SIXTH FIVE-YEAR REVIEW REPORT FOR
MALLORY CAPACITOR COMPANY SUPERFUND SITE
WAYNESBORO, WAYNE COUNTY, TENNESSEE
&EPA
SEPTEMBER 2023
Prepared by
U.S. Environmental Protection Agency
Region 4
Atlanta, Georgia
RANDALL Digitally signed by RANDALL
CHAFFINS
CHAFFINS Date: 2023.09.27 09:08:54 -04'00'
Caroline Y. Freeman, Director
Superfund & Emergency Management Division
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TABLE OF CONTENTS
LIST 01 ABBREVIATIONS & ACRONYMS iii
I. INTRODUCTION 1
Site Background 1
FIVE-YEAR REVIEW SUMMARY FORM 2
II. RESPONSE ACTION SUMMARY 3
Basis for Taking Action 3
Response Actions 4
Status of Implementation 6
Systems Operations/Operation and Maintenance (O&M) 9
Institutional Controls 11
III. PROGRESS SINCE THE LAST REVIEW 14
O&M Reporting 15
IV. FIVE-YEAR REVIEW PROCESS 16
Community Notification, Involvement & Site Interviews 16
Data Review 16
Site Inspection 23
V. TECHNICAL ASSESSMENT 24
QUESTION A: Is the remedy functioning as intended by the decision documents? 24
QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels and RAOs used at the
time of the remedy selection still valid? 25
QUESTION C: Has any other information come to light that could call into question the
protectiveness of the remedy? 25
VI. ISSUES/RECOMMENDATIONS 25
OTHER FINDINGS 27
VII. PROTECTIVENESS STATEMENT 27
VIII. NEXT REVIEW 28
APPENDIX A - REFERENCE LIST A-l
APPENDIX B - CURRENT SITE STATUS B-l
APPENDIX C - SITE CHRONOLOGY C-l
APPENDIX D - SITE BACKGROUND D-l
APPENDIX E - DATA REVIEW TABLES AND FIGURES E-l
APPENDIX F - COMPARISON OF TOXICITY FACTORS 1-1
APPENDIX G - SITE INSPECTION CHECKLIST G-l
APPENDIX H - SITE INSPECTION PHOTOGRAPHS 11-1
APPENDIX I - INSTITUTIONAL CONTROLS 1-1
APPENDIX J - PRESS NOTICE J-l
APPENDIX K - INTERVIEW FORMS K-l
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TABLES
Table 1: 1991 ROD Remediation Goals for Groundwater 5
Table 2: 1991 ROD Remediation Goals for Surface Water 6
Table 3: Annual O&M Costs (rounded to nearest $1,000) 11
Table 4: Summary of Institutional Controls (ICs) 12
Table 5A: Protectiveness Determinations/Statement from the 2018 FYR 14
Table 6: Site Chronology C-l
Table 7: PCB, TCE and cis-DCE Concentrations in Select Shallow Bedrock Monitoring Wells E-9
Table 8: PCB, TCE, and cis-DCE Concentrations in Select Deep Bedrock Monitoring Wells E-14
Table 9: PCB and TCE Concentrations in Select Deeper Bedrock Monitoring Wells E-19
Table 10: cis-DCE Concentrations in Select Deeper Bedrock Monitoring Wells E-22
Table 11: Mass Removal Estimates Since the 2018 FYR E-24
Table 12: Mass Removal Summary (pounds) E-26
Table 13: TCE and cis-DCE soil gas concentrations (|ig/m3) E-28
Table 14: TCE indoor air and crawl space air concentrations (|ig/m3) E-29
FIGURES
Figure 1: Site Location Map E-l
Figure 2: Site Layout E-2
Figure 3: Shallow Bedrock Potentiometric Surface Map E-3
Figure 4: Deep Bedrock Potentiometric Surface Map E-4
Figure 5: Deeper Bedrock Potentiometric Surface Map E-5
Figure 6: Extent of PCBs and VOCs above MCLs, Shallow Bedrock - 2022 E-6
Figure 7: Extent of PCBs and VOCs above MCLs, Deep Bedrock - 2022 E-7
Figure 8: Extent of PCBs and VOCs above MCLs, Deeper Bedrock - 2022 E-8
Figure 9: PCB Concentrations Shallow Bedrock E-10
Figure 10: TCE Concentrations Shallow Bedrock E-ll
Figure 11: cis-DCE Concentrations Shallow Bedrock E-12
Figure 12: Monitoring Well OW37-89 PCB, TCE and cis-DCE Concentrations E-13
Figure 13: PCB Concentrations Deep Bedrock E-l5
Figure 14: TCE Concentrations Deep Bedrock E-l6
Figure 15: cis-DCE Concentrations Deep Bedrock E-l7
Figure 16: Monitoring Well OW38-89 PCB, TCE and cis-DCE Concentrations E-18
Figure 17: PCB Concentrations Deeper Bedrock E-20
Figure 18: TCE Concentrations Deeper Bedrock E-21
Figure 19: cis-DCE Concentrations Deeper Bedrock E-23
Figure 20: Annual Mass Removed E-26
Figure 21: Vapor Intrusion Assessment 2022-2023 - Soil Gas Boring Locations E-27
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LIST OF ABBREVIATIONS & ACRONYMS
Mg/kg
Micrograms per Kilogram
l-ig/L
Micrograms per Liter
ARAR
Applicable or Relevant and Appropriate Requirement
bgs
Below Ground Surface
BPI
Battery Properties, Inc.
CERCLA
Comprehensive Environmental Response, Compensation, and Liability Act
CFR
Code of Federal Regulations
COC
Contaminant of Concern
CRA
Conestoga-Rovers and Associates
DCE
Dichloroethylene (1,2- includes cis- and trans-)
Duracell
Duracell International, Inc.
Emhart
Emhart Industries, Inc.
EPA
United States Environmental Protection Agency
ESV
Ecological Screening Value
FYR
Five-Year Review
gpm
Gallons per Minute
GHD
GHD Group
IC/EC
Institutional Control/Engineering Control
IRIS
Integrated Risk Information System
Mallory
Mallory Capacitor Company
MCL
Maximum Contaminant Level
mg/kg
Milligrams per Kilogram
MNA
Monitored Natural Attenuation
MS/MSD
Matrix Spike/Matrix Spike Duplicate
NAPL
Non-Aqueous Phase Liquid
NCP
National Oil and Hazardous Substances Pollution Contingency Plan
NPL
National Priorities List
NLUR
Notice of Land Use Restrictions
O&M
Operation and Maintenance
OU
Operable Unit
PCB
Polychlorinated biphenyl
PPm
Part per Million
PRP
Potentially Responsible Party
QA/QC
Quality Assurance and Quality Control
QPR
Quarterly Progress Report
RAO
Remedial Action Objectives
RfD
Reference Dose
RI/FS
Remedial Investigation/Feasibility Study
ROD
Record of Decision
RPD
Relative Percent Difference
RPM
Remedial Project Manager
RSV
Refinement Screening Value
TBC
To Be Considered
TCE
T richloroethylene
TDEC-DoR
Tennessee Department of Environment and Conservation-Division of Remediation
TPY
Tons per Year
UAO
Unilateral Administrative Order
VI
Vapor Intrusion
VISL
Vapor Intrusion Screening Level Calculator
VOC
Volatile Organic Compound
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I. INTRODUCTION
The purpose of a Five-Year Review (FYR) is to evaluate the implementation and performance of a
remedy in order to determine if the remedy is and will continue to be protective of human health and the
environment. FYR reports, such as this one, document the methods, findings, and conclusions from
reviews of current site conditions, land use and toxicological factors. In addition, FYR reports identify
issues found during the review, if any, and document recommendations to address them.
The U.S. Environmental Protection Agency prepared this FYR pursuant to the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA) Section 121, consistent with the
National Contingency Plan (NCP) (40 CFR Section 300.430(f)(4)(h)), and considering EPA policy.
This is the sixth FYR for the Mallory Capacitor Company Superfund Site (the Site). The triggering
action for this statutory review is the previous FYR. The FYR has been prepared because hazardous
substances, pollutants, or contaminants remain at the Site above levels that allow for unlimited use and
unrestricted exposure (UU/UE).
The Site consists of a single Site-wide operable unit (OU) that is the subject of this FYR; the remedies
performed within the OU addressed contaminated soils and groundwater.
EPA Remedial Project Manager (RPM), Amanda Howell led the FYR. Participants included: James
Ferreira, the EPA hydrologist; Kevin Koporec, the EPA risk assessor; Caroline Philson, the EPA
attorney-advisor; Zariah Lewis, the EPA Community Involvement Coordinator; John Hoffelt, the
Tennessee Department of Environment and Conservation-Division of Remediation (TDEC-DoR) project
manager; Kevin Kyrias-Gann, Battery Properties, Inc. (BPI); and Winston Guidry, GHD Group (GHD).
The review began on October 6, 2022.
Site Background
The Site is located 0.2 miles southeast of the center of Waynesboro (Wayne County Courthouse), in
Wayne County, Tennessee - about 80 miles southwest of Nashville, Tennessee (see Appendix E,
Figure 1). Figure 2 in Appendix E provides a Site layout, including the locations of the extraction and
monitoring wells and the surface water monitoring locations. The Site address is Belew Circle,
Waynesboro, Tennessee, 38485. BPI owns the property; the parcel number is 077G F 001.00.
The property is unfenced; however, a solid-wood privacy fence encloses an area next to the former
warehouse. The vapor phase carbon absorption units (air emissions treatment) for groundwater treatment
off-gasses sit inside the enclosed area. According to the 2020 census, about 2,320 people live within one
mile of the Site, and multiple businesses and commercial properties are within this area. Municipal
water is available to the area residents and businesses; The City of Waynesboro enacted an ordinance
prohibiting groundwater withdrawal in the Site vicinity (see Appendix I).
The Mallory Capacitor Company (Mallory) manufactured electrical capacitors from 1969 until 1984 in
the City of Waynesboro, Wayne County, Tennessee. The former Mallory facility consists of an 8.6-acre
vacant industrial parcel situated along the west bank of the Green River. The only building on the
facility parcel is a former warehouse that now houses the groundwater remediation treatment system.
Surrounding land uses include residential and commercial properties.
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The manufacturing process for the capacitors occurred in a former manufacturing building and involved
impregnating the capacitors with dielectric fluid containing polychlorinated biphenyls (PCBs) or dioctyl
phthalate. Mallory drained the unused dielectric fluid from the impregnation chambers, treated the fluid
to remove impurities, and then recycled the dielectric fluid for reuse. The impregnated capacitors then
underwent a degreasing process using trichloroethylene (TCE). The manufacturing facility ceased
operations in July 1984 and remained inactive with little maintenance effort until Duracell International,
Inc. (Duracell - owner of the site) disassembled and removed the manufacturing building in 1988 and
1989.
