of the contaminated area. The results from the groundwater monitoring would be used to
determine the effectiveness of the treatment system as a remedial option and to assess potential
contaminant migration. A review of the groundwater data collected at the Site would be evaluated
guarterly until contaminant concentrations in the groundwater no longer exceed groundwater
cleanup levels for three consecutive years. Groundwater cleanup levels are expected to be
achieved within thirty years. The emissions from the air stripping system would meet all State
and Federal air guality reguirements relating to the treatment system. The estimated cost
for this alternative is $1,880,000.
7.2 Alternatives for Soil Remediation
Alternatives for soil which would treat the principal threats posed by the PCB contamination
vary by treatment, guantities and characteristics of the residuals and untreated wastes.
Soil Alternative A: No Action
No action would be taken to address PCBs remaining in the soil above 10 mg/kg at no further
cost. The NCP reguires using "no action" as a basis for comparing active cleanup measures.
This alternative would not be protective and would not achieve ARARs.
Soil Alternative B: Institutional Controls
Alternative B would use deed restrictions on the Site for future and present land use as a
control to reduce the risks posed by PCBs at the Site. In conjunction with deed restrictions, a
security fence would be constructed around the contaminated area to reduce the possibility of
ingestion or direct contact with the PCBs. A monitoring well(s) would be installed and sampled
to determine if the PCBs were moving to the groundwater. The estimated cost is $82,500.
Soil Alternative C: Controls and Containment
Alternative C would use the same controls and monitoring as B in addition to containment to
reduce potential health risks associated with the PCBs in soils. The fencing would reduce the
possibility of direct contact with the PCBs. Containment would include the construction of an
asphalt cap over the contaminated area. The cap design would include drainage controls at an
estimated cost of $123,200.
Soil Alternative D: Excavation/Off-Site Disposal
Soil Alternative D would include excavation of the contaminated soil above 10 ppm and
transportation to an off-site Toxic Substances Control Act (TSCA) -permitted landfill.
Excavation would be done by conventional construction eguipment and loaded into a lined, covered
roll-off containers or dump trucks. The excavated area would be backfilled with clean fill
material. Total cost is estimated at $56,200.
Soil Alternative E: Solvent Extraction/On-Site Disposal of Treated Soil/Off-Site Disposal of
PCBs
This alternative would involve excavation, treatment, and on-site disposal of the treated soil.
A solvent extraction process would be used to treat the contaminated soils on-site. This
treatment involves removing PCBs from the excavated soil. Extracting the PCBs may reguire more
than one stage to reduce PCB concentrations in the soil to less than 2 mg/kg so they will be
acceptable for on-site disposal with no additional controls. Recovered PCBs would be placed in
appropriate containers and shipped off-site for disposal at a TSCA-permitted facility. The
estimated cost is $214,800 for this alternative.
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8.0 SUMMARY OF COMPARATIVE ANALYSIS OF ALTERNATIVES
A detailed comparative analysis was performed on the five soil alternatives and four groundwater
alternatives during the FS using the nine evaluation criteria set forth in the NCP. The
advantages and disadvantages were compared to identify the alternative with the best balance
among these nine criteria.
The NCP categorizes the none criteria into three groups:
(1) Threshold Criteria - overall protection of human health and the environment and compliance
with ARARs (or invoking a waiver) are the threshold criteria that must be satisfied in order for
an alternative to be eligible for selection;
(2) Primary Balancing Criteria - long-term effectiveness and permanence; reduction of toxicity,
mobility, or volume; short-term effectiveness; implementability and cost are primary balancing
factors used to weigh major trade-offs among alternative hazardous waste management strategies;
and
(3) Modifying Criteria - state and community acceptance are modifying criteria that are
formally taken into account after public comment is received on the proposed plan and
incorporated in the ROD.
The selected alternative must meet the threshold criteria and comply with all ARARs or be
granted a waiver for compliance with ARARs. Any alternative that does not satisfy both of these
reguirements is not eligible for selection. The Primary Balancing Criteria are the technical
criteria upon which the detailed analysis is primarily based. The final two criteria, known as
Modifying Criteria, assess the public's and the state agency's acceptance of the alternative.
