&ERA
United States
Environmental Protection 1200 Pennsylvania Avenue, N.W.
Agency Washington, D.C. 20460 May 2013
Office of Solid Waste and Emergency Response
Support Document for the
Revised National Priorities List
Final Rule - Macon Naval Ordnance Plant
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Support Document for the
Revised National Priorities List
Final Rule
Macon Naval Ordnance Plant
May 2013
Site Assessment and Remedy Decisions Branch
Office of Superfund Remediation and Technology Innovation
Office of Solid Waste and Emergency Response
U.S. Environmental Protection Agency
Washington, DC 20460
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Macon Naval Ordnance Plant NPL Listing Support Document May 2013
Table of Contents
Executive Summary iv
Introduction iv
Background of the NPL iv
Development of the NPL iv
Hazard Ranking System v
Other Mechanisms for Listing .vi
Organization of this Document vi
Glossary vii
1. List of Commenters and Correspondence 1
2. Site Description 1
3. Summary of Comments 2
3.1 Support for Listing and Other Non-opposition Comments 5
3.2 Consistency with HRS 5
3.2.1 Consistency with Guidance 6
3.3 Site Name 7
3.4 Liability 7
3.5 Criteria for Listing 8
3.6 Data Quality Issues 8
3.7 Data Selection - Use of Previous Sampling Data 9
3.8 Site Definition 10
3.9 Source 1 11
3.9.1 Representativeness of the Background Sample 13
3.9.2 Using Qualified Analytical Data that Impact the Quantification of Mercury in the Source Sample .15
3.9.3 Documenting Mercury Contamination in the Source Sample 17
3.10 Observed Release - Background 18
3.10.1 Adequacy of Background Sample - Observed Release 20
3.10.2 Sample Similarity 21
3.10.3 Number of Background Samples Used to Identify an Observed Release 22
3.11 Observed Release - Attribution 23
3.11.1 Possible Mercury Releases from Alternative Sites 25
3.11.1.1 Wastewater Discharges from GP and the Southern Wood Piedmont Company via the RCWRF 27
3.11.1.2 GP Air Emissions 29
3.11.1.3 Contribution of Sources West and North of Source 1 30
3.11.2 Contaminant Concentration Gradient in Drainage Ditch #4 30
3.11.3 Contaminant Concentration Downgradient of the RCWRF 32
3.11.4 Other Data Sets 34
3.12 Characterization ofPPE 1 36
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Macon Naval Ordnance Plant NPL Listing Support Document May 2013
4. Conclusion 37
Attachment 1: Macon Water Authority, Rocky Creek Effluent Sample Results, Various Dates
Attachment 2: Macon Water Authority, Rocky Creek Biosolids Mercury Data, Undated
Attachment 3: Macon Water Authority, Status of MWA lines to Ocmulgee River from Rocky
Creek POTW, January 24, 2003
in
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Macon Naval Ordnance Plant NPL Listing Support Document
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Executive Summary
Section 105(a)(8)(B) of CERCLA, as amended by SARA, requires that the EPA prepare a list of national
priorities among the known releases or threatened releases of hazardous substances, pollutants, or
contaminants throughout the United States. An original National Priorities List (NPL) was promulgated
on September 8, 1983 (48 FR 40658). CERCLA requires that the EPA update the list at least annually.
This document provides responses to public comments received on the Macon Naval Ordnance Plant,
proposed on March 15, 2012 (77 FR 15344). This site is being added to the NPL based on an evaluation
under the EPA's Hazard Ranking System (HRS) in a final rule published in the Federal Register in May
2013.
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Macon Naval Ordnance Plant NPL Listing Support Document
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Introduction
This document explains the rationale for adding the Macon Naval Ordnance Plant site in Macon, Georgia, to the
National Priorities List (NPL) of uncontrolled hazardous waste sites and also provides the responses to public
comments received on this site. The EPA proposed this site on March 15, 2012 (77 FR 15344). This site is being
added to the NPL based on an evaluation under the Hazard Ranking System (HRS) in a final rule published in the
Federal Register in May 2013.
Background of the NPL
In 1980, Congress enacted the Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA), 42 U.S.C. Sections 9601 etseq. in response to the dangers of uncontrolled hazardous waste sites.
CERCLA was amended on October 17, 1986, by the Superfund Amendments and Reauthorization Act (SARA),
Public Law No. 99-499, stat., 1613 el seq. To implement CERCLA, the EPA promulgated the revised National
Oil and Hazardous Substances Pollution Contingency Plan (NCP), 40 CFR Part 300, on July 16, 1982 (47 FR
31180), pursuant to CERCLA Section 105 and Executive Order 12316 (46 FR 42237, August 20, 1981). The
NCP, further revised by the EPA on September 16, 1985 (50 FR 37624) and November 20, 1985 (50 FR 47912),
sets forth guidelines and procedures needed to respond under CERCLA to releases and threatened releases of
hazardous substances, pollutants, or contaminants. On March 8, 1990 (55 FR 8666), the EPA further revised the
NCP in response to SARA.
Section 105(a)(8)(A) of CERCLA, as amended by SARA, requires that the NCP include
criteria for determining priorities among releases or threatened releases throughout the United
States for the purpose of taking remedial action and, to the extent practicable, take into account
the potential urgency of such action, for the purpose of taking removal action.
Removal action involves cleanup or other actions that are taken in response to emergency conditions or on a
short-term or temporary basis (CERCLA Section 101). Remedial action is generally long-term in nature and
involves response actions that are consistent with a permanent remedy for a release (CERCLA Section 101).
Criteria for placing sites on the NPL, which makes them eligible for remedial actions financed by the Trust Fund
established under CERCLA, were included in the HRS. The EPA promulgated the HRS as Appendix A of the
NCP (47 FR 31219, July 16, 1982). On December 14, 1990 (56 FR 51532), the EPA promulgated revisions to the
HRS in response to SARA, and established the effective date for the HRS revisions as March 15, 1991.
Section 105(a)(8)(B) of CERCLA, as amended, requires that the statutory criteria provided by the HRS be used to
prepare a list of national priorities among the known releases or threatened releases of hazardous substances,
pollutants, or contaminants throughout the United States. The list, which is Appendix B of the NCP, is the NPL.
An original NPL of 406 sites was promulgated on September 8, 1983 (48 FR 40658). At that time, an HRS score
of 28.50 was established as the cutoff for listing because it yielded an initial NPL of at least 400 sites, as
suggested by CERCLA. The NPL has been expanded several times since then, most recently on September 18,
2012 (77 FR 57546). The Agency also has published a number of proposed rulemakings to add sites to the NPL.
The most recent proposal was on September 18, 2012 (77 FR 57546).
Development of the NPL
The primary purpose of the NPL is stat ed in the legi slative history of CERCLA (Report of the Committ ee on
Environment and Public Works, Senate Report No. 96-848, 96th Cong., 2d Sess. 60 [1980]).
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Macon Naval Ordnance Plant NPL Listing Support Document
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The priority list serves primarily informational purposes, identifying for the States and the public
those facilities and sites or other releases which appear to warrant remedial actions. Inclusion of a
facility or site on the list does not in itself reflect a judgment of the activities of its owner or
operator, it does not require those persons to undertake any action, nor does it assign liability to
any person. Subsequent government actions will be necessary in order to do so, and these actions
will be attended by all appropriate procedural safeguards.
The NPL, therefore, is primarily an informational and management tool. The identification of a site for the NPL is
intended primarily to guide the EPA in determining which sites warrant further investigation to assess the nature
and extent of the human health and environmental risks associated with the site and to determine what CERCLA-
financed remedial action(s), if any, may be appropriate. The NPL also serves to notify the public of sites the EPA
believes warrant further investigation. Finally, listing a site may, to the extent potentially responsible parties are
identifiable at the time of listing, serve as notice to such parties that the Agency may initiate CERCLA-financed
remedial action.
CERCLA Section 105(a)(8)(B) directs the EPA to list priority sites among the known releases or threatened
release of hazardous substances, pollutants, or contaminants, and Section 105(a)(8)(A) directs the EPA to
consider certain enumerated and other appropriate factors in doing so. Thus, as a matter of policy, the EPA has
the discretion not to use CERCLA to respond to certain types of releases. Where other authorities exist, placing
sites on the NPL for possible remedial action under CERCLA may not be appropriate. Therefore, the EPA has
chosen not to place certain types of sites on the NPL even though CERCLA does not exclude such action. If,
however, the Agency later determines that sites not listed as a matter of policy are not being properly responded
to, the Agency may consider placing them on the NPL.
Hazard Ranking System
The HRS is the principle mechanism the EPA uses to place uncontrolled waste sites on the NPL. It is a
numerically based screening system that uses information from initial, limited investigations ~ the preliminary
assessment and site inspection ~ to assess the relative potential of sites to pose a threat to human health or the
environment. HRS scores, however, do not determine the sequence in which the EPA funds remedial response
actions, because the information collected to develop HRS scores is not sufficient in itself to determine either the
extent of contamination or the appropriate response for a particular site. Moreover, the sites with the highest
scores do not necessarily come to the Agency's attention first, so that addressing sites strictly on the basis of
ranking would in some cases require stopping work at sites where it was already underway. Thus, the EPA relies
on further, more detailed studies in the remedial investigation/feasibility study that typically follows listing.
The HRS uses a structured value analysis approach to scoring sites. This approach assigns numerical values to
factors that relate to or indicate risk, based on conditions at the site. The factors are grouped into three categories.
Each category has a maximum value. The categories are:
• likelihood that a site has released or has the potential to release hazardous substances into the
environment;
• characteristics of the waste (toxicity and waste quantity); and
• people or sensitive environments (targets) affected by the release.
Under the HRS, four pathways can be scored for one or more threats as identified below:
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• Ground Water Migration (Sgw)
- drinking water
• Surface Water Migration (Ssw)
The following threats are evaluated for two separate migration components, overland/flood migration and
ground water to surface water.
- drinking water
- human food chain
- sensitive environments
• Soil Exposure (Ss)
- resident population
- nearby population
- sensitive environments
• Air Migration (Sa)
- population
- sensitive environments
After scores are calculated for one or more pathways according to prescribed guidelines, they are combined using
the following root-mean-square equation to determine the overall site score (S), which ranges from 0 to 100:
If all pathway scores are low, the HRS score is low. However, the HRS score can be relatively high even if only
one pathway score is high. This is an important requirement for HRS scoring because some extremely dangerous
sites pose threats through only one pathway. For example, buried leaking drums of hazardous substances can
contaminate drinking water wells, but ~ if the drums are buried deep enough and the substances not very volatile
-- not surface water or air.
Other Mechanisms for Listing
There are two mechanisms other than the HRS by which sites can be placed on the NPL. The first of these
mechanisms, authorized by the NCP at 40 CFR 300.425(c)(2), allows each State and Territory to designate one
site as its highest priority regardless of score. The last mechanism, authorized by the NCP at 40 CFR
300.425(c)(3), allows listing a site if it meets the following three requirements:
• Agency for Toxic Substances and Dis ease Registry (ATSDR) o f the U.S. P ublic Health Service has
issued a health advisory that recommends dissociation of individuals from the release;
• EPA determines the site poses a significant threat to public health; and
• EPA anticipates it will be more cost-effective to us e its remedial authority than to use it s emergency
removal authority to respond to the site.
Organization of this Document
The following section contains the EPA responses to site-specific public comments received on the proposal of
the Macon Naval Ordnance Plant site on March 15, 2012 (77 FR 15344). The site discussion begins with a list of
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commenters, followed by a site description, a summary of comments, and Agency responses to each comment. A
concluding statement indicates the effect of the comments on the HRS score for the site.
Glossary
The following acronyms and abbreviations are used throughout the text:
Agency U.S. Environmental Protection Agency
AIP Allied Industrial Park
APA Administrative Procedure Act
AWI Armstrong World Industries
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act of 1980, 42
U.S.C. Sections 9601 etseq., also known as Superfund
CFR Code of Federal Regulations
D.C. Cir U.S. Court of Appeals for the District of Columbia Circuit
DoD Department of Defense
EPA U.S. Environmental Protection Agency, also USEPA
FMNOL Former Macon Naval Ordnance Landfill
FR Federal Register
GP Graphic Packaging
HRS Hazard Ranking System, Appendix A of the NCP
HRS score Overall site score calculated using the Hazard Ranking System; ranges from 0 to 100
MCL Maximum contaminant level
[jg/kg Micrograms per kilogram
|jg/l_ Micrograms per liter
MNOP Macon Naval Ordnance Plant
MWA Macon Water Authority
NCP National Oil and Hazardous Substances Pollution Contingency Plan, 40 C.F.R. Part 300
NPDES National Pollution Discharge Elimination System
NPL National Priorities List, Appendix B of the NCP
NWI National Wetlands Inventory
OR Observed release
OSWER USEPA's Office of Solid Waste and Emergency Response
PA Preliminary assessment
PCE Tetrachloroethene or tetrachloroethylene
PRP Potentially responsible party
PSA Pre-CERCLIS screening assessment
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QAPP Quality assurance project plan
QA/QC Quality assurance/quality control
RCRA Resource Conservation and Recovery Act
RCWRF Rocky Creek Water Reclamation Facility
Rl Remedial investigation
ROD Record of decision
SARA Superfund Amendments and Reauthorization Act
SCDM Superfund Chemical Data Matrix
SESD Science and Ecosystem Support Division
SI Site inspection
SWPC Southern Wood Piedmont Company
TCE Trichloroethene or trichloroethylene
USACE United States Army Corps of Engineers
USGS United States Geological Survey
VOC Volatile organic compound
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1. List of Commenters and Correspondence
EPA-HQ-SFUND-2012-0064-0004
EPA-HQ-SFUND-2012-0064-0005
EPA-HQ-SF UND-2012-0064-0006
EPA-HQ-SFUND-2012-0064-0008
EPA-HQ-SFUND-2012-0064-0007
EPA-HQ-SFUND-2012-0064-0009
EPA-HQ-SFUND-2012-0071 -0005
State Concurrence Letter - Macon Naval Ordnance Plant
submitted by F. Allen Barnes, Director, Georgia Department of
Natural Resources
Comment and attachment submitted by Peter J. Fontaine of
Cozen O'Conner
Comment and attachment submitted by Maureen
Sullivan, Director, Environmental Management, on behalf of the
Department of Defense (DoD)
Comment and attachment submitted by Peter J. Fontaine of
Cozen O'Conner on behalf of Unimax Corporation
Comment and attachment submitted by Michael W. Steinberg,
Counsel, Morgan, Lewis & Bockius LLP
Comment and attachment submitted by Emily Hinchman,
Rutgers University School of Law - Camden
2. Site Description
The Macon Naval Ordnance Plant (MNOP) site (the Site), located in Macon, Georgia, is composed of the release
of mercury from the former MNOP facility to Drainage Ditch #4 and into Rocky Creek. Land uses at the facility
are predominantly commercial and heavy industrial. The MNOP facility was constructed and operated by the
Reynolds Corporation before World War II for production of ordnance. In 1941, the U.S. Navy assumed
operation of the plant and continued to manufacture ordnance there until 1965. Ordnance manufactured at the
MNOP included flares, small primers, detonators, and other triggering mechanisms. Several industrial businesses
such as Maxson Electronics Corporation, Allied Chemical Corporation, and Macon-Bibb County Industrial
Authority have owned and operated at the location of the MNOP facility since the Department of Defense (DoD)
operations ceased in 1965.
The MNOP facility property is bordered to the north by Guy Paine Road; to the east by Mead Road and the
Norfolk Southern railroad tracks; to the southeast by Graphic Packaging; to the south by the Macon Water
Authority (MWA) Rocky Creek Water Reclamation Facility (RCWRF), the Armstrong World Industries (AWI)
remote landfill, the former Macon Naval Ordnance Landfill (FMNOL), and Rocky Creek; and to the west by the
AWI plant property (see Figure 1).
The Site forHRS scoring purposes includes one source (Source 1) ~ contaminated soil on the eastern section of
the MNOP property near Building 109, and the associated releases from the Site to drainage ditch #4. Source 1
consists of contaminated soil surrounding Building 109 which was a primary explosives production area. Soil
samples collected from this area during the U.S. Army Corps of Engineer's (USACE) 1996 site investigation
contained mercury. Mercury has also been detected at significant levels in sediments collected in wetlands that
receive runoff from Source 1 via Drainage Ditch #4 on the east side of the facility, indicating that a release has
occurred to the surface water migration pathway. The HRS Site score is based on the release of mercury to the
surface water migration pathway and the resulting risk to nearby wetlands and a human food chain fishery.
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Macon Naval Ordnance Plant NPL Listing Support Document
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Several investigations have been conducted at MNOP between 1989 and 2011. Mercury has been associated with
the MNOP site. The most recent investigation was a June 2011 Supplemental Sampling Event (shown in Figure 1
below) and while all available data was used in the site evaluation and included as references to the HRS
documentation record at proposal, the June 2011 data was the basis for the HRS evaluation as it is the most
current data and is focused on contamination in Drainage Ditch #4. Source background samples were taken on the
northern portion of the MNOP property (MNOP-Ol-SF shown in Figure 1 below) and an observed release
background level was based on a sample taken from southwest of the MNOP property located in the same
wetland as the observed release sample (MNOP-W-Ol-SD shown on Figure 3 of the HRS documentation record
at proposal).
3. Summary of Comments
Two commenters, Michael W. Steinberg, on behalf of Counsel, Morgan, Lewis and Bockius LLP, and Emily
Hinchman, from Rutgers University School of Law, each submitted a comment regarding all sites proposed for
listing in March 2012, which include the former Macon Naval Ordnance Plant. These comments applicable to
multiple sites are addressed in the preamble of the first Final Rule promulgating sites that were proposed for
listing in March 2012 (77 FR 57498-57500, September 18, 2012).
The Director of the Georgia Department of Natural Resources, F. Allen Barnes, supported the placement of the
former Macon Naval Ordnance Site on the National Priorities List (NPL) and commented that the listing will help
compel responsible parties to plan remedial action that is needed at the Site.
Three commenters submitted comments in opposition to placing the former Macon Naval Ordnance Plant on the
NPL. Peter J. Fontaine of Cozen O'Conner (Cozen) submitted a set of preliminary comments and later submitted
additional comments on behalf of the Unimax Corporation (Unimax). Maureen Sullivan, Director of
Environmental Management, submitted comments on behalf of DoD. Cozen, Unimax, and DoD raised both site
eligibility policy and technical HRS scoring issues.
Unimax commented that the EPA did not correctly follow the HRS or HRS guidance in placing the Site on the
NPL. Unimax also commented that the data used in the HRS documentation record was not of known and
documented quality, was from unreliable previous sampling events, and used qualified data that should not be
used in an HRS evaluation.
DoD commented that the Site should be renamed "Allied Industrial Park," since DoD activities have ceased and
the property is now commonly known as such. DoD, Cozen, and Unimax also commented that the property has
been owned and operated by several different businesses and the EPA fails to discuss these other potentially
responsible parties (PRPs), as well as failing to discuss possible sources such as the Rocky Creek Water
Reclamation Facility (RCWRF), Graphic Packaging (GP), and an adjacent NPL site that is currently being
remediated.
DoD, Unimax, and Cozen commented that Source 1 has not been properly established and that the background
sample used for Source 1 is insufficient to show that contamination is non-ubiquitous. Unimax and Cozen
commented that a single source soil background sample is suspect also because it is a qualified value and merely
an estimate.