During production of capacitors, Mallory released contaminants to the environment through spills and
discharges while removing the fluid-filled capacitors from the impregnation chambers. Mallory
collected spilled dielectric fluid in troughs in the building floor and transferred the fluid to a
4,000-gallon underground storage tank, which leaked. Other sources of contamination included leaking
drums of liquids and sludge stored in a below-grade storage room. The media impacted from releases at
the Site include facility structures, soil, groundwater, surface water and sediment. Primary contaminants
of concern include PCBs and volatile organic compounds (principally TCE).
Appendix A includes documents reviewed as part of this FYR. Appendix B includes the EPA's site
status information. Appendix C provides the Site's chronology of events.
FIVE-YEAR REVIEW SUMMARY FORM
SITE IDENTIFICATION
Site Name:
Mallory Capacitor Company
EPA ID:
TND 075 453 688
Region: 4
State: TN
City/County: Waynesboro/Wayne County
SITE STATUS
NPL Status: Final
Multiple OUs?
No
Has the site achieved construction completion?
Yes
REVIEW STATUS
Lead agency: EPA
Author name: Amanda Howell (EPA) and John Hoffelt (TDEC-DoR)
Author affiliation: U.S. EPA and TDEC-DoR
Review period: 10/1/2022 - 9/15/2023
Date of site inspection: 11/16/2022
Type of review: Statutory
Review number: 6
Triggering action date: 9/18/2018
Due date (fiveyears after triggering action date): 9/18/2023
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II. RESPONSE ACTION SUMMARY
Basis for Taking Action
The EPA placed the Site on the National Priorities List (NPL) on October 4, 1989. Several removal
actions completed by Duracell prior to NPL listing demonstrated Site impacts from releases of PCBs
and chlorinated solvents. Commencing in 1969, the Mallory Capacitor Company began to manufacture
electrical capacitors at the Site. In early 1979, Dart Industries, Inc. acquired Mallory and sold the
Waynesboro facility to Emhart Industries, Inc. (Emhart). As part of the sales agreement with Emhart,
Mallory removed certain PCB wastes from the Site as initial response actions. In 1980, Mallory's name
changed to Duracell International, Inc. Litigation ensued between Emhart and Duracell from 1985 to
1988 over PCB liability. In 1988, Duracell's parent corporation formed a separate subsidiary, BPI, to
assume ownership of the Site with all associated liability. The following section describes the initial
response actions taken by Mallory and Duracell.
Mallory conducted the following activities between 1976 and 1980:
Disposal of still bottoms containing PCBs
Drainage of vacuum pumps
Disposal of pump oils containing PCBs
Implementation of a pilot program for cleaning plant equipment
Removal of 80 drums of liquids and sludge from a below-grade storage room, followed
by backfilling the storage room with cherty clay to within one foot of the ceiling, then
capping the filled room with a concrete slab
Removal of a (leaky) 4,000-gallon underground storage tank used for storing dielectric
fluid liquid wastes
Excavation of contaminated soils adjacent to the leaking underground storage tank,
followed by lining, backfilling and capping with concrete the entire former tank area
After signing an Administrative Order on Consent with EPA dated February 18, 1988, Duracell
completed the following removal activities in January 1989:
Cleaning and disposal of equipment within the plant, exclusive of equipment located
within the impregnation room of the plant
Cleaning and disposal of stock within the plant
Demolition and removal of the impregnation room, including annexed building and all
equipment contained therein, and the plant's air handling systems
Excavation to the depth of bedrock, followed by offsite disposal, of soil contaminated
with PCBs at concentrations greater than 10 milligrams per kilogram (mg/kg) that were
located south of the plant
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Cleaning of floor, wall, ceiling and overhead surfaces within the remaining portions of
the facility
Restoration of the Site by backfilling all excavations, placing topsoil and seeding
Regrading soils from beneath the former plant and using soil with PCBs less than 10
mg/kg as backfill
Complete excavation backfilling with clean imported soil
Removal of soil containing PCBs at concentrations in excess of 10 mg/kg at one isolated
location in the grassy area adjacent to the Green River
Removal of sediments containing PCBs in one sanitary sewer manhole located on the
facility property
Confirmatory soil samples showed concentrations of PCBs ranging from 12 to 270 mg/kg near the
former boiler and impregnation rooms of the plant and south of the southeast corner of the plant,
exceeding the on-Site removal action criterion of 10 mg/kg. However, because this contamination at
bedrock was below the water table present in the excavation and overlain by as much as 10 feet of clean
soils, Duracell left the contaminated bedrock soils in place.
Duracell completed a Remedial Investigation/Feasibility Study (RI/FS) in August 1991. The RI
characterized the nature and extent of human and environmental health risks associated with residual
contamination present in soil, groundwater, surface water and sediment. The results indicated that
groundwater in both the shallow and deep bedrock aquifers required remedial action due to unacceptable
human health risks associated with potable use of the groundwater. The Contaminants of Concern
(COC) for groundwater and surface water include PCBs and TCE, with the TCE degradation byproduct
1,2-dichloroethylene, which includes two isomers known as cis-l,2-dichloroethylene (cis-DCE) and
trans-1,2-dichloroethylene (trans-DCE).
Response Actions
Following completion of the RI/FS, EPA signed the ROD on August 29, 1991, to address contamination
on- and off- the facility property in the shallow and deep bedrock aquifers. The FS listed the following
Remedial Action Objectives (RAO):
Prevent human exposure to groundwater contaminated with chlorinated volatile organic
compounds (VOC) and PCBs
Prevent or mitigate the migration of site-related contaminated groundwater, both on the
facility property and hydraulically downgradient from the facility property
Monitor groundwater and surface water in a manner to verify the effectiveness of
remedial measures
The 1991 ROD included the following remedy components:
Installation of groundwater extraction wells in a phased approach (e.g., initially install
five wells at hot spots on facility property, followed in one year by the installation of up
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to nine additional wells at the outer edge of the contaminant plume for groundwater
containment and additional contaminant removal - EPA later modified this approach due
to the potential to draw contaminants toward the outer edge of the plume containment
area)
Pumping collected water for on-Site treatment of TCE and TCE-degradation products
using air stripping, bag filtration and carbon adsorption
Discharge of treated groundwater to the Green River or the local water treatment plant
Investigations to better determine northern extent of off-Site groundwater contamination
Investigations to determine possible impacts to Cold Water Creek
Placing deed restrictions on the Site properties' title to identify the presence of PCBs,
1,2-DCE and TCE, and to prevent the installation of groundwater extraction wells on
properties within the zone of groundwater contamination
• Effectiveness monitoring
Contingency measures: if it is determined that certain portions of the aquifer cannot be
restored to beneficial use for any one of the COCs, all of the following measures
involving long-term management may occur1:
¦ Engineering controls such as physical barriers or long-term gradient control by
low-level pumping
¦ Waiver of chemical-specific ARARs for those portions of the aquifer based on the
technical impracticability of achieving further contaminant reduction
¦ Institutional controls to restrict access to those portions of the aquifer that remain
above remediation goals for any of the COCs
¦ Continued monitoring of specific wells
¦ Periodic re-evaluation of remedial technologies for groundwater restoration
Table 1 provides the remediation goals for groundwater; Table 2 provides the remediation goals for
surface water.
Table 1: 1991 ROD Remediation Goals for Groundwater
Chemical of Concern
Remediation Goal
(micrograms per liter - ng/L)a
Dichloroethylene, cis-1,2- (cis-DCE)
70
Dichloroethylene, tran-1,2- (trans-DCE)
100
Polychlorinated biphenyls (PCBs)
0.5b
Trichloroethylene (TCE)
5
Notes:
1 According to the 1991 ROD, if any of the contingency measures are warranted, an Explanation of Significant Differences or
a ROD Amendment will be required.
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a = Safe Drinking Water Act 40 CFR 141, Primary Drinking Water standards listed in the EPA
1991 ROD
b = According to the 1991 ROD, because of the infeasibility of removing sufficient amounts of
PCBs from the aquifer for treatment, none of the alternatives are estimated to comply with the
Primary Drinking Water standard for PCBs.
Table 2: 1991 ROD Remediation Goals for Surface Water
Remediation Goal (jig/L)"
Chemical of Concern
Discharge Pipe Effluent Limits
Green River
Maximum Allowable
Continuous Discharge
Ingestion of Fish and
Drinking Water River
Total 1,2-
Dichloroethylenes (sum
of cis-DCE and trans-
DCE)
3,030
303
0.057
Polychlorinated
biphenyls (PCBs)
0.2
0.014
0.00079
Trichloroethylene (TCE)
NAb
NA
2.7
•totes:
a = The EPA Ambient Water Quality Criteria for PCBs, TCE and cis- and trans-DCE as listed in the 1991 ROD.
b = Not Available, as criteria not established at time EPA published the 1991 ROD.
(ig/L = micrograms per liter
Status of Implementation
Duracell (or its subsidiary BPI) conducted remedial activities in phases, including a Phase I and a
Phase II. Under the Unilateral Administrative Order issued by EPA on March 16, 1992, BPI
undertook groundwater remediation at the Site. BPI started the remedial design for Phase I on
March 30, 1992 and completed the remedial design on June 8, 1993. The remedial action activities
included the following:
Installation and operation of five on-Site groundwater extraction wells
¦ Construction and operation of an on-Site groundwater treatment facility with
effluent discharged to the Green River
¦ Implementation of an effectiveness monitoring program consisting of
hydraulic and groundwater quality monitoring in the shallow, deep and deeper
bedrock aquifers; and surface water quality monitoring in the Green River and
Cold Water Creek.
After collecting hydraulic and analytical data for one year, BPI, in February 1995, recommended
maximizing the on-Site extraction system and increasing the groundwater treatment system pump
rate. The EPA approved the modifications with additional recommendations on March 13, 1995.
The Phase II remedial action construction began on October 9, 1995. Startup of the revised systems
occurred on December 7, 1995, and included the following:
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Maximizing the pumping rates of all five on-Site extraction wells
Increasing the capacity of the on-Site groundwater treatment system
Providing pretreatment to groundwater extracted from extraction well EW-5 to
address elevated PCB concentrations attributed to the dense non-aqueous phase
liquid present in the well during the Phase I remedial action
Deepen extraction well EW-2 from 35 feet to 100 feet below ground surface to
increase drawdown at this well due to increased pumping rate
Installation of two additional downgradient shallow bedrock piezometers north of the
Site to define hydraulic containment in this region
In August 1996, BPI recommended modifications to the system following a 6-month data
collection period. BPI identified that the hydraulic head differentials from the deeper bedrock to the
deep bedrock that existed under non-pumping conditions, reversed during pumping, likely causing
the increased concentrations of site-related contaminants observed in the deeper bedrock. The EPA
approved the modifications on August 16, 1996. The modifications occurred in a two-stage process.