Based on these final two criteria, EPA may modify aspects of a specific alternative.
The following analysis is a summary of evaluation of alternatives for remediating the
contamination found at the Firestone Site under each of the criteria. A comparison is made
between each of the alternatives for achievement of a specific criterion.
THRESHOLD CRITERIA
8.1 Overall Protection of Human Health & Environment addresses whether or not a remedy provides
adeguate protection and describes how risks are eliminated, reduced, or controlled through
treatment, engineering controls or institutional controls. Criteria used to evaluate the
protectiveness of an alternative included the following: (1) no cancer risks from exposure to
groundwater with concentrations that exceed MCLs; (2) no significant risks of threshold toxic
effect (HI less than 1); and (3) no significant risk or adverse impact on the environment.
Groundwater Alternative A would not protect human health or the environment from the potential
risks posed by the groundwater contamination at the Site. Alternatives B and C would provide
protection to human health by reducing the potential for ingesting groundwater through deed
restrictions. In addition, C would reduce movement of contaminants into the deeper aguifer
which is a water supply source. Groundwater extraction in D would provide additional protection
through treatment of groundwater to remove the contamination.
Since Groundwater Alternative A does not eliminate, reduce or control any of the exposure
pathways, it is therefore not protective of human health or the environment and will not be
considered further in this analysis.
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Soil Alternative A would not protect human health or the environment from risks posed by the
PCBs in the soil or meet cleanup levels. Alternatives B and C would provide some protection by
reducing the potential for direct contact with contaminants. The cap under Alternative C would
provide additional protection for the environment by reducing the penetration of water through
the source area. This would reduce the potential for contaminants to move into the groundwater.
A long-term risk would exist under C because the contaminants would be contained rather than
destroyed. Alternatives D and E would provide the most protection for human health and the
environment by removing contaminants from the Site. Solvent extraction would treat the
contaminated soils in E. Alternatives D and E would meet cleanup levels.
Since Soil Alternative A does not eliminate, reduce or control any of the exposure pathways, it
is therefore not protective of human health or the environment and will not be considered
further in this analysis.
8.2 Compliance with ARARs addresses whether or not a remedy will meet all of the applicable or
relevant and appropriate reguirements of other Federal and State environmental and/or provide
grounds for a waiver. The identified ARARs for this Site are listed in Section 10.2.
Groundwater Alternative A would not provide a way to evaluate compliance with the
chemical-specific cleanup reguirements. Action-specific reguirements would not be applicable to
A because no cleanup action would be taken. Alternatives B, C and D would comply with health and
environmental reguirements. There are no location specific reguirements applicable to the Site.
The 10 mg/kg TSCA action level is appropriate as a PCB cleanup level for Site soils. No
location-specific reguirements are appropriate to this Site. Soil Alternative A would not meet
any standards because no action would be taken. Alternative B, Controls, would not meet any
reguirements because no active measures would be included. Alternatives C, D and E would comply
with all federal and state action-specific reguirements.
Since Soil Alternative B would not comply with the TSCA action level, it will not be considered
further in this analysis.
PRIMARY BALANCING CRITERIA
8.3 Long-term Effectiveness and Permanence refers to expected residual risk and the ability of
a remedy to maintain reliable protection of human health and the environment over time, once
cleanup levels have been achieved. This criterion includes the consideration of residual risk
and adeguacy and reliability of controls.
Groundwater Alternative B would provide a means to measure change in contamination and would
provide additional protection of human health by restricting future use of the property.
Alternative C would provide long-term effectiveness and permanence and would also serve to
reduce movement of contaminants through containment. Alterative D would best reduce long-term
risk through extraction and treatment of groundwater.
Proper maintenance of the cap in Alternative C should ensure long-term reliability. In addition
under this alternative, monitoring would provide a way to measure the effectiveness of the cap.
Alternatives D and E would have better long-term effectiveness and permanence because the
contamination would be removed from the Site.
8.4 Reduction Toxicity, Mobility or Volume Through Treatment refers to the anticipated
performance of the treatment technologies a remedy may employ.
