Superfund Proposed Plan Operable Units of the Anniston PCB Site Anniston Calhoun County Alabama August 2010

U.S. ENVIRONMENTAL PROTECTION AGENCY
SUPERFUND PROPOSED PLAN

W OPERABLE UNIT 3 OF THE ANN IS TON PCB SITE

ANMSTON, CALHOUN COUNTY, ALABAMA

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Al GUST 2010

This document has been prepared to provide the general public with an understanding of the activities that have been occurring at the Anniston
PCB Site. For technical information, please review the documents in the Administrative Record located at the information repositories.

INTRODUCTION

The U.S. Lnvironmental Protection Agency
(LPA) is releasing this Proposed Plan (Plan) for
the environmental cleanup at Operable Unit 3
(OUT) of the Anniston PCB Superfund Site (Site)
in Anniston. Calhoun County. Alabama. OU3
includes the Anniston Plant (Plant) and the
adjacent closed West lind Landfill and closed
South Landfill. The Plant is located at 702
Clydesdale Avenue. Anniston. Alabama. This
Plan identifies the preferred alternatives for
cleaning up the soil and groundwater
contamination that pose a potential risk to human
health and the environment at OU3. It includes a
description of all the cleanup alternatives
considered and provides LPA's reasons for
proposing the Preferred Alternative. 1 PA is
issuing this Plan as part of its public participation
responsibilities under Section 117(a) of the
Comprehensive Lnvironmental Response.
Compensation, and Liability Act (CLRCLA) and
Section 300.430(0(2) of the National Oil and
Hazardous Substances Pollution Contingency
Plan (NCP).

Public participation is an important part of the
site cleanup decision process. Based on public
comments, EPA may modify the preferred
alternative or select another alternative presented
in this Plan. Therefore, the public is encouraged
to review and comment on all cleanup
alternatives presented in this Plan. LPA u ill
select a final remedy for the Site after reviewing
and considering all information submitted during

Public Comment Period

September 1, 2010 to September 30, 2010

Public Meeting

Monday, September 13, 2010

6:00 p.m.

Anniston Meeting Center
1615 Noble Street
Anniston, AL 36201

The community is invited to a public meeting where
EPA will present its understanding of conditions at
Operable Unit 3, alternatives evaluated in the
Feasibility Study, and provide its rationale for the
Preferred Alternative presented in this Plan. In
addition, this meeting provides the public with an
opportunity to ask EPA questions about the
Preferred Alternative and the Operable Unit 3.

The Administrative Record file for the Anniston
PCB Site is available at two locations of the Public
Library of Anniston-Calhoun County:

Main Branch
108 East 10th Street
Anniston, Alabama
Or

Carver Branch

722 West 14th Street
Anniston, Alabama

In addition, the Administrative Record is available
at:

U.S. EPA Records Center
61 Forsyth Street, S.W.

Atlanta, GA 30303
(404) 562-8946

1

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Figure 1. The Superfund Process

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Remedy Selection

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Feasibility
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the 30-day public comment period. Issuance of
this Plan is part of the Superfund process
depicted in Figure 1.

EPA will hold a public meeting on Monday,
September 13, 2010 at 6:00 pm at the Anniston
Meeting Center, 1615 Noble Street, Anniston,
Alabama. The purpose of the meeting is to
present the Proposed Plan for cleaning up OU3.
This meeting will provide an opportunity for
citizens to ask questions of EPA representatives.
Questions and answers will be recorded to assist
EPA in the final selection of the remedy and in
preparation of a Record of Decision (ROD). All
comments received during the public comment
period and corresponding responses will be
documented in the Responsiveness Summary of
the ROD. EPA may modify the preferred
alternative or select another response action
presented in this Proposed Plan based on new
information or comments received during the 30-
day public comment period which starts on
September 1, 2010, and ends on September 30,
2010.

During this 30-day period, the public is
encouraged to review the findings of the
Remedial Investigation (RI) and the details of the
alternatives presented in the Feasibility Study
(FS). These and other documents are available at
the information repositories listed on page 32 of

this Plan. Citizens are encouraged to submit
written comments to EPA. Following the public
comment period, EPA will carefully consider all
public comments before selecting the remedy for
OU3. All comments submitted in writing by
September 30, 2010, will be addressed in the
Responsiveness Summary, as will the questions
and answers discussed at the public meeting. If
you are not on the Site mailing list and would
like to be, please contact Ms. Pam Scully at 404-
562-8935 or 1-800-435-9234.

A ROD, which summarizes the remedy decision
process and selects the remedy, will be prepared
and signed by EPA. Once the ROD is issued,
EPA will enter into negotiations for a new
Consent Decree with the Potentially Responsible
Parties (PRPs) to implement the Remedial
Design and Remedial Action (RD/RA) for the
final remedy selected for OU3 in the ROD.

SITE BACKGROUND

The Anniston PCB Site consists of residential,
commercial, and public properties located in and
around Anniston, Calhoun County, Alabama,
which contain hazardous substances, including
polychlorinated biphenyls (PCBs) originating
from historic operations at the Anniston Plant.
The Site is located in the north-central part of
Alabama and has been evaluated for over 30

2

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years through both the Resource Conservation
and Recovery Act (RCRA) and CFRCI.A
regulatory frameworks. The Site is not on the
National Priority List (NFL), but is considered to
be a Superlund Alternative Site (SAS). The Site
has been divided into three operable units (OUs),
which were selected based on geographic
location and complexity (Figure 2). GUI and
OU2, which were previously separate, have been
combined into a single OU. know n as OULOU2.
OUI/OU2 generally consists of both residential
and non-residential properties around the and
downstream of the Plant, following Snow Creek
to Highway 78. OU3 consists of the Plant, the
closed South Landfill, and the closed West End
Landfill (Figure 3). OU4 includes Snow Creek
and its lloodplain downstream of Highway 78 to
the confluence of Snow and Choceoloceo
Creeks, and Choccoloeco Creek from the
backwater area upstream of Snow Creek to Lake
Logan Martin. This Flan identities the
Preferred Alternative for cleaning up (H 3,
which consists of the Plant and adjacent
closed South and West F.nd Landfills.

The Plant is currently active and operates in
accordance with a variety of environmental
permits. PCBs w ere produced at the Plant from
1929 until 1971. The Plant encompasses
approximately 70 acres of land and is located
about one mile west of downtow n Anniston.

Alabama. The Plant is bounded to the north by
the Norfolk Southern and Erie railroads, to the
cast by Clydesdale Avenue, to the west by E'

Avenue, and to the south by U.S. Highway 202.
Solutia currently produces polypheny!
compounds ant! phosphate ester-based non-
flammable hydraulic fluids at the Plant.

During its operational history, disposal of
hazardous and non-hazardous substances,
pollutants, and contaminants occurred in two
primary areas, the approximately 17-aere closed
West End Landfill and the approximately 53-
acre closed South Landfill, both of w hich are
located adjacent to the Plant. Surface water
containing PCBs discharged from the Plant and
closed landfills to a ditch, which flowed into
local and dow nstream w aterways. Sampling by
EPA. Solutia. the Alabama Department of

3

Environmental Management (ADEM), and other

parties has demonstrated that sediments in
waterways leading away from the Plant, as well
as soils in the floodplains of these waterways,
contain varying levels of PCBs and other
contaminants. Additionally, distribution of
contaminants, including PCBs. may have
occurred through air pathways and through the
movement of fill materials.

On April 5. 1995. SolutiaVs corporate
predecessor, Monsanto Company (Monsanto),
entered into a Consent Order with ADFM to
develop and implement a sampling plan for
sediments in the storm water drainage system
down gradient of the plant. On March 8. 1996,
Monsanto entered into a second Consent Order
with ADEM that expanded and defined the scope
of the ongoing investigation and corrective
measure activities for certain areas outside the
Plant. In October 1996. ADFM issued a Draft
Hazardous Waste Post-Closure Permit to
regulate the Plant's post-closure responsibilities
at waste management areas (WMA I and WMA
II) and to address certain interim and final
corrective actions for Solid Waste Management
I. nils (SWMUs) and potential areas of concern
located both at the Plant and areas outside of the
Plant. The permit was finalized and issued on
January 7. 1.997 and subsequently modified on
November 13, 1997. May 3. 2001. December 11.
2003, May 5. 2006. and October 31. 2008. The
Plant's current Posl-Closure Permit specifically
deferred 19 SWMUs to EPA for further
investigation and/or remediation.

Beginning in 2000. investigatory and removal
work were also conducted in the vicinity of the
Plant under EPA's CERCl .A authority. In
October 2001, Solutia entered into an
administrative order on consent for removal
action (Removal Order) to conduct certain time-
critical removal actions to address PCB-impaeted
residential properties. The Removal Order also
required a removal response for a portion of the
1 I1" Street Ditch, sampling of a portion of the
West 9n Street Creek, and a removal response at
areas outside of the Plant related to activities
previously completed at Quintard Mall and the
Ox lord Lake Softball Complex.

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Figure 2.
Anniston PCB Site
Operable Units

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Figure 3.
Anniston PCB Site
Operable Unit 3

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A Partial Consent Decree (PCD) between EPA
and Solutia and Pharmacia Corporation
(collectively, S/P) was lodged in the United
States District Court for the Northern District of
Alabama in March 2002, and entered by the
court on August 4, 2003. The PCD provided for
judicial oversight of the RI, risk assessment, FS,
and time-critical and non-time-critical removal
activities at the Site.

SCOPE AND ROLE OF PROPOSED
REMEDY

The proposed remedy for OU3 is intended to be
the first remedial cleanup for the Site. Time-
critical and non-time critical removals have
already taken place at the Site. Additional
remedies are planned for OU1/OU2 (residential
and non-residential properties around and
downstream of the Plant, following Snow Creek

to Highway 78) and OU4 (Snow Creek and its
floodplain downstream of Highway 78 to the
confluence of Snow and Choccolocco Creeks,
and Choccolocco Creek from the backwater area
upstream of Snow Creek to Lake Logan Martin).
When the remedial investigation for OU4 is
complete, EPA will consider whether an
additional downstream investigation of the
Coosa River System is warranted.