BPI conducted Stage I between September 1996 and mid-February 1997. These actions included
the following:
Temporarily sealing the bottoms of extraction wells EW-2, EW-3 and EW-5 with
inflatable packers as a stopgap action to remove the potential for downward
migration through the well bore
Permanently grouting the bottom portions of these extraction wells
Optimizing the extraction well pumping rates to reduce, or reverse, the downward
vertical hydraulic gradients from the deep to the deeper bedrock
For the Stage II modifications, BPI performed the same actions as Stage I on extraction wells EW-1
and EW-4 between mid-February to September 1997.
The EPA completed the Preliminary Closeout Report on September 24, 1996, verifying completion
of the physical construction for the remedy.
In September 1997, the EPA and the TDEC-DoR raised concerns that (1) karst features in the
bedrock beneath the Site may influence groundwater flow and contaminant migration from the Site;
and (2) the RI did not provide delineation of contamination in the northern portion of the Site in the
deep and deeper bedrock aquifers. The EPA and TDEC-DoR approved the Stage II modifications
on March 11, 1998, with the following conditions:
Conduct a karst hydrogeologic assessment with the Site vicinity to include a dye
tracer study
Defer the recommendation to install monitoring wells OW-68 (deep bedrock) and
OW-69 (deeper bedrock) until the completion of the karst hydrogeologic assessment
Initiate confirmatory groundwater quality sampling at the time of the karst
hydrogeologic assessment to evaluate the need for additional monitoring wells
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BPI completed the karst investigation on May 1, 1998. The investigation did not identify significant
karst features in the immediate Site vicinity; however, BPI could not conclude with certainty
whether karst features influence groundwater flow beneath the Site. As a result, BPI proposed on
May 11, 1998, to conduct a dye tracer study, which the EPA and the TDEC-DoR subsequently
approved. BPI completed the tracer study on October 23, 1998, concluding that bedrock beneath
the Site is not highly karstic and that karst features may not significantly influence groundwater
flow.
Due to the observed presence of non-aqueous phase liquids in the sampling port of extraction well
EW-3 and the detected PCB concentrations in water samples collected from extraction well EW-4,
BPI modified the treatment system in September 2000. BPI connected extraction wells EW-3 and
EW-4 to the PCB treatment stream, along with the addition of two primary resin filtration units and
two secondary resin filtration units to the filtration train.
The EPA requested that BPI install six additional monitoring wells north of the facility property.
These monitoring wells consisted of the following designations: OW68-01, OW69-01, OW70-01,
OW71-01, OW72-01 and OW73-01. BPI performed this work between September 7, 2001, and
October 1, 2001. On January 9, 2002, North Wind Environmental conducted an independent
performance review of the monitoring results for the new well installations and provided the
following recommendations:
Add existing monitoring wells to the groundwater quality monitoring network
Install a new downgradient (off facility property) shallow/deep/deeper bedrock
monitoring well nest about mid-way between existing shallow bedrock monitoring
wells OW58-90 and OW59-90
BPI completed an assessment of the monitoring network from 2003 to 2004, resulting in the addition of
deep bedrock monitoring wells OW26-89 and OW52-89 to the annual monitoring event to monitor the
extent of PCBs and VOCs in groundwater to the east and north of the facility property. Sampling on a
five-year frequency of the shallow bedrock monitoring well OW50-89 and the deep bedrock monitoring
well OW42-89 was also recommended to better evaluate source area concentration on the facility
property.
BPI conducted a vapor intrusion (VI) evaluation at the Site from 2004 to 2005 at the request of the EPA
and results were reported to EPA in May 2005. Soil gas samples were collected on the facility property
where the maximum VOC concentrations occurred in shallow groundwater.
In November 2007, BPI installed three additional off-Site groundwater monitoring wells north of the
facility property to further define the extent of the aqueous phase PCBs and VOCs, including one
shallow bedrock monitoring well (OW74-07), one deep bedrock monitoring well (OW75-07) and one
deeper bedrock monitoring well (OW76-07).
In April 2008, BPI submitted a Monitored Natural Attenuation (MNA) Evaluation report to the EPA and
demonstrated that natural attenuation processes, and in particular biodegradation, are active at the Site
and are facilitating some reduction in the COC concentrations in groundwater both on-Site and
downgradient from the Site.
On September 19, 2008, the EPA requested three additional Green River surface water sampling
locations to the surface water monitoring program, including two downgradient from monitoring wells
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OW27-89 and OW59-90, and the third opposite monitoring well OW65-92, for a total of six surface
water sampling locations (G1 through G6). BPI and the EPA use the analytical data from these sampling
stations to assess contaminant migration through groundwater discharge to surface water during high
water table conditions. Since inclusion of the six stations in the surface water monitoring program, the
analytical results show that the Site COCs remain at or below the limits of detection. For the reporting
period covered by this FYR, the reporting limit for PCBs in surface water ranged between 0.48 |ig/L and
0.63 |ig/L; the reporting limit for VOCs in water is 1.0 |ig/L. (Note that these reporting limits are
higher than the Remediation Goals for Surface Water - see Table 2).
On June 24, 2009, the EPA prepared an Addendum to the 2008 FYR (FYR Addendum), because the
EPA previously deferred the protectiveness statement in the 2008 FYR until resolution of risk-related
questions regarding the exposure assumptions, PCBs toxicity data, and the methodology to calculate the
exposure point concentrations. The FYR Addendum indicated that the remedy is protective in the short
term; however, the FYR Addendum recommended additional actions to ensure the groundwater remedy
will be protective in the long term. The additional remedial actions recommended included
implementation of institutional controls (IC) and collection of additional groundwater data to verify
long-term protectiveness. BPI is currently conducting annual surface water and groundwater sampling
and analysis at the Site to quantify and verify the long-term protectiveness of the remedial actions, and
ICs are now in place for Site properties.
On August 17, 2011, BPI filed a notice of land use restrictions (NLUR) on the deed for the facility
property to restrict uses of the property for industrial purposes, only. Restrictions also prohibit extraction
and use of groundwater except for remediation purposes, and the restrictions prohibit land disturbance of
the Site and associated remedial equipment. Appendix I provides the NLUR for the facility property.
In May 2014, the City of Waynesboro enacted an ordinance to prohibit withdrawal and use of
groundwater within the portion of the city identified as potentially impacted by the Site. In addition, the
ordinance requires plugging and abandonment of any existing wells (or conversion to monitoring wells)
within the identified area. Appendix I provides the ordinance.
The EPA published an updated toxicological assessment for Trichloroethylene (TCE) in the Integrated
Risk Information System (IRIS) database in 2011. Additionally in 2015, the EPA finalized the VI
guidance (EPA 2015). In July 2018, the Fifth Five Year Review recommended that BPI continue plans
to conduct another VI investigation under the 2015 EPA guidance methodology to supplement the data
from the 2005 VI investigation.
In 2022, the EPA approved the Work Plan for Updated VI Assessment and the Quality Assurance
Project Plan and GHD collected soil gas samples in November 2022. Based on the results, GHD
collected additional soil gas samples in February 2023. Indoor air, crawl space air and additional soil gas
samples were also collected in April and May 2023. The VI Assessment is ongoing at the time of this
report.
Systems Operations/Operation and Maintenance (O&M)
The EPA approved the Operations, Maintenance and Monitoring Plan (O&M Plan) on June 7, 1996.
Remedial construction activities included the construction and commissioning of three main systems:
groundwater extraction system; groundwater treatment system and treated water discharge system.
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The remedial design for groundwater treatment provides for either of two (2) treatment streams for
the recovered groundwater. The first treatment stream addresses PCB contamination and consists of
air stripping, oil-water separation, bag filtration, polymeric resin adsorption and activated carbon
adsorption. The second treatment stream addresses YOC contamination and consists of air
stripping, bag filtration and activated carbon adsorption. An activated carbon adsorption unit
captures the off-gas emissions from the air strippers for treatment prior to release to the
atmosphere. BPI discharges the treated groundwater to the Green River along the eastern Site
boundary. Both air and water samples are collected from the effluents of the treatment system and
results are discussed further in Section IV.
During the 2018 - 2023 reporting period, BPI made no changes to the O&M Plan. In 2015, the
original remedial contractor (Conestoga-Rovers and Associates, Inc. - CRA) merged with GHD;
however, the personnel involved with Site remedial activities did not change. In 2021, the EPA
RPM retired, and the EPA named Amanda Howell as the new RPM. Also in 2021, the GHD Project
Manager left the company, and GHD named Winston Guidry as the new Project Manager.
Over the FYR period, the groundwater treatment system operated continuously except for brief
periods associated with system maintenance or unplanned shutdowns. Based on the reported run
times, the treatment system operated 97.4 percent of the time. In addition to routine filter and semi-
annual maintenance, the most common unplanned reasons for system shutdown include a high-
level alarm on the mix tank, pump and motor replacement, and power outages. (Individual
extraction wells automatically shut down if the water level lowers beneath a pre-set point, to allow
water levels to recover.)
Pump and motor replacement may be anticipated events, although not always planned; power
outages are uncommon and out of the control of the contractor. The remedial system flow-through
is a dynamic process coordinated between the pumping yield of the aquifer and the treatment rate
of the treatment system components. The high-level alarm on the mix tank allows for control of the
flow through the treatment system in periods of high aquifer yield.
As part of the performance monitoring of components within the remediation system, GHD collects
samples from various points within the treatment stream. Starting in February 2022, GHD detected
PCB breakthrough between the resin filtration units. (BPI installed the resin filtration units, and an
oil-water separator, in 1995 to reduce free-phase PCBs from Extraction Well EW-5, thus reducing
the PCB loading to the liquid-phase carbon vessels.) In July 2022, GHD detected breakthrough of
TCE and 1,2-DCE between the liquid-phase carbon vessels. These breakthroughs signaled the need
for change-out of the resin and liquid-phase carbon. However, the long-time supplier of the
filtration resin media is no longer in business; and, after considerable effort, GHD identified a new
vendor to supply a suitable replacement for the resin media.