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No contaminated groundwater would be treated under Alternatives B or C. Thus, reduction in
toxicity mobility or volume would only result through the passive means of natural processes.
Alternative C would result in additional reduction in contaminant mobility by preventing rain
from penetrating the cap. The toxicity, mobility and volume would be reduced by Alternative D
at an accelerated pace by active means.
Soil Alternative C would not reduce toxicity or volume, but would reduce the potential for
movement of contaminants to the groundwater. The toxicity, mobility and volume of the
contaminants would be effectively reduced in Alternatives D and E by excavating the contaminated
soil and treating it either on or off-site. Alterative E would provide the only on-site
treatment remedy for the Site.
8.5 Short-Term Effectiveness refers to the period of time needed to complete the remedy and any
adverse impacts on human health and the environment that may be posed during the construction
and implementation of the remedy until cleanup levels are achieved.
Groundwater contamination currently exceeds cleanup levels at the boundary of the manufacturing
area. Risks during cleanup under Groundwater Alternatives B, C and D would be minimal. Risk to
Site workers would be somewhat higher, but this risk would be reduced by compliance with health
and safety regulations.
The short-term risk to the public and the environment under Soil Alternatives C, D and E would
be minimal. Risks to Site workers would be somewhat greater, but this risk would be reduced by
compliance with health and safety regulations.
8.6 Implementability is the technical and administrative feasibility of a remedy, including the
availability of materials and services needed to implement the chosen solution.
Groundwater Alternatives B, C and D would be the same with respect to implementability because
the technologies, the materials, and services reguired are readily available for each. The
overall effectiveness of these alternatives would be determined by sampling the groundwater at
the Site and in addition for D to monitor the treated effluent.
Soil Alternative C would reguire working with state and local government to establish and
enforce the deed restrictions. Capping, as specified under C, is a conventional and widely used
method for containing contamination. However, C might be difficult to implement, as it could
affect growth of the facility. Alternative D would be relatively easy to implement because
excavation is a widely used and proven method for removing contamination. The last alternative
would be difficult to implement due to the relatively complex nature of on-site treatment for
the small volume of soils to be treated. Treatability studies would be reguired during design
for E to insure that solvent extraction would work effectively.
8.7 Cost - The total costs associated with Alterative B would be lower than Alterative C or D.
The total present worth cost of Alternative B is $334,500, and the total present worth of C is
$611,500; while the present worth of D is $1,980,000.
Only Alternative C would reguire operation and maintenance costs after the cleanup was
completed. The total cost of Alternative C is estimated at $123,200; D's total cost would be
$56,200, and the estimated cost for E would be $214,800.
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MODIFYING CRITERIA
8.8 State Acceptance - EPA and GAEPD have cooperated throughout the RI/FS process. The State
has participated in the development of the RI/FS through comment on each of the planning and
decision documents developed by EPA, and the Proposed Plan and the Draft ROD and through
freguent contact between the EPA and the GAEPD Site project managers. GAEPD concurs with EPA on
the remedy selection to remediate the contaminated media at the Firestone Site. 8.9 Community
Acceptance - Based on comments received during the January 12, 1993 public meeting and the lack
of negative comments received during the comment period, it appears that the Albany community
generally agrees with the selected remedy.
9. 0 THE SEIiECTED REMEDY
Based upon consideration of the CERCLA reguirements, the detailed analysis of the alternatives
using the nine criteria, and public comment, EPA has selected Groundwater Alternative D (Pump
and Treat) and Soil Alternative D (Off-Site Disposal) to reduce risk at the Firestone Tire and
Rubber Site.
This preferred alterative will permanently treat the remaining threats at the Site. It will be
fully protective, cost-effective, and attain all Federal and State reguirements.
9.1 Performance Standards
(1) Soil Treatment
Soil contaminated with concentrations of PCBs that exceed 10 ppm (approximately 20 cubic yards)
shall be excavated and transported to a TSCA permitted landfill. The excavated area will be
backfiled with clean fill material.