SITE CHARACTERISTICS

The RI for began in August 2004. Data
summarized in the RI includes sampling results
collected at OU3 during the RCRA Plant
Investigation/ Confirmatory Sampling (RFI/CS),
the Supplemental RFI/CS, and the CERCLA RI
Programs. Soil and groundwater samples were
collected at the Plant in all three investigations.
Surface water from OU3 is conveyed to off-site

5

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discharge points and monitored through the
Plant's National Pollution Discharge Elimination
System (NPDF.S) permit: that data was also
considered in the RI. Air data collected by LPA
and by Solutia during the RI I CS from 2000 to
2004 was also considered in the evaluation of
risk to human health at OU3,

The scope of the RI included: gathering data to
close gaps in site characterization: identifying
the nature and extent of contamination:
calculating the risk posed by contaminants; and,
evaluating alternative:- to address unacceptable
risks. Because the RFI CS and Supplemental
RFI/CS were focused on individual SWMUs. the
RI focused on locations where no data was
available and locations where more data was
needed.

Soil

As part of the RCRA RFI/CS. 17 surface or near-
surface soil samples were collected from various
locations across the Plant and landfills, in
addition, live subsurface samples were collected.
These samples were obtained to evaluate the
potential for off-site migration from different
SWMUs, to confirm the effectiveness of existing
corrective measures (such as landfill caps), and
to investigate areas that exhibited visual
indications of residual staining. These samples
were analyzed for a list of contaminants
developed for the Plant under the RCRA
program, including PCRs.

In response to comments about the RFI/CS, the
Supplemental Rl'I/CS was conducted and
included additional soil sampling. Thirteen soil
samples were collected from five SWMUs and
analyzed for PCBs: tw o of the samples w ere also
analyzed for mercury. Additionally, eight
composite soil samples were collected from the
surface of the closed South Landfill cap and
analv/ed for PCBs. One soil sample w as
collected in the vicinity of the Former PCB
Production Area (SWMU-42) and analyzed for
polychlorinated dibenzodioxins furans
(PCDD I s).

Additional surface and subsurface soil data were
needed to further characterize areas of the Plant

and provide the data necessary for completing
the risk assessment and the RI. Fourteen surface
and subsurface soil samples were collected and
analyzed for PCBs. The PCB results were
reviewed, and three sample locations were
selected to represent areas of high, medium, and
low PCB concentrations. These locations were
sampled and analyzed for a broad suite of
parameters, including metals, volatile organic
compounds, semi-volatile organic compounds,
pesticides, and PCL)I) I s. Two surface samples
w ere collected at the closed West Lnd Landfill
cap to determine the PCB concentrations in the
landfill cap.

The samples collected during the R1T CS
Program. Supplemental RI I CS Program, and RI
Program were used to determine a list of
contaminants of potential concern (COPCs) for
the Plant, the West Fnd l andfill cap. and the
South Landfill cap. Subsurface COPCs w ere
evaluated in the operations area of the Plant only.
In addition, five samples collected prior to the
RFI/CS to determine PCB concentrations in the
soil cap over the closed RCRA cells in the South
Landfill were considered. The soil sample
locations are show n in Figure 4. Maximum
detected concentrations of chemicals were
compared to risk-based screening levels to
identify COPCs lor use in the Human Health
Risk Assessment (HIIRA). Screening levels
were taken from FPA Region 9 preliminary
remediation goals (PRGs) for residential soil,
using a target cancer risk of 10"° (one in one
million) and a target hazard quotient of 0.1.

At the operations area, COPCs for surface soils
included ben/o(a)anthracene. benzo(a)pyrene.
benzo(b)fluoranthene. dibenz.(a. h) anthracene,
indeno(l .2.3-ed)pyrene, heptaehlor epoxide.

aluminum, antimony, arsenic, cadmium,
chromium, iron, lead, manganese, mercury,
vanadium, total PCBs. and dioxin toxic
equivalent (TLQ). For subsurface soils, COPCs
included the surface soil COPCs. as well as
barium and nickel.

For the West Lnd and South Landfills, the only
contaminant analyzed for in the surface soil of
the capping material was PCBs. No PCBs were

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Figure 4. Operable Unit 3 Soil Sample Locations

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detected in the surface soils of the West I .andfill
during the RI, although a review of historical
records indicate that up to 21 milligram per
kilogram (nig kg) of PCBs are present in surface
soils adjacent to the landfill cap. Total PCBs
was the only COPC analyzed for and detected in
the surface soil of the South Landfill cap, with a
maximum PCB concentration of 10 mg kg.

Groundwater

A significant number of groundwater monitoring
wells exists around the perimeter of the
operations area and the landfills associated with
the South Landfill | SWM11-1) Corrective Action
System and the New Limestone Bed (SWMP-
10) WMA II Corrective Action System. During
the RIT'CS Program, 12 new monitoring wells
(live shallow and seven deep) were installed.
During the Supplemental RFLCS, lour additional
observation wells were installed; one observation
well was abandoned and re-installed; four
additional interceptor wells were installed to
upgrade the WMA II Corrective Action System;
and one interceptor well was abandoned and
re-installed. In addition, an angled boring was
drilled to deiermine the hydraulic properties of
the interface (contact) of the discontinuity
located north of the operations area.

After the conclusion of the R1T/CS and
Supplemental R1 I CS Programs, groundw ater
data gaps for areas of the Plan! were identified,
and additional groundwater samples were
collected during the RI to address these data
gaps. The well locations are shown on Figure 5.
Maximum detected concentrations of chemicals
were compared to drinking water Maximum
Contaminant Levels (MCLs), if available, or
risk-based screening levels to identify COPCs
for use in the IIIIRA. Screening levels were
taken from 1 .PA Region 9 PRC is for residential
tap water, using a larget cancer risk of 10"{> and a
target hazard quotient of 0.1. Additionally, site-
specific limits were developed for two
constituents using procedures established for
calculating the Region 9 PRGs.

COPCs for groundwater included 1.2.4-
trichloroben/ene. 1,4-dichloroben/ene.
chloroben/ene, cis-1,2-dichloroeihene.

pentachlorophenol, trichloroethylene, 2.4,6-
trichlorophenol. indeno( 1,2.3-cd)pyrene, total
PCBs, gamma-BlIC. methyl parathion.
parathion. Dioxiti 1LQ. antimony, arsenic,
manganese, and mercury.

Surface Water

There are no surface water bodies at the Plant or
landfills. Storm water is conveyed via
underground piping, open trenches, and lined
and unlined drainage ditches to discharges points
off the Plant site. Storm water samples have
been collected on a quarterly and semi-annual
basis at the discharge points in accordance with
the Plant's NPDLS Permit. Only one location is
currently sampled quarterly for flow. pll.
biological oxygen demand (BOD), chemical
oxygen demand (COD), oil and grease, total
suspended solids (TSS). total dissolved solids
(TDS). and PCBs.

Storm water samples were also collected during
the RI 1,';CS Program in June and July 1998 to
assess the possible migration of constituents by
surface water routes from the plant production
areas. Two NPDLS outfall points were sampled
alter precipitation events produced sufficient
water flow to the outfall points to enable sample
collection. PCBs have been detected in 23 of 60
surface water samples considered in the RI.
ranging from 0.23 to 22.0 micrograms per liter
(|ig/L).

Aii-

Air samples were collected and analyzed for
PCBs at or near the Plant between 2000 and

2002 by both Solutia and the 1 PA. Five stations
were monitored by Solutia for PCBs from
January 25. 2000. to December 18. 2002. LPA
monitored eight additional locations in June
2000. Following the 2000 to 2002 monitoring.
Solutia conducted an ambient air monitoring
program near the Plant, including continuous
collection of meteorological monitoring data
over !he course of a one-vear period from April

2003 through March 2004. The sampling stations
are shown in Figure 6, The results ranged from
non-detect to 145.4 nanograms per cubic meter
(ng/nV ) PCBs northw est of the plant on October
2 L 2003.

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Figure 5. Operable Unit 3 Well Locations

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Figure 6. Operable Unit 3 Air Monitoring Locations

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LEGEND

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Primary
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Potential Receptors

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Worker

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LEGEND

—* = Pathways, current, histoncat and future
# = Pathways for quantitative evaluation
— = Incomplete or insignificant pathways

Figure 7. Site Conceptual Exposure Model

SUMMARY OF SITE RISKS

Risk assessments were conducted to determine
the current and future effects of contaminants on

human health and the environment.

Human Health Risk Assessment (HHRA)

A HHRA was conducted using soil, ground-
water, and air sampling results as summarized in
the Rl. The receptors selected for assessment of
human risk were selected based on current and
likely future land-uses ofOin (i.e., current and
likely industrial use; not residential). Thus,
receptors were evaluated for potential non-cancer
ha/ard and cancer risk.

Iixposure point concentrations (LPCs) for all
COPCs were calculated for each media. LPCs
are calculated as the lower of the maximum
detected concentration or the 95 percent upper
confidence limit (lTCT.) of the arithmetic mean.
This approach is a conservative (i.e.. protective)
estimate of average COPC concentrations and is
used to account for uncertainties in the risk
assessment dataset. Separate LPCs were
calculated for current and future operations area
workers to take into account soil contaminants

that are currently under asphalt or other cover
and not currently accessible.

Exposure pathways are identified to estimate
risks and hazards to current and future receptors
assuming no additional site remediation occurs.
The receptors evaluated include operations area
workers, operation and maintenance (O&M)
workers, trespassers, and construction workers.
In addilion. off-site residential exposures to air
and groundwater from the Plant and landfills
were considered to address community concerns
(Figure 7).

A range of risks w ere considered for each
exposure scenario. The range varies from a
reasonable maximum exposure (RML). which is
based on default upper bound exposure
assumptions, to an average exposure (CIT),
based on exposure assumptions which are
reflective of what is more likely to occur.

Both Cancer and Non-Cancer Risks were
evaluated. Cancer Risk is the increased
probability, or chance, of getting cancer as a
result of exposure to chemicals a! a Mte. In the
report for this site, a 1 in 1.000.000 chance is
written 1L-06 or 1 Non-cancer Risk is a

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comparison of an allowable exposure to the
amount of exposure estimated at a site. The
comparison is called the Hazard Index (HI). An

HI greater that 1 indicates that site exposure
could cause some risk.