GHD changed-out the resin and carbon media during the week of July 25, 2022. After change-out,
GHD did not detect any Site contaminants between the carbon filters, but GHD did detect low
levels of PCBs between the resin filtration units. These results confirm that the resin units are
removing a significant portion of the PCB mass and providing appropriate pretreatment of PCBs
ahead of the liquid phase carbon. The between system component locations will continue to be
monitored to determine when to change-out the liquid phase treatment media.
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In March 2020, GHD also replaced the liquid-phase carbon media, and at the same time, GHD
replaced the oil-water separator, which was showing signs of corrosion (rust) due to age. The oil-
water separator consisted of a custom-built carbon-steel tank. GHD contacted the original
fabricator of the remedial treatment system, who fabricated and installed an exact duplicate of the
original oil-water separator.
During the Site Inspection, the EPA noted that the as-built Process and Instrumentation Diagram
for the treatment system is outdated; in February 2023, GHD provided an updated Process and
Instrumentation Diagram and updated the O&M Manual in March 2023.
GHD provides quarterly reports that summarize maintenance activities and that provide operational
data, including intra-system monitoring and effluent monitoring. The Data Review portion of
Section IV herein (Five-Year Review Process) provides additional information taken from the
quarterly reports.
Table 3 summarizes the annual O&M costs for this FYR period. The highest costs occurred over
2022 due to the VI investigation, replacement of resin and carbon media, and subsequent waste
disposal. The ROD forecasted O&M costs of $80,000 per year and monitoring of $60,000 per year for a
total of $140,000 per year. As shown in Table 3, the O&M costs are substantially higher than estimated
in the ROD. The ROD cost estimate was based on the initial groundwater extraction and treatment
system, which anticipated a much lower groundwater recovery rate of five gallons per minute (gpm).
BPI upgraded the extraction and treatment systems to match the actual and much higher groundwater
extraction rate, which averages about 30 gpm, resulting in higher O&M costs. Additionally, BPI
expanded the monitoring network (monitoring wells and surface water locations) several times (from 24
locations to 44 locations), thus increasing the monitoring costs over those contemplated in the ROD.
e 3: Annual O&M Costs (roun<
led to nearest $1,000)
Date Range
Total Cost
January 2018 - December 2018
$379,000
January 2019 - December 2019
$410,000
January 2020 - December 2020
$421,000
January 2021 - December 2021
$355,000
January 2022 - December 2022
$457,000
Institutional Controls
BPI provides both Institutional Controls (IC) and Engineering Controls (EC) for the former facility
property, and the City of Waynesboro provides ICs for surrounding properties and in the
downgradient direction. The soil and groundwater ICs are required by decision documents. Vapor
intrusion ICs are not currently required by decision documents. The need for vapor intrusion ICs
will be determine once the ongoing Vapor Intrusion Assessment is completed. The IC documents
are provided in Appendix I and summarized in Table 4.
Former Facility Parcel. In 2011, BPI posted aNLUR (Instrument No. 59151) for the former facility
property, parcel No. 077G F 001.00. The NLUR is recorded in Record Book 139, Pages 518-536.
The NLUR prohibits (1) unrestricted use of the property; (2) installation of potable water wells and
access, extraction, or use of groundwater, except as authorized as part of the remediation system;
and (3) any activity that would interfere with the performance of the remedy called for in the ROD.
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The property owner must notify TDEC-DoR within 30 days of any transfer of ownership of the
property. The NLUR also notes (1) the Site COCs, (2) removal actions undertaken to dispose of
PCB-contaminated soil, and (3) the engineering controls constructed and operated as called for in
the ROD.
Waynesboro Groundwater Withdrawal Ordinance. In 2014, the City of Waynesboro enacted an
ordinance Title 14, Chapter 4 - Prohibition on Groundwater Withdrawals in Certain Areas. The
title of the ordinance is given as "Waynesboro Groundwater Withdrawal Ordinance." The
ordinance (1) identifies areas where groundwater withdrawal and use are prohibited, (2) prohibits
installation of new groundwater withdrawal wells and use of groundwater in the identified area, (3)
requires decommissioning of all existing groundwater withdrawal wells in the identified area, and
(4) prohibits the cross-connection of groundwater withdrawal wells in the identified area.
Appendix I provides the Waynesboro Groundwater Withdrawal Ordinance (including map and
legal description) showing the ordinance boundary. Measured from the former facility, the
ordinance boundary is situated 500 feet south (upgradient), 820 feet west (side gradient), 780 to
1,300 feet east (side gradient) and 2,110 feet north (downgradient). State of Tennessee well records
do not identify any water supply wells within the ordinance boundary; the only wells within the
ordinance boundary are wells associated with implementation of the remedy called for in the ROD.
Vapor Intrusion. In 2022, BPI conducted a Vapor Intrusion Assessment in the immediate area
surrounding the Site property. Based on TCE concentrations found in soil gas samples, indoor air
samples were collected. The indoor air samples collected reported TCE concentrations up to 3.5 |ig/m3
which exceeds the TCE residential action level for sensitive populations (2.1 |ig/m3 corresponds to a
HQ=1 for pregnant woman or a woman of child-bearing age). The Vapor Intrusion Assessment is
ongoing. More information about the assessment in provided in the Data Review Section under IV.
Five-Year Review Progress.
"able 4: Summa
ry of Instituti
Dnal Controls (ICs
Media
ICs Needed
ICs Called for in
the Decision
Documents
Impacted
Parcel(s)
IC Objective
Title of IC
Instrument
Implemented
and Date
Soil
Yes
Yes
077GF 001.00
Industrial Use
Only, No Land
Disturbing Activity
Notice of Land
Use Restriction
Instrument No.
59151 -8/4/2011
Groundwater
Yes
Yes
Facility Parcel:
007GF 001.00
Site Area:
Multiple Parcels
Prevent installation
of drinking water
wells and use of
groundwater
except as part of
approved remedial
actions
Facility Parcel:
Notice of Land
Use Restriction
Instrument No.
59151 -8/4/2011
Site Area:
Waynesboro
Groundwater
Withdrawal
Ordinance, Title
14 Chapter 4 -
5/30/2014
12
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Media
ICs Needed
ICs Called for in
the Decision
Documents
Impacted
Parcel(s)
IC Objective
Title of IC
Instrument
Implemented
and Date
Air
(Vapor Intrusion)
Yes
No
077G F011.001
Prevent human
exposure to
contaminated
indoor air
TBD
1 - More parcels may be identified during ongoing Vapor Intrusion Assessment
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III. PROGRESS SINCE THE LAST REVIEW
This section includes the protectiveness statement and issues from the last FYR, as well as the
recommendations from the last FYR and the current status of those recommendations. Table 5A
provides the Protectiveness Determination and Protectiveness Statement from the 2018 FYR.
Table 5A: Protectiveness Determinations/Statement from the 2018 FYR
ou#
Protectiveness Determination
Protectiveness Statement
Sitewide
Protective
The Site remedy protects human health and the
environment for the following reasons: (1) contaminated
soil and sediment were removed from the site down to
bedrock, (2) groundwater extraction prevents migration
of contaminated groundwater, and treatment of the
extracted groundwater destroys and removes the site
contaminants, and (3) institutional controls are in place
both on the facility property and within the site area to
prevent exposure to site contaminants.
The 2018 FYR did not identify any issues or recommendations other than to continue operation of
the groundwater extraction and treatment system. However, the 2018 FYR did provide the
following "Other Findings" that do not affect current or future protectiveness:
Continue operation of the groundwater extraction and treatment system as a source
control and mass removal mechanism.
BPI should follow-up with the planned VI investigation under the 2015 EPA guidance
methodology. This data will supplement the data from the 2005 VI investigation.
BPI should reconcile the Site Layout diagram with as-built locations for the extraction
and monitoring wells shown on the diagram.
The following provides updates for each Finding:
Operation of the groundwater extraction and treatment system. GHD, on behalf of BPI, continued
operation of the groundwater extraction and treatment system. Details of system efficacy and operation
are provided herein, and a technical evaluation of the system's performance is presented in Section IV.
VI Investigation. The 2020 COVID-19 pandemic affected the scheduling of the VI investigation;
however, BPI was able to initiate the investigation for consideration in this FYR. GHD, on behalf of
BPI, collected soil gas samples for the VI investigation in November 2022 and February 2023. Samples
were also collected in April and May 2023 that included residential indoor air, crawl space air and
additional soil gas samples. More details regarding the ongoing VI investigation are provided in Section
IV.
Reconciled Site Layout Diagram. During the 2018 FYR, TDEC-DoR noted that the Site Layout
Diagram did not accurately reflect the as-built locations for Site extraction and monitoring wells. As part
of the VI investigation activities, GHD surveyed all wells and soil gas monitoring points and created an
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updated Site Layout Diagram, included herein Figure 2.
O&M Reporting
Throughout each year, BPI provides several reports for various Site activities. These reports include an
Annual Progress Report, Quarterly Progress Reports, and an Annual Groundwater and Surface Water
Monitoring Report. Each report focuses on different aspects of the site remediation.
Annual Progress Reports. The Annual Progress Reports provide a listing of (1) tasks performed during
the previous year, including the other reports made to EPA and any non-routine issues or
communications that may arise, (2) tasks remaining to be performed, and (3) the project schedule. Over
this FYR period, no comments were generated, or issues noted, concerning the Annual Progress Reports.
Quarterly Progress Reports (QPR). Each quarter, BPI provides EPA with a report of Site remediation
and system monitoring activities. The reports are divided into seven sections, as follows: (1)
Groundwater Extraction and Treatment Systems Operation, Maintenance, and Monitoring; (2)
Groundwater Effectiveness Monitoring Program; (3) Green River Sediment Data; (4) Laboratory
Analytical Reports and Data Validation; (5) Submittals Completed This Reporting Period; (6) Activities
Scheduled for Next Reporting Period; and (7) Project Status. The quarterly reports provide the
substantive information for evaluating the extraction and treatment system performance, and QPRs 80 -
96 provide the data for evaluation of the treatment system in this FYR.
In Section 1 (Groundwater Extraction and Treatment Systems Operation), GHD provides extraction and
treatment system operational data including maintenance activities, extraction flow rates, and system run
times (with reasons for outages). GHD inspects the treatment system monthly for evidence of non-
aqueous phase liquid (NAPL) in the sump of air stripper No. 2; GHD reports that no NAPL was
observed during this FYR period. The section also provides a description of alterations (such as pump or
motor change-out) made to the system. Section 1 includes a narrative of in-stream and effluent sample
collection and resulting analytical data. The effluent data includes both air and water discharges.