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Macon Naval Ordnance Plant NPL Listing Support Document May 2013
MNOP-02-SF |
|Hg =0.05 UJ mg/kg|
( MNOP-03-SF
1 Hg =0.072 J- mg/kg|
MNOP-05-SF
Hg = 0.058 J- mg/kg
MNOP-05-SF-DUP j
Hg = 0.070 J- mg/kg|
I MNOP-04-SF S
[Hg = 0.40 rng/kg|
"Former" Macon Naval
Ordnance Plant |
MNOP-D4-01-SD
[Hg = 0.050 UJ mg/kc
! MNOP-D4-02-SD
Hg = 0.051 J- mg/kg
IMNOP-D4-02-SD-DUP
I Hg =0.050 U mg/kg |
MNOP-D4-03-SD
Hg =0.050 UJ mg/kc
J MNOP-D4-04-SD \
Hg = 0.083 J- mg/kg
MNOP-D4-06-SD i
[Hg = 0.050 UJ mg/kg|
Rocky Creek
W^ter Reclamation
Facility
JMNOP-D4-07-SD
| Hg = 0.46 mg/kg |
MNOP-D4-W-08-SD]
[ Hg = 0.19 J- mg/kg |
Hg = 1.1 mg/kg
jcJSTQ-twM
MNOP-D4-W-09-SD
, United States
Envimnmental Protection Agency
MACON NAVAL ORDNANCE PLANT
MACON,
BIBB COUNTY,
GEORGIA
TDD No. TTEM I- 05-003-012 7
JUNE 2011 SUPPLEMENTAL
SAMPLING LOCATIONS WITH
MERCURY CONCENTRATIONS
TETRATECH
Legend
June2011 Sample Locations
A Sediment Sample
B Soil Sample
[Ml Background Soil Sample
Map Features
— Creek
Drain age Ditch
(. .| "Former" Macon Naval
I ' I Ordnance Plant
Wetland Areas
Freshwater Palustrine
Emergent Wetland
Freshwater Palustrine
Forested/Shrub Wetland
Feet
1:9,600
Map Source:
Aerial Photograph - ESRI 13 Imagery Prime, 2009.
Property Boundary - Macon-Bibb County Board of
Tax Assessors.
Wetlands- U.S. Fish and Wildlife Sen/ice National
Wfetlands Inventory
Notes:
D- Drainage Ditch
Hg - Mercury
mg/kg - Milligrams per kilogram
MNOP- Macon Naval Ordnance Plant
SD - Sediment Sample
SF - Surface Soil Sample
Figure 1
3
- Map of the Macon Naval Ordnance Plant area showing the property boundaries, drainage ditches, wetlands, and 2011 sampling data.
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Q.'^l u rite 3 States
En won mental Protection Agency
MACON NAVAL ORDNANCE PLANT
MACON,
BIBB COUNTY,
GEORGIA
TOO No TTEMi-Oe-003-0127
FIGURE 3
SAMPLING LOCATIONS
TETRA TECH
Legend
June2011 Sample Locations
~ Sediment Sample
¦ Sail Sample
A Background Wetland
Sediment Sample
Bfl Background Soil Sample
Map Features
Creek
Drainage Ditch
I 1 •Former" Macon Naval
I 1 Ordnance P ant
Wetland Areas
Fresnwater Palustrine
1^3 Emergert Wetfand
Fresnwater Palustrine
Forested'Shrub Wetland
N
0 530 1.000
e
Feel
S 1:12,030
Map Source
Aeria P-iotog-apl' -b irg Maps,20C9
Property Boundary -via cor-Bibb C aunty Board of
Tax Assessors
Weiland9- U.S FIs!" andWldlfe Sewice National
\Atelland9 Inventory
Reference9.pa * ,3
Notes
O -Qr sinage Ditch
Hg • Mercury
con Naval OrdnancePlarrt
FPE- Probable Pair! ofEnlry
SO-s eaimerl Sample
SF • Surface Sal Sample
W- wetland
Figure 2 - Large-scale map of the Macon Naval Ordnance Plant area showing the neighboring facilities of Graphic Packaging Incorporated and
Armstrong World Industries, and location of the background wetland sediment sample used to establish the observed release in Drainage Ditch
#4.
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Cozen and Unimax commented that only one background sediment sample used to establish an observed release
is insufficient and not defensible to establish background conditions, account for background variability, and
attribute contamination to the former Macon Naval Ordnance Plant. Additionally, Unimax and Cozen commented
that this background sample (the observed release background sample) was not taken from the same media as the
observed release sample and is therefore insufficient to show sample similarity.
Unimax and Cozen commented that the mercury contaminant concentration gradient in Drainage Ditch #4 does
not support MNOP being the source of mercury contamination. Unimax commented that the HRS documentation
record only obtained a small set of data focused around Building 109 and Drainage Ditch #4, and commented that
a large volume of spatially extensive, high-quality, relevant data has been ignored. Unimax and Cozen
commented that there are other sources of mercury in the area and that mercury discharges from GP and the
Southern Wood Piedmont Company (SWPC) to the RCWRF had not been considered in attributing the mercury
contamination to the MNOP site. Unimax also identified that the GP released mercury to the air and that GP
should also be considered a possible source of the mercury.
Finally, Unimax commented that the probable point of entry (PPE) is located within a settling basin of the
RCWRF in which the National Wetlands Inventory (NWI) characterizes the location as Emergent Wetland
"PEMlFx," which is depicted as part of the RCWRF.
3.1 Support for Listing and Other Non-opposition Comments
Comment: F. Allen Barnes, Director of the Georgia Department of Natural Resources, expressed support for the
placement of the Macon Naval Ordnance Plant site on the National Priorities List (NPL). Mr. Barnes stated that
"[t]he NPL listing will help compel the PRPs to move forward with the investigation and remedial action that is
needed at the Site."
Response: The Macon Naval Ordnance site is being added to the NPL. Listing makes a site eligible for remedial
action funding under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA),
and the EPA will examine the Site to determine the appropriate response action(s). Actual funding may not
necessarily be undertaken in the precise order of HRS scores. In addition, upon more detailed investigation may
not be necessary at all in some cases. The need for using Superfund monies for remedial activities will be
determined on a site-by-site basis, taking into account the NPL ranking, State priorities, further site investigation,
other response alternatives, and other factors as appropriate.
3.2 Consistency with HRS
Comment: Unimax commented that the EPA failed to follow the HRS in placing this site on the NPL, and as a
result the placement of the Site on the NPL is arbitrary and capricious. Unimax asserted that the EPA should
withdraw its proposed listing of the Site.
Response: The HRS evaluation of the Site is consistent with the HRS regulation and the Administrative Procedure
Act (APA); EPA's decision to add the Site to the NPL based on the HRS evaluation is therefore neither arbitrary
nor capricious. The HRS documentation record at proposal and this support document clearly document that EPA
has complied with the HRS regulation; this support document addresses all comments on the proposed listing of
this site, including those comments that challenge compliance with the HRS, and shows that HRS requirements
have been met in every aspect of the Site evaluation.
Section 553 of the APA authorizes "informal" rulemaking. The informal rulemaking process encourages and
relies on the participation of the public, including PRPs. The public can comment during the comment period
(typically 60 days) after a site is proposed for listing and also during the time the Agency is evaluating and
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selecting a remedy (the Agency may also hold a public hearing during the latter decision-making period). If
private parties conduct remedial action under a Consent Decree between the EPA and the parties, the decree is
also subject to public comment. The Agency believes that the above process offers the public sufficient
opportunity to present facts and opinions germane to its decision-making in a timely manner.
This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.
3.2.1 Consistency with Guidance
Comment: Unimax asserted that the EPA failed to follow its own guidance in the HRS evaluation of the Site.
Unimax specifically commented that the HRS Guidance Manual [The Hazard Ranking System Guidance Manual;
Interim Final, November 1992 (NTIS PB92-963377, EPA 9345.1-07)] was not followed when determining
background concentrations and attributing mercury contamination to the MNOP facility, concluding that "the
background determination is arbitrary..." Unimax made the following statements regarding the EPA's use of the
HRS Guidance Manual:
• EPA's failure to explain why the off-site mercury impacts in Ditch #4 are not derived from the Rocky
Creek Water Reclamation Facility (RCWRF) and the Graphic Packaging (GP) facilities is contrary to
EPA's HRS guidance.
• EPA's failure to consider the RCWRF and the GP facilities as sources of the mercury impacts detected in
Drainage Ditch #4 and at the so-called "source area" on the former MNOP is contrary to EPA's HRS
guidance.
• According to EPA HRS Guidance, there is no source of mercury on the MNOP property.
Unimax asserted that these inconsistencies with guidance render the HRS evaluation arbitrary and capricious.
Response: The EPA followed the HRS regulation to list the Site. Furthermore, the HRS Guidance Manual was
also applied appropriately in the HRS evaluation based on the facts and circumstances presented for this site. The
responses presented in this support document demonstrate that the HRS evaluation was consistent with EPA
guidance. The technical aspects of this comment are addressed in this support document in sections 3.9, Source 1;
3.10, Observed Release - Background; and 3.11, Observed Release - Attribution.
Unlike the HRS regulation itself, the HRS Guidance Manual is not a regulation and imposes no mandatory
requirements on the agency. The HRS Guidance Manual states that:
[t]he procedures set forth in this document are intended as guidance to employees of the U.S.
Environmental Protection Agency (EPA), States, and other government agencies. EPA officials
may decide to follow the guidance provided in this directive, or to act at variance with it, based
on analysis of specific site circumstances.
In evaluating whether a site merits NPL listing, the EPA complies with the HRS regulation in the HRS evaluation
and uses the HRS Guidance Manual as guidance to determine how best to perform the evaluation based on the
facts or circumstances presented at each site. The HRS Guidance Manual is consistent with the HRS (this was not
challenged by Unimax). As shown in this support document, the EPA has followed the HRS in scoring the Site
and applied the HRS Guidance Manual as appropriate to the Site situation. EPA is therefore neither arbitrary nor
capricious in the decision to list this site on the NPL.
This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.
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3.3 Site Name
Comment: The DoD commented that the Site should be renamed "Allied Industrial Park," as several industrial
businesses have owned and operated the property since the DoD activities have ceased and the property is now
commonly known as Allied Industrial Park (AIP).
Response: The Site name has not been revised. While neither CERCLA nor the NCP establishes a required
procedure for assigning a site name to a proposed listing, in this case it is reasonable to have named the site the
Macon Naval Ordnance Plant site. Since the primary purpose of an NPL listing is to inform the public that the site
warrants further investigation, the attempt is made to select the name that most clearly informs the public as to the
location of the site, what appears to be the primary source(s) of the problems at the site, and/or considers
assigning a geographic name. The attempt is also made to select names that do not offend local sensitivities (see
RSR Corporation v. EPA, 102 F.3d 1266 (D.C. Cir. 1997)). The EPA chose to name the Site Macon Naval
Ordinance Plant, as that site name is expected to have some degree of name-association to the public.
The site was named after the Macon Naval Ordnance Plant, which was constructed and operated by the Reynolds
Corporation before World War II for production of ordnance. The U.S. Navy assumed operations in 1941 and
continued to manufacture ordnance at the MNOP until 1965. Ordnance manufactured at the MNOP included
flares, small primers, detonators, and other triggering mechanisms. Page 13 of the HRS Documentation record at
proposal states:
Explosive compounds were either handled or stored at many areas throughout the MNOP
property, including numerous small dryer buildings, ordnance magazines, and blending and
weighing houses (Ref. 13, pp. 11, 12, 54) (see Figure 2 of this HRS documentation record).
According to a technical manual prepared by the Department of the Army, military explosives,
such as those that were manufactured at the MNOP, contained mercury compounds as initiating
agents, including mercury fulminate (Ref. 23, pp. 7-5, 7-8). Building 109, located in the eastern
portion of the MNOP, was a primary explosives production site (Ref. 13, pp. 11, 12, 54)
Importantly, the name of the Site does not in any way restrict the evaluation of the Site, its sources, its releases, or
extent of contamination to only the practices of the Macon Naval Ordnance Plant. Any and all areas of
contamination associated with the Site will be explored during further investigation activities.
This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.
3.4 Liability
Comment: The DoD and Unimax commented that the MNOP property has been owned and operated by several
different industrial businesses since DoD activity and operations have ceased. The DoD stated that "the current
narrative... fails to discuss the other potentially responsible parties whose operations appear to be associated with
the areas evaluated for this proposed listing."
Response: Inasmuch as this comment addresses the owners and operators of the property on which the Site source
is located, liability for site contamination is not considered when evaluating a site under the HRS, nor is liability
established or apportioned based on the decision to place a site on the NPL. The NPL serves primarily as an
informational tool for use by the EPA in identifying those sites that appear to present a significant risk to public
health or the environment. It does not reflect a judgment on the activities of the owner(s) or operator(s) of a site. It
does not require those persons to undertake any action, nor does it assign any liability to any person. This
position, stated in the legislative history of CERCLA, has been explained more fully in the Federal Register (48
FR 40759, September 8, 1983 and 53 FR 23988, June 24, 1988). See Kent County v. EPA, 963 F.2d 391 (D.C.
Cir. 1992).
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This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.
3.5 Criteria for Listing
Comment: The DoD commented that the Site Narrative should identify and include one or more listing criteria as
set forth in the NCP and stated that "[i]n this case, the applicable criterion appears to be the HRS score." The DoD
also asserted that the Site may not need listing because contamination may originate from a source area on an
adjacent NPL site that is currently being remediated.
Response: The listing criteria are provided in the administrative record for this rulemaking, which includes the
HRS documentation record and supporting materials, including this support document. For prospective sites under
consideration for listing on the NPL, the EPA follows NCP procedures by conducting a preliminary assessment
(PA) of the site. Depending on the results, the PA may be followed up by a site inspection report (SI), which
involves gathering more information about the site by contacting the state and interested parties on and around the
site. When a site is proposed to the NPL, the EPA provides its detailed rationale, including consideration of
information gathered in the PA and SI, along with other site-related information in documents (i.e., the HRS
documentation record and supporting materials) made publicly available at the EPA Headquarters in Washington,
DC, in the Regional offices, and by electronic access at htpp://www.regulations.gov. In this case, the MNOP site
qualifies for listing on the NPL; the Site has received an HRS score of greater than 28.50 and has met CERCLA
and NCP listing criteria. Furthermore, the State concurred with the listing and stated that remedial action was
needed at the Site. The purpose of NPL listing is explained in the Final Rule, National Priorities List for
Uncontrolled Hazardous Waste Sites, published February 21, 1990 (55 FR 6154), excerpted below.
The purpose of the NPL, therefore, is primarily to serve as an informational and management
tool. The initial identification of a site for the NPL is intended primarily to guide EPA in
determining which sites warrant further investigation to assess the nature and extent of the public
health and environmental risks associated with the site and to determine what CERCLA-financed
remedial action(s), if any, may be appropriate. The NPL also serves to notify the public of sites
EPA believes warrant further investigation.
While remediation may be occurring on an adjacent NPL site, the source (Source 1) identified in the HRS
documentation record at proposal warrants further investigation and there have been no efforts or plans to
remediate the source as part of any other site. Furthermore, the HRS evaluation of the MNOP site yielded a site
score of 48.97; this score is substantially above the 28.50 score that qualifies a site for listing and is sufficient, in
and of itself, to place the Site on the NPL.
This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.
3.6 Data Quality Issues
Comment: Unimax commented that the Tetra Tech 2011 data used in the HRS documentation record at proposal
was not of "known and documented quality." Specifically, Unimax commented that data validations and QA/QC
procedures were not provided in the HRS documentation package for the 2011 assessment. Unimax concluded
that "until evidence that QA/QC procedures were correctly followed, the data from Tetra Tech, 2011 is not
reliable." Unimax also noted that the data used in the HRS documentation record at proposal contained qualified
data that "is merely an estimate (denoted by the ' J-Value')" and asserted that qualified data should not be used in
the HRS evaluation.
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Response: The data used in the HRS evaluation were properly validated according to documented validation and
QA/QC procedures, and are of known and documented quality. In addition, qualified data was used appropriately
in this HRS evaluation. The analytical data used in the HRS scoring of this site came from a June 2011
supplemental sampling event that was performed in accordance with the EPA Quality Assurance Project Plan
(QAPP) for the sampling event, dated June 20, 2011. Soil samples collected in this event were collected in
accordance with the EPA Region 4 Science and Ecosystem Support Division (SESD) Field Branches Quality
System and Technical Procedure for Soil Sampling, November 2007 (SESDPROC-300-R1) (Reference 24 to the
HRS documentation record at proposal) and sediment samples were collected in accordance with the EPA Region
4 SESD Field Branches Quality System and Technical Procedure for Sediment Sampling, September 2010
(SESDPROC-200-R2) (Reference 25 to the HRS documentation record at proposal).
Regarding data validation, the June 2011 analytical data was reviewed, and validated in accordance with EPA
procedures; therefore the data are of known and documented quality. Page 17 of the HRS documentation record
at proposal states that "EPA Region 4 [Science and Ecosystem Support Division] SESD reviewed all data
according to the laboratory contract statement of work (SOW) and EPA guidelines (Refs. 28; 11, p. 1)."
Reference 28 of the HRS documentation record at proposal, provides a description of how data review,
validation, and verification is conducted in the EPA SESD program. Data validation reports and the QA/QC
procedures for the June 2011 sampling event are provided in References 10, 11, 26, 27, and 28 of the HRS
documentation record at proposal.
Regarding the use of qualified data in the HRS evaluation, the U.S. Court of Appeals for the D.C. Circuit has
specifically ruled on the use of analytical data in the scoring of a site using the HRS when there are possible
weaknesses in the laboratory analysis. In the case of Board of Resents of the University of Washington v. EPA, 86
F.3d 1214 (DC Cir. 1996), the Court, in response to the petitioner's challenge regarding the quality of the data
used in an HRS evaluation—specifically, when there were issues dealing with the analysis—stated that "EPA
does not face a standard of absolute perfection. . . . Rather, it is statutorily required to 'assure to the maximum
extent feasible,' that it 'accurately assesses the relative degree of risk,'" [emphasis in original] and that "[i]t would
hardly make sense for the courts to respond to the resulting evidence by treating a lab's findings as fatally
defective whenever it comes up short in any way." Also in this decision, the Court repeated a statement in an
earlier NPL HRS case (Eagle-Picher Indus., Inc. v. EPA, 759 F.2d. 905, 921, D.C. Cir. 1985) that explained the
Agency has met its obligations when "[t]he EPA has thus 'examined [the] relevant data and . . . articulated a
rational explanation for its action.'" [addition of "the" in original]
Therefore, the data used in the HRS evaluation are of known and documented quality and are appropriate for use
in the HRS evaluation consistent with the intent of the HRS and court rulings.
See also section 3.9.2, Using Qualified Analytical Data that Impact the Quantification of Mercury in the Source
Sample, of this support document, which addresses the technical aspects of this comment regarding the use of
analytical data and data quality.
This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.
3.7 Data Selection - Use of Previous Sampling Data
Comment: Unimax commented that other previous data sets (i.e., 2009 Region 4 SESD data completed by
TetraTech and 1998 Rust data) are available for the Site that were not included in the HRS documentation record
at proposal. Unimax commented that a large volume of spatially extensive, relevant data has been ignored and
that these other data sets show that the Site conditions were not adequately represented in the HRS documentation
record at proposal. Unimax noted that the only data used in the HRS documentation record to justify NPL listing
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was obtained in a small sampling event in 2011, which shows "an arbitrary selectivity in the use of the data."
Unimax claimed, "EPA's failure to attempt to explain this contradictory data is arbitrary and capricious."