Acceptable risks for cancer health effects are
considered by I: PA to be less than I in
1.000.000. For risk estimates between a 1 in
1.000.000 and a 1 in 10.000 ? 11 -04 or 10~4)
chance. EP.-Vs risk range. I:PA looks at site-
specific factors affecting risk and uncertainties
with the estimate to determine if actions are
needed to reduce risk. For risk estimates greater
than 1 in 10.000. 1 PA must take action to reduce
risk.

Acceptable Risk for non-cancer health effects are
reflected by a Hazard Index (HI) less than 1.
EPA does not have an acceptable risk range for
non-cancer health effects. Typically LPA
Region 4 will look at site-specific factors and
uncertainties for an HI between 1 and 3 to
determine if actions are needed to reduce risk.

The cancer and non-cancer risks calculated for
current exposure pathways are shown
graphically in Figures 8 and 9. The cancer and
non-cancer risks calculated for future exposure
pathways are shown graphically in Figures 10
and 11. The following summarizes the results of
the OU3 IIIIRA:

• For current operations area workers, cancer

risks range from within EPA's risk range to
slightly above EPA's risk range (Figure 8),
and non-cancer Ills are above 1 (Figure 9).
PCBs at one soil location drive both cancer
and non-cancer risks. Prior to completion of
the RIPS, Solutia conducted a removal of
principal threat waste at the soil location
driving current operations area worker
risk( SSRI-11): the current risk w as not
recalculated to reflect this removal and may
be lower than the presented in Figures 8 and
9.

• Cancer risks and non-cancer hazards for
future operations area workers at the plant
exceed EPA's thresholds (Figures 10 and

1 1). These estimates suggest unacceptable
risks, due primarily to PCBs in soil and to
fulure exposure to contaminated groundwater
(GW). These risks are associated with
existing contamination in the Plant area
assuming Solutia no longer controls access or
maintains existing covers. Prior to
completion of the RFFCS and RI/FS. Solutia
conducted a removals of principal threat
waste at the soil locations driving future
operations area worker risk location (SSR-18
and SSRI-11); the future risk was not
recalculated to reflect these removals and
may be lower than the presented in Figures
10 and 11.

• Cancer risks and non-cancer hazards
associated with future trespassers at the
Plant range from within FPA's risk range to
above FPA's risk range, and non-cancer
hazard indices are above 1. suggesting
unacceptable risks and hazards (Figures 10
and 11). The unacceptable risks are due
primarily to PCBs in soil and were not
recalculated to reflect the removals described
above; the actual risk may be lower than the
presented in Figures 10 and 11.

• Cancer risks and non-cancer hazards are
within or below FPA limits for current and
future O&M workers exposed to the West
End landfill (WEI.) and the South Land fill
(SI.) (Figures 7. 8. 9 and 10). These
estimates suggest negligible risks.

• Cancer risks and non-cancer hazards are
within or below FPA limits for current and
future trespassers to the West End Fandlill
(WEE) and South Fandlill (SI.) (Figures 8. 9.
10. and 11). These estimates suggest
negligible risks.

• Cancer risks associated with current off-.site
residents' exposure to PCB vapors in
ambient air are low and indicate no

unacceptable health threat currently exists
(Figures 8 and 9). The highest risks for is a
conservative estimate. If FPA adjusted air
concentrations based on wind speed and

direction changes,

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Figure 8. Summary of the Range of Current Cancer Risks

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J- ^

^ cT

# £/
^ > . o>

r4>'

-------
Figure 10. Summary of the Range of Future Cancer Risks

nj
u
(0
O)

tft

03
U

1.E+00
1.E-01
1.E-02
1.E-03
1.E-04

1.E-07
1.E-08
1.E-09
1.E-10

i 2.E-01

6.E-03 2pn2

3BTJ3 1.E-03

.E-C

7.E-04

1.E-03

1.E-04

E-C

z.t-u#

LJ 6

3.E-05 b

E-C

1.E-08 1'E"07

1.E-07

7.E-09

3^09

E-1

&¦

^ <*

^ A°V

<$"

S / f / ~

Exposure Scenarios

-------
ambient air concentrations would be

lower, and estimated risks would be
lower.

• Cancer risks and non-cancer hazards for
all future workers and off-site residents
are much higher than EPA's thresholds
if groundw ater (G\V) i^ considered
accessible, due primarily to PCBs and
parathion (figures 10 and 11).

Streamlined Ideological Risk Assessment

A Streamlined Ecological Risk Assessment
(SI.ERA) was conducted for OU3. A
review of the habitat characteristics
(ecological setting) for the Plant and
landfills was conducted. The Plant area is
described as largely occupied by buildings,
parking lots, areas actively used for
industrial purposes, and impervious
surfaces. As a result, "habitat" in this area is
primarily characterized by maintained
surfaces pavement, structures, and
gravel covers), with small strips and
medians of mowed and maintained lawns
and decorative plantings. Based on the
direct observation, there does not appear to
be a functional ecosystem within the Plant
area.

furthermore, the Plant is fenced off.
potentially restricting terrestrial wildlife
access to the area. The habitat of the West
End and South Landfills is poor, reflecting
maintenance activities (cutting and
mowing), low plant diversity, and poor soil
conditions. Because the Plant is expected to
continue operations for the foreseeable
future, a risk-management decision was
made that no further assessment of
ecological risk at OU3 is necessary. Any
actions taken to protect human health risk at
the plant will also reduce risk to ecological
receptors.

It should be noted that residual PCBs are of
great concern to ecological receptors, and a
full Ecological Risk Assessment is being
c on duc t ed fo r O U 4.

Basis for Taking Action

It is the LPA's current judgment, as the lead
agency, that the Preferred Alternative

identified in this Plan, or one of the other
active measures considered in the Plan, is
necessary to protect public health or welfare
or the environment from actual or threatened

releases of pollutants or contaminants from
this site which may present an imminent and
substantial endangerment to public health or
welfare

REMEDIAL ACTION OBJECTIVES
AND REMEDIAL GOALS

Remedial Action Objectives (RAOs) for
OU3 are based on the current understanding
and available data identified in the f S.

RAOs describe what a proposed site cleanup
is expected to accomplish. In some cases,
cleaning up one area will achieve the
Remedial Goals (RGs) of another area. At
the Anniston PCB Site, addressing
contamination in soil will also help to
achieve the RAOs and RGS for
groundwater.

The RAOs for soil, at OU3 of the Anniston
PCB Site are to:

• Reduce or eliminate risks to receptors
(Plant operations area worker, O&M
worker, and trespasser) from direct
contact with, inhalation of or incidental
ingestion of Contaminants of Concern
(COCs) in surface soil above the RGs;

• Reduce or eliminate risks to the
construction worker from direct contact
with or incidental ingestion of COCs in
subsurface soil above the RGs.

• During soil disturbance activities,
prevent ingestion or inhalation of soil

particulates in air that contain COCs in
soil in excess of the RGs;

• Prevent migration and leaching of

-------
contaminants in surface and subsurface
soils to groundwater that could result in
groundwater contamination in excess of
maximum contaminant levels (MCLs) or
health-based risk levels at the point of
groundwater compliance;

• Permanently and/or significantly reduce
the mobility, toxicity, and'or volume of
hazardous substances, pollutants, and/or
contaminants with treatment;

• Prevent migration of contaminants in
excess of the R( is in surface soil to

surface water; and

• Control future releases of contaminants
to ensure protection of human health and
the environment.

RCis established to satisfy these RAOs for

soil are presented in Table 1.

The RAOs for groundwater at Ot '3 of the

Aimiston PCB Site are to:

• Reduce or eliminate risks to receptors
from direct contact with or ingestion of
COCs in groundwater at concentrations
above the R( is:

• Prevent the migration of pollutants
beyond the existing limits of the known
contaminant plume or established point
of compliance;

• Control future releases of COCs in
groundwater to ensure protection of
human health and the environment; and

• Restore groundwater to meet cleanup
goals, such as MCLs. throughout each
plume, or at and beyond the edge of the

waste management area(s).

RCis established to satislX these RAOs for

groundwater are presented in Table 2.

SUMMARY OF ALTERNATIVES

The following alternatives were developed
to meet the RAOs and cleanup goals for
OU3 of the Site. The numbering
corresponds to the numbering used in the FS
report. There are live soil and four
groundwater alternatives. One of the soil
alternatives has two options. The Preferred
Alternative is a combination of soil and
groundwater alternatives.

Impact Areas

Based on RlfCS. Supplemental Rl'I CS.
and R1 sampling results c\ alualed m the risk

assessment, eight soil impact areas (Areas
A-I J) and four groundwater impact areas
{near Area A. near Area I:, near well OW-
21A, and near the South I.andtlll) have been
identified in Ol 13 (figure 12). Ill addition,
data from interim measures taken at the
West End and South Landfills was
considered to determine the adequacy of the
interim measures. A description of these
impact areas is provided below.

Area A - This soil and groundw ater impact
area consists of the open, currently-grassed
area to the north of the employee parking lot
in the ucniiiy of the former Phosphoric
Acid Basins (SW VII -12). and it i>
approximately 3.3 acres in size. PCB
concentrations measured in soil exceeded
both the surface soil and subsurface soil
RGs. Subsurface impacts extend to a depth
of 10 feet below ground (53.240 cubic
yards) and groundwater in the area exceeds
the groundwater goals for PCBs. mercury,
trichloroethyiene. beryllium, manganese,
and gamma-B1IC. Arsenic concentrations
also exceeded the surface soil R(i in this
area. Prior to completing the I S. Solulia
implemented delineation sampling and a

-------
TABLE 1. REMEDIATION GOALS FOR SOIL CONTAMINANTS OF CONCERN

Constituent Surface
Soil

Range of Detections
(mg;kg)

Remedial Goal
{nig/kg)

Basis for RG

PCBs

0-023 - 930 current
0.023-16.620 future*

Superf'und PCB Guidance / HHRA
Current Operation 7E-6 cancer risk
Future Operations 2.5E-5 cancer risk
Construction Worker RME HQ 1.9 /CTE
HQ-0.7

Arsenic

3.1-390

HHRA for a current operations worker of
1E-05 cancer risk

Constituent Subsurface Soil

PCBs

0.23 -16.620*

Construction worker
RME HQ=3.5 / CTE HQ=0.9

Arsenic

3.1 -390

217

HHRA for construction worker at an HQ 1

I* Large degree of uncertainty with future concentration. Likely 500 mg'kg maximum due to interim removal.