Section 2 of the QPR (Groundwater Effectiveness Monitoring Program) provides a narrative and data
for hydraulic monitoring (water levels in the 5 extraction and 57 monitoring wells and from the Green
River) and for contaminant concentrations in the five extraction wells. From this data, GHD provides
quarterly potentiometric surface maps for the shallow, deep, and deeper water bearing zones, showing
the effects of pumping on the aquifer.
Section 3 (Green River Sediment Data) provides monthly analytical data for Green River sediment at the
effluent discharge pipe (15 feet north and 6 feet east from the end of the pipe). Due to the Green River in
flood stage, GHD was unable to collect a sediment sample in April 2019 and November 2019.
Section 4 of the QPR (Laboratory Analytical Reports and Data Validation) provides a summary of
quality assurance and quality control (QA/QC) measures taken to ensure and quantify the accuracy and
precision of the analytical data sets. The discussion includes the reasons for any data qualifications, such
as estimated values. In 2021, TDEC-DoR noted several issues regarding data quality, as discussed in
Section IV, herein below.
The remaining sections of the QPR identify (1) the submittals completed during the report period, (2)
the activities planned for the next report period, and (3) the project status as compared to the schedule
stipulated in the 1992 Unilateral Administrative Order (UAO).
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Annual Groundwater and Surface Water Sampling Results. In the annual report of groundwater and
surface water sampling and analysis, GHD provides (1) a brief narrative of sampling activities, (2) the
analytical data, and (3) a summary of QA/QC measures taken to ensure and quantify the accuracy and
precision of the analytical data set, including reasons for any data qualifications resulting from data
validation. GHD samples groundwater from 35 monitoring wells and surface water from nine locations
(6 on the Green River and 3 on Cold Water Creek). This FYR includes data from 2018 through 2022. In
2020 and 2021, TDEC-DoR noted data quality issues, as discussed in Section IV, herein below.
Section IV provides an in-depth evaluation of the analytical data with respect to clean-up and restoration
of the groundwater aquifer.
IV. FIVE-YEAR REVIEW PROCESS
Community Notification, Involvement & Site Interviews
The EPA issued an online news release on October 19, 2022, to announce that the FYR was underway.
A copy of the news release is included in Appendix J. The results of the review and the completed FYR
Report will be made available on EPA's site profile page: https://www.epa.gov/superfund/mallory-
capacitor. The EPA has copies of previous FYR documents along with decision documents associated
with this Site available for review in the designated site repository: Wayne County Public Library,
located at US 64 East, Waynesboro, Tennessee, 38485.
During the FYR process, three interviews were conducted to document any perceived problems or
successes with the remedy that has been implemented to date. Interviews were conducted via email with
the Amanda Howell, EPA RPM, John Hoffelt, TDEC RPM, and an O&M contractor via email. The
CIC, Zariah Lewis, attempted to conduct interviews with three community members that either did not
respond or did not want to participate in the interview.
Those interviewed have stated that contamination remains at the Site but the maintenance and
monitoring of the Site appear to be in good condition and working as expected. There have been
concerns with vapor intrusion in the surrounding area. While a temporary mitigation system has been
installed for impacted properties, more sampling is necessary to determine if vapor intrusion impacts
other parts of the neighborhood. The interviews are summarized below and included in Appendix K.
Data Review
On behalf of BPI, GHD performs several types of monitoring activities to evaluate the performance of
the groundwater extraction and treatment system. The monitoring activities include the following:
Groundwater Extraction and Treatment Systems Operation, Maintenance and Monitoring
Groundwater Effectiveness Monitoring
Sediment Monitoring
The following subsections provide a review of the data collected over this FYR period, including data
quality, as documented in Quarterly Progress Reports and Annual Groundwater and Surface Water
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Monitoring Reports. All additional tables (Tables 7-14) and all figures discussed in this section are
provided in Appendix E.
Data Quality. In the quarterly and annual reports, GHD provides an evaluation and assessment of data
quality. If any persistent or systemic data issues are discovered, corrective actions may be implemented
either in the field-sampling program or in the analytical laboratory.
Sampling and analysis of site PCBs can be challenging to meet standard quality control criteria. PCBs
are insoluble, and the contaminant molecules are not necessarily evenly distributed throughout the
aquifer or within the water column of a monitoring well. Thus, data for duplicate samples may be
indicative of anisotropic conditions within the aquifer but not meet standard relative percent difference
targets for precision.
Another challenge for Site PCB analyses concerns the PCB sample chromatogram, from decades-old
PCBs released to the environment. The sample chromatograms may be poor matches to the PCB
standard chromatogram. In such cases, the laboratory quantifies and reports the sample data using the
best overall Aroclor-standard pattern match relative to the reference standards. In addition, some
samples require a copper or tetrabutylammonium sulfite clean-up to reduce matrix interferences caused
by sulfur.
The following provides a synopsis of identified data issues over the FYR period:
Upon review of the Annual Groundwater and Surface Water Monitoring Report (dated April 8, 2020),
which provides results for samples collected in 2019, a low recovery was noted for cis-1,
2-Dichloroethylene in a matrix spike (MS) sample and again in a different matrix spike duplicate (MSD)
sample. GHD did not qualify the reported results because the accompanying MSD and MS samples were
within control limits, and the relative percent differences (RPD) were within control limits. In the same
report, the laboratory experienced solvent exchange issues that resulted in PCB data qualification due to
analysis of the samples outside of the required holding time.
Based on review of the QPRNo. 89 (dated April 16, 2021), quality control issues were noted for each of
the three (3) months covered by the report (January, February, and March 2021). For January, there the
MS/MSD data shows a high bias for the PCB Arocl or 1016; and the RPD was high. There was no
MS/MSD data provided for either VOCs or PCBs for the February sampling event. Also, there was no
MS/MSD data provided for VOCs for the March sampling event. Without site-specific MS/MSD data,
no evaluation of potential matrix interference to data accuracy is possible. In addition, it is unclear what
effect the high bias for Aroclor 1016 has on the January data set. Because of the concentrations and
nature (degraded PCBs) of the contaminants at the Mallory site, it is not uncommon to observe QC
issues in the analysis of field samples, such as potential matrix interference and RPD out of control
limits.
In the QPR No. 90, similar concerns were noted regarding quality control sampling and data reporting.
GHD did not provide any MS/MSD data for PCBs. In addition, no MS/MSD data for VOCs was
provided for the May 2021 sampling event. It is noteworthy that the reported data are either within the
recent ranges of the last four (4) quarterly reports or higher than this range of recent data. However, the
lack of the MS/MSD data indicates sampling or laboratory issues with these quality control samples
continuing from the previous QPRNo. 89. On August 14, 2021, GHD confirmed that going forward
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site-specific MS/MSD samples will be provided with each data set, with the expected frequency of 1 in
20, and that the data validation reports will be included in future reports.
The Annual Groundwater and Surface Water Monitoring Report (dated August 27, 2021), which
provides results for samples collected in 2020, revealed the following data quality issues:
The laboratory opened the volatile organic analysis (VOA) sample vial from monitoring well
OW37-89 to test for sample preservation. The report flags this VOA data as estimated and
potentially biased low due to sample volatilization when the vial was opened. The data user
should be aware in use of this VOA data for any trend analysis, that the data may not be
representative of the conditions in the monitoring well (the data is lower than expected based
on recent sampling events).
PCBs were found in an equipment rinsate blank sample at 34 jj.g/1. This affected the samples
from monitoring wells OW26-89, OW37-89, OW38-89, and OW50-89. Because of the
equipment blank contamination, the report considers PCB detections for these samples to be
"non-detect". However, the sample results from monitoring wells OW37-89 and OW50-89 are
greater than five times the blank sample (330 jj.g/1 and 570 jj.g/1, respectively). Therefore, these
detections are considered positive, but estimated, concentrations. It is also noted that these
concentrations are significantly lower than expected based on recent sampling events. Concern
was expressed over the presence of PCB contamination in the equipment rinsate blank sample,
especially at 34 jj.g/1. In 2019, PCBs were also reported in equipment rinsate blank samples;
although, the 2019 concentrations were 10 percent or less than the 2020 detection. To correct
this issue, GHD re-evaluated field decontamination and sampling procedures to reduce or
eliminate cross contamination as indicated by the equipment rinsate blank samples.
Groundwater Extraction and Treatment Systems Monitoring. Monitoring activities of the groundwater
extraction and treatment system includes checks and observations of various components and meters to
ensure the system is operating within the design parameters for each of the process components. GHD
monitors extraction well flow rates, and GHD alters the system to accommodate equipment maintenance
(e.g., filter change out). The system operated continuously except for short down times to complete
maintenance activities, as discussed in Section II, herein above.
Treated Water and Treatment System Components: GHD collects samples from within the treatment
system components and of the treated effluent water for analysis of PCBs, TCE, cis-DCE, trans-DCE
and vinyl chloride (VC). GHD uses this information to determine if the system is operating effectively
and whether any system maintenance is required. Based on the data, GHD addresses any breakthrough
of chemicals in the system by changing out the carbon in the adsorption unit and resin infiltration unit to
ensure compliance with the monitoring plan. As described in Section II, GHD changed the lead resin
filter and the liquid-phase carbon filter in 2022 to address breakthrough of site contaminants.
GHD collects monthly water discharge samples from the effluent pipe at the Green River. GHD reported
no detections in the water effluent of PCBs or TCE and related daughter products. The reporting limit
for the VOCs is 1.0 |ig/L, which meets the discharge limits provided in Table 2. However, the reporting
limit for PCBs typically ranges between 0.38 and 0.54 |ig/L, which fails to meet the concentrations in
Table 2. The Maximum Contaminant Level (MCL) and the Tennessee Water Quality Criteria for PCBs
is 0.5 |ig/l; however, the discharge limits set forth in the ROD, and provided in Table 2, are 0.2 jj.g/1
maximum allowable concentration in one (1) day and 0.014 jj.g/1 for continuous discharge. For the
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sample collected December 8, 2021, the laboratory reporting limit is 4.8 |ig/L, and for the sample
collected January 17, 2022, the reporting limit is 10.0 |ig/L.
Extraction Well Monitoring: GHD collects groundwater from the extraction wells (EW-1, EW-2, EW-3,
EW-4, and EW-5) for chemical analyses on a monthly basis to monitor the concentrations of PCBs,
TCE, cis-DCE, trans-DCE and VC, as well as field measurements of conductivity, pH and temperature.
In all monitoring conducted since the 2018 FYR, the predominant contaminants detected were TCE and
PCBs. Extraction well EW-3 usually contains the highest concentration of PCBs, and extraction well
EW-4 contains the highest concentration of TCE.