Response: Contrary to Unimax's assertions, all of the data sets that the commenter mentioned (2009 Region 4
SESD data completed by TetraTech, 1998 Rust data, and June 2011 Supplemental Sampling Event data) were
relied upon in the evaluation of the MNOP site and were included in the HRS documentation record at proposal as
references to the HRS documentation record. However, none of the data from the previous sampling events
impacted the scoring of the MNOP site, so the most recent data (June 2011 Supplemental Sampling Event) was
used in the HRS documentation record to most accurately represent the current conditions at the MNOP site.
While all of the data from all prior sampling events were considered in the evaluation of the MNOP site and are
referenced in the HRS documentation record at proposal, the June 2011 Supplemental Sampling Event data was
used to score the Site because this data is most recent and best represents current Site conditions. The 2009
Region 4 SESD data (referred to by Unimax as 2009 TetraTech data) are included as References 7, 34 and 35 of
the HRS documentation record at proposal and the 1998 Rust Report is included as Reference 13 of the HRS
documentation record at proposal; the results from the prior sampling events are consistent with the results from
the June 2011 Supplemental Sampling Event and the HRS documentation record characterization of the Site,
source, or observed releases.
The HRS documentation record at proposal uses the most current data (June 2011) to establish the presence of
mercury in Source 1 and an observed release of mercury downgradient in Drainage Ditch #4. The HRS
requirements for identifying sources and the hazardous substances associated with the source as well as the HRS
requirements for establishing an observed release by chemical analysis have been met. All previous studies and
additional data would be considered in performing other stages of the Superfund process after listing.
This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.
3.8 Site Definition
Comment: Unimax and Cozen made several comments using the term "onsite" to refer to the MNOP property and
using the term "offsite" to refer to areas other than the MNOP property. Examples of these comments include:
• Unimax commented that elevated mercury samples "onsite," as well as samples within Drainage Ditch
#4, may have migrated from "offsite" sources.
• Sediment samples in Drainage Ditch #4 that are consistently low in mercury, while "onsite" and exhibit
elevated concentrations only in "offsite" portions of the ditch.
• Most "onsite" sediment concentrations are lower than those found in the most upgradient portions of
Rocky Creek.
Response: In their comments, Cozen and Unimax incorrectly equated "site" with the MNOP property; whereas, as
defined in the HRS, "site" refers to an area where a hazardous substance has been deposited, stored, disposed, or
placed, or has otherwise come to be located, and is not restricted by or defined by property boundaries. This
response describes the meaning of "site" as used in the HRS documentation record and in this support document,
and clarifies that the HRS defines the term "site" to encompass a different physical area than Cozen and Unimax
referred to in their comments. The technical aspects of their comments are addressed in this support document in
sections 3.9, Source 1; 3.10, Observed Release - Background, and 3.11; Observed Release - Attribution.
HRS Section 1.1, Definitions, provides the definition for the term "site":
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Site: Area(s) where a hazardous substance has been deposited, stored, disposed, or placed, or has
otherwise come to be located. Such areas may include multiple sources and may include the area
between sources.
Page 15346 of NPL Proposed Rule No. 56, published March 15, 2012 (77 FR 15344) clarifies that:
the NPL site is not necessarily coextensive with the boundaries of the installation or plant, and the
boundaries of the installation or plant are not necessarily the "boundaries" of the site. Rather, the
site consists of all contaminated areas within the area used to identify the site, as well as any other
location where that contamination has come to be located or from where that contamination came.
The HRS documentation record at proposal states that "[f]or HRS scoring, the site consists of one source and
associated releases." Source 1 is contaminated soil on the eastern section of the MNOP property, which contains
elevated concentrations of mercury over background levels (see section 3.9, Source 1, of this support document).
An associated release of mercury has also been detected at significant levels in sediments collected in wetlands
outside of the MNOP property boundaries that receive runoff from Source 1 via Drainage Ditch 4.
Therefore, a site is not associated with property or facility boundaries and the MNOP site is not confined to the
MNOP property boundaries.
This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.
3.9 Source 1
Comment: The DoD, Unimax, and Cozen commented that Source 1 has not been properly established. These
commenters asserted that the former MNOP is not the source of mercury contamination found at the Site and that
Source 1 does not contain mercury contamination above levels found in the local environment.
Unimax commented that the HRS Site score should be 0 because the MNOP does not contain a source of mercury
that contributes to the observed release. Unimax stated that "there appears to be no credible basis to assume that
its [the EPA's] 'Source No. 1' somewhere near Building 109 exists." Unimax commented that other available
data shows low levels of mercury contamination present on the western portion of the property "thousands of feet
west of Drainage Ditch #4" and no mercury contamination on the eastern portion of the property where Source 1
is located. Unimax asserted that since the western portion of the property is not a plausible source of the mercury
contamination found in the Drainage Ditch #4 samples, the Source sample "is not representative of site
conditions..." and therefore Source 1 was not properly established.
Response: The HRS documentation record at proposal correctly identifies Source 1 as a contaminated soil source
on the MNOP property. Mercury contamination has been documented to be present at levels above background at
the facility surrounding Building 109 as determined by sampling and documented in the HRS documentation
record at proposal1.
1 This section of the support document deals exclusively with samples that are used to establish Source 1. Background
samples discussed in this section are not the same as the background sample that is used to establish the observed release
sample (see Figures 1 and 2). While background samples are not required to establish site sources, as explained in section
3.9.1, Representativeness of the Background Sample, of this support document, Source 1 background samples were used
solely to demonstrate that mercury contamination in Source 1 is elevated over natural mercury concentrations in the local
environment. The commenters' concerns about the observed release samples, including the background sample used to
establish an observed release, are discussed in section 3.10, Observed Release - Background, of this support document.
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The HRS defines a site as "[a]ny area where a hazardous substance has been deposited, stored, disposed, or
placed, plus those soils that have become contaminated from migration of a hazardous substance."
The HRS directs the scorer to identify sources at each site. HRS Section 2.2.1, Identify sources, states:
For the three migration pathways, identify the sources at the site that contain hazardous
substances. Identify the migration pathway(s) to which each source applies. For the soil exposure
pathway, identify areas of observed contamination at the site (see section 5.0.1).
HRS Section 2.2.2, Identify hazardous substances associated with a source, states:
For each of the three migration pathways, consider those hazardous substances documented in a
source (for example, by sampling, labels, manifests, oral or written statements) to be associated
with that source when evaluating each pathway.
The HRS documentation record at proposal documents that the soil on the eastern portion of the MNOP property
(specifically around Building 109) is contaminated with mercury. The HRS documentation record at proposal
states on page 15:
Source No. 1 consists of contaminated soil on the eastern portion of the MNOP property (Refs. 9,
p. 3; 11, p. 8) (see Figure 3 of this HRS documentation record). MNOP operated as an ordnance
manufacturing facility from before World War II until 1973 (Ref. 12, p. 1-1, 1-7). Ordnance
manufactured at MNOP included flares, small primers, detonators, and other triggering
mechanisms (Ref. 13, p. 2).
According to a technical manual prepared by the Department of the Army, military explosives,
such as those that were manufactured at the MNOP, contained mercury compounds as initiating
agents, including mercury fulminate (Ref. 23, pp. 7-5, 7-8). Explosive compounds were either
handled or stored in many areas throughout the MNOP property, including numerous small dryer
buildings, ordnance magazines, and blending and weighing houses. Specifically, Building 109,
located in the eastern portion of the MNOP near Source No. 1, was a primary explosives
production site (Ref. 13, pp. 11, 12, 54) (see Figures 2 and 3 of this HRS documentation record).
Soil samples collected from this area during the U.S. Army Corps of Engineers (USACE) 1996
site investigation and the EPA June 2011 supplemental sampling event contained mercury (Refs.
9, p. 1; 11, p. 8; 13, pp. 58, 83,84).
The HRS documentation record at proposal presents the analytical results for Source 1 and the background
sample on page 17:
TABLE 3: Analytical Results for Background and Source No. 1 Samples - June 2011
Sample
Designation
Sample ID
Hazardous
Substance
Hazardous
Substance
Concentration
MRL
References
Background
MNOP-01-SF
Mercury
0.073J (0.13)
mg/kg
0.050 mg/kg
11, pp. 4, 5; 31
Source No. 1
MNOP-04-SF
Mercury
0.40 mg/kg
0.050 mg/kg
11, P- 8
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As presented above, the HRS documentation record at proposal establishes Source 1 as an area of soil that has
come to be contaminated by mercury, a hazardous substance. Analytical data presented show that contaminated
soil is present at the facility surrounding Building 109 above naturally occurring levels. Additionally, historical
operations in Building 109 have been documented in the HRS documentation record at proposal to include
explosives production, which is known to have used mercury compounds as initiating agents. The contaminated
soil, as shown in the above table, has been documented to contain mercury at concentrations that are above
background levels (mercury levels that would be naturally present, or ubiquitous) in the area surrounding
Building 109 (see section 3.9.1, Representativeness of the Background Sample, of this support document). Thus,
the contaminated soil surrounding Building 109 (Source 1) is present as a result of hazardous substance migration
from the historical operations in Building 109 and Source 1 was properly established in the HRS documentation
record at proposal.
The HRS documentation record at proposal demonstrates that mercury concentrations in Source 1 are elevated
over natural conditions by taking background samples at locations near Source 1 (see Figure 1) and comparing the
source samples to these background samples. Source 1 mercury concentrations were documented to be greater
than the highest recorded background samples; thus, the HRS documentation record at proposal correctly
established Source 1 as contaminated soil near Building 109.
Specific comments related to the Site source are addressed in the following subsections:
• 3.9.1 Representativeness of the Background Sample
• 3.9.2 Using Qualified Analytical Data that Impact the Quantification of Mercury in the Source Sample
• 3.9.3 Documenting Mercury Contamination in the Source Sample
3.9.1 Representativeness of the Background Sample
Comment: Unimax and Cozen commented that the background sample used for Source 1 is insufficient to show
that contamination is non-ubiquitous in the area and due to former MNOP facility operations. Unimax asserted
that without a sufficient number of background samples, a source cannot be determined at the Site. Unimax
commented that GP has deposited low levels of contamination throughout the property and asserted GP's air
emissions may be the cause of the contamination at Source 1 and not the former MNOP facility operations.
Response: The HRS documentation record at proposal correctly presented background concentrations to show
that contamination is non-ubiquitous in the local environment and established Source 1 as contaminated soil near
Building 109. The background sample used in the HRS documentation record at proposal to establish Source 1 as
containing mercury concentrations above natural levels (MNOP-01-SF) contained a detected mercury
concentration of 0.073 mg/Kg. Source 1 was determined to have 0.40 mg/Kg mercury which is above the
background sample and was correctly established in the HRS documentation record at proposal.
The HRS does not require background samples be taken to establish the presence of source contamination, rather,
the HRS requires that the scorer identify sources at each site as stated in Section 2.2.1, Identify sources:
For the three migration pathways, identify the sources at the site that contain hazardous
substances. Identify the migration pathway(s) to which each source applies. For the soil exposure
pathway, identify areas of observed contamination at the site (see section 5.0.1).
The HRS defines a source to be "[a]ny area where a hazardous substance has been deposited, stored, disposed, or
placed, plus those soils that have become contaminated from migration of a hazardous substance."
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The HRS documentation record at proposal includes source background samples to establish that mercury
contamination in Source 1 is elevated over naturally occurring mercury levels in the local environment. Pages 16
and 17 of the HRS documentation record at proposal state:
The background and source soil samples listed in Table 2 were collected during the EPA June
2011 supplemental sampling event (Refs. 9, pp. 1, 3, 7, 9; 11, p. 3). The background soil sample
was collected from the north-central portion of the MNOP property where no site-related
activities have been known to occur (Refs. 8; 9, pp. 1, 3; 17, pp. 11, 17, 21, 25, 29, 33, 37, 41,
45). The source soil sample was collected from the eastern portion of the MNOP property where
mercury has been previously detected, near where facility operations were known to have
occurred and where explosives were handled and stored (Refs. 7, Appendix A, p. A-4; 9, p. 3; 13,
pp. 11, 12, 54). The background and source surface soil samples were collected at a depth of 0 to
6 inches bgs (Refs. 9, p. 1; 10, Appendix B, p. B-l).
Background and Source No. 1 surface soil samples were collected during the same sampling
event, from the same type of soil (sandy loam), and in accordance with the same sampling
procedures (Refs. 9, pp. 1, 6, 9; 10, p. 4; 30, pp. 1, 3). Surface soil samples were collected in
accordance with the EPA Region 4 SESD Field Branch Quality System and Technical Procedures
for Soil Sampling, SESDPROC-300-R1 (Refs. 9, p. 6; 10, p. 4; 24).
Background and Source No. 1 samples listed in Table 3 were analyzed for mercury in accordance
with EPA Method 245.5 and the EPA Region 4 Analytical Support Branch (ASB) Laboratory
Operations and Quality Assurance Manual (LOQAM), January 2011 (Refs. 9, p. 1; 11, p. 1; 27).
EPA Region 4 SESD reviewed all data according to the contract statement of work (SOW) and
EPA guidelines (Refs. 28; 11, p. 1). The minimum reporting limits (MRL) are listed on the
analytical data sheets in Reference 11. Each MRL is sample-specific and corresponds to the
lowest quantitative point on the calibration curve; it is adjusted for the amount of sample prepared
and any dilutions performed, as well as for percent moisture. The MRLs are equivalent to sample
quantitation limits (SQL) (Ref. 29).
While the HRS does not require background samples to establish the presence of hazardous substances in sources,
a background sample was used at this Site to establish elevated mercury concentrations in the source sample over
naturally occurring levels of mercury in the local environment. Unimax correctly stated that an observed release
determined by chemical analysis is established when the contaminant concentration in the observed release
sample is three times or more above the background concentration; however, this criteria does not apply to
identifying sources. As established in the HRS documentation record at proposal, the background sample shows
that mercury is not ubiquitous in the local soil and that Source 1 contains mercury at elevated levels compared to
background concentrations.
The background sample identified in the HRS documentation record at proposal contained a mercury
concentration of 0.073 J (0.13) mg/Kg. The most accurate estimate of the true value of mercury in the background
sample (MNOP-01-SF) is 0.073 mg/Kg mercury; however, in order to adjust for possible bias in the sample, or
sample analysis, the sample concentration was adjusted. As a result, the HRS documentation record at proposal
considers the background sample MNOP-01-SF to contain 0.13 mg/Kg mercury to account for possible bias (see
section 3.9.2, Using Qualified Analytical Data that Impact the Quantification of Mercury in the Source Sample, of
this support document for using qualified data). Thus, the contaminated soil surrounding Building 109 has been
established as containing contaminated soil related to Site activities.
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Even if the adjusted background sample concentration of mercury were 0.1336 mg/Kg as Unimax suggested,
instead of 0.13 mg/Kg as in the HRS documentation record at proposal, this would have no effect on the
identification of Source 1. The mercury concentration of 0.40 mg/Kg found in Source 1 is elevated above those
values found to be present in the soil surrounding Source 1. While an argument could be made that natural levels
of mercury in the local soil could be as high as 0.1336 mg/Kg, the natural levels of mercury were not found to be
ubiquitous at the mercury concentrations found in Source 1. Further, the commenter has not shown that the
natural levels of mercury in the soil surrounding the Site contain concentrations of mercury above this established
background level. Therefore, the background sample was correctly identified in the HRS documentation record at
proposal and Source 1 was correctly established.
Regarding aerial deposition from the nearby GP facility, the HRS documentation record at proposal documents
elevated concentrations of mercury surrounding Building 109 on the MNOP property relative to background
samples that were taken in nearby soils. While GP may have released mercury through air emissions that have
settled throughout the MNOP property, the contaminated soil scored as Source 1 has been compared to
background samples to determine that the contaminated soil is due to local deposits of mercury surrounding
Building 109 on the MNOP property. Furthermore, if the mercury contamination is found to be more extensive
than the existing preliminary sampling has indicated, then this will be considered in later stages of the Superfund
process.
Finally, the commenters' assertion that the HRS documentation record at proposal includes an insufficient number
of background samples to establish Source 1 is incorrect. While only one background sample is listed in the HRS
documentation record at proposal, other soil samples were taken from nearby locations and also show that
mercury is not a ubiquitous hazardous substance in the local environment near Source 1. Four other soil samples
were collected as part of the 2011 Supplemental Sampling Event (see Reference 9 of the HRS documentation
record at proposal) near Source 1 and none of the samples contained mercury at a concentration higher than the
sample reported as the background sample (MNOP-01-SF).
Therefore, the background sample used in the HRS documentation record at proposal is representative of the Site
conditions and natural levels of mercury in the soil and was properly used to show that Source 1 contains elevated
concentrations of mercury over natural levels.
This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.
3.9.2 Using Qualified Analytical Data that Impact the Quantification of Mercury in the Source
Sample
Comment: Unimax and Cozen challenged the association of mercury with Source 1. Unimax and Cozen asserted
that the concentration of mercury in the source sample was not three times the concentration in the source
background sample. The commenters argued that the mercury concentration in the source sample was not three
times the concentration in the background sample after the background concentration is adjusted upward to
account for issues in the analysis of the sample.
Unimax and Cozen commented that the single source soil background sample is suspect because it is merely an
estimate, denoted by the "J" value. Cozen stated that "there is significant doubt as to the utility of this soil
sample" particularly when the difference between the source soil sample and background sample is 0.01 mg/Kg.
Unimax stated "[w]hen analytical results are flagged by "J" ("estimated") qualifiers, the attendant uncertainty
creates a problem in determining whether a release may have occurred." Unimax further commented that "[t]he
calculation of the background value is incorrect due to an arithmetic error" and when computed correctly, Unimax
asserted that the soil sample contamination does not exceed three times background level. Unimax commented
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that although the correct analyte and medium-specific factor for mercury in soil was used (1.83), "sufficient
numerical precision" was not used.
Response: The use of qualified data and the possible bias associated with this analytical sampling data was
accounted for in the association of mercury with Source 1. The mercury concentration in the source sample is
sufficiently higher than in the background sample to document that the soil in Source 1 is contaminated with
mercury. Thus, mercury is correctly associated with the source. The HRS does not require that the increase
between the background and source sample contamination be three times the background level (i.e., observed
release criteria) to demonstrate that a source is contaminated with a hazardous substance. The HRS only requires
the contaminant be present at the source.
HRS Section 2.2.2, Identify hazardous substances associated with a source, states how to associate hazardous
substances with a source:
For each of the three migration pathways, consider those hazardous substances documented in a
source (for example, by sampling, labels, manifests, oral or written statements) to be associated
with that source when evaluating each pathway.
The HRS documentation record at proposal presents the analytical results for Source 1 and the background
sample on page 17:
TABLE 3: Analytical Results for Background and Source No. 1 Samples - June 2011
Sample
Designation
Sample ID
Hazardous
Substance
Hazardous
Substance
Concentration
MRL
References
Background
MNOP-Ol-SF
Mercury
0.073J (0.13)
mg/kg
0.050 mg/kg
11, pp. 4, 5; 31
Source No. 1
MNOP-04-SF
Mercury
0.40 mg/kg
0.050 mg/kg
11, P- 8
As shown in Table 3, the mercury level in the background sample (MNOP-Ol-SF) was reported as 0.073 mg/kg
and assigned a data quality qualifier of a J (in this case, a J qualifier means that the identification of the analyte is
acceptable, but the reported value is an estimate due to laboratory issues). The addition of a qualifier to the data
does not mean the reported data value is incorrect, rather, the addition of a qualifier to the data only cautions the
user that the reported value might be slightly inexact due to possible bias. However, the reported (qualified) value
is the best estimate of the true value of mercury in the surrounding soils and the adjusted value (0.13 mg/kg) is an
estimate of the highest concentration that could have been present in the sample if the sample were biased low2.