(2) Groundwater Treatment
Groundwater extraction and treatment system shall be constructed by installing pumps in
monitoring wells in which contaminants have been detected above the cleanup levels. The
installation of additional wells may be reguired to adeguately extract the contaminated
groundwater. The location, type and number of pumps and wells reguired to extract the
contaminated groundwater will be determined during the Remedial Design. The extracted
groundwater would be pumped through any necessary solids removal system to remove suspended
and/or dissolved solids (including metals) and through the air stripping system to remove VOCs.
The treated groundwater would be discharged through the existing sewer system to the local
Publicly Owned Treatment Works (POTW) after all discharge reguirements are met. If the POTW
discharge becomes unavailable, EPA may amend the ROD to allow discharge to surface water. If
EPA deems necessary, additional air strippers and/or monitoring wells will be installed as part
of the remedial action to ensure compliance with the cleanup levels of the selected remedy.
The groundwater extraction system will continue to operate until cleanup levels for the
contaminants of concern are reached throughout the contaminated area.
The Residuum aguifer and the Floridan aguifer (referred to in some of the documents as the
Residuum, Transition Zone and upper and lower Ocala aguifers) will be treated until the cleanup
levels for the contaminants, as listed below are attained.
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Contaminant Cleanup Type of
Level Regulation
Antimony 6 ug/1 SDWA MCL
Beryllium 4 ug/1 SDWA MCL
Benzene 5 ug/1 SDWA MCL
Carbon Disulfide 56 ug/1 Hazard Index = 1
[*] Chromium 100 ug/1 SDWA MCL
1,1-DCE 7 ug/1 SWDA MCL
PCBs 0.5 ug/1 SWDA MCL
Lead 15 ug/1 Action Level
1,1,1-TCA 200 ug/1 SDWA MCL
Cleanup level based on Maximum Contaminant Level (MCL),
cancer Risk of increased chance of cancer of 1 case in
1,000,000 people (1x10[-6]), Hazard Index of 1 (dosage not
causing adverse effects), or Action Level depending on
whether MCLs have been established.
* Contaminant added after the Proposed Plan was issued.
Although Chromium was not included as a contaminant of concern in the Proposed Plan, the
information used to include Chromium is a part of the FS and is contained in the Administrative
Record. Chromium was found on-site in the groundwater at concentrations above the MCL (100
ug/1) and therefore EPA is adding it as a contaminant of concern. EPA has determined that this
is not a significant change because the original remedy already addresses metals in the
groundwater and EPA believes this remedy will also address the Chromium in the groundwater.
This ROD reguires sampling and analysis during the remedial design to further define the
background groundwater concentrations of the inorganic contaminants. If, based on that
information, the background concentration for an inorganic contaminant exceeds the SDWA MCL, EPA
will reexamine whether compliance with SDWA MCL continues to be appropriate for the inorganic
contaminants. The true background for inorganics at this Site will be determined by collecting
additional groundwater samples for at least the first year of the RD, from the original
background sampling locations using a peristaltic pump operating at a low flow rate. This
procedure will be incorporated into the guarterly sampling activities which are currently
ongoing. The operation of the peristaltic pump may become ineffective at depths below 20 ft.
If this situation occurs, the groundwater samples will be collected in accordance with the
Region IV Standard Operating Procedures and Quality Assurance Manual used during the RI/FS
activities If EPA deems it necessary, additional wells will be installed off-site to determine
if the elevated concentrations of the inorganic contaminants of concern are a result of past
facility activities.
The selected remedy will include groundwater extraction and treatment until established cleanup
levels are achieved. During the operation of the treatment system, performance will be
carefully monitored on a regular basis and adjusted as warranted by the performance data
collected during operation. The operating system may include:
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a) discontinuing operation of extraction wells in areas where cleanup levels have been
attained;
b) alternating pumping at wells to eliminate stagnation points; and
c) pulse pumping to allow aquifer equilibration and to encourage adsorbed contaminants to
partition into groundwater.
To ensure that cleanup levels continue to be maintained, the aquifer will be monitored at those
wells where pumping has ceased on an occurrence of at least every 5 years following the
discontinuation of groundwater extraction.
All extracted groundwater shall be treated to levels which allow for discharge to a POTW.