TABLE 2. REMEDIATION COALS FOR GROl 'NDWATER C ONTAMINANTS OF CONCERN

Constituent

Range of
Detections

(pg/L)

Remedial Goal
(MS'I-)

Basis for RG

o,o.o-Triethylphosphorothioate

1.3-530

310

HHRA review of Part B
Permit limit

1.1,2,2 -T e trachloroethane

0.67

0.067

Region Screen Level

1,2,4-TricMorobenzene

0.8-1.200

MCI.

2.4.6-TricMoroplienol

3.4-25.1

HHRA HQ 1

PNP

3.6-31.000

125

HHRA HQ 1

Benzo(a) pyrene

2.5

0.2

MCL

Beryllium

1.3-6.8

MCL

Cobalt

0.78-300

Region Screen Level

Gamma-BHC

0.1-0.56

0.2

MCL

Indeno( 1.2.3-cd)pvrene

0.02

1E-06 Cancer Risk

Lead

2.2-33

MCL

Manganese

20-12,000

880

Region Screen Level

Mercury

0.081-50

MCL

Methyl Parathion

1.4-74

HHRA HQ 1

Methylene Chloride

0.46-36

MCL

Parathion

0.17-23,000

HHRA HQ-I

P( Bs

0.32-15,500

0.5

MCL

Pentachlorophenol

1.2-95.4

MCL

T etraethvldithiopyrophosphate (Sulfotepp)

0.19-150

111 IRA IIQ 1

T richloroethylene

3.4-10

MCL

-------
Figure 12. Soil and Groundwater Impact Areas

¦ ' C1 • ^ LUUJTT-

^ S^M '

<-,pB

, , / —I" Biiif1 \"C
I 'n ^ fa&MD 'V//'

-------
removal action to address PCB "principal threat

waste" material {i.e., soil containing PCBs
concentrations greater than 500 mg/kg) at SSRI-
I 1 (within Area A). However, it seems likclv
that concentrations of PCBs remain in soil with

the potential to impact groundwater.

Area B - This soil impact area is located in the
center of the Site at the location of the former
Waste Drum Satellite Accumulation Area
(SWMU-44). SWMlJ 44 was a pit.
approximately 19-feet by 16-feci (304 square
feel) in si/e. with 4-inch concrete curbs and two
conical sumps 6-feet to 8-feet deep. Soil sample
SSR-18 was collected near the SWMU-44 and
yielded the highest estimated PCB concentration
reported in soil of 16,620 mg/kg. SSR-18 w as
collected immediately north of the former PCB
Production Area (S\Y\U "-42). This area and the
sumps were subsequently partially excavated and
covered with a concrete. However Solutia did
not take samples to confirm that concentrations
were reduced. Area B is approximately 0.5 acres
in size. Before being excavated and covered in
concrete, this area was likely a source of
groundwater contamination.

Area C - This soil impact area is located in the
southwest portion of the Plant in the vicinity of
the former Santotar-R- Pit (SWMU-07). This area
is approximately 1.5 acres in si/e. In 1989. the
remaining solidified Santotar-R' was removed
from the pit 12 to 16 feet below grade and the pit
was backfilled with clay. This area is currently
covered with between 7 and 12 inches of clean
coarse gravel. .ITevated PCBs were detected in
surface soil (beneath the gravel) at SSR-9 (282
mg/kg), which exceeds the surface soil RG.
Because the area was previously excavated, was
not used in the PCB process, and no groundw ater
impacts have been noted nearby and
downgradient, it seems likely the impacts in this
area are only surfieial.

staging area for phosphorus slag and tailings
received from the phosphorus furnaces.

Land filling was unlikely to have occurred at this
location due to its proximity to active production
areas. This area was also used for a
neutralization pit for the treatment of acidic
wastewater as part of the parathion production
process and likely contained limestone as a
treatment media. The basin received acidic
wastewater from the scrubber system of the
sulfur incinerator which w as used to burn
residues from intermediates of the parathion
production process. The effluent from the
neutralization basin was discharged through the
plant sewer system to the Phosphoric Acid
Basins. The suspect area was approximately
150-fcel long by 170-feet w ide. Currently, the
whole area is covered w ith two to eight inches of
gravel. ITevated PCBs were detected in surface
soil (beneath the gravel) at SSR-7 (229 mg/kg),
which exceeds the surface soil RG. Because the
area was not used in the PCB process, and no
groundwater impacts have been noted nearby
and downgradient, it seems likely the impacts in
this area are only surfieial.

Area 1 - This soil and groundwater impact area
consists of the open, currently-grassed area to the
w est of the main office building and to the east
of the former PCB Production Area (SWMU-42)
and is approximately 0.75 acres in si/e. ITevated
PCB detections in soils include 250 mg/kg
(SSRI-07) at the surface and 56 mg/kg at depth,
exceeding both the surface soil and subsurface
soil RGs. Subsurface impacts extend to a depth
of at least 4 feet below ground (4,840 cubic
yards), and groundw ater in the area exceeds the
groundwater goals for PCBs. mercury, and
pentachlorophenol.

Area F - This soil impact area consists of the
open currently grassed area to the northwest of
the \1CC Warehouse and is approximately 1.5
acres in size. Flevated PCB detections in soils
include (SSR1-05) 37.6 mg/kg at the surface and
85 mg/kg at depth, exceeding both the surface
soil and subsurface soil RGs. However,
groundw ater goals have not been exceeded at
nearby and downgradient wells.

Area 1) This .soil impact area is located in the

southwest portion of the Plant in the vicinity of
the Phosphate Landfill (SWMU-06) to the
northw est of Area C and is approximately 1 acre

in size. The landfill description is a misnomer
because this area was reportedly used as a

-------
Area G This soil impact area is in the
southeastern portion of the Plant, north of the
Boiler Feed Tank (SWMU-25), and is
approximately 0.3 acres, in size. Derated PC 13
detection in soil includes 37.6 mg/kg (SWMU-
25-6A) at the surface, exceeding the surface RCi.
The former PCB Production Area (SWMU-42)
and the former Waste Drum Satellite
Accumulation Area (SWMU-44) are directly
downgradient of this area. Contaminated
groundwater downgradient of all these units are
not likely from Area G.

Area H - This soil impact area is an open,
currently-grassed area north of the walking trail
area along the southern portion of the parking lot
and is approximately 0.4 acres in size. ITcvated
PCB detections in soils include an estimated 38.4
mg/kg (SSR1-09) at the surface and an estimated
13.1 mg kg at depth: only the surface soil RG is
exceeded and groundw ater is not likely to be
affected by this area.

Observation Well OW-21A Observation well
OW-21A was installed north of the Plant (on the
North side property owned by Solutia) in
February 2003 during the Supplemental RFFCS
Program to replace well OW-21. At this
location, groundwater impacts have been
detected in recent sampling events. In June
2005. RGs were exceeded for Total PCBs (7.400
ug I ). PNP (16.000 ftg/F). parathion (I 1,000
tig. F). and sulfotepp (59 ug'F).Several other
wells were installed to define the extent of
contamination. These data indicate a localized
area of groundwater impacts, separate from
WMA II. The attempt to locate an upgradient
source was not successful, because moving
further upgradient from temporary monitoring
well T-04 would have run into successive
obstructions of the railroad and then the WMA II
Groundwater Correcti ve Action System. A
subsurface soil and groundwater investigation
took place in March 2008 to determine a possible
source for the OW-21A contamination. The soil
remaining in place does not appear to be
providing an ongoing source to groundwater.

West I lid Landfill The closed West Fnd
Fandfill is located along the western boundary of

the Plant and operated as a single, unlined
landfill cell from approximately 1930 to
approximately 1960, receiving production wastes
and general trash from the Plant. PCB
concentrations were measured in soil adjacent to
the landfill prior to constructing the existing
cover system. The samples included were
collected from 1994 through 1996. Solutia
excavated and removed soil from the adjacent
areas prior to placing a multilayer cap over the
landfill and prior to placing a minimum 18-inch
thick soil cover over the adjacent areas.
Additionally, soil was excavated from outside
the fence line of the West Fnd Fandfill along 1st
Avenue to address PCBs found in soil/sediment
and to improve drainage in the area. The area
addressed includes a strip of grass betw een the
road and the fence line approximately eight to
ten feet wide.

Surface soil samples were collected from the
closed West Fnd Fandfill and adjacent areas
following completion of the cover systems and
analyzed for PCBs. The PCB concentrations
ranged from non-detect to 21 mg/kg. The higher
concentrations were measured along the fence
line adjacent to the Alabama Power Company
switchyard.

Flevated PCB concentrations were also detected
in the soil underlying the Alabama Power
Company switchyard located within the limits of
the West Fnd Fandfill property. T he samples
were collected from beneath the gravel present in
the switchyard. Although no additional capping
of this area was completed as part of the interim
measures. Alabama Power maintains a
substantial gravel cover over the area and
restricts access to the switchyard to its
employees only. The area is enclosed with a
chain link fence, which remains locked to
prevent unauthorized entry or trespass.

There have been several detections of PCBs
slightly above and below the MCF for PCBs in
wells installed to monitor the West Fnd Landfill.
Give the age of the waste and low? levels detected
(ranging between non-detect and 0.72 ug 1.).
ongoing groundwater impacts from the landfill
are considered to be negligible.