The HRS documentation record at proposal uses the adjusted value of 0.13 mg/Kg mercury to establish the
natural levels of mercury concentrations and thus provides a reasoned estimate of mercury background
concentrations in the soil surrounding Source 1 (see section 3.6, Data Quality Issues, of this support document,
regarding the use of qualified data in the HRS evaluation).
The commenters incorrectly calculated and asserted that the difference between the background sample and
source sample is 0.01 mg/Kg. To reach this number, the commenters adjusted the background sample
2 Biased low means that the true concentration of the hazardous substance in the sample, if no quality control issues were
identified, might be greater than the measured laboratory value. Thus, the adjusted value represents the maximum
concentration of that substance that could be present in the sample. However, the adjusted value does not necessarily
represent a more accurate value or the true value.
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concentration (0.13 mg/kg), multiplying it by 3 for a total of 0.39 mg/kg, then compared the adjusted background
sample concentration (0.39 mg/kg) to the Source 1 sample concentration (0.40 mg/kg) to calculate the difference
of 0.01 mg/kg. Multiplying the background sample concentration by 3 is incorrect when determining the natural
levels of a contaminant in the local environment for the purpose of establishing a source during an HRS
evaluation (see sections 3.9, Source 1; and 3.9.3, Documenting Mercury Contamination in the Source Sample, of
this support document). The HRS does not require source samples to be 3 times the background concentration to
establish natural levels of a contaminant in the local environment. The HRS only requires that a source be an area
where hazardous substances have been "deposited, stored, disposed, or placed..." and that the site source contain
a hazardous substance(s) available to a pathway (at this site, the surface water pathway). The HRS documentation
record at proposal uses the background concentration value (0.13 mg/Kg) to determine the natural levels of
mercury in the local environment; therefore, Source 1 was properly established as containing mercury
contamination above background levels and contains contamination due to Site-related activities.
This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.
3.9.3 Documenting Mercury Contamination in the Source Sample
Comment: The DoD, Unimax, and Cozen commented that the number of source samples and background source
samples raises uncertainty about the identification of Source 1. Unimax stated that "[t]he proposed listing is based
on comparing one background surface soil sample to a single soil sample obtained at the Site in 2011." Unimax
further stated that comparing one background soil sample to only one other soil sample is "an insufficient quantity
of samples to establish a background concentration and therefore the data does not indicate a release." Unimax
asserted that without a sufficient number of background samples, a source cannot be determined at the Site.
Response: The HRS documentation record at proposal correctly establishes Source 1 contaminated soil as
containing a hazardous substance at concentrations above background levels. Background samples are used to
show that soil contamination in a source is above natural levels in the local environment. The HRS does not
require that multiple samples be taken to identify a source or to determine background concentrations, and Source
1 was correctly established in the HRS documentation record at proposal as containing contaminated soil above
background concentrations.
As quoted in section 3.9, Source 1, of this support document, the HRS directs the scorer to "identify the sources at
the site that contain hazardous substances." Source 1 was correctly identified and established in the HRS
documentation record at proposal as being contaminated soil near Building 109.
While the HRS does not require background samples (or multiple background samples) for source soil samples,
and the HRS documentation record at proposal only lists one background sample under Source 1, other soil
samples were taken from nearby locations (see Reference 9, June 2011 Supplemental Sampling Event, of the HRS
documentation record at proposal). These other samples show that mercury is not a ubiquitous hazardous
substance near Source 1 (see Figure 1 of this support document, and page 3 of Reference 9 of the HRS
documentation record at proposal). None of the four other soil samples that were collected as part of the 2011
Supplemental Sampling Event contained mercury at a concentration higher than the background sample (MNOP-
01-SF) used in establishing Source 1.
Therefore, the background sample used in the HRS documentation record at proposal in establishing Source 1 is
representative of the Site conditions, and was properly used to show that Source 1 contains elevated
concentrations of mercury over the natural levels present in the surrounding soil.
This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.
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3.10 Observed Release - Background
Comment: Unimax and Cozen commented that the background sample used to establish an observed release was
determined incorrectly, contained an insufficient number of background samples, and was not of the same media
as the observed release sample.
Response: A single valid background sample for mercury in surface water is sufficient to identify that a
significant increase in the mercury concentration in the release sample (used to establish an observed release to
surface water) has been documented. While the background level assigned is based on a single sample, this level
is supported by other samples taken in the vicinity of the site. The background sample (MNOP-W-Ol-SD; see
Figure 2) is located west and upgradient of Drainage Ditch #4 in the same watershed and same wetland as the
observed release sample and from the same medium, without the potential influence from the MNOP facility (see
Figure 2 of this support document and Figure 3 of the HRS documentation record at proposal).
The HRS addresses background in the context of identifying an observed release of a hazardous substance to the
environment by chemical analysis. HRS Section 4.1.2.1.1, Observed release, states in relevant part:
Establish an observed release to surface water for a watershed by demonstrating that the site has
released a hazardous substance to the surface water in the watershed. Base this demonstration on
either:
• Direct observation: . . .
• Chemical analysis:
- Analysis of surface water, benthic, or sediment samples indicates that the
concentration of hazardous substance(s) has increased significantly above the
background concentration for the site for that type of sample (see section 2.3)
- Limit comparisons to similar types of samples and background
concentrations—for example, compare surface water samples to surface
water background concentrations.
• Some portion of the significant increase must be attributable to the site to establish the
observed release, except: when the site itself consists of contaminated sediments with no
identified source, no separate attribution is required.
If an observed release can be established for a watershed, assign an observed release factor value
of 550 to that watershed, enter this value in Table 4-1, and proceed to section 4.1.2.1.3...
In establishing whether a hazardous substance is significantly above background concentrations, HRS Section
4.1.2.1.1 refers the scorer to HRS Section 2.3 for requirements for establishing significant increases in hazardous
substance concentrations. HRS Section 2.3, Likelihood of release, specifies that the scorer is to "[u]se the criteria
in Table 2-3 as the standard for determining analytical significance." HRS Table 2-3 states:
An observed release is established as follows:
• If the background concentration is not detected (or is less than the detection limit), an
observed release is established when the sample measurement equals or exceeds the
sample quantitation limit.
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• If the background concentration equals or exceeds the detection limit, an observed release
is established when the sample measurement is 3 times or more above the background
concentration.
Based on HRS Table 2-3, the purpose of the background sample is to establish a background level (the
concentration of a hazardous substance) for the Site that provides a reference point to evaluate whether a release
has occurred.
HRS Section 4.1.2.1.1, Observed Release, in part states that samples should be compared to similar types of
samples:
• Chemical analysis:
-Limit comparisons to similar types of samples and background concentrations—for
example, compare surface water samples to surface water background concentrations...
Thus, a background sample should be located in the same media as the release samples being evaluated and
outside of any potential impacts from facility operations. Background samples are used to demonstrate an increase
in hazardous contamination due to facility operations and provide a reference point for contamination that may be
naturally present in the local environment
The HRS documentation record at proposal on page 22 explains the rationale for the establishment of a
background level at the MNOP site:
During the EPA June 2011 supplemental sampling event, one background sediment sample,
MNOP-W-Ol-SD, was collected from HRS-eligible palustrine forested wetlands west of and
upgradient from Drainage Ditch 4. Contaminated sediment sample MNOP-D4-W-09-SD was
collected from Drainage Ditch 4 within HRS-eligible palustrine forested wetlands downstream of
the PPE. Background and contaminated sediment samples were collected from HRS-eligible
palustrine forested wetlands at depths ranging from 0 to 3 inches bgs (Refs. 9, pp. 1, 3, 8, 9; 36,
Map 1).
The sediment samples were collected in accordance with the EPA Region 4 SESD Field Branches
Quality System and Technical Procedures for Sediment Sampling, SESDPROC-200-R2 (Refs. 9,
pp. 1, 6; 10, p. 4; 25)...
The background and contaminated sediment samples were collected during the same sampling
event, in accordance with the same sampling procedures, and from the same type of HRS-eligible
wetland (palustrine forested).(Refs. 9, pp. 1, 3, 6;36) (see Figure 3 of this HRS documentation
record).
Table 7 from page 23 of the HRS documentation record at proposal, provides the background and observed
release samples as follows:
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TABLE 7: Analytical Results for Background and Contaminated Sediment Samples - June 2011
Sample
Description
Sample ID
Hazardous
Substance
Concentration
MRL
References
Background
MNOP-W-01-SD
Mercury
0.16J (0.29)
mg/kg
0.050 mg/kg
11, pp. 4, 22; 31; 32,
pp. 8,18
Release
MNOP-D4-W-09-SD
Mercury
1.1 mg/kg
0.050 mg/kg
11, P- 21
The commenters' specific issues with this background level determination are addressed in the following
subsections:
• 3.10.1 Adequacy of Background Sample - Observed Release
• 3.10.2 Sample Similarity
• 3.10.3 Number of Samples used to Identify an Observed Release
3.10.1 Adequacy of Background Sample - Observed Release
Comment: Cozen and Unimax commented that the single observed release background sample, which is intended
to provide a defensible reference to evaluate whether a release from the site has occurred, is insufficient to
determine attribution of mercury in Drainage Ditch #4 to the former MNOP. Cozen and Unimax added that
observed release samples must be significantly greater than the background concentration. Unimax asserted that
the determination of the observed release sample (MNOP-D4-W-09-SD) to be significantly greater than
background contamination levels is incorrect.
Unimax commented that the sediment samples found in the upper portions of Drainage Ditch #4 contain lower
concentrations of mercury than in the background sample, and that in 2009 TetraTech considered the upper
portion of Drainage Ditch #4 to be background. Unimax stated that for the sample to be considered a release, the
concentration must exceed three times the background; which "strongly suggests the background determination
[in the HRS evaluation] is arbitrary and contradicted by the additional data contained in the HRS references."
Response: The background level established in the HRS documentation record at proposal, based on the single
observed release background sample, is sufficient for identification of a significant increase in mercury
concentrations consistent with the HRS. The background sample was taken from the same palustrine forested
wetland and upgradient of any release from Source 1. However, this background sample was not the only sample
used to establish the background level.
Other samples considered in establishing the background level include those samples taken from Drainage Ditch
#4 upgradient of the observed release sample in Drainage Ditch #4. These samples in the upper portions of
Drainage Ditch #4 showed mercury concentrations ranging from non-detect (0.050 mg/kg in samples MNOP-D4-
01-SD, MNOP-D4-02-SD-DUP, MNOP-D4-03-SD, MNOP-D4-05-SD, and MNOP-D4-06-SD) to 0.083 mg/kg
in sample MNOP-D4-04-SD.
These samples show that the background mercury level in the vicinity of the Site is no more than the background
concentration of the designated mercury background sample. These samples are located upgradient of the release
sample location but were not considered for background samples as they are part of the contaminant migration
pathway from Building 109 at the MNOP site. However, as discussed in section 3.11.2, Contaminant
Concentration Gradient in Drainage Ditch #4, of this support document, these samples contain different
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streambed morphologies and thus may not have elevated mercury concentrations due to this difference, but the
absence of mercury contamination in these upgradient samples indicates that mercury is not ubiquitous.
In addition to the 2011 Supplemental Sampling Event samples, Reference 7 of the HRS documentation record at
proposal includes analytical data from an Expanded Site Inspection that includes samples taken from Rocky
Creek upgradient of the confluence with Drainage Ditch #1 (and upgradient of Drainage Ditch #4). Samples RC-
400-SD, RC-401-SD, RC-402-SD and RC-403-SD (sample locations are shown in Figure 4 on page A-4 of
Reference 7 of the HRS documentation record at proposal) of the Expanded Site Inspection all contain mercury
levels that are below the detection limit and less than the concentration identified in background sample MNOP-
W-01-SD (see page B-110 of Reference 7 of the HRS documentation record at proposal).
However, background sample MNOP-W-Ol-SD was collected from the same HRS-eligible wetland west of the
observed release sample (MNOP-D4-W-09-SD) which had similar background conditions as the release sample
location and was collected during the same sampling event; therefore this sample is sufficient for identifying a
significant increase in mercury concentrations in Drainage Ditch #4.
Insomuch as this comment addresses the attribution of mercury at the Site, section 3.11, Observed Release -
Attribution, of this support document further addresses the attribution component of establishing a release by
chemical analysis to the Site.
This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.
3.10.2 Sample Similarity
Comment: Cozen commented that the EPA failed to explain why a sample obtained from palustrine forested
wetlands, west of Drainage Ditch #4, was used for the background concentration to establish an observed release
by chemical analysis. Cozen asserted that the background sample was "apparently not [collected] from sediments
in a stream and/or drainage ditch" and is not in the same media as the observed release sample (i.e., sediment to
sediment). Cozen and Unimax commented that samples used for comparison purposes must be from the same
media.
Response: The background level was correctly established consistent with the HRS. The background sample was
collected in a similar environment and in the same media as the release sample. The background sample was
taken upgradient of the release samples in Drainage Ditch #4, in the same palustrine wetland, using the same
sampling procedures, and at the same time the release samples were collected (see Figure 3 of the HRS
documentation record at proposal). For HRS purposes, the sample similarity of background sample (MNOP-W-
01-SD), collected in palustrine forested wetlands and considered a surface water sample, is correctly compared to
the surface water observed release sample (MNOP-D4-W-09-SD), collected from Drainage Ditch #4, as they are
both surface water samples.
As defined by HRS Section 4.0.2, Surface water categories, surface water is defined in part as follows:
For HRS purposes, classify surface water into four categories: rivers, lakes, oceans, and coastal
tidal waters.
-Rivers include:
• Perennially flowing waters from point of origin to the ocean or to coastal tidal
waters, whichever comes first, and wetlands contiguous to these flowing waters.
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HRS Section 4.1.2.1.1, Observed Release, in part states that samples should be compared to similar types of
samples:
• Chemical analysis:
-Limit comparisons to similar types of samples and background concentrations—for
example, compare surface water samples to surface water background concentrations...
Thus, the purpose of a background sample is to establish a background level in the medium of concern for the site
to determine whether or not a release from the site has occurred. Background samples should be taken from the
same media (surface water, sediment, soil, etc.) and should be sufficiently similar to release samples to ensure the
increase in contamination between the background level and the release sample is due to a release and not due to
differences in the samples or the analysis.
Page 22 of the HRS documentation record at proposal identifies that the background and release samples were
collected from the same surface water body:
The background and contaminated sediment samples were collected during the same sampling
event, in accordance with the same sampling procedures, and from the same type of HRS-eligible
wetland (palustrine forested) (Refs. 9, pp. 1, 3, 6; 36).
Hence, both background and observed release sediment samples were collected from the same HRS-eligible3
palustrine forested wetlands, within the same watershed and are thus considered taken from the same media.
Additionally, as stated in the HRS documentation record at proposal, the background sample was taken during the
same sampling event, under the same physical conditions (i.e., weather, season, etc.), and used the same sampling,
handling, and analytical procedures as the release samples. Therefore, the similarities of the background and
release samples at this Site are considered sufficiently similar to ensure the significant increase is not simply due
to difference in the sample media or to differences in sampling and analysis procedures, and the significant
increase criteria for establishing an observed release have been met.
This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.
3.10.3 Number of Background Samples Used to Identify an Observed Release
Comment: Cozen and Unimax commented that only one background sediment sample used to establish an
observed release is insufficient and not defensible to establish background conditions, account for background
variability, and attribute contamination to the former Macon Naval Ordnance Plant.
Response: The background level is sufficiently supported to establish a significant increase in the mercury level in
the release sample consistent with the HRS. In establishing an observed release, a background concentration is
used to show that contamination in the release sample is significantly above those levels that occur naturally in
the local environment or significantly above those levels that are present due to other nearby facilities. The HRS
does not require that multiple samples be taken to identify an observed release or to determine background
3 Wetlands are considered HRS-eligible if they meet the criteria defined in 40 CFR Section 230.3. Generally this definition
includes areas that are inundated by surface or ground water at a frequency and duration sufficient to support a prevalence of
vegetation typically adapted for life in saturated soil conditions.
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concentrations, rather, the background level is used to show that observed release contamination is significantly
above background levels.
HRS Section 4.1.2.1.1, Observed release, states in relevant part:
Establish an observed release to surface water for a watershed by demonstrating that the site has
released a hazardous substance to the surface water in the watershed.
The HRS does not require multiple background samples to establish an observed release by chemical analysis.
However, as noted in section 3.10.1, Adequacy of Background Sample - Observed Release, of this support
document, Reference 7 of the HRS documentation record at proposal contains additional samples from Rocky
Creek upgradient of the release sample that contain mercury concentrations below the background level
established by sample MNOP-W-Ol-SD in the HRS documentation record at proposal (see Figure 4 and page B-
110 of Reference 7 of the HRS documentation record at proposal). Nevertheless, the observed release was
established based on a significant increase in the concentration of mercury in sample MNOP-D4-W-09-SD (1.1
mg/kg) as compared to background sample MNOP-W-Ol-SD (0.29 mg/kg). Mercury is not naturally occurring at
the levels found in the release sample and therefore the background sample is sufficient and consistent with the
HRS.
This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.
3.11 Observed Release - Attribution
Comment: Unimax commented that the attribution of mercury contamination to the former MNOP site was not
properly established and that the EPA had not considered that the mercury could have come from alternative sites.
Unimax commented that although low levels of mercury are present on the MNOP property, the property is not
the source of any downstream contamination. Unimax asserted that the additional data contained in the HRS
documentation package contradicts the determination of attribution to the MNOP site due to faulty analysis and
the failure to consider alternative sources.
Response: The significant increase of mercury contamination in Drainage Ditch #4 was correctly attributed to the
MNOP site consistent with the HRS.
HRS Section 2.3, Likelihood of release, presents the basic requirements for establishing an observed release
including attribution to the site in relevant part:
Establish an observed release either by direct observation of the release of a hazardous substance
into the media being evaluated (for example, surface water) or by chemical analysis of samples
appropriate to the pathway being evaluated (see sections 3, 4, and 6). The minimum standard to
establish an observed release by chemical analysis is analytical evidence of a hazardous substance
in the media significantly above the background level. Further, some portion of the release
must be attributable to the site, [emphasis added]
HRS Section 4.1.2.1.1, Observed release, contains specific instructions on establishing observed releases to
surface water, and states in relevant part:
Establish an observed release to surface water for a watershed by demonstrating that the site has
released a hazardous substance to the surface water in the watershed. Base this demonstration on
either:
• Direct observation: . . .
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• Chemical analysis:
- Analysis of surface water, benthic, or sediment samples indicates that the
concentration of hazardous substance(s) has increased significantly above the
background concentration for the site for that type of sample (see section 2.3)
- Limit comparisons to similar types of samples and background
concentrations—for example, compare surface water samples to surface
water background concentrations.
- Some portion of the significant increase must be attributable to the site to
establish the observed release, except: when the site itself consists of
contaminated sediments with no identified source, no separate attribution is
required, [emphasis added]
Thus, there are two parts to establishing an observed release by chemical analysis for the ground water migration
pathway: first, establishing a significant increase in contaminant concentrations, and second, attributing at least
part of the increase to the site.
Attribution of a release to a site is also established in two steps. First it is documented that the released
substance(s) is associated with sources at the site and that containment for the HRS component or pathway is not
such that the release could not occur. Second, it is shown that not all of the significant increase in the released
hazardous substances could have come from other sites (i.e., that part of the increase came from the site).