All air emissions from the air stripper(s) shall be in compliance with Federal and State CAA
standards. The method of control of off-gas emissions, if determined necessary during RD, will
be included in the RD Report(s).
(3) Institutional Controls
Institutional controls will be placed on well construction and use in the contaminated area. No
well will be located, constructed or operated which results in the diminution of the extraction
wells at the Site or in the degradation of the contaminated aquifers. Institutional controls
will also restrict the use of groundwater containing or potentially containing levels of
contamination in excess of MCLs by prohibiting the use of on-site groundwater in any manner
resulting in human ingestion or contact. The well restrictions and groundwater controls shall
remain in effect until EPA determines that the cleanup levels have been attained. Institutional
controls shall also include deed restrictions and record notices placed in the chain of title
for the Site in accordance with State law.
10.0 STATUTORY DETERMINATIONS
Under CERCLA Section 121, 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, toxicity, or mobility or hazardous wastes as their principal
element. The following sections discuss how the remedy meets these statutory requirements.
10.1 Protection of Human Health and the Environment
The selected remedy protects human and the environment by excavating the soil contaminated with
PCB concentrations that exceed 10 ppm and transporting the material to a TSCA permitted
landfill; groundwater extraction and treatment via air stripping; and institutional controls.
The selected remedy provides protection of human health and the environment by eliminating,
reducing, or controlling risk through treatment, and/or engineering controls.
10.2 Compliance with Applicable or Relevant and Appropriate Requirements
Remedial actions performed under CERCLA must comply with all applicable or relevant and
appropriate requirements (ARARs). All alternatives considered for the Firestone Site were
evaluated on the basis of the degree to which they complied with these requirements. The
selected remedy was found to meet or exceed the following ARARs.
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Chemical-Specific ARARs:
Safe Drinking Water Act (SDWA) Maximum Contaminant Levels (MCLs) (42 U.S.C. S 1412 (S 300g-l);
40 C.F.R. 141.61 and 141.80) have been set as enforceable standards for public drinking water
systems. These standards are relevant and appropriate to the groundwater remediation at the
Site. Clean Water Act (CWA) Federal Water Quality Criteria (33 U.S.C. S 1314(a) (1) (S 304(a) (1))
are effluent limitations that must meet Best Available Technology(BAT). These standards may be
relevant and appropriate to the discharge of water at the Site.
Discharges to Publicly Owned Treatments Works (POTWs) are subject to the reguirements of section
307 of the Clean Water Act. These reguirements may be applicable to discharge of the treated
groundwater.
Clean Air Act (CAA) National Ambient Air Quality Standards (42 U.S.C. S 7409 (S 109); 40 C.F.R.
Part 50) establishes emissions standards, monitoring and testing reguirements, and reporting
reguirements for eight pollutants in air emissions. These standard may be applicable to the
operation of the air stripper at this Site.
Toxic Substances Control Act (TSCA) 15 U.S.C. S 2601; (40 C.F.R. Part 761.120 to 761.135)
authorizes EPA to establish regulations to control selected chemical substances or mixtures that
pose an imminent hazard.
Location-Specific ARARs
CAA National Ambient Air Quality Standards (42 U.S.C. S 7409 (S 109); 40C.F.R. Part 50)
establishes emission standards to protect public health and public welfare. The standards are
national limitations on ambient air intended to protect health and welfare. The standards may
be applicable for the operation of the air stripper at the Site.
Georgia Water Quality Control Act (Code of Georgia, Title 12, Chapter 5) oversees the guality
and guantity of the state's water resources. Authorizes the Georgia EPD to establish water
guality standards and issue discharge permits and is applicable to the discharge of the treated
groundwater.
Georgia Hazardous Waste Management Act (Code of Georgia, Title 12 Chapter 8, Article 3,
including Georgia Rules for Hazardous Waste Management, 391-3-11-.01,.02,.03,.07,.08,.12,
.13,.16) which establishes standards applicable to generators of hazardous waste in the State of
Georgia. These regulations may be applicable if residuals from the air stripper contain
concentrations of hazardous waste at levels to be considered a generator.