Vapor-phase carbon air emissions quality monitoring: The vapor-phase carbon emissions monitoring
consists of collecting TCE air emission measurements using a Sensidyne® detector tube system at
locations before, between and after the two vapor-phase carbon units. Since the 2018 FYR, these results
indicate that the vapor-phase carbon is effective in the removal of the TCE from the off-gas of the air
strippers and that the final air emissions are meeting the allowable discharge. In accordance with the
standard listed in the 1991 ROD, BPI is allowed discharge of 2 tons per year (TPY) of TCE from the air
emissions. The emitted air data ranges between less than 1 part per million (ppm) and 3 ppm. Based on
the flow rate, GHD calculates the emitted TCE mass associated with these concentrations range between
less than 0.09 TPY to 0.27 TPY. All air emissions were below the 2 TPY limit with 2019 the highest at
1.8 TPY.
Groundwater Effectiveness Monitoring. The groundwater effectiveness monitoring program consists of
quarterly hydraulic monitoring (groundwater potentiometric levels and surface water levels in the Green
River) and annual groundwater and surface water quality monitoring.
Hydraulic Monitoring: GHD monitors the hydraulic head (potentiometric surface) in Site monitoring
wells to ensure that the pumping action of the extraction wells contains the contaminated groundwater
plume from migrating downgradient or the surface water. Figures 3, 4, and 5 provide the hydraulic
contours for the shallow bedrock, deep bedrock, and deeper bedrock, respectively, from the October
2022 monitoring event. The figures indicate that the plume is contained within the zone of influence
created by the extraction wells.
Surface Water Monitoring: GHD collects surface water samples annually for analysis of PCBs, TCE,
cis-DCE, trans-DCE and VC to determine if contaminated groundwater is affecting the Green River and
Cold Water Creek. GHD collects the surface water samples from three locations along Cold Water
Creek and six locations along the Green River, which includes the three locations G4, G5 and G6 as
requested by the EPA on September 19, 2008. The sampling events conducted during this FYR period
indicate that PCBs and VOCs are not present in surface water at or above laboratory detection limits
(VOA =1.0 |ig/L; PCB = 0.48 to 0.63 |ig/L). However, the detection limits exceed the PCB surface
water discharge remedial goals presented in Table 2.
Sediment Quality Monitoring: GHD collects sediment samples monthly for analysis of PCBs from the
effluent pipe discharge area. GHD was unable to collect the sediment samples in April and November of
2019 because the Green River was in flood stage. The maximum concentration measured during this
FYR period (2018-2022) is 9,100 |ig/kg reported in November 2022. The average concentration over
this FYR period for PCBs in the sediment is 400.9 |ig/kg, with non-detect concentrations consisting of
69 percent of the samples. The reporting limit for the non-detects range between 16 and 73 |ig/kg. Note
the average (arithmetic mean) was calculated using one-half of the reporting limit value for all
19
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non-detect concentrations reported.
The Fifth FYR reported the maximum concentration measured was 2,000 ug/kg in October 2015 and the
average PCBs concentration over its FYR period (2013-2017) in the sediment was 168 |ig/kg. GHD
reports non-detect concentrations for 60 percent of the samples with the reporting limit for the sediment
samples ranges between 38 and 210 ug/kg. Note the average (arithmetic mean) was calculated using
one-half of the reporting limit value for all non-detect concentrations reported.
The 1991 ROD does not provide a remediation goal for sediment. In 2018, EPA Region 4 updated the
Ecological Risk Assessment Supplemental Guidance, which provides screening values for sediment.
The ecological screening value (ESV) provided for Step 2 of the Ecological Risk Assessment process is
59.8 ug/kg, and the refinement screening value (RSV) provided for Step 3 is 676 |ig/kg. Because GHD
collects the sediment sample each month from the same location at the end of the treated effluent
discharge pipe, the data reflects a worst-case scenario instead of an estimate of concentrations in
sediment bars within the riverbed. The PCB concentrations in the riverbed sediment bars is expected to
be less than what GHD collects at the discharge pipe due to dilution from the river flow and from
sediment accumulation from off-Site sources. It should be noted that the average concentration and the
maximum concentration were both reported higher during this FYR period than the last FYR period.
Groundwater Quality Monitoring: This data review focuses on clean-up and restoration of the bedrock
groundwater aquifer. For its monitoring program, BPI divides the aquifer into shallow, deep, and deeper
zones, and monitoring wells provide data for these zones on both the facility property and downgradient
of the facility. The shallow zone extends about 30 feet below ground surface (bgs); the deep zone
extends from 30 to 70 feet bgs, and the deeper zone extends from 70 to 100 feet bgs.
GHD collects groundwater samples from the monitoring network on an annual basis. Figure 2 illustrates
the layout of the monitoring network. Figures 6, 7, and 8 show the most current depiction of the PCB
and VOC plumes in the shallow, deep, and deeper bedrock zones. The groundwater-monitoring network
consists of two overburden-bedrock interface wells, 15 shallow bedrock wells, 13 deep bedrock wells,
and five (5) deeper bedrock wells. The analytical data and plume extent shown on the figures confirm
that groundwater impacts remain essentially as previously estimated, with overall contaminant
concentrations declining.
Shallow Bedrock: The highest concentrations of PCB, TCE, and cis-DCE (greater than 1,000 |ig/L) in
the shallow bedrock wells occur north of the former plant area in monitoring well OW37-89, as well as
in the former impregnation area of the plant in monitoring well OW50-89. Cis-DCE (a degradation
product of TCE) concentrations exceeded TCE in monitoring well OW37-89 during most annual
sampling events in this FYR period. In addition, high concentrations (greater than 1,000 |ig/L) of TCE
are detected downgradient consistently in monitoring well OW67-95, which is located about 150 feet
north of the former plant. TCE and its degradation products (cis-DCE, trans-DCE and VC) are at much
lower concentrations downgradient and towards the Green River. Table 7 provides the PCB, TCE and
cis-DCE concentrations over the current FYR period and historical five-year averages for the selected
shallow bedrock monitoring wells. Figure 6 depicts the concentrations reported in all shallow
groundwater monitoring wells sampled during the 2022 annual sampling event. The Figures 9-11 show
the PCB, TCE, and cis-DCE data graphically for the FYR period. Note the figures are presented in
logarithmic scale in order to display monitoring wells with significant different concentration results on
the same graph.
20
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Comparison of the data shows that the concentration of PCBs is more variable than TCE, with more
short-term increases and decreases. The PCB concentrations from OW50-89 and OW37-89 concordant
and appear to mimic each other. The variability of the PCB data set may be due in part to the difference
in solubilities: PCBs are considered insoluble and TCE is much more soluble. The result is that TCE
may be more evenly distributed throughout the aquifer than PCBs, with possible globules of PCBs being
recovered within any given sample as opposed to the dissolved phase TCE spread throughout the
aquifer. Another variable affecting concentration comparisons is the sample turbidity. Because organic
carbon partition coefficient for PCBs is higher than TCE, sediment particles in the sample may result in
higher PCB readings than the actual concentration in the groundwater (PCBs stick to sediment particles
more than TCE). Cis-DCE concentrations appear to be the most consistent little changes observed in the
past five years.
The variable nature of the data from year-to-year may be better evaluated in context over time. Figure 12
shows the change over time for PCBs, TCE, and cis-DCE in monitoring well OW37-89 (the well with
the complete data set). This evaluation uses the five-year average (arithmetic mean) concentration to
smooth-out the dynamic variability of individual samples to better identify the actual trend of
contamination over time. The data shows an overall decrease in PCB, TCE and cis-DCE contaminant
concentrations as compared to the initial data sets from 1993 to 1997.
Deep Bedrock: Historically, the highest concentrations of PCB and TCE in the deep bedrock wells occur
north of the former plant area in monitoring well OW38-89. However, equally high concentrations are
now detected in monitoring well OW52-89, downgradient and northeast of the former plant area
approximately 150 feet from the western bank of the Green River. Table 8 provides the data for these
wells. Figures 13-15 depict PCB, TCE and cis-DCE data for these wells. The PCB concentrations from
the two wells are concordant and seem to mimic each other, while the TCE and cis-DCE concentrations
appear discordant within the range of an order of magnitude.
Figure 16 depicts the change over time for PCBs, TCE, and cis-DCE in monitoring well OW38-89 (the
well with the complete data set). This evaluation uses the five-year average (arithmetic mean)
concentration to smooth-out the dynamic variability of individual samples to better identify the actual
trend of contamination over time. The data indicates an overall decrease in PCB and TCE concentrations
since monitoring began in 1993. However, cis-DCE concentrations appear to remain consistent
throughout the years. Note Figure 16 is presented in logarithmic scale in order to display monitoring
wells with significant different concentration results on the same graph.
Deeper Bedrock: The highest concentrations in the deeper bedrock are not as high as the concentrations
observed in the shallow or deep bedrock wells, with the highest concentrations of TCE consistently
detected near the source area in monitoring well OW62-90. The highest detections of PCBs are present
in monitoring well OW76-07, located downgradient 300 feet north of the former plant area. PCB
concentrations in OW76-90 appear to be increasing over the FYR period and appear to be similar to the
concentrations measured in 1990 when the well was installed. Over this FYR period, GHD did not
detect any TCE in monitoring well OW76-07; however, GHD reported cis-DCE ranging between 590
|ig/L and 640 |ig/L (see Table 10). Table 9 provides the PCB and TCE data for these monitoring wells.
Figure 17 graphs the PCB data for both monitoring wells, and Figure 18 graphs the TCE data for
monitoring well OW62-90.
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Unlike PCB and TCE, cis-DCE has been detected in all deeper bedrock monitoring wells exceeding the
concentration in Table 1, except for monitoring OW63-90 which located on the former facility's
property. Cis-DCE concentrations have also been more consistent than other COCs. Additionally,
cis-DCE concentrations in monitoring wells OW62-90, OW-76-07, and OW60-90, are very closer in
value considering the varying distances for the source area. Table 10 and Figure 19 present the cis-DCE
concentrations for these three wells since OW76-07 was installed in 2007.
In general, the groundwater analytical data shows declining concentrations for PCB, TCE and cis-DCE
in all sections of the aquifer when evaluated over time since the onset of remediation efforts. Over
shorter time intervals, the data frequently shows a high degree of variability. The variability may be due
in part to: (1) differences in the contaminant physical properties; (2) heterogeneity in turbidity of the
collected groundwater samples; and (3) changes in the aquifer related to the influence of the
groundwater extraction wells. Overall, the assessment of remedial actions supports the continued
implementation of groundwater extraction and treatment.