As discussed in section 3.10, Observed Release - Background, of this support document, the background
hazardous substance (mercury) level was correctly established in the HRS documentation record at proposal. The
background level allows for a significant increase of a hazardous substance in a release sample to be identified. A
significant increase in the concentration of mercury was established in sample MNOP-D4-W-09-SD as detailed in
section 4.1.2.1.1, Observed Release, of the HRS documentation record at proposal (see Figure 1) and the
commenters did not challenge that the mercury contamination in this established background sample can also
support the attribution of the release to the Site.
Pages 25 and 26 of the HRS documentation record at proposal establish that some portion of the observed release
is attributable to the Site, stating:
The MNOP was constructed before World War II and was operated as an ordnance
manufacturing facility until 1973 (Refs. 12, p. 1-1; 13, p. 2)...
Explosive compounds were either handled or stored in many areas throughout the MNOP
property, including numerous small dryer buildings, ordnance magazines, and blending and
mixing houses (Ref. 13, pp. 11, 12, 54). According to a technical manual prepared by the
Department of the Army, military explosives, such as those that were manufactured at the
MNOP, contained mercury compounds as initiating agents, including mercury fulminate (Ref. 23,
pp. 7-1, 7-5, 7-8). Building 109, located in the eastern portion of the MNOP near Source No. 1,
was a primary explosives production site (Ref. 13, pp. 11, 12, 54) (see Figures 2 and 3 of this
HRS documentation record). Soil samples collected from this area during the USACE 1996 site
investigation and EPA June 2011 supplemental sampling event contained mercury (Refs. 9, p. 3;
13, pp. 58, 83, 84).
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The HRS documentation record at proposal continues by discussing association of mercury contamination
with the Site source:
The source sample collected from Source No. 1 (contaminated soil on the eastern portion of
MNOP) during the EPA June 2011 supplemental sampling event contained mercury (Refs. 9, p.
3; 11, p. 8) (see Table 3 in Section 2.2.2 for Source No. 1 of this HRS documentation record).
Sediment samples collected from Drainage Ditch 4, which receives runoff from Source No. 1,
also contained mercury. The presence of mercury in Drainage Ditch 4 documents the migration of
releases from Source No. 1 at the MNOP (Refs. 9, p. 3; 11, pp. 13, 16, 19, 20, 21) (also see
Tables 6 and 7 in Section 4.1.2.1.1, Observed Release, of this HRS documentation record).
Furthermore, an observed release of mercury has been documented in HRS-eligible wetlands
along Drainage Ditch 4 (Refs. 9, p. 3; 11, p. 21; 36).
Mercury has been documented in Source No. 1, in Drainage Ditch 4 and in palustrine forested
wetlands indicating migration of hazardous substances from the MNOP property (see Table 3 in
Section 2.2.2 for Source No. 1, and Table 7 in Section 4.1.2.1.1, Observed Release, of this HRS
documentation record).
The following subsections address specific comments regarding the attribution of the significant increase in
mercury to the MNOP site:
• 3.11.1 Possible Mercury Releases from Alternative Sites
• 3.11.2 Contaminant Concentration Gradient in Drainage Ditch #4
• 3.11.3 Contaminant Concentration Downgradient of the RCWRF
• 3.11.4 Other Data Sets
3.11.1 Possible Mercury Releases from Alternative Sites
Comment: Unimax and Cozen commented that the mercury contamination found in the observed release sample
cannot be attributed to the former MNOP and the EPA has failed to consider other sites which may be causing the
mercury contamination.
Unimax commented that the following possible contributors of mercury to Drainage Ditch #4 were not
investigated in establishing attribution of the mercury in the release samples to the MNOP site:
• Rocky Creek Water Reclamation Facility (RCWRF)
• Graphic Packaging International, Inc. (GP)
• Southern Wood Piedmont Company
• "Off-site source areas north of the site"
Unimax commented that the mercury contamination in the release sample is due to operations at facilities other
than the MNOP facility. Unimax asserted that while mercury contamination may be present in the area, it is not
due to operations at the MNOP facility and the significant increase found in the release sample in Drainage Ditch
#4 is due to releases from the RCWRF. Unimax stated that the "EPA's failure to explain why the off-site mercury
impacts to Ditch #4 are not derived from the RCWRF and the GP facilities is contrary to EPA's HRS guidance."
Unimax concluded its comment by stating that since the former MNOP is not the source of contamination in
Drainage Ditch #4, the HRS Site score should be 0.
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Response: The significant increase in mercury concentration found in the release sample (MNOP-D4-W-09-SD)
in Drainage Ditch #4 is correctly attributed to the MNOP site and not to any alternative sites. Other alternative
facilities that could impact the level of mercury contamination in the release sample were considered and
described in the HRS documentation record at proposal and, at that time, were found not to be the source of the
mercury in the observed release in Drainage Ditch #4.
The HRS documentation record at proposal on pages 25-26 discusses other nearby facilities and their possible
contributions to the mercury contamination, stating:
Other facilities in the area include the MBCIA, which renamed the MNOP property the Allied
Industrial Park and currently leases or sells buildings as office and warehouse space to various
industrial and commercial businesses on the AIP property (Refs. 7, Appendix A, p. A-3; 13, pp.
1, 2, 3; 14, p. 2-9; 15). Politex U S Inc. (Politex) is the only manufacturing business that is
currently located at the AIP. Politex is a textile manufacturing firm that produces roofing
membranes, clothing and furniture padding, and building materials (Ref. 15). Politex is located on
the western portion of the MNOP property (Refs. 6, pp. 42 through 49; 7, Appendix A, p. A-3).
Runoff and drainage originating from Politex does not enter Drainage Ditch 4 (Ref. 7, Appendix
A, pp. A-2, A-3) (see Figure 3 of this HRS documentation record). The property where Source
No. 1 soil sample MNOP-04-SF was collected is owned by the City of Macon and is operated as
a recreational park that includes baseball fields (Refs. 6, pp. 7, 8; 7, Appendix A, pp. A-2, A-3; 9,
p. 3).
Possible off-site sources also include the FMNOL, AWI, and the Rocky Creek water reclamation
facility (RC WRF). AWI and FMNOL are currently listed on the EPA NPL under CERCLIS ID
No. GAN000410033 at docket number EPA-HQ-SFUND-2010-0640-0002 (Ref. 47). Runoff
from FMNOL and AWI flows into Rocky Creek via a drainage easement. The drainage easement
enters Rocky Creek west and upstream of Source No. 1 soil sample MNOP-04-SF and Drainage
Ditch 4. Drainage Ditch 4 is located just west of the RC WRF (Ref. 7, Appendix A, p. A-2).
The FMNOL was reportedly used for disposal of solid wastes and ordnance throughout the
operational history (1941 to 1974) of the MNOP (Refs. 8; 17, pp. 42, 43, 46, 47; 18, p. 2). The
landfill was also used for disposal of used parts and construction debris (Refs. 14, p. 2-11; 18, p.
2). During the EPA May 2009 ESI, mercury was detected in soil samples collected from the
FMNOL at concentrations ranging from 0.47 mg/kg (FML-303-SF) to 4.7 mg/kg (FML-304-SB)
(Ref. 35, pp. 130, 132).
Since 1948, AWI has operated an acoustic ceiling tile manufacturing plant on 130 acres of land
west of the MNOP property (Ref. 19, p. 3). In 1980, AWI notified the Georgia Environmental
Protection Division (GAEPD) that it was a generator of hazardous waste and AWI was classified
as a conditionally exempt small quantity generator under the Resource Conservation and
Recovery Act (RCRA). PCBs are the primary hazardous substance of concern for this facility, not
metals (Ref. 19, pp. 5, 6).
The RC WRF, located southeast of and downstream from MNOP, provides wastewater treatment
for the southern and western portions of the City of Macon. Treated wastewater from this facility
is discharged into the Ocmulgee River; however, RC WRF maintains a National Pollutant
Discharge Elimination System (NPDES)-permitted discharge point at the southern property
boundary (Refs. 9, p. 3; 45, pp. 2, 3; 46, pp. 1,8). The NPDES permit requires RC WRF to
monitor outfall discharges for biochemical oxygen demand, total suspended solids, pH, chlorine,
fecal coliform, nitrogen, dissolved oxygen, PCBs, and phosphorus (Ref. 46, pp. 6, 7). There are
currently no documented releases of mercury at this location (Refs. 9, p. 3; 46, pp. 6, 7).
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All nearby facilities were considered in the evaluation of possible contributors of contamination at the Site;
however, the evaluation has not documented any evidence of these other off-site facilities contributing to the
significant increase of mercury in the observed release sample. The evaluation also does not negate EPA's
determination that some portion of the significant increase in mercury levels is attributable to the Site. The
following subsections address the specific off-site facilities that Unimax asserted may be potentially contributing
to the mercury contamination at the Site:
• 3.11.1.1 Wastewater Discharges from GP and the Southern Wood Piedmont Company via the
RCWRF
• 3.11.1.2 GP Air Emissions
• 3.11.1.3 Contribution of Sources West and North of Source 1
3.11.1.1 Wastewater Discharges from GP and the Southern Wood Piedmont Company via the RCWRF
Comment: Unimax commented that mercury discharges from GP and SWPC to the RCWRF had not been
considered in attributing the mercury release to the MNOP site. Unimax commented that both GP and SWPC
have been documented to historically send wastewater containing mercury to the RCWRF. Unimax commented
that the RCWRF has treated wastewater containing mercury since its construction and that the RCWRF has
historically been in non-compliance with its National Pollution Discharge Elimination System (NPDES) permit
for discharge of organic waste. Further, Unimax commented that the HRS documentation record appears to
conclude that since the RCWRF does not currently monitor for mercury it cannot be a current or historic source of
the mercury contamination found in Drainage Ditch #4. Unimax asserted that RCWRF discharge into Drainage
Ditch #4 is responsible for the increase in mercury in the observed release sample.
Response: The possibility of mercury being discharged from the RCWRF due to the inputs of discharge from GP
and SWPC to the RCWRF was considered as a possible contributor to the increase in mercury contamination in
the observed release sample in Drainage Ditch #4. However, discharges from the RCWRF were found not to be
contributing to the mercury contamination to Drainage Ditch #4. The historic effluent outfall from the RCWRF
(from 1975 to 1991) was directly to the wetlands located to the south of the RCWRF facility as shown in Figure 3
below, and in fact, RCWRF effluent has never been directly discharged to Drainage Ditch #4 (see Attachment 3,
and Section 3.11.3, Contaminant Concentration Downgradient of the RCWRF, of this support document for
additional information regarding the RCWRF effluent outfall). Furthermore, no evidence could be found to
document that the RCWRF has ever released mercury into Drainage Ditch #4. In fact, the discharge from the
RCWRF does not contain mercury (see Attachment 1 to this support document). Additionally, aside from general
allegations, Unimax did not present any data to show that mercury contamination is associated with the effluent
from the RCWRF, nor did it provide evidence that the RCWRF has historically discharged effluent to Drainage
Ditch #4, that could contribute to the significant increase in the observed release sample.
Contrary to Unimax's assertions, the HRS documentation record at proposal does not conclude that the RCWRF
is not contributing mercury contamination to Drainage Ditch #4 because the RCWRF discharge is not being
monitored; rather, the HRS documentation record at proposal identifies the facility to be a potential off-site
contributor. However, as discussed above and shown in Figure 3, the historical RCWRF discharge point is
downgradient of the release sample location (MNOP-D4-W-09-SD, shown above in Figure 3 and in Figure 2 of
this support document; also, see Reference 3 of the HRS documentation record at proposal for a topographical
map) and thus it is unlikely that RCWRF discharge contributed to the mercury contamination levels in the release
sample.
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ROCR
MNOP-D4-W-08-SD
(PPE1)
Former Wetlands Outfall
Lat/Long:
32.76844864706199,
-83.638466745615
MNOP-D4-W-09-SD
Figure 3. Aerial image of the Rocky Creek Water Reclamation Facility indicating the location of the historical effluent outfall and the
approximate locations of PPE-1 and the observed release sample MNOP-D4-W-09-SD (see figure 2 for the exact sample locations).
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Even if the RCWRF effluent had been discharged to Drainage Ditch #4, there is no evidence suggesting that
mercury would have been present in the discharge. The RCWRF currently monitors its discharge for mercury as
required by its NPDES permit and performs annual effluent testing with results dating back to 1996 (presented in
Attachment 1 of this support document). The attached sampling results (Attachment 1) show that mercury has
never been documented to be present in the effluent leaving the facility for this time period. Based on the
information available at the time of the HRS evaluation, no evidence exists to suggest that the RCWRF effluent is
a contributor to the mercury contamination found in the observed release sample in Drainage Ditch #4.
Insomuch as any mercury in the discharges from the GP and Southern Wood Piedmont Company would have to
pass through the RCWRF, no indication of a release of mercury from the RCWRF to the wetlands east of
Drainage Ditch #4 can be found (see section 3.11.3, Contaminant Concentration Downgradient of the RCWRF, of
this support document for further explanation of the RCWRF treatment facility processes). Water discharges from
GP and the Southern Wood Piedmont Company cannot be said to have contributed to the significant increase in
the observed release. However, these properties may be considered at a later stage in the Superfund process.
For additional information, see section 3.11.3, Contaminant Concentration Downgradient of the RCWRF, of this
support document, which addresses the concentration gradient in Drainage Ditch #4 as it relates to the RCWRF
discharge
This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.
3.11.1.2 GP Air Emissions
Comment: Unimax commented that the GP released mercury to the air and that GP should be considered a
possible source of the mercury contamination in the vicinity of the Site. Unimax specifically commented that the
mercury will settle out on nearby soils and plants. Unimax asserted that GP air emissions are also a plausible
source of the low levels of mercury found in surface soils throughout the Site and in the background samples.
Response: Contamination originating from GP air emissions is not a likely source of the mercury either in Source
1 or in the observed Release sample in Drainage Ditch #4. The HRS documentation record at proposal includes
samples in the vicinity of the Site that show that widespread mercury contamination is not present, as would be
expected if significant dispersion of mercury resulting from air emissions.
If aerial deposition were the source of contamination at the Site as Unimax asserts, the contamination would be
widespread throughout the MNOP property. The HRS documentation record at proposal contains six soil and
sediment samples from the July 2011 Supplemental Sampling Event that are located throughout the sampling area
on the MNOP property and in Drainage Ditch #4 that do not indicate widespread mercury contamination
(depicted in Figure 1 of this support document and Figure 3 of the HRS documentation record at proposal).
Additionally, the 2009 Region 4 SESD (performed by TetraTech) data (these data sets were identified by
Unimax) are included as References 7, 34 and 35 of the HRS documentation record at proposal; and, as Unimax
commented, only 6 of the 43 surface soil samples show detectable mercury levels in the 2009 Region 4 SESD
data. These findings support that mercury is not ubiquitous or widespread throughout the MNOP property except
for the mercury contamination as identified in the HRS documentation record at proposal as Source 1 near
Building 109. Furthermore, Unimax presented no data to support that widespread mercury contamination on the
MNOP property exists that would be consistent with aerial depositions from the GP facility.
This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.
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3.11.1.3 Contribution of Sources West and North of Source 1
Comment: Unimax asserted that the mercury contamination in the release sample in Drainage Ditch #4 did not
come from MNOP or from contamination caused by MNOP. Unimax commented that the mercury contamination
in the western portion of the MNOP property did not cause the mercury contamination in the release in Drainage
Ditch #4 and that the contamination in the northern area of the MNOP property did not originate from MNOP.
Unimax also commented that other data sets indicate that mercury contamination may be present on the western
portion of the MNOP property but Unimax concluded that the western portion of the property does not affect
Drainage Ditch #4.
Response: Mercury contamination in the release sample has been documented to have originated from the MNOP
site, not from sources west and north of Source 1. Mercury in the contaminated soils on the northern portion of
the Site came from the MNOP facility (Source 1), not other off-site sources; this area of mercury contaminated
soil, which drains to Drainage Ditch #4, is the only identified mercury source documented to enter Drainage Ditch
#4. As discussed in section 3.9, Source 1, of this support document, multiple soil samples collected throughout the
MNOP property show that the mercury contamination in Source 1 is not originating from off-site sources,
including those areas north or west of the Site.
Regarding the possible northern sources, as shown in Figure 1 of this support document, multiple soil samples
were taken throughout the MNOP property in the June 2011 Supplemental Sampling Event. These samples
include locations to the north (MNOP-02-SF) and west (MNOP-05-SF) of Source 1. These sample locations are
south of the northern source area pointed to by the Unimax and are thus located between the northern area and
both Source 1 and Drainage Ditch #4. These samples contain mercury at levels that are not detectible or below the
concentration in the background sample (MNOP-Ol-SF) and show that contamination in Source 1 is not
originating from off-site sources to the north or west of Source 1. If mercury contamination were reaching Source
1 from these areas, the mercury in samples from between the areas should be detectible and at similar levels as
found in Source 1.
Regarding contamination in the western portion of the Site; while some mercury contamination may be present on
the western portions of the MNOP property, the western portion of the MNOP property drains into Drainage
Ditch #1 and does not impact the eastern portion of the MNOP property or Drainage Ditch #4. The HRS
documentation record at proposal lists the western portion of the property as a possible source of contamination,
but states that it does not drain to Drainage Ditch #4. Unimax agreed in their comments that the western portions
of the property do not affect the contamination found in Drainage Ditch #4.
This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.
3.11.2 Contaminant Concentration Gradient in Drainage Ditch #4
Comment: Unimax challenged the attribution of mercury contamination to the MNOP by claiming the sampling
in the intermittent ditch (Drainage Ditch #4) between the Site source and the observed release sample did not
indicate the mercury migrated to the release sample via that route. Unimax and Cozen commented that the
contaminant concentration gradient in Drainage Ditch #4 is not supportive of MNOP being the upgradient source
of mercury contamination and provided the following comments:
• Unimax commented that "[t]he hypothesized transport pathway [used in the HRS evaluation] through
Drainage Ditch #4 is not supported by the data."
• Unimax commented that the lowest mercury concentrations in sediment occur near the MNOP facility
and in the upstream reaches of Rocky Creek.
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• Unimax stated that the mercury concentrations in the ditches on the MNOP property tend to decrease as
they travel downgradient on the property.
• Cozen commented that the EPA background sediment sample is an order of magnitude higher than the
sediment samples taken from Drainage Ditch #4 on MNOP property.
Unimax stated that the "EPA's failure to consider the concentration gradient, which reveals very low or non
detectable levels of mercury in Ditch #4 at the southern site boundary and north of the RCWRF and the highest
levels of mercury immediately downgradient of the RCWRF, is arbitrary and capricious." Unimax commented
that by plotting the mercury concentration gradient in Drainage Ditch #4 it becomes clear that the MNOP is not a
"likely or material" contributor to the higher mercury concentrations at and downgradient of the RCWRF.
Further, the low mercury concentrations found in sediment samples in Drainage Ditch #4 on the MNOP property
provide "evidence of no source of mercury upgradient of their locations."
Response: The contaminant concentration gradient in Drainage Ditch #4 is supportive of an upgradient source of
mercury contamination and the significant increase in mercury contamination found in the release sample
(MNOP-D4-W-09-SD) is attributed to the Site. While the mercury concentration gradient is not at a constant
concentration or a slowly decreasing concentration with distance from Source 1, this is most likely due to the
streambed morphology.
As cited in section 3.11, Observed Release - Attribution, of this support document, the HRS requires that for an
observed release by chemical analysis to be identified, at least part of the significant increase in a hazardous
substance in a release sample be attributable to a release from the site. The HRS documentation record at proposal
on pages 25 and 26 establishes that at least some portion of the mercury contamination found in the release
sample (MNOP-D4-W-09-SD) is due to the Site as addressed in section 3.11, Observed Release - Attribution, of
this support document.