Georgia Air Quality Act (Code of Georgia, Title 12, Chapter 9, including Georgia Rules for Air
Quality Control, 391-3-1-.02 (3) (ii)) which allows more stringent emission limitations of other
reguirements if deemed necessary to safeguard the public health, safety or welfare of the people
of the State of Georgia. The reguirements are applicable to the remedial activities to be
conducted at the Site.
Action-Specific ARARs
CWA Discharge Limitations (33 U.S.C. S 1311 (S 301); 40 C.F.R. Parts 122, 125, 129, 133, 136 and
403) prohibits unpermitted discharge of any pollutant or combination of pollutants or
combinations of pollutants to waters of the U.S. from any point source. Standards and
limitations are established for and are applicable to the discharges of treated groundwater to a
POTW and direct discharge to surface water.
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CAA National Emission Standards for Hazardous Air Pollutants (42 U.S.C. S 7412 (S 112); 40
C.F.R. Part 61) establishes emissions standards, monitoring and testing reguirements, and
reporting reguirements for pollutants in air emissions. These standards are applicable for the
operation of the air stripper at the Site.
To Be Considered Materials (TBCs)
EPA Groundwater Protection Strategy (EPA, 1984) is a policy to restore groundwater to its
beneficial uses within a time frame that is reasonable.
56 FR, June 7, 1991 - MCLGs & NPDWRs for Lead & Copper [Action levels established for lead
(0.015 ppm) and copper (1.3 ppm)] in groundwater.
City of Albany Sewer Ordinance establishes standards for discharge in the sewer system. Any
discharge of the treated groundwater to the local sewer system must comply with these
ordinances.
10.3 Cost Effectiveness
The selected remedy, Soil Alternative D and Groundwater Alternative D were chosen because they
provide the best balance among criteria used to evaluate the alternatives considered in the
Detailed Analysis. These alternatives were found to achieve both adeguate protection of human
health and the environment and to meet the statutory reguirements of Section 121 of CERCLA. The
present worth cost of Soil Alternative D and Groundwater Alternative D are $56,200 and
$1,980,000 respectively and appears to be reasonable.
10.4 Utilization of Permanent Solutions and Alternative Treatment Technologies or Resource
Recovery Technologies to the Maximum Extent Practicable
EPA and GAEPD 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 ROD at the Firestone Tire and Rubber Site. Of those alternatives that are protective
of human health and the environment and comply with ARARs, EPA and GAEPD have determined that
the 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, cost, while also considering the statutory preference for
treatment as a principal element and considering State and community acceptance.
The selected remedy treats the principal threats posed by groundwater and removes the principal
threats posed by soils, achieving significant contaminant reductions. This remedy provides the
most cost effective treatment of any of the alternatives considered. The selection of
excavation and off Site disposal for the small volume of contaminated soils and extraction and
treatment of contaminated groundwater is consistent with program expectations that highly toxic
and mobile wastes are a priority for treatment to ensure the long-term effectiveness of a
remedy.
10.5 Preference for Treatment as a Principal Element
By treating the contaminated groundwater by air stripping, the selected remedy addresses the
principal threats posed by the Site through the use of treatment technologies. By utilizing
treatment as a significant portion of the remedy, the statutory preference for remedies that
employ treatment as a principal element is satisfied.
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Georgia Department of Natural Resources
205 Butler Street, S.E., Suite 1252, Atlanta, Georgia 30334
Joe D. Tanner, Commissioner
Harold F. Reheis, Director
Environmental Protection Division
June 21, 1993
Mr. Richard D. Green
Associate Director
Superfund and Emergency Response
U.S. Environmental Protection Agency
Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
RE: Record of Decision
Firestone Tire & Rubber Company Site
Albany, Dougherty County, Georgia
May 21, 1993
Dear Mr. Green:
The Georgia Environmental Protection Division has reviewed the above referenced document and
concurs with the Record of Decision and the Environmental Protection Agency's selected remedial
action for the Firestone Tire & Rubber Company Site.
If we can be of further assistance to you, please contact Bill Mundy at (404) 656-7802.
Sincerely,
Harold F. Reheis
Director
HFR/dmb
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