Contaminant Mass Removal Estimate. The contaminant mass removals achieved by the extraction wells
for PCBs TCE, and DCE are estimated on an annual basis using the average annual contaminant
concentrations detected in extraction well influent samples and the average annual extraction well flow
rates (both measured monthly). The Quarterly Progress Reports provide the measurements and
monitoring results as reported to EPA. Table 11 provides a summary of the mass removal estimates.
Based on the reported run times, flow rates, and contaminant concentration data, the system treated a
total of 6,410.3 pounds of PCBs, 393.9 pounds of TCE and 473.2 pounds of cis-DCE over the FYR
period. Mass removal estimates for cis-DCE have not been previously calculated during past FYRs.
However, comparing TCE to cis-DCE, more pounds of cis-DCE were consistently removed from the
groundwater during this FYR period.
The PCB estimate is surprising both in its magnitude and compared to the continued decline of TCE.
This again highlights the differences in contaminant characteristics between soluble TCE and insoluble
PCBs. The high PCB estimate is driven by a few exceptionally high detections from monthly monitoring
of Extraction Well EW-3. Over the FYR period, PCB concentrations in EW-3 ranged from 87 |ig/L to
1,800,000 |ig/L. Notably, GHD reported the following concentrations from EW-3: 1,800,000 |ig/L
April 2022, 360,000 |ig/L May 2021, 180,000 |ig/L February 2019, 150,000 |ig/L March 2022, and
130,000 |ig/L June 2019. These and other data points far exceed the historical range of the PCB data set
for not only EW-3, but for all extraction and monitoring wells. The PCB concentration fluctuations
observed in downgradient monitoring wells are much less than these orders of magnitude. It is possible
that EW-3 is now capturing PCB globules previously contained in the aquifer, such as within bedding
plane partings, with the sampling event coincidental to a high concentration slug passing through the
system.
In addition, extraction well EW-3 is more turbid than the other extraction wells, and the treatment
system uses an extra filter for the EW-3 influent. PCBs adsorb onto clay particles, and the higher
turbidity from EW-3 may account for the increased PCB concentrations measured. In concept, this may
support the indication that PCBs previously contained within bedding plane partings (which often
contain clay minerals and particles) are now being recovered by the extraction well.
TCE concentrations continue to decline as observed through previous FYRs. Table 12 provides a
synopsis of mass removed over five-year periods, and Figure 20 graphically shows the annual removed
mass for each year.
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BPI does not provide an estimate of contaminant mass remaining in the aquifer; and the downgradient
boundary of the plume may not be strictly defined. Groundwater monitoring data shows exceedances
over MCLs for chlorinated solvents (various combinations) in most of the boundary and downgradient
monitoring wells. However, the recovery trend and the monitoring concentrations suggest that the
remaining mass of the chlorinated solvents is much less (perhaps by 2 orders of magnitude) than what
has already been recovered and treated. In boundary and downgradient monitoring wells, PCB
concentrations appear to be decreasing in the overburden and shallow bedrock but increasing in the deep
bedrock and deeper bedrock monitoring wells.
Vapor Intrusion Assessment. BPI conducted a VI evaluation at the Site from 2004 to 2005 at the request
of the EPA and results were reported to EPA in May 2005. Soil gas samples were collected on the
facility property where the maximum VOC concentrations occurred in shallow groundwater. At that
time no unacceptable risks were estimated. In 2011, the EPA published an updated toxicological
assessment for TCE in the IRIS database. Additionally in 2015, the EPA finalized the VI guidance.
Considering the new VI guidance, the Fifth Five Year Review (2018) recommended that BPI conduct
another VI investigation under the 2015 EPA guidance methodology to supplement the data from the
2005 VI investigation. The 2020 COVID-19 pandemic affected the scheduling of the VI investigation.
However, in 2022 EPA approved the Work Plan for Updated VI Assessment and the Quality Assurance
Project Plan that considered both the 2015 VI guidance and the updated toxicological assessment of
TCE. Twelve soil gas boring locations were sampled in November based on shallow groundwater
concentrations and the calculated Vapor Intrusion Screening Levels (VISL). PCB was analyzed in four
borings and was not detected; detection limits were deemed adequate relative to risk-based levels.
Based on the TCE results, additional soil gas samples were collected in February and May 2023. Indoor
air samples and crawl space air samples were collected in April and May 2023 at the residential home
located on the same property as soil gas boring location GP14-23. The soil gas results for TCE and
cis-DCE concentrations are presented in Table 13, the air samples are presented in Table 14 and the soil
gas boring locations are depicted in Figure 21.
The indoor air samples collected reported TCE concentrations up to 3.5 |ig/m3 which exceeds the TCE
residential action level for sensitive populations (2.1 |ig/m3 corresponds to a HQ=1 for pregnant
woman or a woman of child-bearing age). Temporary mitigation consisting of a motorized fan and
opening all vents in the crawlspace was completed in July 2023. The VI assessment is currently ongoing
with additional samples being collected in June and August 2023; however, results were not available in
time to include in this document. Additionally, a plan for permanent mitigation was submitted to
the EPA by GHD in August 2023. The plan is currently under review by the EPA.
Site Inspection
The Site Inspection occurred on November 16, 2022. The following individuals participated in the Site
Inspection: Amanda Howell (the EPA RPM), James Ferreira (EPA); John Hoffelt (TDEC-DoR); Kevin
Kyrias-Gann (Kraft-Heinz); and Winston Guidry (GHD). For a full list of Site Inspection activities, see
the Site Inspection Checklist in Appendix G. For photographs of the Site, see Appendix H.
The purpose of the Site Inspection was to observe site conditions. All Site Inspection participants
met at the project office at the Site, located in the warehouse structure housing the remediation system.
Ms. Howell provided an overview of the scope and objectives of the FYR process, followed by
23
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Mr. Guidry providing a summary of the groundwater remediation system components and an overview
of the groundwater and surface water monitoring network.
Mr. Guidry led the Site tour, starting with a more detailed description of the groundwater extraction and
treatment system, which includes the extraction well lines into the treatment system where the extracted
groundwater is treated by air stripping, bag filtration, carbon adsorption (includes both liquid and vapor
phase carbon adsorption units) and the liquid phase resin adsorption units to treat PCBs. The tour
continued outdoors to include observation of the extraction wells and monitor wells, and the newly
installed soil gas vapor monitoring pins, both on the Site property as well as downgradient properties.
The group observed the location of the treated effluent discharge to the Green River, and the group
observed the residential areas located downgradient of the Site and north of Belew Circle Drive,
including Cold Water Creek that flows through the residential area eventually discharging to the Green
River.
The discussion of the treatment system noted that it is a custom-made system, and modifications to the
system made over time are not accurately reflected by the original design process flow charts and
diagrams. GHD agreed to produce updated process flow charts and diagrams.
The Site is not fenced (except for the privacy fence enclosing vapor phase carbon absorption units), with
no direct-contact exposure pathway because the impacted soils have been removed to bedrock and
replaced with fill and vegetative cover that is well-maintained with routine mowing. All monitoring and
extraction wells were in good condition, although one of the locks was not functional at the time of the
inspection. Mr. Guidry indicated vandalism has not occurred. The Site and treatment system is
monitored on Monday through Friday, according to the logbook maintained in the warehouse office.
The inspection team agreed that the Site layout diagram, also identified in the 2018 FYR, does not
match as-built locations for some of the monitoring points. BPI stated that all the monitoring locations
would be surveyed at the time that the newly installed soil gas vapor monitoring points are surveyed.
The updated Site layout diagram is included herein Appendix E, Figure E-2.
The EPA staff also visited the Site repository, Wayne County Library, which is located a short distance
from the Site within Waynesboro, TN. Historical Site documents are located at the library for public
review.
V. TECHNICAL ASSESSMENT
QUESTION A: Is the remedy functioning as intended by the decision documents?
Question A Summary:
The review of decision documents, ARARs and the results of the Site inspection indicate the remedy is
functioning as intended by the ROD. The PRP excavated contaminated soils and sediments down to
bedrock and removed them from the Site. Land use controls, as called for in the ROD, are in place to
restrict on-Site activities to industrial use only and to prohibit the disturbance of Site soils and
remediation equipment. In addition, ICs are in place that prohibit installation of potable groundwater
wells both on the facility property and in downgradient areas; and ICs prohibit the extraction or use of
groundwater both on-Site downgradient areas.
24
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In general, the groundwater analytical data shows declining concentrations for PCB, TCE and cis-DCE
in all sections of the aquifer when evaluated over time since the onset of remediation efforts. The
assessment of remedial actions supports the continued implementation of groundwater extraction and
treatment.
QUESTION B: Are the exposure assumptions, toxicity data, cleanup levels and RAOs used at the time
of the remedy selection still valid?
Question B Summary:
Exposure assumptions, RAOs and ARARs used at the time of the remedy selection are still valid. In
2014, the EPA updated default exposure factors, but the net effect on dose and risk is not significant.
Appendix F provides a comparison and discussion of current toxicity factors compared to the toxicity
factors used at the time of remedy selection. The groundwater ARARs have not changed for any of the
COCs since the 2018 FYR. The remediation goals required by the ROD for the discharge of treated
groundwater to the Green River are more stringent with respect to human ingestion of surface water and
fish than the ambient water quality criteria for PCBs and TCE established under the National Pollutant
Discharge Elimination System program. According to the 2009 Addendum to the 2008 FYR (2009
Addendum), multiple lines of evidence were presented to support the conclusion that human exposure
through fish ingestion was considered a negligible exposure pathway.
Due to the presence of TCE at the Site, BPI tested in 2013 to determine whether the chlorinated solvent
stabilizer 1,4-dioxane is present in the contaminated groundwater plume. The EPA identified 1,4-
dioxane as an emerging contaminant. 2 This probable human carcinogen readily dissolves in water, and
as a result, can migrate much further than a chlorinated solvent plume. BPI did not detect 1,4-dioxane in
any of the groundwater samples.
The ROD does not address the potential risk of vapor intrusion to residential properties due to the VOC
groundwater plume at the Site. In 2022, a TCE soil gas concentration of 270,000 |ig/m3 was reported
beneath the roadbed of Belew Circle. Additional air sampling found TCE concentrations within a
residential home and the crawl space, indicating vapor intrusion. A temporary mitigation system was
installed and plans for a permanent system have been submitted to the EPA at the time this document.
Additional investigation is ongoing and based on the findings a decision document may be needed to
ensure vapor intrusion is addressed.
QUESTION C : Has any other information come to light that could call into question the protectiveness
of the remedy?
No additional information has come to light that calls into question the protectiveness of the remedy.