The contaminant concentration gradient observed in Drainage Ditch #4 (presented in Figure 1 of this support
document) is supportive of an upgradient source of mercury on the MNOP property. The physical characteristics
of the drainage ditch support the mercury contamination concentration gradient seen in the data presented in the
HRS documentation record at proposal. These physical characteristics include the intermittent nature and the
streambed gradient of Drainage Ditch #4. These two characteristics explain how the data collected in the Ditch
support contamination originating from the MNOP site source.
Drainage Ditch #4 is an intermittent stream as shown in Reference 3 of the HRS documentation record at
proposal. In addition to having intermittent flow, the streambed gradient4 of Drainage Ditch #4 from the MNOP
property to PPE-15 in the palustrine forested wetland is approximately 75 ft/mile (gradient of 1.5%). The
streambed gradient after PPE-1 (once the Ditch reaches the palustrine forested wetlands) is less than 10 ft/mile
(streambed gradient of 0.2%) (see Reference 3 of the HRS documentation record at proposal).6 The streambed
gradient suggests that water flowing in the ditch exhibits two different flow regimes. The first flow regime occurs
in the water in the portion upgradient of PPE-1. The upper portion of Drainage Ditch #4 flows at a high velocity
4 Streambed gradient is calculated by dividing the change in elevation by the lateral distance covered. The gradient is then
multiplied by 100 to attain a percent gradient.
5 PPE-1 is located along Drainage Ditch #4 at the point where the ditch enters HRS-eligible wetlands (at this site, Palustrine
forested wetlands) and does not correspond to a sample location.
6 This gradient value was calculated using the topographical map for the area presented in the HRS Documentation Record at
proposal (Reference 3 of the HRS documentation record at proposal). The upstream portion of Drainage Ditch #4 drops 30
feet in elevation from the southern boundary of the MNOP property to PPE-1 (which is approximately 2000 ft. downgradient
of the property). The downgradient portion, below PPE-1, does not show an elevation change on the topographical map
within one mile of PPE-1, therefore an estimation of 10 feet was used as the elevation change could not be greater than 10
feet if it does not cross a topographical contour line.
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(high streambed gradient) and carries water, and any contamination, away from the MNOP facility with little to
no deposition within Drainage Ditch #4. The second flow regime occurs as the water enters the palustrine forested
wetlands at PPE-1. The lower portion of Drainage Ditch #4, after the ditch enters the wetland, flows at a low
velocity (lower streambed gradient) and is supportive of sediment (and contaminant) deposition.
The flow regime in the upper portions of Drainage Ditch #4 (upgradient of PPE-1) retard the settling of particles
(including those containing or associated with contamination) in the ditch following precipitation events. The
sediments and contamination in the water will travel at a higher velocity upgradient of PPE-1 and will have less
time to settle (if at all) in this portion of the streambed of Drainage Ditch #4 where the upgradient sediment
samples were taken. After the flow enters the palustrine forested wetlands (at PPE-1), the flow regime changes.
The streambed gradient lowers to 0.2% and the velocity of the water slows to allow for increased amounts of
suspended sediments to settle out in the streambed of Drainage Ditch #4. This area is where samples MNOP-D4-
W-08-SD and MNOP-D4-W-09-SD were taken.
Therefore, it is expected that upgradient streambed sediment samples in the area of the first, higher velocity flow
regime would have lower contamination than sediment samples downgradient of PPE-1 as the contamination
from Source 1 would have more time to settle into the sediment in the drainage ditch in the area of the second
flow regime, which slows in the palustrine forested wetlands. Thus, the concentration gradient of mercury
contamination observed in Drainage Ditch #4 is supportive of an upgradient source of mercury consistent with the
MNOP facility. The possibility of the mercury originating from other possible facility sources is discussed further
in Section 3.11.1, Possible Mercury Releases from Alternative Sites, of this support document.
This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.
3.11.3 Contaminant Concentration Downgradient of the RCWRF
Comment: Unimax argued that because the concentration of mercury is higher downstream of the RCWRF
facility, the source of the mercury was not Source 1 at the Site. Unimax commented that the highest mercury
concentrations occur downgradient of the RCWRF discharge, suggesting that the source of the mercury in the
release samples is the discharge from the RCWRF. Unimax stated that the "EPA's failure to consider the
concentration gradient, which reveals very low or nondetectable levels of mercury in Ditch #4 at the southern site
boundary and north of the RCWRF and the highest levels of mercury immediately downgradient of the RCWRF,
is arbitrary and capricious." Unimax further commented that the attribution of an observed release to the former
MNOP is not supported by the data; instead, the data indicate the RCWRF and its industrial user, GP, as the
responsible parties for the mercury contamination found in the observed release sample. Unimax asserted that the
RCWRF has historically received mercury-containing wastewater from the GP facility and other industrial
facilities.
Response: The significant increase in mercury concentration in Drainage Ditch #4 downgradient of the RCWRF
location (i.e., the increased concentration gradient) was correctly attributed to the MNOP site and not to
discharges from the RCWRF. While the concentration of mercury in Drainage Ditch #4 is higher in a sample
downgradient of the RCWRF facility location, as explained in section 3.11.1, Possible Mercury Releases from
Alternative Sites, of this support document, the location of the sample used to establish an observed release is
upgradient of the location of the historical discharge outfall from the RCWRF. Furthermore, the RCWRF
discharge does not contain mercury. Therefore discharge from the RCWRF is not likely the cause of the
significant increase in mercury contamination in the observed release sample (see Section 3.11.1.1, Wastewater
Discharges from GP and SWPC via the RCWRF, of this support document).
Based on information collected in responding to this comment (see Attachment 1 and Figure 3 of this support
document), the discharge from this wastewater treatment facility contained no mercury and the historical outfall
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from the RCWRF was discharged directly into the wetland south of the treatment facility and not to Drainage
Ditch #4; Unimax did not identify any information documenting releases of mercury from the RCWRF.
As described in 3.11.2, Contaminant Concentration Gradient in Drainage Ditch #4, of this support document, the
possible causes of the contaminant concentration gradient in Drainage Ditch #4 were evaluated and it was
determined that the gradient is consistent with an upgradient source such as Source 1 on the MNOP property.
Potential mercury discharges from the RCWRF were considered when establishing attribution of the mercury
release to the Site. No evidence was identified (nor did the commenters present any evidence) to suggest that the
RCWRF ever discharged mercury into Drainage Ditch #4 (see section 3.11.1.1, Wastewater Discharges from GP
and the Southern Wood Piedmont Company via the RCWRF, of this support document).
Pages 25 and 26 of the HRS documentation record at proposal discuss the attribution of mercury contamination
found at the Site and considered the RCWRF as a potential contributor to the contamination in Drainage Ditch #4
as follows:
Possible off-site sources also include the FMNOL, AWI, and the Rocky Creek water reclamation
facility (RC WRF). AWI and FMNOL are currently listed on the EPA NPL under CERCLIS ID
No. GAN000410033 at docket number EPA-HQ-SFUND-2010-0640-0002 (Ref. 47). Runoff
from FMNOL and AWI flows into Rocky Creek via a drainage easement. The drainage easement
enters Rocky Creek west and upstream of Source No. 1 soil sample MNOP-04-SF and Drainage
Ditch 4. Drainage Ditch 4 is located just west of the RC WRF (Ref. 7, Appendix A, p. A-2).
The RC WRF, located southeast of and downstream from MNOP, provides wastewater treatment
for the southern and western portions of the City of Macon. Treated wastewater from this facility
is discharged into the Ocmulgee River; however, RC WRF maintains a National Pollutant
Discharge Elimination System (NPDES)-permitted discharge point at the southern property
boundary (Refs. 9, p. 3; 45, pp. 2, 3; 46, pp. 1,8). The NPDES permit requires RC WRF to
monitor outfall discharges for biochemical oxygen demand, total suspended solids, pH, chlorine,
fecal coliform, nitrogen, dissolved oxygen, PCBs, and phosphorus (Ref. 46, pp. 6, 7). There are
currently no documented releases of mercury at this location (Refs. 9, p. 3; 46, pp. 6, 7).
The RCWRF was built as a joint treatment facility with the Macon Kraft Company, now called GP, and provides
wastewater treatment for the GP facility. Mercury may be a possible constituent in the waste water from GP that
is discharged to the RCWRF for treatment. While the RCWRF may have received mercury-containing waste
water from GP, the RCWRF was designed to treat effluent delivered to the facility. The RCWRF plant is an
advanced secondary wastewater treatment facility that includes activated sludge aeration basins, clarifiers,
conventional filtration, as well as disinfectants before its effluent is discharged into the Ocmulgee River
(http://maconwater.org/water-reclamation-facilities'). As shown in Attachment 2 to this support document,
mercury is one of the metals known to be captured by the extended aeration activated sludge process and is found
in the biosolids7 that are removed from the wastewater. These processes combined effectively treat the mercury in
the effluent, and there has been no documented mercury in the discharge from the RCWRF.
The RCWRF historically discharged to the wetlands east of Drainage Ditch #4 from the time it began operation in
1971 to the mid 1980's when the discharge was re-routed to the Ocmulgee River. The RCWRF currently
discharges to the Ocmulgee River which is approximately 2 miles east of the facility (see Reference 3 of the HRS
7 Biosolids is a term used to describe municipal treatment plant solids that result from the treatment of wastewater. Biosolids
are processed wastewater solids that have met specific criteria and are suitable for land application. Specifically, the RCWRF
biosolids have been tested for mercury, and the results are presented in Attachment 2 of this support document.
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documentation record at proposal). Although the RCWRF has discharged effluent to the wetlands east of
Drainage Ditch #4, no evidence or data supports a release of mercury from the RCWRF facility. Attachment 1 of
this support document presents annual monitoring data (which dates back to 1996) for the effluent of the RCWRF
and shows no mercury in the facility effluent. While the discharge point for the RCWRF has been repositioned,
no information was found or was presented by the commenter, to indicate that the conditions at the RCWRF
significantly changed. The treatment system at the RCWRF is essentially the same as before 1996 and there is no
evidence to suggest that discharge prior to 1996 might contain mercury. Therefore, no evidence suggests that the
RCWRF effluent is a contributor to the mercury contamination found in the release sample in Drainage Ditch #4
For additional information, see section 3.11.1, Wastewater Discharges from GP and the Southern Wood Piedmont
Company via the RCWRF, which addresses the possible contaminant contributions of GP and SWPC via the
RCWRF.
This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.
3.11.4 Other Data Sets
Comment: Unimax commented that a large volume of "spatially extensive, high-quality, relevant data" has been
ignored and stated that "[t]he HRS documentation record shows an arbitrary selectivity in use of the data."
Unimax asserted that the failure to present or analyze these data is a fundamental mistake because they help to
explain the Site conditions. Unimax stated that "[E]PA guidance recommends using existing analytical data when
they are of sufficient quality."
Unimax commented that the HRS documentation record only obtained a small set of data focused around
Building 109 and Drainage Ditch #4 and only used these data samples to show mercury contamination at the
facility even though previous investigations found "no significantly elevated mercury concentrations." Unimax
stated that the "EPA's failure to attempt to explain this contradictory data is arbitrary and capricious."
Unimax commented that both Rust and TetraTech obtained usable mercury measurements of more than 100
surface soil and sediment samples and found that low levels of mercury are pervasive in surface soils throughout
the area and are not unique to the MNOP facility. Unimax further stated that "[t]hese data present a convincing
picture of the absence of any material source of mercury to Drainage Ditch #4." Unimax asserted that these
additional data sets contradict the establishment of a source of mercury on the MNOP facility.
Unimax concluded that these other data sets show that mercury contamination on the MNOP facility cannot be
contributing to the contamination in the observed release sample downgradient in Drainage Ditch #4.
Response: The June 2011 Supplemental Sampling Event provided sufficient analytical data to document and
attribute the significant increase in mercury contamination in the observed release to migration from Source 1 on
the MNOP property, and best represents the current Site conditions. While the other data sets were not used for
scoring purposes in the HRS evaluation, these other data sets were made available as references in the HRS
documentation record at proposal and show mercury contamination that is consistent with the sampling results in
the June 2011 Supplemental Sampling Event.
The HRS documentation record at proposal did not fail to present or analyze additional available data; rather, the
HRS documentation record at proposal included the additional data referred to by Unimax (see References 7, 12,
13, 14, 21, 34 and 35 of the HRS documentation record at proposal) which support the findings in the June 2011
Supplemental Sampling Event data. The HRS documentation record at proposal lists and provides references that
contain the results of six other investigations that were performed at the Site prior to the June 2011 Supplemental
Sampling Event. Table 1 on pages 13 and 14 of the HRS documentation record at proposal summarizes these
previous investigations:
34
-------
Macon Naval Ordnance Plant NPL Listing Support Document
May 2013
TABLE 1: Summary of Previous Investigations
Company/
Agency
Investigation
Date
Samples
Collected
Hazardous
Substances
Detected
References
Beaver
Environmental
1989
Soil
Metals
13, p. 3
Engineering
Assessment
Environmental
Confirmation
1990
Soil, ground
Arsenic
14, pp. I, 2-1,3-
Science and
Study of the
water, and
Cadmium
4, 3-6, 3-9, 3-
Engineering
Former Macon
Naval Ordnance
Plant
sediment
Chromium
Lead
TCE
11,4-2, 4-3,4-
11,4-12
USACE,
Site
1996
Soil, ground
Cadmium
13, pp. vi, 1, 13,
Savannah
Investigation
water, surface
Chromium
20, 27, 28, 55
District
water, and
sediment
Lead
Mercury
through 60, 63,
71 through 92,
94 through 104,
106,107
USACE,
Hazardous Site
1998 to 2000
Soil, ground
Arsenic
12, pp. i, ii,l-l,
Savannah
Response Act
water, surface
Cadmium
1-10, 2-9, 2-19,
District
(HSRA)
water, and
Chromium
2-33, Appendix
Compliance
Status Report
sediment
Lead
Zinc
TCE
PCE
Benzo(a)pyrene
O, pp. 015
through 053
USACE,
Post-Test
2004
Ground water
DCE
21, pp. 1,2,5,
Savannah
Groundwater
TCE
11
District
Sampling
PCE
Vinyl Chloride
EPA
Expanded Site
Inspection
May 2009
Soil, ground
water, surface
water, and
sediment
Cadmium
Chromium
Copper
Lead
Manganese
Mercury
Nickel
PCBs
Pesticides
SVOCs
VOCs
7, pp. 1, 6, 7,
Appendix B, pp.
B-12 through B-
69, B-71
through B-75,
B-77 through B-
113
EPA
Supplemental
Sampling Event
June 2011
Soil and
sediment
Mercury
9, pp. 1,3; 11,
pp.5, 8, 19,21
The HRS documentation record did not fail to present or analyze additional data sets available for the Site.
Rather, in June 2011 a supplemental sampling event was completed and included samples located on the MNOP
property and in Drainage Ditch #4. The HRS documentation record at proposal scored the Site on this June 2011
Supplemental Sampling Event because it is the most current data that is available for the Site. As presented in the
HRS documentation record at proposal, the June 2011 Supplemental Sampling Event included multiple surface
soil samples and sediment samples located in Drainage Ditch #4 (see Figure 1). These samples, as presented in
35
-------
Macon Naval Ordnance Plant NPL Listing Support Document
May 2013
the HRS documentation record at proposal, provide sufficient data to score the Site as discussed in this support
document in sections 3.9, Source 1; 3.10, Observed Release - Background; and 3.11, Observed Release -
Attribution.
The additional data sets noted by the commenter do not contradict the establishment of Source 1 or the observed
release of mercury in Drainage Ditch #4. These additional data sets do support Unimax's assertion that mercury
contamination is not ubiquitous throughout the property, however, it is not true that there are no "elevated
mercury concentrations" identified in these data sets. For example, in the 2009 Expanded Site Assessment alone,
mercury is not detected in the background sample located on the north east portion of the MNOP property and at
least two soil samples located near Building 109 are detected at concentrations above the sample quantitation
limit as required by the HRS and explained in section 3.9, Source 1, of this support document.
The contamination found in the June 2011 Supplemental Sampling Event is supported by the additional data sets
that the commenters mention and are provided as references to the HRS documentation record at proposal as
shown in Table 1 above. However, the June 2011 data set is sufficient to document attribution, at least in part, to
Source 1 on the MNOP property.
This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.
3.12 Characterization of PPE 1
Comment: Unimax commented that PPE 1 is located within a settling basin of the RCWRF in which the National
Wetlands Inventory (NWI) characterizes the location as Emergent Wetland "PEMlFx". Unimax asserts that this
is a man-made, or excavated basin or channel and according to topographic quadrangle maps this area is depicted
as part of the RCWRF.
Response: The HRS documentation record at proposal correctly identifies the probable point of entry to Drainage
Ditch #4 from Source 1 (see Figure 2). PPE-1 was identified at the point at which Drainage Ditch #4 intersects an
eligible surface water body; specifically, the eligible surface water body at this site is the HRS eligible wetland:
Freshwater Palustrine Forested/Shrub Wetland (see Figure 1 of this support document). The HRS documentation
record at proposal does not identify PPE-1 as being located within a settling basin of the RCWRF labeled an
emergent wetland "PEMlFx."
HRS Section 4.0.2, Surface water categories, defines what is considered a surface water body for HRS
purposes as follows:
For HRS purposes, classify surface water into four categories: rivers, lakes, oceans, and coastal
tidal waters.
-Rivers include:
• Perennially flowing waters from point of origin to the ocean or to coastal tidal
waters, whichever comes first, and wetlands contiguous to these flowing waters.
HRS Section 4.1, Overland/flood migration component, establishes how to identify a probable point of entry for a
source. It states to "[u]se the overland/flood migration component to evaluate surface water threats that result
from overland migration of hazardous substances from a source at the site to surface water."
Page 21 of the HRS documentation record at proposal explains the establishment of PPE 1, stating:
36
-------
Macon Naval Ordnance Plant NPL Listing Support Document
May 2013
The hazardous substance migration pathway includes both the overland segment and the in-water
segment that hazardous substances would take as they migrate away from sources. The overland
segment begins at the source and proceeds downgradient to the probable point of entry (PPE) to
surface water. The in-water segment at the PPE continues in the direction of flow (Ref. 1, Section
4.1.1.1).
Overland flow from Source No. 1 (contaminated soil in the eastern portion of the MNOP
property) is directed to Drainage Ditch 4. Drainage Ditch 4 is an intermittent drainage route
located upgradient of the PPE along the eastern boundary of the MNOP property (Ref. 9, pp. 1,
3). Surface water runoff from Source No. 1 flows overland about 625 feet and enters Drainage
Ditch 4. Drainage Ditch 4 flows south for about 3,250 feet and enters HRS-eligible palustrine
forested wetlands adjacent to Rocky Creek. The point where Drainage Ditch 4 enters the
palustrine forested wetlands is PPE 1. Drainage Ditch 4 continues south within palustrine forested
wetlands for about 1,250 feet and enters Rocky Creek (Refs. 3; 36, Map 1) (also see Figure 3 of
this HRS documentation record).
The HRS documentation record at proposal establishes PPE-1 as the point at which hazardous substances
migrating overland via runoff enter an eligible surface water body. The HRS documentation record at proposal
does not identify PPE-1 as being located within a historical settling basin of the RCWRF, rather, as shown in
Figure 2 of this support document, PPE-1 is identified at sample location MNOP-D4-W-08-SD, which is the entry
point of surface runoff in Drainage Ditch #4 to Palustrine Forested, Broad-Leaved Deciduous, Seasonally Flooded
wetland. As identified by HRS Section 4.0.2, Surface water categories, HRS-eligible wetlands contiguous to
flowing waters are considered surface water; therefore, PPE-1 is correctly established at this intersection in
Drainage Ditch #4 where overland flow enters palustrine forested wetlands.