-------
South Landfill The South \.and fill operated
with 10 individual cells from 1960 to 1988, and
was used for the disposal of production wastes,
demolition materials, and trash from the Plant.
Cells I E. 21... and 31'. received waste that was
generated by the phosphorus, chlorine, and PCB
processes, and they are the only cells remaining
in the landfill with a simple cap of compacted
soil and a vegetative layer. PCB concentrations
measured in the w ells located immediately
downgradient of Cells I Li. 21i. and 3Li (MW-
11 A. M W-12A. and MW-13 A) have shown no
reported exceedances in groundwater, indicating
that leaching to groundwater is not occurring.
However, analytical results for OWR-5D
indicated that total PCB concentrations near the
corrective action system for the South Landfill
are three orders of magnitude above the
groundwater PCB goal. Additionally, a seep has
been identified on the cover near Cell 3ii
containing 1.4-dichlorobenzene and PCBs.

Dow ngradient of the South Landfill is an area
where surface w ater runoff from parts of the
South Landfill (low ed prior to construction of
Highway 202. This area is referred to as the
Walking Trail Area. In May 1995. soil and
sediment samples were collected from the
Walking frail Area. The samples were field
screened for PCB.s. and approximately 10"n of
the field samples were submitted for laboratory
analysis of PCBs. Of the samples collected, nine
soil and eight sediment samples exceeded the
screening level of 10 mg kg. Laboratory
concentrations ranged from 6.1 mg/kg to 157
mg kg. After being sampled, a geotextile and
soil cover was placed over the area. Portions of
the ditches were enclosed and surface water from
the South I.andfiil and the Walking Trail Area is
routed to surface water monitoring station (DSN-
012). The results from DSN-012 indicate mostly
no or low -level detections of PCBs in the years
following construction of the soil cover system
over this area. Based on the constituents
detected, groundwater impacts measured below
this area most likely originated from the South
Landfill. The existing cover system over this
area is protective of human health.

Summary of Impacts

There are three types of contaminant impact that
need to be addressed at the site: human health
impacts caused by surface soil contamination;
human health impacts caused by subsurface soil
contamination: and groundwater impacts caused
bv possible ongoing subsurface soil leaching or
plume management. In order to achieve the
surface soil RGs in OI '3, remedial action will be
required for Areas A, C. I). and Ii. Remedial
action is required in Areas A. Li. and I: to address
subsurface soil impacts. Remedial actions in
Areas A. Li. and South Landfill Cells Hi. 21 . and
31 i are needed to address the potential for COCs
leaching to groundwater.

Because remedial actions for Areas A and E
must address all three types of impacts, any
remedial action involving excavation in these
two areas should extend to the full depth of
impact, and containment options should include
means for reducing further impacts to
groundwater. Remedial actions for Areas C and
Ii) need only address surface soil impacts.
Remedial actions for South Landfill Cells Hi.
21. and 31" must address the potential for
leaching to groundwater. Remedial actions for
Area F must address subsurface soil impacts.

Common Klenients to All Alternatives

There are a number of soil and groundwater
interim corrective measures and final closures
that serve as the initial condition for evaluation
of OU3 risks to human health and the
environment and for use in the screening and
evaluation of remedial actions. The
implementation, operation, and maintenance of
many of the interim corrective measures and
final closures are the foundation of the
alternatives and must be continued to make the
alternatives effective. Unless modified by the
alternatives presented, all of the interim and final
corrective measures implemented at OU3 prior
to the ROD are being proposed as acceptable
remedial actions under CLRCLA. and the
evaluation of alternatives includes the evaluation
of those actions.

The costs to maintain the existing soil measures
(S40,000 in O&M costs over 30 years using a

-------
7(/o discount rate, amounting to a present worth
cost of S496.000) are included in all of the
evaluated soil remedial alternatives, except the
No Action Alternative. Likewise, the costs to
maintain the groundwater measures (S i 10.000 in
operations and maintenance costs over 30 years
using a 7% discount rate, amounting to a present
w orth cost of SI .365.000) are included in all of
the ev aluated groundwater remedial alternatives,
except the No Action Alternative

Additionally, all of the soil alternatives include:

• 1 nier into an environmental covenant with
ADF.M to restrict land use: and

• Enhance institutional and engineering
controls with a "no dig policy" restricting
excavations within the Plant (particularly in
Area F). and add perimeter fencing in the
northeast portion of the Plant and along the
southern portion of the employee parking lot.

• Verify with confirmation samples that the
principal threat waste under cover in Area B
has been removed; and

• Verify with subsurface soil or groundwater
samples that there are no groundwater
impacts in Areas B. F. and G.

Additionally, all of the groundw ater alternatives

include:

• Fmer into an environmental covenant with
ADIAl to restrict groundwater use; and

• Enhance institutional controls, including
extension of the deed restriction prohibiting
groundwater use to include the North Side
and Fast Side Properties (in the vicinity of
monitoring wells OW-21A and OW-10 OW-
11).

Soil Alternatives

The five soil alternatives, including both options
for Alternative S-C. are as follows:

S-A No Action

Capital Cost: $ 0

Estimated O&M: $ 0

Total Present Worth: $ 0

Estimated Construction Timeframe: None

Estimated Time to Achieve RAOs: > 100years

AIL-IRs met: None

Alternative S-A is the No Action Alternative for
soil, which means that no additional remedial
action will be conducted for soil. Under
Alternative S-A. the existing corrective measures
would be continued (i.e.. operated or maintained)
under RCRA authority, but no new actions
w ould be implemented under CFRCEA. "I"his
alternative is presented and analyzed as required
by the NCP. 40 C.F.R. Section 300.430(e)(6).
The No Action Alternative does not prov ide
adequate protection of human health and the
environment. The No Action Alternative will
not address the unacceptable risks to current and
future operations area workers and construction
workers.

S-B Additional Institutional and

Engineering Controls and Soil
Excavation with off-Site Disposal

Estimated Capital Cost: $ 28,785,000
Estimated O&M Cost: $ 713.000
Total Present Worth: $ 29,498,000
Estimated Construction Timeframe: 2 years
Estimated Time to Achieve RA Os: 2 years
ARARs met: This alternative is anticipated to
meet the ARARs and TBCpertaining to this
alternative.

Alternative S-B includes the common elements
described above for soil and the following:

• Fxcavate impacted soils in Areas A. C. D.
and E:

• Dispose of impacted soils off-site:

• Backfill excavated areas with clean soils:

Alternative S-B includes excavation and off-site
disposal of an estimated 63,900 cubic yards of
impacted soil. Appropriate temporary erosion
and sedimentation control measures and surface
water management structures will be put in place
to prevent off-site migration of contaminants
during excavation. Continuous air monitoring
w ill be conducted at the location of the
excavation and the perimeter of the Plant to
monitor air for soil particulates containing
contaminants in excess of RGs. Additionally,
EPA will review all existing O&M requirements
and may make revisions to all plans as deemed

-------
necessary to ensure that the remedies are

protective of human health and the environment.

S-C Option 1 Additional Institutional and
Engineering Controls and Soil ( ontainment
(Capping)

Capital Cost: $ 2,063,000
Estimated O&M: $ 796,000
Total Present Worth: $ 2,859,000
Estimated Construction Timeframe: 2
Estimated Time to Achieve RAOs: 2years
ARARs met: This alternative is anticipated to
meet the A RARs and TBC pertaining to this
alternative.

Alternative S-C Option 1 includes the common
elements described above for soil and the
following;

• Contain by capping impacted soils in Areas
A and F; the cap requires a low-permeability
barrier layer to eliminate dermal contact,
minimize potential soil leaching to
groundwater, and to direct storm water a wax1
from the impacted area;

• Contain by capping impacted soils in Areas
C and I); the cap requires a barrier layer to
eliminate dermal contact exposure and to
direct storm water away from the impacted
area; and

• Provide operation, monitoring, and
maintenance to ensure continued long-term
effectiveness of the remedy.

Typical cover sections for the caps required by
this alternative are provided in Figure 13. Areas
A and F will be capped with either a 6-inch-thick
asphalt or concrete cap or a geomembrane cap.
Other design parameters may be used to ensure
that the cap meets the RAOs. Area C and D will
be capped with a 2-foot-thick vegetated soil
cover (soil and grass cover). Cover materials
will be imported to OU3. Any existing materials
that arc cut or excavated for grading purposes
will be contained under the proposed caps. The
final surface will be graded to promote drainage
away from the capped area. Wherever possible,
existing surface water management structures
will be used to convey storm water awav from
the capped areas. New surface water

management structures will be installed as
needed. The final surfaces of the capped areas
w ill be gently graded into the surrounding
terrain, with no significant or noticeable changes
from the existing topography. Appropriate
temporary erosion and sedimentation control
measures and surface w ater management
structures will be put in place to prevent off-site
migration of contaminants during excavation.
Continuous air monitoring will be conducted at
the location of the excavation and the perimeter
of the Plant to monitor air for soil particulates
containing contaminants in excess of RCis.
Additionally. FPA w ill review all existing O&M
requirements and may make revisions to all
plans as deemed necessary to ensure that the
remedies are protective of human health and the
environment.

S-C Option 2 Additional Institutional and
Engineering Controls and Soil ( ontainment
(Capping)

Capital Cost: $4,172,000
Estimated O&M: $ 946,000
Total Present Worth: $ 5,118,000
Estimated Construction Timeframe: 2 years
Estimated Time to Achieve RAOs: 2 years
ARARs met: This alternative is anticipated to
meet the ARARs and TBC pertaining to this
alternative.

Alternative S-C Option 2 includes the common

elements described above for soil and the
following:

• Place a new geomembrane cap over the PCB
cells (Cells I E. 21.. and 31 ) of the South
Landfill; the cap requires a low-permeability-
barrier layer to eliminate dermal contact,
minimize potential soil leaching to
groundwater, and to direct storm water away
from the impacted area;

• Contain by capping impacted soils in Areas
C and D: the cap requires a barrier layer to

-------
Figure 13. Capping Sections

.van/ ¦

Ifr..