This comment results in no change to the HRS score and no change in the decision to place the Site on the NPL.
4. Conclusion
The original HRS score for this site was 48.97. Based on the above responses to comments, the Site score remains
unchanged. The final scores for the MNOP site are:
Ground Water Not Scored
Surface Water 97.94
Soil Exposure Not Scored
Air Not Scored
HRS Site Score 48.97
37
-------
Attachment 1:
Macon Water Authority, Rocky Creek Effluent Sample
Results, Various Dates
-------
Client Sample Results
Client: Macon Water Authority
Project/Site; Rocky Creek Effluent Annual PP Scan
Nlent Sample ID: AA32930 Rocky Creek Effluent Pre-CI2
^ate Collected: 12/13/11 00:00
Date Received; 12/14/11 09:43
TestAmerica Job (D: 680-75245-2
Lab Sample ID: 680-75245-3
Matrix: Water
Method: 200,8 - Metals (ICR/MS)
Atialyte
Antimony
Arsenic
Beryllium
Cadmium
Chromium
Copper
lead
Nickel
Selenium
Sliver
Thallium
Zinc
Method: 245,1 - Mercury (CVAA)
Analyte
Result Qualifier
<0,0050
<0,0050
<0.0010
<0,00070
<0,0050
<0,0050
' <0,0010'
<0,0050
<0,0050
<0,0050
<0,0010
0.042
Result Qualifier
RL
0,0050
0.0060
0.0010
0.00070
0.0050
0.0050
0.0010
0.0050
0.0050
0,0050
0,0010
0,010
RL
MDL Unit
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
MDL Unit
D - Prepared
12/15/11 11:06
12/15/11 11:06
12/15/11 11:06
12/16/1111:06
12/16/11 11:06
12/15/11 11:06
12/15/11 11:06
12/15/11 11:06
12/15/11 11:06
12/16/11 11:06
12/16/11 11:06
12/15/11 11:06
Prepared
Analyzed
12/15/11 17:37
12/15/11 17:37
12/15/11 17:37
' 12/15/11 17:37'
12/15/11 17:37
12/16/11 17:37
12/15/11 17:37
12/15/11 17:37
12/15/11 17:37
12/15/11 17:37
12/15/11 17:37
12/16/11 17:37
Analyzed
Dlt Fac
Dlt Fae
Mercury
<0.00050
0,00050
mg/L
12/16/1110:18 12/19/1116:01
1
Page 6 of 29
TestAmerica Savannah
12/23/2011
-------
Analytical Data
Client: Macon Water Authority Job Number: 680-65488-1
Client Sample 10: AA27826 - Rocky Creek EFF
Lab Sample ID: 680-65488-1 Dale Sampled: 02/08/2011 0000
Client Matrix: Water Date Received: 02/09/20110930
200.8 Metals (iCP/MS)
Method: 200.8 Analysis Batch: 680-194263 Instrument ID: ICPMSB
Preparation: 200.8 Prep Batch: 680-194066 Lab File ID: 194066,ehr
Dilution: 1.0 Initial Weight/Volume: 50 ml
Date Analyzed: 02/11/2011 1549 Final Weight/Volume: 250 mL
Date Prepared: 02/10/2011 1200
Analyte Result (mg/L) Qualifier RL
Antimony <0.0050 6.0050
Arsenic <0.0050 0.0050
Beryllium <0.0010 0.0010
Cadmium <0.00070 0.00070
Chromium <0.0050 0.0050
Copper <0.0050 0.0050
Lead <0.0010 0.0010
Nickel <0,0050 0.0050
Selenium <0.0050 0.0050
Silver <0,0050 0.0050
Thallium <0,0010 0.0010
Zinc 0.030 0.010
245.1 Mercury (CVAA)
Method: 245.1 Analysis Batch: 680-194712 Instrument ID: LEEMAN1
Preparation: 245.1 Prep Batch: 680-194192 Lab File ID: 021611.chr
Dilution; 1.0 Initial Weight/Volume: 50 mL
Date Analyzed: 02/16/2011 1308 Final Weight/Volume: 50 mL
Date Prepared: 02/11/2011 1051
Analyte Result {mg/L) Qualifier RL
Mercury """" '
-------
Client: Macon Wafer Authority
Analytical Data
Job Number: 680-44771-2
Client Sample ID: AA16048
Lab Sample ID: 680-44771-3 Date Sampled: 02/15/2009 0000
Client Matrix; Water Date Received: 02/17/2009 0902
200.8 Metals (ICF/MS)
Method: 200.8 Analysis Batch: 680-130762 instrument ID: ICR MS-A
Preparation: 200,8 Prep Batch: 680-130575 Lab File ID: N/A
Dilution; 1.0 Initial Weight/Volume: 50 mL
Dale Analyzed: 02/19/2009 2141 Final Weight/Volume: 250 mL
Date Prepared: 02/19/2009 1116
Analyte Result (mg/L) Qualifier RL
Antimony <0.0050 0.0050
Arsenic <0.0050 0.0050
Beryllium <0.0010 0.0010
Cadmium - <0.00070 0.00070
Chromium <0.0050 0.0050
Copper 0.0060 0.0050
Lead <0.0010 0.0010
Nickel <0.0050 0.0050
Selenium <0.0050 0.0050
Silver <0.0050 0.0050
Thallium <0.0010 0.0010
Zinc 0.023 0.010
245.1 Mercury (CVAA)
Method: 245.1 Analysis Batch; 680-130779 tnslmment ID: LEEMAN1
Preparation: 245,1 Prep Batch: 680-130453 Lab File ID; N/A
Dilution: 1.0 Initial Weight/Volume: 50 ml.
Data Analyzed: 02/19/2009 1532 Final Weight/Volume: 50 ml.
Data Prepared; 02/18/2009 1208
Analyte Result (mg/L) Qualifier RL
Mercury <0.00050 0.00050
TestAmerica Savannah
Page 11 of 30
-------
Client: Macon Water Authority
Analytical Data
Job Number; 680-54888-2
Client Sample ID: Rocky Creek Pre-Chlor!nated Effluent (AA21742)
Lab Sample ID:
Client Matrix:
Method:
Preparation;
Dilution:
Date Analyzed:
Date Prepared:
680-54888-3
Water
200,8
200.8
1,0
02/13/2010 0618
02/10/2010 1122
200,8 Metals (ICR/MS)
Analysis Batch: 680-160823
Prep Batch: 680-160403
Date Sampled: 02/07/2010 0000
Date Received: 02/09/2010 1114
Instrument ID: ICPMSB
Lab File ID: N/A
Initial Weight/Volume: 50 rriL
Final Weight/Volume: 250 mL
Analyte
Result (mg/L)
Qualifier
RL
Antimony
''"*'<070050*
oVobso
Arsenic
<0.0050
0.0050
Cadmium
<0.00070
0.00070
Chromium
<0.0050
0.0050
Copper
0,019
0,0050
Lead
0.0012
0,0010
Nickel
<0.0050
0.0050
Selenium
<0.0050
0.0050
Silver
<0.0050
0.0050
Thallium
<0.0010
0.0010
Zinc
0.042
0.010
Method: 200,8 Analysis Batch: 680-160824 Instrument ID: ICPMSB
Preparation: 200.8 Prep Batch: 680-160403 Lab File ID: N/A
Dilution: 1.0 Initial Weight/Volume: 50 ml
Date Analyzed: 02/13/2010 0618 Final Weight/Volume: 250 mL
Date Prepared: 02/10/2010 1122
Analyte Result (mg/L) Qualifier RL
Beryllium"" ""'"TaaoicT - — — jooicT
245.1 Mercury (CVAA)
Method: 245.1 Analysis Batch: 680-160775 Instrument ID: LEEMAH1
Preparation: 245.1 Prep Batch: 680-160393 Lab File ID: N/A
Dilution: 1.0 . Initial Weight/Volume: 50 mL
Date Analyzed: 02/11/2010 1526 Final Weight/Volume: 50 mL
Date Prepared: 02/10/2010 1052
Analyte Result (mg/L) Qualifier RL
Mercury <6,00050 6.00050
TestAmerlca Savannah
Page 13 of 33
04/05/2010
-------
ANALYTICAL iRViCES. INC.
Environmental Monitoring & Laboratory Analysis
110 Technology Parkway Norcross, GA 30092
(770) 734-4200 FAX (770) 734-4201
Laboratory Report
Macon Water Authority
PO Box 108
Macon, GA 31202
Attention: Mr. Mark Wyzalek
Macon Water Authority
Sample Description: Wastewater. Composite, Rocky Creek PPL-GA 129, Rocky Creek Effluent, 01/24/2008, 00:00, received 01/26/2008
Report. Analytical Preparation Dil. Results Preparation Analytical
Analyte Result Limit Units Qual. Method Method Factor CAS # Source ID Batch # Date Time Date Time Init.
February 5, 2008
Report No. 254514-2
129 Priority Pollutants - Georgia
General Chemistry
Total Phosphorus (P)
0.37
0.02
mg/L
SM 45Q0-P B,E
SM 4500-P B.E
1
7723-14-0
254514-2
148966
1/28/08
1130
1/29/08
1400
YM
Inorganic Anions
Nitrate-Nitrite Nitrogen (N)
4.9
0.1 .
mg/L
EPA 300.0
1
E-10128
254514-2
149166
2/1/08
1346
LMH
Metals
Total Antimony (Sb)
ND
5
ug/L
EPA 200.8
EPA 200.8
1
7440-36-0
254514-2
148689
1/28/08
0840
1/28/08
1829
CKE
Total Arsenic (As)
ND
5
ug/L
EPA 200.8
EPA 200.8
1
7440-38-2
254514-2
148689
1/28/08
0840
1/28/08
1829
CKE
Total Beryllium (Be)
ND
1
ug/L
EPA 200.8
EPA 200-8
1
7440-41-7
254514-2
148689
1/28/08
0840
1/28/08
1829
CKE
Total Cadmium (Cd)
ND
0.7
ug/L
EPA 200.8
EPA 200.8
1
7440-43-9
254514-2
148689
1/28/08
0840
1/28/08
1829
CKE
Total Chromium (Cr)
ND
5
ug/L
EPA 200.8
EPA 200.8
1
7440-47-3
254514-2
148689
1/28/08
0840
1/28/08
1829
CKE
Total Copper (Cu)
6
5
ug/L
EPA 200.8
EPA 200.8
1
7440-50-8
254514-2
148689
1/28/08
0840
1/28/08
1829
CKE
Total Lead (Pb)
ND
1
ug/L
EPA 200.8
EPA 200.8
1
7439-92-1
254514-2
148689
1/28/08
0840
1/28/08
1829
CKE
Total Mercury (Hg)
ND
0.5
ug/L
EPA 245.1
EPA 245.1
1
7439-97-6
254514-2
148917
1/29/08
0940
1/29/08
1650
CSW
Total Nickel (Ni)
ND
5
ug/L
EPA 200.8
EPA 200.8
1
7440-02-0
254514-2
148689
1/28/08
0840
1/28/08
1829
CKE
Total Selenium (Se)
ND
5
ug/L
EPA 200.8
EPA 200.8
1
7782-49-2
254514-2
148689
1/28/08
0840
1/28/08
1829
CKE
Total Silver (Ag)
ND
5
ug/L
EPA 200.8
EPA 200.8
1
7440-22-4
254514-2
148689
1/28/08
0840
1/28/08
1829
CKE
Total Thallium (TI)
ND
1
ug/L
EPA 200.8
EPA 200.8 '
1
7440-28-0
254514-2
148689
1/28/08
0840
1/28/08
1829
CKE
Total Zinc (Zn)
19
10
ug/L
EPA 200.8
EPA 200.8
1
7440-66-6
254514-2
148689
1/28/08
0840
1/28/08
1829
CKE
Paae 1 of 1
-------
ANALYTICAL ERV1CES. INC.
Environmental Monitoring & Laboratory Analysis
110 Technology Parkway Norcross, GA 30092
(770) 734-4200 FAX (770) 734-4201
Laboratory Report
Macon Water Authority
PO Box 103
Macon, GA 31202
Attention: Mr, Mark Wyzalek
Macon Water Authority
Sample Description: Wastewater, Composite, Rocky Creek PPL, RC Effluent, 06/28-06/29/2006, 00:00 - 00:00, received 06/30/2006
Artalyte
Result
Report,
Limit
Units
Analytical
Qua I. Method
Preparation
Method
Oil.
Factor
CAS#
Results
Source ID
Batch #
Preparation
Date Time
Analytical
Date Time
Init
123 Priority Pollutants - Georgia
General Chemistry
Total Cyanide (CN)
ND
20
ug/L
EPA 335.2
EPA 335.2
1
57-12-5
230497-1
130401
7/3/06
1830
7/5/06
1845
OMB
Total Phosphorus (P)
0.56
0.02
mg/L
SM 4500-P B,E
SM 4500-P 8,E
1
7723-14-0
230497-1
130429
7/5/06
1800
7/6/06
2330
OMB
Inorganic Anions
Nitrate-Nitrite Nitrogen (N)
2.7
0.1
mg/L
EPA 300.0
1
E-10128
230497-1
130469
7/4/06
0800
HE
Metals
Total Antimony (Sb)
ND
5
ug/L
EPA 200.8
EPA 200.8
1
7440-36-0
230497-1
130298
7/3/06
0625
7/5/06
1902
MCJ
Total Arsenic (As)
ND
5
ug/L
EPA 200.8
EPA 200.8
1
7440-38-2
230497-1
130298
7/3/06
0625
7/5/06
1902
MCJ
Total Beryllium (Be)
ND
1
ug/L
EPA 200.8
EPA 200.8
1
7440-41-7
230497-1
130298
7/3/06
0625
7/5/06
1902
MCJ
Total Cadmium (Cd)
ND
0.7
ug/L
EPA 200.8
EPA 200.8
1
7440-43-9
230497-1
130298
7/3/06
0625
7/5/06
1902
MCJ
Total Chromium (Cr)
ND
5
ug/L
EPA 200.8
EPA 200.8
1
7440-47-3
230497-1
130298
7/3/06
0625
7/5/06
1902
MCJ
Total Copper (Cu)
6
5
ug/L
EPA 200.8
EPA 200,8
1
7440-50-8
230497-1
130298
7/3/06
0625
7/5/06
1902
MCJ
Total Lead (Pb)
ND
1
ug/L
EPA 200.8
EPA 200.8
1
7439-92-1
230497-1
130298
7/3/06
0625
7/5/06
1902
MCJ
Total Mercury (Hg)
ND
0.5
ug/L
EPA 245.1
EPA 245.1
1
7439-97-6
230497-1
129730
7/3/06
0535
7/3/06
1534
MCJ
Total Nickel (Ni)
ND
5
ug/L
EPA 200.8
EPA 200.8
1
7440-02-0
230497-1
130298
7/3/06
0625
7/5/06
1902
MCJ
Total Selenium (Se)
ND
5
ug/L
EPA 200,8
EPA 200.8
1
7782-49-2
230497-1
130298
7/3/06
0625
7/5/06
1902
MCJ
Total Silver (Ag)
ND
5
ug/L
EPA 200.8
EPA 200.8
1
7440-22-4
230497-1
130298
7/3/08
0625
7/5/06
1902
MCJ
Total Thallium (Tl)
ND
1
ug/L
EPA 200,8
EPA 200.8
1
7440-28-0
230497-1
130298
7/3/06
0625
7/5/06
1902
MCJ
Total Zinc (Zn)
33
10
ug/L
EPA 200.8
EPA 200.8
1
7440-66-6
230497-1
130298
7/3/06
0625
7/5/06
1902
MCJ
I ¦
Ml
July 18, 2006
Report No, 230497-1
-------
ANALYTICAL SERVICES, INC.
Environmental Monitoring & Laboratory Analysis
110 Technology Parkway Norcross, GA 30092
(770)734-4200 FAX (770) 734-4201 •
Macon Water Authority
PO Box 108
Macon, GA 31202
Laboratory Report
Attention: Mr. Mark Wyzalek
Report No. 224948-1
March 8, 2006
Sample Description
Macon Water Authority
Analytical
Method
Analyte
Result
Detection Limit
Units
129 Priority Pollutants
- Georgia
¦
General Chemistry
EPA 335.2
Total Cyanide (CN)
BDL
20
ug/L
SM 4500-P B,E
Total Phosphorus (P)
1.3
• 0.2
mg/L
Inorganic Anions
EPA 300.0
Nitrate-Nitrite Nitrogen (N)
4.1
0.1
mg/L
Metals
EPA 200.8
Total Antimony (Sb)
BDL
5
ug/L
EPA 200.8
Total Arsenic (As)
BDL
5
ug/L
EPA 200.8
Total Beryllium (Be)
BDL
1
ug/L
EPA 200.8
Total Cadmium (Cd)
BDL
0.7
ug/L
EPA 200.8
Total Chromium (Cr)
BDL
; 5
ug/L
EPA 200.8
Total Copper (Cu)
6
5
ug/L
EPA 200.8
Total Lead (Pb)
BDL
1
ug/L
EPA 245.1
Total Mercury (Hg)
BDL
0.5
ug/L
EPA 200.8
Total Nickel (Ni)
BDL
5
ug/L
EPA 200.8
Total Selenium (Se)
BDL
i 5
ug/L
EPA 200.8
Total Silver (Ag)
BDL
5
ug/L
EPA 200.8
Total Thallium (Tl)
BDL
1
ug/L
EPA 200.8
Total Zinc (Zn)
33
10
ug/L
BDL - Below Detection Limit
Page 1 of 1
-------
ANALYTICAL SERVICES, INC.
Environmental Monitoring & Laboratory Analysis
110 Technology Parkway Norcross, GA 30092
(770) 734-4200 FAX (770) 734-4201
Laboratory Report
Macon Water Authority
PO Box 108
Macon, GA 31202
Attention: Mr. Mark Wyzalek
Report No. 219930-1 November 14, 2005
Sample Description
Macon Water Authority
Wastewater, Composite, Rocky Creek PPL, RC Effluent, 11/01-11/02/2005, 06:00 - 06:00, received 11/03/2005
Analytical
Method
Analyte
Result
Detection Limit
Units
Priority Pollutant Metals
Metals
EPA 200.7
Total Antimony (Sb)
BDL
0.005
mg/L
EPA 200.8
Total Arsenic (As)
BDL
0.005
mg/L
EPA 200.7
Total Beryllium (Be)
BDL
0.001
mg/L
EPA 200.8
Total Cadmium (Cd)
BDL
0.0007
mg/L
EPA 200,7
Total Chromium (Cr)
BDL
0.005
mg/L
EPA 200.7
Total Copper (Cu)
0.006
0.005
mg/L
EPA 200.8
Total Lead (Pb)
0.001
0.001
mg/L
EPA 245.1
Total Mercury (Hg)
BDL
0.0005
mg/L
EPA 200.7
Total Nickel (Nl)
BDL
0.005
mg/L
EPA 200.8
Total Selenium (Se)
BDL
0.005
mg/L
EPA 200.7
Total Silver (Ag)
BDL
0.005
mg/L
EPA 200.8
Total Thallium (Tl)
BDL
0.001
mg/L
EPA 200.7
Total Zinc (Zn)
0,04
0.01
mg/L
Below Detection Limit
Page 1 of 1
-------
A:
ANALYTICAL SERVICES, INC
Macon Water Authority
PO Box 108
Macon, GA 31202
Environmental Monitoring & Laboratory Analysis
110 Technology Parkway Norcross, GA 30092
(770) 734-4200 FAX (770) 734-4201
Laboratory Report
Attention: Mr. Mark Wyzalek
Report No. 206502-3 January 27, 2005
Sample Description
Macon Water Authority
Wastewater, Composite, PPL GA 129, Rocky Creek Effluent, 01/11-01/12/2005,11:50, received 01/13/2005
Analytical
Method
Analyte
Result
Detection Limit
Units
129 Priority Pollutants - Georgia
Metals
EPA 200.7
Total Antimony (Sb)
BDL
5
ug/L
EPA 206.2
Total Arsenic (As)
BDL
5
ug/L
EPA 200.7
Total Beryllium (Be)
BDL
1
ug/L
EPA 213.2
Total Cadmium (Cd)
BDL
0.7
ug/L
EPA 200.7
Total Chromium (Cr)
BDL
5
ug/L
EPA 200.7
Total Copper (Cu)
BDL
5
ug/L
EPA 239.2
Total Lead (Pb)
BDL
1
ug/L
EPA 245.1
Total Mercury (Hg)
BDL
0.5
ug/L
EPA 200.7
Total Nickel (Ni)
BDL
5
ug/L
EPA 270.2
Total Selenium (Se)
BDL
5
ug/L
EPA 200.7
Total Silver (Ag)
BDL
5
ug/L
EPA 279.2
Total Thallium (Tl)
BDL
1
ug/L
EPA 200.7
Total Zinc (Zn)
29
10
ug/L
BDL - Below Detection Limit
Page 1 of 1
-------
ANALYTICAL SERVICES, INC
Environmental Monitoring & Laboratory Analysis
110 Technology Parkway Norcross, GA 30092
(770) 734-4200 FAX (770) 734-4201
Laboratory Report
Macon Water Authority
PO Box 108
Macon, GA 31202
Attention: Mr. Mark Wyzalek
Report No, 188691 -1 February 3, 2004
Sample Description
Macon Water Authority
Wastewater, Composite, PPL GA 129, Rocky Creek Effluent, 01/20-01/21/2004,13:02, received 01/22/2004
Analytical
Method Analyte Result Detection Limit Units
Priority Pollutant Metals
Metals
EPA 200.7
Total Antimony (Sb)
BDL
0.005
mg/L
EPA 206.2
Total Arsenic (As)
BDL
0.005
mg/L
EPA 200.7
Total Beryllium (Be)
BDL
0.001
mg/L
EPA 213.2
Total Cadmium (Cd)
BDL
0.0007
mg/L
EPA 200.7
Total Chromium (Cr)
BDL
0.005
mg/L
EPA 200.7
Total Copper (Cu)
0.005
0.005
mg/L
EPA 239.2
Total Lead (Pb)
BDL
0.001
mg/L
EPA 245.1
Total Mercury (Hg)
BDL
0.0005
mg/L
EPA 200.7
Total Nickel (Ni)
BDL
0,005
mg/L
EPA 270.2
Total Selenium (Se)
BDL
0.005
mg/L
EPA 200.7
Total Silver (Ag)
BDL
0.005
mg/L
EPA 279.2
Total Thallium (Tl)
BDL
0,001
mg/L
EPA 200.7
Total Zinc (Zn)
0.04
0,01
mg/L
BDL - Below Detection Limit
Page 1 of 1
-------
ANALYTICAL SERVICES, INC.
Environmental Monitoring & Laboratory Analysis
110 Technology Parkway Norcross, GA 30092
(770) 734-4200 FAX (770) 734-4201
Laboratory Report
Macon Water Authority
PO Box 108
Macon, GA 31202
Attention: Mr. Mark Wyzafek
Report No, 169451-1 January 30, 2003
Sample Description
Macon Water Authority
Wastewater, Composite, PPL GA 129, Rocky Creek Effluent, 01/13-01/14/2003, 09:44, received 01/15/2003
Analytical
Method Analyte Result Detection Limit Units
AS I
Priority Pollutant Metals
Metals
EPA 204,2
Total Antimony (Sb)
BDL
0.005
mg/L
EPA 206,2
Total Arsenic (As)
BDL
0.005
mg/L
EPA 200.7
Total Beryllium (Be)
BDL
0.001
mg/L
EPA 213.2
Total Cadmium (Cd)
BDL
0.0007
mg/L
¦PA 200,7
Total Chromium (Cr)
BDL
0.005
mg/L
EPA 200.7
Total Copper (Cu)
0.009
0.005
mg/L
EPA 239.2
Total Lead (Pb)
BDL
0.001
mg/L
EPA 245.1
Total Mercury (Hg)
BDL
0.0005
mg/L
EPA 200.7
Total Nickel (Ni)
BDL
0.005
mg/L
EPA 270,2
Total Selenium (Se)
BDL
0.005
mg/L
EPA 200.7
Total Silver (Ag)
BDL
0.005
mg/L
EPA 279.2
Total Thallium (Tl)
BDL
0.001
mg/L
EPA 200.7
Total Zinc (Zn)
0.05
0,01
mg/L
BDL - Below Detection Limit
Page 1 of 1
-------
ANALYTICAL SERVICES, INC
Environmental Monitoring & Laboratory Analysis
110 Technology Parkway Norcross, GA 30092
(770) 734-4200 FAX (770) 734-4201
Macon Water Authority
PO Box 108
Macon, GA 31202
Attention; Mr, Mark Wyzalek
Report No. 150600-1
Laboratory Report
March 12, 2002
Sample Description
Macon Water Authority
Wastewater, Composite, Priority Pollutants GA 129, Rocky Creek Eff., 01/22-01/23/2002,10:49, received 01/24/2002
Analytical
Method
Analyto
Result
Detection Limit
Units
Priority Pollutant Metals
Metals
EPA 204.2
Total Antimony (Sb)
BDL
0.005
mg/L
EPA 206.2
Total Arsenic (As)
BDL
0.005
mg/L
zPA 200.7
Total Beryllium (Be)
BDL
0.001
mg/L
EPA 213.2
Total Cadmium (Cd)
BDL
0.0007
mg/L
EPA 200.7
Total Chromium (Cr)
BDL
0.005
mg/L
EPA 200.7
Total Copper (Cu)
0,013
0.005
mg/L
EPA 239.2
Total Lead (Pb)
BDL
0.001
mg/L
EPA 245.1
Total Mercury (Hg)
BDL
0.0005
mg/L
EPA 200.7
Total Nickel (Ni)
BDL
0.005
mg/L
EPA 270.2
Total Selenium (Se)
BDL
0.005
mg/L
EPA 200.7
Total Silver (Ag)
BDL
0.005
mg/L
EPA 279.2
Total Thallium (Tl)
BDL
0.001
mg/L
EPA 200.7
Total Zinc (Zn)
0.05
0.01
mg/L
BDL - Below Detection Limit
Page 1 of 1
-------
ANALYTICAL SERVICES, INC.
Environmental Monitoring & Laboratory Analysis
110 Technology Parkway Norcross, GA 30092
(770) 734-4200 FAX (770) 734-4201
Laboratory Report
Macon Water Authority
P.O. BOX 108
Macon, GA 31202
Attention: Mr. Mark Wyzalek
Report No. 131164-1 January 15, 20
Sample Description
Macon Water Authority
Wastewater, composite, Rocky Creek Effluent, 12/12-13/2000,12:50pm, received 12/15/2000
Analytical
Method Analyte Result Detection Limit Units
AS I
Priority Pollutant Metals
Metals
EPA 200.7 Total Antimony (Sb) BDL 0.05 mg/L
EPA 200.7 Total Arsenic (As) BDL 0,03 mg/L
EPA 200,7 Total Beryllium (Be) BDL 0,01 mg/L
EPA 200.7 Total Cadmium (Cd) BDL 0.01 mg/L
EPA 200.7 Total Chromium (Cr) BDL 0.01 mg/L
EPA 200.7 Total Copper (Cu) BDL 0.02 mg/L
EPA 200.7 Total Lead (Pb) BDL 0.025 mg/L
EPA 245.1 Total Mercury (Hg) BDL 0.0005 mg/L
EPA 200.7 Total Nickel (Ni) BDL 0.02 mg/L
EPA 200.7 Total Selenium (Se) BDL 0.04 mg/L
EPA 200.7 Total Silver (Ag) BDL 0,01 mg/L
EPA 200.7 Total Thallium (Tl) BDL 0.05 mg/L
EPA 200.7 Total Zinc (Zn) 0.04 0.02 mg/L
BDL - Below Detection Limit
Page 1 of 1
-------
ANALYTICAL SERVICES,. INC.
Environmental Monitoring & Laboratory Analysis
110 Technology Parkway Norcross, GA 30092
(770) 734-4200 FAX (770) 734-4201
Laboratory Report
Macon Water Authority
P.O. Box 108
Macon, GA 31202
Attention: Mr. Mark Wyzalek
Report No. 117078-1 February 1, 2000
Sample Description
Macon Water Authority
Wastewater, composite, EPD 129 PP, RC Effluent, 01/12-13/2000, 13:29-13:36, received 01/14/2000
Analytical
Method Analyte Result Detection Limit Units
AS!
129 Priority Pollutants
- Georgia
General Chemistry
SM 3500-Cr D
Hexavalent Chromium (Cr*°)
BDL
10
ug/L
Metals
EPA 200.7
Total Antimony (Sb)
BDL
50
ug/L
EPA 200.7
Total Arsenic (As)
BDL
30
ug/L
EPA 200.7
Total Beryllium (Be)
BDL
10
ug/L
EPA 200.7
Total Cadmium (Cd)
BDL
10
ug/L
EPA 200.7
Total Chromium (Cr)
BDL
10
ug/L
EPA 200.7
Total Copper (Cu)
BDL
20
ug/L
EPA 200.7
Total Lead (Pb)
BDL
25
ug/L
EPA 245.1
Total Mercury (Hg)
BDL
0.5
ug/L
EPA 200.7
Total Nickel (Ni)
BDL
20
ug/L
EPA 200.7
Total Selenium (Se)
BDL
40
ug/L
EPA 200.7
Total Silver (Ag)
BDL
10
ug/L
EPA 200.7
Total Thallium (Tl)
BDL
50
ug/L
EPA 200.7
Total Zinc (Zn)
110
20
ug/L
BDL - Below Detection Limit
Page 1 of 1
-------
AS!
ANALYTICAL SERVICES, INC.
ENVIRONMENTAL MONITORING & LABORATORY ANALYSIS
110 TECHNOLOGY PARKWAY • NORCROSS, GA 30092
(770) 734-4200 « FAX (770) 734-4201
LABORATORY REPORT
Macon Water Authority March 3, 1999
P.O. Box 108
Macon, GA 31202
Attention: Mr. Mark Wyzalek Report No. 104553-1
Sample Description
Water, composite, Rocky Creek, 02/0 9-10/99, 3 :10-3 :10, received 02/11/99
RESULTS
129 Priority Pollutants - Georgia
Detection
Result
Limit
Metals
(ucr/1)
(ug/1)
Total
Antimony (Sb)(EPA 200.7)
BDL
50
Total
Arsenic (As) (EPA 200.7)
BDL
30
Total
Beryllium (Be) (EPA 200.7)
BDL
10
Total
Cadmium (Cd) (EPA 200.7)
10
Total
Chromium (Cr)(EPA 200.7)
BDL
10
Total
Copper (Cu)(EPA 2 0 0.7)
BDL
20
Total
Lead (Pb)(EPA 200.7)
' BDL
25
Total
Mercury (Hg) (EPA 245.1)
BDL
0.5
Total
Nickel (Ni)(EPA 200.7)
BDL
.20
Total
Selenium (Se)(EPA 200.7)
BDL
40
Total
Silver (Ag)(EPA 200.7)
BDL
10
Total
Thallium (Tl)(EPA 200.7)
50
Total
Zinc (Zn) (EPA 200.7) .
20
BDL - Below Detection Limit
Respectfully submitted,
Qhipx vb-AM.
a "Project Mafiager
- At
Quality\ Assurance
A Unit of American Analytical Services, Inc.
-------
ANALYTICAL SERVICES, INC.
ENVIRONMENTAL MONITORING S LABORATORY ANALYSIS
110 TECHNOLOGY PARKWAY • NORCROSS, GA 30092
(770) 734-4200 * FAX (770) 734-4201
LABORATORY REPORT
Macon Water Authority March 16, 19 98
P.O. Box 108
Macon, GA 31202
Attention: Mr. Mark Wyzalek Report No. 92392-1
Sample Description
Wastewater, composite, RC 129PP, Final Effluent, 02/25-26/98, 12:50-12:46,
received 02/27/98
RESULTS
Detection
Priority Pollutant Metals Result Limit
Metals (uq/1)
Total Antimony (Sb) (EPA 200,7) BDL 50
Total Arsenic (As) (EPA 200 .7) BDL 30
Total Beryllium (Be) (EPA 200,7) BDL 10
Total Cadmium (Cd) (EPA 200.7) BDL 10
Total Chromium (Cr) (EPA 200.7) BDL 10
Total Copper (Cu) (EPA 200 . 7) BDL 20
Total Lead (Pb) (EPA 200.7) BDL 25
Total Mercury (Hg) (EPA 245 .1) ....... BDL 0
Total Nickel (Ni) (EPA 200 . 7) BDL 20
Total Selenium (Se) (EPA 200.7) BDL 40
Total silver (Ag) (EPA 2 0 0.7) BDL 10
Total Thallium (Tl) (EPA 200.7) .......... BDL 50
Total Zinc (Zn) (EPA 200 .7) BDL 20
BDL - Below Detection Limit
Respectfully submitted,
A Unit of American Analytical Services, Inc.
-------
HARBOR BRANCH ENVIRONMENTAL LABORATORY
Trace Metals Analysis
mstitwtiok
Client:
Project/HPN NO.:
1 IRS Certification No.:
Macon Water Authority
Priority Pollutant Scan/62195
E96080 and 96230
Station ID:
HSN ID:
Work Order No.:
Rocky Creek Effluent Com p.
62195003
2195
Sampled: 10/09/96 Received: 10/10/96
Data Released By: N. Myron Gunsalus Matrix: Environmental Water
Metal
Method
Date
Digested
Date
Analyzed
Results
(mg/L)
Qualifier
Detection Limit
(mg/L)
Antimony
200.7
10/16/96
10/17/96
ND
0.050 v
Arsenic
200.7
10/16/96
10/17/96
ND
0.030 •/
Beryllium
200.7
10/16/96
10/17/96
ND
0.010 ^
Cadmium
200,7
10/16/96
10/17/96
ND
0.010 ~
Chromium
200.7
10/16/96
10/17/96
ND
0.010 *
Copper
200.7
10/16/96
10/17/96
ND
0.020
Lead
200.7
10/16/96
10/17/96
ND
0.025 ^
Mercury
245.1
10/14/96
10/15/96
ND
0.00050 J
Nickel
200.7
10/16/9 6
10/17/96
ND
0.020 J
Selenium
200.7
10/16/96
10/17/96
ND
0.040 ^
Silver
200.7
10/16/96
10/17/96
ND
0.010 v
Thallium
279.2
10/16/96
10/17/96
ND
0.050 ^
Zinc
200.7
10/16/96
10/17/96
0.074
0.020 ^
ND - Not Detectable
-------
Attachment 2:
Macon Water Authority, Rocky Creek Biosolids Mercury
Data, Undated
-------
Mercury (total) Biosolids RC_BIOSOLIDS Plot 1 of 1
MWA's Rocky Creek WRF Biosolids bi-monthly
analyses; mercury is one of the metals tested.
Units are mg/kg dry weight. Mercury is one of
the metals known to be captured by the
extended aeration activated sludge process. All
data submitted annually to Georgia EPD and
US EPA in annual biosolids report and meets
requirements of 40 CFR 503.
12/10/08 10:43
02/12/09 10:00
04/14/09 09:30
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O
a
o
10/07/09 09:00
12/07/09 00:00
o
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o
o
lB
SS
o
LO
¦<;
a
a
5
§
a
06/15/10 09:15
08/24/10 00:00
12/16/10 10:56
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o
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o
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06/07/11 13:17
08/11/11 11:23
10/06/11 09:33
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02/16/12 13:25
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06/12/12 10:24
00/14/12 13:26
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-------
Attachment 3:
Macon Water Authority, Status of MWA lines to Ocmulgee
River from Rocky Creek POTW, January 24, 2003
-------
R.A. "Tony" Rojas
Executive Director
Macon Water Authority
Members
Frank C. Amerson Jr., Chair
Javors J. Lucas, Vice-Chair
Dorothy "Dot" C. Black
Joe Allen
Barbara Knight
Charles W. Bishop
Henry C. Ficklin
790 Second Street - P.O. Box 108
Macon, GA 31202-0108
(478) 464-5620
January 24, 2003
VIA MAIL & FAX 404 3 62-2691
Jeff Larson
Program Manager
Georgia EPD
4220 International Parkway
Suite 101
Atlanta GA, 30354
Dear Mr. Larson:
Subject: Status of MWA lines to Ocmulgee River from Rocky Creek POTW
This letter is being submitted as per your request concerning the status of MWA lines to the
Ocmulgee River from Rocky Creek POTW.
1. Until 1975 a MWA 30" gravity sewer line discharged to the Ocmulgee River.
a. The MWA 30" line closely parallels two lines owned by Riverwood International
along the service road from Riverwood International to the Ocmulgee. The MWA
30" line lies south of the two Riverwood lines and terminates in the Ocmulgee
River next to Riverwood's discharge line and it is north of the current Rocky
Creek NPDES discharge point by about 100 ft.
b. When the Rocky Creek POTW came into service in 1975 the 30" line was
abandoned and made inactive. A small MWA lift station was built to service only
the sanitary sewer from Macon Kraft (now Riverwood International) and what
was the Inland Container company; the lift station discharges into the force main
from Riverwood International to Rocky Creek POTW. The 30" sewer line was
terminated in the wet well of the lift station and bricked in so that no sewer
discharge could flow to the Ocmulgee River. The first manhole just downstream
of the lift station was filled with grout to further ensure no sewer discharge could
occur through the abandoned line.
c. Inspections of this 30" line confirm that it is abandoned and inactive. A break in
the line near a creek crossing has been observed, at times of higher groundwater
level due to higher Ocmulgee River level, to discharge groundwater inflow and
infiltration. Inspection of the broken line on January 23, when the groundwater
and Ocmulgee river level was lower showed no water in the line. Today (January
24), when collection system personnel were going to repair the break for aesthetic
AN AFFIRMATIVE ACTION/EQUAL OPPORTUNITY EMPLOYER
-------
Page 2 of 2
January 24, 2003
reasons, groundwater was found to be discharging due to higher river and
groundwater levels. Collection system personnel will repair the break using brick
and grout on the first day that the pipe is again dry.
2. From 1975 to 1991 Rocky Creek POTW discharged to an area immediately adjacent to
the facility.
3. In 1991 a 54" line was put into service that conveys the Rocky Creek facility's discharge
to the Ocmulgee. This 54" line for most of its length parallels the abandoned 30" MWA
line and lies south of it. Inspections of this line showed no discharge except for the
permitted NPDES discharge.
It is my understanding that Riverwood International will be submitting their own information to
you concerning the water line and discharge line owned by them.
If any further information is required concerning this matter please do not hesitate to contact me.
Sincerely,
Mark Wyzalek
Manager, Laboratory & Industrial Monitoring Services
Office 478 464-5678, fax 478 745-9531
cc: Tony Rojas, Terry Forrest, Frank Sanders, and Winton Evans - MWA
Marion Bard - Riverwood International, via mail and fax 784-4444
------- |