VEGETATIVE SURFACE

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(OR EQUIVALENT}

IMPERMEABLE SECTION #1
GEOMEMBRANE COVER
SEE NOTE 3 FOR PROPOSED AREAS

NOTES

1. THICKNESS OF PAVEMENT SURFACE TO BE 6* MIN.
AS PER 40 CFR 761.61 AND 40 CFR 761.75 GUIDANCE.

2. SUBGRADE PREPARATION TO BE DESIGNED BASED
ON EM STING CONDITIONS AND INTENDED SERVICE USE
OF PAVEMENT.

3. SELECTION OF IMPERMEABLE COVER OPTION FOR
AREAS A&E Vila BE MADE DURING A PRE-DESIGN
INVESTIGATION. FOR ALTERNATIVE S-C OPTION 2, A
GEOMEMBRANE COVER WLL BE USED OVER THE PCS
CELLS.

SO L U T I A

Golder

Associates

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TYPICAL COVER SECTIONS

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-------
• eliminate dermal contact exposure and to
direct storm water away from the impacted
area: and

Provide operation, monitoring, and maintenance
to ensure continued long-term effectiveness of

tlie remedy.

Typical cover sections for the caps required by-
tills alternative are provided in Figure 13. Cells
11... 21:. and 31.) of the South Landfill will be
capped with a geomembrane cap. Other design
parameters may be used to ensure that the cap
meets the RAOs. Areas A and 1 will be capped
with either a 6-inch-thiek asphalt or concrete
cap. or a geomembrane cap based on the
intended end use determined during remedial
design. Areas C and D will be capped with a
2-foot-thick vegetated soil cover (soil and grass
cover). Cover materials will be imported to
OU3. Any existing materials that are cut or
excavated for grading purposes w ill be contained
under the proposed caps. The final surface will
be graded to promote drainage away from the
capped area. Wherever possible, existing surface
water management structures will be used to
convey storm water away from the capped areas.
New surface water management structures will
be installed as needed. The final surfaces of the
capped areas will be gently graded into the
surrounding terrain, with no significant or
noticeable changes from the existing topography.

Appropriate temporary erosion and
sedimentation control measures and surface
water management structures w ill be put in place
to prevent off-site migration of contaminants
during excavation. Continuous air monitoring
will be conducted at the location of the
excavation and the perimeter of the Plant to
monitor air for soil particulates containing
contaminants in excess of RGs. Additionally.
I.PA will review all existing O&M requirements
and may make revisions to all plans as deemed
necessaiy to ensure that the remedies are
protective of human health and the environment.

Capital Cost: $ 39,305,000
Estimated O&M: $ 713,000
Total Present Worth: $ 40,018,000
Estimated Construction Timeframe: 2
Estimated Time to Achieve RA Os: 4 years
ARARs met: This alternative is anticipated to
meet the ARARs and TBCpertaining to this
alternative.

Alternative S-D includes the common elements
described above for soil and the following:

• Excavate impacted soils in Areas A. C. D.
and ! :

• Dispose of soils that qualify for Subtitle D
landfill o ff-site;

• Treat remaining excavated soils using on-site
chemical dehalogenation; and

• Backfill excavated areas with treated soils
that meet RGs or clean soils.

Alternative S-D includes soil excavation and on-
site treatment using chemical dehalogenation.
Soils qualifying for Subtitle I.) landfill disposal
will be disposed of accordingly in lieu of
treatment in order to reduce the cost to
implement this option. Remaining soils will be
treated using on-site chemical dehalogenation.
There is an estimated 63.900 cubic yards of
impacted soil.

There are a number of chemical dehalogenation
technologies including base-catalyzed
decomposition (BCD), alkaline metal hydroxide
polyethylene glycol (API C). and potassium
metal hydroxide polyethylene glycol
(KPLGTM). BCD appears to be the most
proven, efficient, and cost effective of these
processes: therefore. BCD is the only one
considered in this alternative. However, prior to
implementation, a treatability study will need to
be conducted at OU3 to determine what
technology is most appropriate for OU3
conditions. The presence of multiple COCs
could affect the effectiveness of this technology
and therefore will need to be evaluated further
during the treatability study.

Treated soils will be sampled and analyzed: soil

meeting the RGs will be backfilled within the

S-I) Additional Institutional and

Engineering Controls and Soil Excavation
with Treatment Using on-Site Chemical
Dehalogenation

-------
areas of excavation. Soil not meeting the RGs
will be retreated or disposed off-site. A 6-inch
thick vegetative soil cover or gravel cover will
be used above the treated soil backfill.

Appropriate temporary erosion and
sedimentation control measures and surface
water management structures will be put in place
to prevent off-Site migration of contaminants
during excavation. Continuous air monitoring
will be conducted at the location of the
excav ation and the perimeter of the Plant to
monitor air for soil particulates containing
contaminants in excess of RGs. Additionally.
EPA will review all existing O&M requirements
and may make revisions to all plans as deemed
necessary to ensure that the remedies are
protective of human health and the environment.

S-E Additional Institutional and
Engineering Controls and Soil Excavation
with on-Site Thermal Desorption

Capital Cost: $ 27,069,000
Estimated O&M: $ 713,000
Total Present Worth: $ 27,782.000
Estimated Construction Timeframe: 2
Estimated Time to Achieve R.iOs: 4 years
ARARs met: This alternative is anticipated to
meet the ARARs and TBCpertaining to this
alternative.

Alternative S-E includes the common elements
described above lor soil and the following:

• Excavate impacted soils in Areas A. C\ 1),
and E;

• Dispose of soils that qualify for Subtitle E>
landfill off-site:

• Treat remaining excavated soils rising on-site
thermal desorption;

• Backfill excavated areas with treated soils
that meet RGs or clean soils;

Alternative S-E includes soil excavation and on-

site treatment using thermal desorption. Soils
qualifying for Subtitle 1) landfill disposal will be
disposed of accordingly in lieu of treatment in

order to reduce the cost to implement this option.
Remaining soils will be treated using on-site

thermal desorption. There is an estimated 63,900
cubic yards of impacted soil.

Appropriate temporary erosion and
sedimentation control measures and surface
water management structures will be put in place
to prevent off-site migration of contaminants
during excavation. Continuous air monitoring
will be conducted at the location of the
excavation and the perimeter of the Plant to
monitor air for soil particulates containing
contaminants in excess of RGs. Additionally.
EPA will review all existing O&M requirements
and may make revisions to all plans as deemed
necessary to ensure that the remedies are
protective of human health and the environment .

Groundwater Alternatives

The four groundw ater alternatives are as follows:

GW-A No Action

Capital Cost: $ 0

Estimated O&M: $ 0

Total Present Worth: $ 0

Estimated Construction Timeframe: None

Estimated Time to Achieve RAOs: > 100years

ARARs met: None

Alternative GW-A is the No Action Alternative,
which means that no additional remedial actions
will be conducted. Under Alternative GW-A. the
existing corrective measures would be continued
under RCRA {i.e.. operated or maintained), bul
no new actions would be implemented under
CERCEA. This alternative is presented and
analyzed as required by the NCP. 40 C.E.R.
Section 300.430(e)(6). The No Action
Alternative does not provide adequate protection
of human health and the environment. The No
Action Alternative will not address the
unacceptable risks to future operations area
workers and off-site residents who might ingest
contaminated groundwater.

GW-B Additional Institutional Controls and
Expanded Groundwater Extraction

Capital Cost: $ 305,000
Estimated O&M: $ 2,002.000
Total Present Worth: $ 2,307,000
Estimated Construction Timeframe: < 1 year

-------
Estimated Time to Achieve RA Os: 30 years
ARARs met: This alternative is anticipated to
meet the AILIRs and TBCpertaining to this
alternative.

Alternative GW-B includes the common
elements described above for groundwater and
the following:

• Optimize and expand the existing
groundw ater corrective action system to
provide further containment of groundwater
near OW-21A and Area A (OW-IO OW-l 1);

• Pre-treat extracted groundwater using a
carbon filtration system;

• After filtration, the water will How to the on-
Sile equalization basin for discharge to the
Anniston Publically-Owned Treatment
Works (PC) l'W) for further treatment;

• Provide operation, monitoring, and
maintenance to ensure continued long-term
effectiveness of the remedy.

Alternative GW-B includes the optimization and
expansion of the existing groundw ater corrective
action system. The existing system will continue
to be operated, and will be optimized and
expanded through the incorporation of additional
interceptor wells, which may be deeper wells in
some areas, to provide for complete perimeter
control of groundwater impacts, Figure 12
shows the locations of the proposed expansion in
the locations noted as "Potential Groundwater
Impact Areas." Two new interceptor wells have
been assumed to be required at the two proposed
expansion locations. Three observation wells,
two existing and one proposed, will be used to
monitor the effectiveness of the new? interceptor
wells. The exact location and number of
interceptor well and monitoring well locations
will be determined in design. Extracted water
will be pre-treated using a carbon filtration
system, and then sent to the on-site equalization
basin. Trom the equalization basin, extracted
groundwater is discharged to the Anniston
POT W for further treatment.

Water levels will be collected will be collected

for all wells. A report verifying capture will be
provided so that system modifications are

possible to pre vein the escape of any

contamination.

The remedial components included in this
alternative are intended to contain and remove
contaminated groundwater. In conjunction with
the soil remedies proposed, groundwater outside
of the limits of approved waste management
areas will be restored to satisfy RAOs. If
necessary, the groundwater recovery network
will be modified periodically until groundwater
satisfies RAOs.

GW-C Additional Institutional C ontrols,
Expanded Groundwater Extraction and MNA

Capita1 Cost: $ 414,000
Estimated O&M: $ 2,955,000
Total Present Worth: $ 3,369,000
Estimated Construction Timeframe: <1 year
Estimated Time to Achieve RAOs: 30years
ARARs met: This alternative is anticipated to
meet the ARARs and TBC pertaining to this
alternative.

Alternative GW-C includes the common
elements described above for groundwater and

the following:

• Monitor select wells for natural attenuation
parameters, to demonstrate natural
attenuation of PNP and parathion;

• Optimize and expand the existing
groundwater corrective action system to
provide further containment of groundwater
near OW-21 A and Area A (OW-IO'OW-I I ):

• Pre-treat extracted groundwater using a
carbon filtration system;

• After filtration, the water will flow to the on-
Site equalization basin for discharge to the
Anniston POTW for further treatment; and

• Provide operation, monitoring, and
maintenance to ensure continued long-term
effectiveness of the remedy.

Alternative GW-C includes the optimization and
expansion of the existing groundwater corrective
action system, as described in GW-B. in addition

to providing for the use of natural attenuation
parameters to optimize PNP and parathion

recovery.

-------
Select, existing wells will be sampled for
dissolved oxygen, oxidation-reduction potential,
turbidity, pH. specific conductance, methane,
ethane, ethene, total organic carbon, alkalinity,
TSS. nitrate, .sulfate, sulfide, ferrous iron, and
chloride. Water levels will be measured during
each sampling event, and equipotential maps will
be constructed to monitor groundwater How and
direction. A report verifying capture will be
provided so that system modifications are
possible to prevent the escape of any
contamination.

The remedial components included in this
alternative are intended to contain and remove
contaminated groundwater. In conjunction with
the soil remedies proposed, groundwater outside
of the limits of approved w aste management
areas will be restored to satisfy RAOs. If
necessary, the groundwater recovery network
will he modified periodically until groundwater
satisfies RAOs.

GW-D Additional Institutional Controls and
Groundwater Treatment using Funnel and
Gate Zero \ a lent Iron (ZYI) Walls

Capital Cost: $ 8,826,000
Estimated (MM: $ 4,624,000
Total Present Worth: $ 13,450,000
Estimated Construction Timeframe: <1 year
Estimated Time to Achieve RAOs: 30 years
ARARs met: This alternative is anticipated to
meet the A RARs and TBCpertaining to this
alternative.

Alternative GW-D includes the common
elements described above for groundwater and

the following:

• Install funnel and Gate / VI Walls to treat
groundwater in-situ: and

• Provide operation, monitoring, and
maintenance to ensure continued long-term
effectiveness of the remedy.

Alternative GW-D includes groundwater
treatment using funnel and gate ZVI Walls. Two
in-situ treatment units will be installed: one near
()W-21 A. and the other near OW-10. The funnel
will consist of slurry walls constructed of a

bentonite soil mix and extended to
approximately 45 feet below ground surface to
act as local impermeable barriers to groundwater
flow. The slurry walls will be constructed using
standard construction techniques (i.e., extending
a trench to the necessary depth and length with
simultaneous injection of bentonite slurry). 7.VI
is an effective reduetant that can treat many
contaminants, and is particularly effective for
chlorinated solvents. PCBs. pesticides, and
dioxins. These compounds are completely
reduced to non-toxic compounds such as ethane
and carbon dioxide. In addition, ZYI is
potentially effective in the treatment of certain
metals, including cadmium, cobalt, nickel, lead,
copper, mercury, and chromium. As
groundwater passes through the permeable
treatment area, COCs are treated resulting in
reduced groundwater concentrations
downgradient from the treatment area.

A series of bench scale studies will be performed
during a design to establish the efficacy of ZYI
on all groundwater COCs. Assuming some
COCs are not treated, secondary treatment will
consist of groundwater extraction beyond the
ZYI wall and discharge to the Anniston POTW.

The remedial components included in this
alternative are intended to treat contaminated
groundwater in-situ. In conjunction with the soil
remedies proposed, groundwater outside ol'the
limits of approved waste management areas will
he restored to satisfy RAOs. If necessary, the
groundwater recovery network will be modified
until groundwater satisfies RAOs.

EVALUATION OF ALTERNATIVES

Laeh alternative was evaluated using the nine
evaluation criteria in the NCP. 40 C.F.R. Section
300.430(e)(9)(iii). The criteria are grouped by
threshold criteria, primary balancing criteria, and
modi lying criteria, and are summarized in
Table 3. The nine evaluation criteria are
discussed below. A detailed analysis of
alternatives, as well as information about the
evaluation process may be found in the TS.

-------
Overall protection of human health and

the environment - All alternatives, except the
No Action Alternatives (Alternative S-A and

Alternative GW-A) preside protection of human
health and the environment. However, there are
varying degree* to which the alternatives provide
such protection. For soil. Alternatives S-D and
N-l provide a higher level of protection because
they destroy PCBs. pres enting them from ever
being released to the environment in the future.
For groundwater. Alternative GW-C provides a
higher level of protective because it involves
active extraction and remediation that does not
rely only on natural groundwater How to move
groundwater toward the reactive gate materials,
and the data collected will allow for adjustments
in the system to enhance natural attenuation.

Compliance with ARARs - All retained
alternatives, except the No Action Alternatives
(Alternative S-A and Alternative GW-A) are
expected to achieve compliance with those
chemical-specific and action-specific ARARs
that pertain to each alternative. Alternatives S-D
and S-F. which include treatment of soil via
chemical dehalogenation and thermal desorption,
respectively, will require extensive design, pilot
studies, and air moni toring in order to achieve
the action- and chemical-specific ARARs
associated with air emissions. Alternative GW-
D will also require extensive design, pilot
studies, and air monitoring in order to achieve

Table 3. NCR Evaluation Criteria

the action- and chemical-specific and action-
specific ARARs associated with air emissions.

Because Alternatives S-A and GW-A do not

satisfy the Threshold Criteria, they will not be
evaluated further.

Long-term effectiveness and
permanence- The long-term effectiveness and
permanence of Alternatives S-B. S-D, and S-F.
are equally effective and permanent to OU3.
However. Alternatives S-D and S-F provide
greater long-term effectiveness because
contaminants are destroyed or reduced in
volume. Alternatives S-B. S-D. and S-F. are
ranked higher than S-C (Option 1 and 2) due to
the residuals remaining on-site under caps.
Within Alternative S-C. Option 2 provides an
improved cap on the PCB cells of the South
I.andfill. which will be more effective long-term
protection.

The long-term effectiveness and permanence of
Alternatives GW-B and GW-C is expected it) be
higher than Alternative GW-1). which presents
implementability concerns that could potentially
reduce its long-term effectiveness and
permanence. Alternatives GW-B and GW-C
include a highly effective and proven remedial
component (groundwater extraction).

Alternative GW-C provides an additional degree
of effectiveness, compared to Alternative G W-B.
through the use of monitoring to continuously
evaluate the long-term effectiveness of the
remediation and associated natural attenuation

Threshold
Criteria

Primary

Balancing

Criteria

Overall protection of human
health and the environment

Compliance with Applicable or
Relevant and Appropriate

Requirements (ARARs)

Long-term effectiveness and
permanence

Reduction of toxicity, mobility, or
volume

Short-term effectiveness
Implementability

Cost

Modifying
Criteria

State acceptance
Community acceptance

processes.

Reduction of toxicity, mobility, or volume

The reduction of toxicity, mobility, and volume
through treatment is highest for alternatives that
treat impacted soil. Alternatives S-D and S-F
treat impacted soil via chemical dehalogenation
and thermal desorption. respectively. Pilot
studies for both of these technologies have
shown reductions in the concentration of PCBs
in treated soil. Both of these processes,
however, produce a significant amount of
residual products that require treatment or off-

-------
site disposal. In addition, reuse of the treated

soil on-site is not always appropriate due to the
change in physical characteristics of the
materials. Alternatives S-D and S-L are ranked
higher for reducing the toxicity, mobility, and
volume of impacted soil through treatment than
those alternatives which have either a
containment or excavation with off-site disposal
component for impacted soils.

Short-term effectiveness

Alternative S-C (Options 1 and 2) will have
minimal short-term impacts because
contaminated soil is not be excavated and treated
on-site. Alternative S-R will have some
additional short-term impacts due to hauling
activities associated with off-site disposal of soil.
Alternatives S-I) and S-l: are both anticipated to
have a high potential for short-term impacts
compared to the other alternatives due Lo the soil
treatment components of these alternatives. Both
of these alternatives will require on-site
treatment of impacted soil using systems that
will be in operation 24 hours per day throughout
treatment. As a result, there will be the
continued potential for air emissions, and noise
and light impacts to the Plant workers and
surrounding communities. In addition, fuel and

power demands, staging areas, and health and
safety requirements will have the potential to
cause disturbances to the existing Plant
operations. Particular attention would be
required for air monitoring during treatment
activities to provide protection for the
construction worker. Plant w orker, and local
community members.

Implementability

For soil. Alternative S-C. Options 1 and 2. are
easiest to implement, followed by Alternative S-
B. Alternatives S-F) and S-F. are the most
difficult to implement. For groundwater.
Alternatives GW-B and GW-C are equally easy
to implement. Alternative GW-D is the most
difficult to implement.

Cost - The cost of alternatives, from most to
least expensiv e is provided in Table 5.

State Acceptance - AIM \i has received all
documents related to dev elopment of the RL FS,
and Proposed Plan for OU3 of the Anniston PCB
Site. 1 PA anticipates working with AI) F \ 1 to
obtain support for the Plan.

Alternative

Capital Cost

Total Present Worth

Soil:

S-D

S 39.305.000

$ 713,000

S 40.01 H.000

S-l5.

$ 28,785,000

$ 713,000

$ 29,498,000

S-F

S 27,069,000

$ 713,000

$ 27,782,000

S-C (Option 2)

S 4,172,000

$ 946,000

$ 5,118,000

S-C (Option 1)

S 2,063,000

$ 796,000

$ 2,859,000

S-A

S 0

$ 0

Groundwater:

GW-I)

S 8.826.000

$ 4,624,000

$ 13,450,000

GW-C

$ 414,000

$ 2,955,000

$ 3,369,000

GW-B

$ 305,000

S 2.002.000

$ 2,307,000

GW-A

$ 0

Table 4. Cost Comparison of Alternatives

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Community Acceptance - Community
acceptance of the Preferred Alternative will be
evaluated after the Proposed Plan comment

period ends and will be described in the
Responsiveness Summary of the ROD for OU3.

PREFERRED ALTERNATIVE

Because OU3 is an operating plant with multiple
existing waste management areas and
groundwater corrective action systems in place.
EPA's Preferred Alternative is Alternative S-C,
Option 2 (Additional Institutional and
Engineering Controls and Soil ( ontainment).
combined with Alternative GW'-( ( Additional
Institutional Controls, Expanded
Groundwater Extraction and VINA). These
alternatives incorporate as CFRCFA remedies all
of the interim and filial corrective measures
implemented at OX !3 prior to the ROD. This
combination of alternatives will protect human
health and the environment, while restoring
groundwater, without also interfering with
operations at the Plant.

Alternative S-C, Option 2, includes maintaining
all of the existing corrective measures and adds a
containment remedy to address impacted surface
soil. In addition, enhanced institutional and
engineering controls are included in this
alternative. Option 2 includes constructing or
supplementing caps over Areas A. C, 1"). and F.
plus upgrading the cap over Cells I E, 21 . and 3E
at the South Landfill. Three different cap
systems are proposed for different areas of the
Site as shown on Figure 13 and include two
impermeable caps and one soil/vegetative cap.
The capping systems will be an impermeable cap
(Areas A and F and Cells IF. 2F. and 3F at the
South Landfill) to minimize potential soil
leaching to groundwater, and a vegetated soil
cover (Areas C and D) where leaching to
groundwater is not likely. Cover materials will
be imported to Ol '3. Any existing materials thai
are cut or excavated for grading purposes w ill be
contained under the proposed caps. The final
surface will be graded to promote drainage away
from the capped area. The final surfaces of the
capped areas will be gently graded into the
surrounding terrain, and no significant or

noticeable changes from the existing topography
are anticipated. Additionally. EPA has added the

following actions to the alternative presented in
the FS to verify site assumptions: confirm the
principal threat waste under the cover in Area B
has been removed; and confirm with temporary
wells or subsurface samples that there are no
groundwater impacts from Areas B. F. and G.

Alternative GW-C includes the expansion of the
existing groundwater corrective action system
through the incorporation of additional
interceptor wells to provide for complete
perimeter control of groundwater impacts. For
evaluation and comparative analysis, two new
interceptor wells have been assumed to be
required at the two proposed expansion
locations, with the spacing of these wells based
on available hydrogeologic data from existing
wells in close proximity to the proposed
expansion locations. Three observation wells,
two existing and one proposed, w ill be used to
monitor the effectiveness of the new interceptor
w ells. These observation w ells w ill be
incorporated into the OU3-wide groundwater
monitoring program. The exact location and
number of interceptor well and monitoring wells
will be determined during design. Extracted
water will be pre-treated using a carbon filtration
system and then sent to the on-site equalization
basin. From the equalization basin, extracted
groundwater is discharged to the Anniston
POTW for further treatment. Natural attenuation
parameters to be monitored include dissolved
oxygen, oxidation-reduction potential, turbidity,
piI. specific conductance, methane, ethane,
ethene. total organic carbon, alkalinity. TSS,
nitrate, sulfate, sulfide, ferrous iron, and chloride
at select wells. Understanding natural
attenuation of parathion and PNP will allow for
better optimization of groundwater corrective
action systems at OU3.

Prior to any surface disturbance, appropriate

temporary erosion and sedimentation control
measures and surface water management
structures will be put in place to prevent off-site
migration of contaminants during excavation.
Continuous air monitoring will be conducted at
the location of soil disturbances and the

-------
perimeter of the Plant to monitor air for .soil
particulates containing COCs in excess of R( is.

Enhanced institutional controls including an
environmental covenant will be included to
restrict future uses of the Plant, and enhanced
engineering controls in the lorm of extended
perimeter fences are included in this alternative
to further restrict access. In addition,
administrative controls in the form of a "no dig
policy" will be implemented at the Plant
requiring a permit prior to excavating at the
Plant. Anyone performing such excavations will
require the proper training. Appropriate air
monitoring will be required during any soil
disturbance activities. Operation, monitoring,
and maintenance of the existing and proposed
additional remedial components are included in
this alternative.

COMMUNITY PARTICIPATION

1 PA provide-, information to the community
regarding Superfund cleanup through fact sheets,
public meetings, local site information

repository, and the Administrative Record file.
1 .PA encourages the public to learn more about
the Anniston PCB Site and Superfund activities
that have been conducted at the Site by visiting
the site information repositories listed on page 1
of this Proposed Plan and below.

Public Meeting

The public meeting for OU3 of the Anniston
PCB Superfund Site will be held at on Monday.

September 13, 2010, at 6:00 p.m. at:

Anniston Meeting Center
1615 Noble Street
Anniston, Alabama 36201

Written Comments

Written comments on this Proposed Plan will be
accepted until September 30, 2010, and should
be mailed to:

Ms. Pam Scully

Superfund Remediation Branch
I Si PA. Region 4
61 Forsyth Street, SAY.

Atlanta. Georgia 30303

oi to

Ms. Pam Scully-

US LP A Public Outreach Office
902 Noble Street
Anniston. Alabama 36201

Mailing List

Anyone wishing to be placed on the mailing list

for this Site should send his/her request to Ms.
Pam Scully, EPA Project Manager, at
scully.pam@epa.gov or call 256-236-2599 or
404-562-8935.

Inform at ion Repositories
The Administrative Record file lor the Anniston
PCB Superfund Site is available at two locations
of the Public Library of Anniston-Calhoun

County:

Main Branch
108 Last 10th Street
A nn iston. A1 aba ma.

Carver Branch

722 West 14th Street
Anniston. Alabama

in addition, the Administrative Record is
available at:

U.S. I PA Records Center

61 Forsyth Street, S.W.
Atlanta. (iA 30303

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AU GLOSSARY

Administrative Record: Material documenting
TPA's selection of cleanup remedies at
Snperfund sites, usually placed in the
information repository near the Site.

Applicable or Relevant and Appropriate
Requirements (ARARs): Refers to federal and

state environmental or facility cleanup standards,
standards of control, and siting requirements
which a selected remedy must attain; ARARs
vary from site to site.

Central Tendency Expsoure (( TIC): The

average exposure thai can he expected to occur
for a human or other living organisms at a site
undercurrent and potential future site uses.

Contaminants of Concern (COCs): Hazardous
substances, pollutants, or contaminants
associated with a site which have been released.

or threatened to be released, into the
environment,

("omprehensive Environmental Response,
Compensation, and Liability Act (CERCLA):

Also known as Snperfund. is a federal law
passed in 1980 and modified in 1986 by the
Superfund Amendment and Reauthorization Act
(SARA) and codified at 42 U.S.C. Section 9601
et.seq.; the act created a trust fund to investigate
and cleanup abandoned or uncontrolled
hazardous siles. The law authorizes the federal
government to respond directly to releases of
hazardous substances, pollutants, or
contaminants that may endanger public health or
the environment. EPA is responsible for
managing the Superfund.

Detection Limit (PL): The lowest quantity of a
hazardous substance that can be distinguished
from the normal random "noise" of an analytical

instrument or method.

Feasibility Study: Study conducted after the
Remedial

Investigation to determine what alternaihes or

technologies could be applied at the site to
remediate specific COCs.

Groundwater: The supply of fresh w ater found
beneath the Earth's surface (usually aquifers)
which is often used for supplying w ells and

springs.

Human Health or Ecological Baseline Risk
Assessment: A qualitative and quantitative
evaluation performed in an effort to define the

risk posed to human health and the environment
by the presence or potential presence and use of

specific pollutants.

Information Repository: A library or other
location where documents and data related to a
Superfund project is placed to allow public

access to the material.

Institutional Control; Non-engineering

instruments, such as legal or administrative
controls that help to minimize the potential for
human exposure to contamination and protect the
integrity of the remedy. These can include land
use permits, zoning, easements, or deed
restrictions.

Maximum Contaminant Level (MCI ):

Maximum concentration of a contaminant

that is allowed in drinking waster as
established by either the State of Alabama or
the EPA under the federal Safe Drinking
Water Act.

National Oil and Hazardous Substance
Pollution Contingency Plan (NCP): The

federal regulations that guide the Superfund

program, located at 40 C.F.R. Part 300, The NCP
was re\ised in February 1990.

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Ope ration and Maintenance (O&M):

Activities conducted at sites after cleanup
remedies have been constructed to ensure that
they are properly functioning.

Proposed Plan: Superfund public participation
fact sheet which summarizes the preferred
cleanup strategy and the rationale and a summary
of ihe Rl/FS.

Record of Decision (ROD): A public document
describing LPA's rationale for selection of a
Superfund cleanup alternative.

Remedial Investigation (RI): Part one of a two
part investigation conducted to fully assess the
nature and extent of the release, or threat of
release, of hazardous substances, pollutants, or

contaminants, and to identify alternatives for
clean up. The Remedial Investigation gathers the
necessary data to support the corresponding

Feasibility Study.

Reasonable Maximum Exposure (RME): Hie

highest exposure that can be reasonably
expected to occur for a human or other living

organisms at a site under current and potential
future site uses.

Responsiveness Summary: A summary of oral
and written comments received by IP A during a
comment period on key FPA documents, and
FP.-Vs responses to those comments. The

responsiveness summary is a key part of the
ROD. highlighting community concerns for EPA

decision-makers.

Superfund: The common name used for the
Comprehetisive F.m ironmenial Response.
Compensation and Liability Act of 1980
(CERCEA). the federal law that mandates
cleanup of abandoned hazardous waste sites.

TEQ: Toxic Equivalents for 2. 3, 7. 8-
Tetrachlorodiben/.o-pdioxin (TCDD). Since
there are multiple dioxins and furans with
different toxic effects, so concentrations of the
different dioxins and furans detected are
weighted according to toxicity and collectively
added to determine the TEQ.

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AVMSTON PCH SUPEREVSD SITE PI BMC COMMENT SHEET

Your input on the Proposed Plan for the Anniston PC B Superfund Site is important in helping EPA
select a remedy for the Site. You may use the space below to write your comments, then fold and mail,
or deliver to EPA \ Public Outreach Office at 902 .\oble Street, Anniston, Alabama. .1 response to
your comment will be included in the Responsiveness Summary.

Name

Address

City

State and Zip

Comment:

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Name
Address
State

Stamp
Here

Pain Scully. Remedial Project Manager
U. S. 1 PA. Region 4
Super fund Remedial Branch
61 Forsyth Si.. SW
Atlanta, GA 30303

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