VI. ISSUES/RECOMMENDATIONS
Issues/Recommendations
OU(s) without Issues/Recommendations Identified in the FYR:
2l,4-Dioxane Overview. EPA's Contaminated Site Cleanup Information.
http://cluin.org/contaminantfocus/default.focus/sec/l%2C4-Dioxane/cat/Overview
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Site-Wide - No issues or recommendations identified in this FYR; continue operation of groundwater extraction and
treatment system.
Issues and Recommendations Identified in the FYR:
OU(s): OU1
(Sitewide)
Issue Category: Changed Site Conditions
Issue: During the 2022 VI investigation, a TCE concentration was reported at 270,000 |ig/L
in a soil gas sample collected in close proximity to residential properties. Follow-up indoor
air samples collected at an adjacent residence reported TCE concentrations up to 3.5 |ig/m3
which exceeds the TCE residential action level for sensitive populations. Temporary
mitigation was installed in the crawlspace in July 2023. The VI assessment is currently
ongoing with additional samples being collected in June and August 2023; however, results
were not available in time to include in this document. A work plan for permanent mitigation
was submitted to the EPA by GHD in August 2023. The plan is currently under review by the
EPA.
Recommendation: Based on data available to date, a permanent mitigation system, with a
monitoring and maintenance schedule, is required. Additionally, the VI assessment must be
completed
Affect Current
Protectiveness
Affect Future
Protectiveness
Party Responsible
Oversight Party
Milestone Date
No
Yes
PRP
EPA/State
2/18/2025
OU(s): OU1
(Sitewide)
Issue Category: Remedy Performance
Issue: The current groundwater treatment system has been pumping for 30 years. The ROD
included contingency measures if it was determined that certain portions of the aquifer could
not be restored to beneficial use for any one of the COCs. One of those measures is periodic
re-evaluation of remedial technologies for groundwater restoration. Considering the high
groundwater contaminant concentrations still present after 30 years and the recent discovery
of high soil gas concentrations at the Site, an optimization analysis on the current treatment is
warranted.
Recommendation: Conduct optimization analysis
Affect Current
Protectiveness
Affect Future
Protectiveness
Party Responsible
Oversight Party
Milestone Date
No
No
PRP
EPA/State
9/18/2028
OU(s): OU1
(Sitewide)
Issue Category: Changed Site Conditions
Issue: The source of the high TCE soil gas vapors and the pathway with which the soil gas is
migrating is still unknown. The high potential for contaminated soil gas to mobilize,
particularly with an unknown source and migratory path, leads to a high potential risk for
future vapor intrusion in neighboring residential properties. The source of the high soil gas
concentrations must be identified.
Recommendation: Conduct source investigation and modify a decision document as needed
Affect Current
Protectiveness
Affect Future
Protectiveness
Party Responsible
Oversight Party
Milestone Date
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No
No
PRP
EPA/State
9/18/2028
OTHER FINDINGS
In addition, the following are recommendations identified during the FYR but do not affect current or
future protectiveness:
• The EPA Region 4 Superfund Division has required Electronic Data Deliverables (EDDs) since
2010. However, BPI is not currently meeting this requirement. All future investigations and
sampling reports must include the submittal of environmental data in the EDD format.
Additionally, all historical data that is currently stored in databases (e.g., Microsoft excel,
Microsoft access, etc.) by BPI should also be submitted to the EPA in the required EDD format.
The website https://www.epa.gov/superfund/region-4-superfund-electronic-data-submission
provides information regarding policy, procedures, and guidance.
• Sediment is sampled monthly and reported to the EPA in quarterly reports. The 1991 ROD does
not provide a remediation goal for sediment, only surface water. Additionally, GHD collects the
sediment sample each month from the end of the treated effluent discharge pipe, reflecting a
worst-case scenario instead of an estimate of concentrations in sediment bars within the riverbed.
The PCB concentrations in the riverbed sediment bars is expected to be less than what GHD
collects at the discharge pipe due to dilution from the river flow and from sediment accumulation
from off-Site sources. The maximum concentration measured during this FYR period (2018-
2022) is 9,100 |ig/kg reported in November 2022. The ESV provided for Step 2 of the Ecological
Risk Assessment process is 59.8 ng/kg, and the RSV provided for Step 3 is 676 |ig/kg. Sediment
samples, from the riverbed of Green River, should be collected to ensure that the high PCB
concentrations reported beneath the effluent discharge pipe are not adversely affecting sediments
within the river.
• BPI should evaluate other PCB water analytical methods for the groundwater effluent pipe and
surface water samples that has a lower detection limit that will detect levels at or below the
Remedial Goals listed for surface water in Table 2.
• BPI should provide a written response to past MS/MSD issues discussed in the FYR, including
any corrective actions needed or already taken, whether any data should be considered estimated,
and the overall effect on data quality evaluation of the individual data set.
VII. PROTECTIVENESS STATEMENT
Sitewide Protectiveness Statement
Protectiveness Determination:
Protectiveness Deferred
Planned Addendum Completion Date:
2/18/2025
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Protectiveness Statement:
The Site remedy protects human health and the environment for the following reasons: (1)
contaminated soil and sediment were removed from the Site down to bedrock, (2) groundwater
extraction prevents migration of contaminated groundwater and treatment of the extracted
groundwater destroys and removes the Site contaminants, and (3) institutional controls are in
place both on the facility property and within the Site area (meaning the aerial extent of
contamination) to prevent exposure to Site contaminants. However, during the 2022 VI
investigation, a TCE concentration was reported at 270,000 |ig/L in a soil gas sample collected in
close proximity to residential properties. Follow-up indoor air samples collected in a residence
reported TCE concentrations up to 3.5 |ig/m3 which exceeds the TCE residential action level for
sensitive populations. Temporary mitigation was installed in the crawlspace in July 2023. The VI
assessment is currently ongoing. A work plan for permanent mitigation at the residence is
currently under review by EPA. The protectiveness determination is deferred until the VI
investigation is completed and permanent mitigation is in place.
VIII. NEXT REVIEW
The next FYR for the Site is required five years from the completion date of this review.
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APPENDIX A - REFERENCE LIST
Phase II Operation, Maintenance, and Monitoring Plan. Prepared by Conestoga-Rovers and Associates
(CRA) on behalf of Battery Properties, Inc. (BPI). May 1996. Modified by U.S. Environmental
Protection Agency (EPA) in 2001, 2003, 2004, 2007, and 2008. Updated March 2023 (with updated
Process and Instrumentation Diagram), by GHD Services, Inc. (GHD) on behalf of BPI.
Annual Progress Reports covering the period 2018 through 2022. Prepared by GHD on behalf of BPI.
BPI provides the reports to the EPA in April of each year covering the activities and progress of the
previous year.
Quarterly Progress Reports covering the period October 2018 through December 2022. Prepared by
GHD on behalf of BPI. BPI provides the reports to the EPA in the month after each calendar quarter to
document extraction, treatment, and effluent activities and monitoring data.
Annual Groundwater and Surface Water Sampling Results covering the period 2018 through 2021.
Prepared by GHD on behalf of BPI. BPI provides the reports to the EPA to document the results of
annual sampling and analysis of groundwater and surface water.
Draft Phase I and Draft Phase II Vapor Intrusion Assessment. Prepared by GHD on behalf of BPI and
submitted to the EPA (under review during preparation of this FYR). February 2023.
Letter from D. Hill (CRA) to L. Carr (EPA) dated September 24, 2014. CRA provided the letter on
behalf of BPI to respond to comments provided by the Tennessee Department of Environment and
Conservation, Division of Remediation in letter dated August 25, 2014.
U.S. Census Data for Waynesboro, Wayne County, Tennessee. 2020. Available online at
https://www.census.gov/data.html
Final Remedial Investigation Report for the Mallory Capacitor Company Site, Waynesboro, Tennessee.
January 1991. Prepared by CRA on behalf of Duracell, Inc. (Duracell). Duracell provided the report to
the EPA to document the results of Site characterization.
Final Feasibility Study Report for the Mallory Capacitor Company Site, Waynesboro, Tennessee. May
1991. Prepared by CRA on behalf of Duracell, Inc. (Duracell). Duracell provided the report to the EPA
to present the remedial options considered for the site and to recommend a selected remedy.
Record of Decision for the Mallory Capacitor Company Site, Waynesboro, Tennessee. August 1991.
Prepared by the EPA to document the selected remedy for the Site. Available online at
https://nepis.epa.gov
Final Fifth Five-Year Review for the Mallory Capacitor Company Site, Waynesboro, Tennessee.
September 2018. Prepared by the EPA to evaluate Site remedial actions from June 2013 to June 2018
and to assess whether the remedial actions are protective of human health and the environment.
Available online at https://semspub.epa.gOv/work/04/l 1111845.pdf
OSWER Technical Guide for Assessing and Mitigating the Vapor Intrusion Pathway fi'om Subsurface
Vapor Sources to Indoor Air. OSWER Publication 9200.2-154. June 2015. Prepared by the EPA as a
A-l
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guidance for vapor intrusion assessment and mitigation. Available online at
https://www.epa.gov/sites/production/files/2015-09/documents/oswer-vapor-intrusion-technical-guide-
final.pdf
Region 4 Ecological Risk Assessment Supplemental Guidance. March 2018 update. Prepared by EPA
Region 4 to provide screening values for ecological risk assessment. Available online at
https://www.epa.gov/sites/default/files/2018-
03/documents/era_regional_supplemental_guidance_report-march-2018_update.pdf
IRIS. Integrated Risk and Information System, Toxicological Assessment of Trichloroethylene. National
Center for Environmental Assessment, Office of Research & Development, USEPA (website
rwww.epa.gov/irisl. updates added periodically).
Regional Screening Levels. November 2022. Prepared by the EPA to provide screening values for
human health risk assessment. Available online at https://semspub.epa.gov/work/HQ/403656.pdf
Vapor Intrusion Screening Levels Calculator (VISL), March 2023. Prepared by the aEPA to provide
screening values for vapor intrusion considerations. Available online at https://epa-visl.ornl.gov/cgi-
bin/visl search
A-2
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APPENDIX B - CURRENT SITE STATUS
Environmental Indicators
- Current human exposures at the Site are under control.
- Current groundwater migration is under control.
Are Necessary Institutional Controls in Place?
All O Some Q None
Has EPA Designated the Site as Sitewide Ready for Anticipated Use?
] Yes
No
Has the Site Been Put into Reuse?
~ Yes 1K1
No
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APPENDIX C - SITE CHRONOLOGY
Table 6: Site Chronology
Event
Date
Site Discovery
August 1, 1980
Tennessee Department of Health and Environment (TDHE) completed the Preliminary
Assessment
August 1, 1984
TDHE completed the Site Inspection
November 15, 1985
TDHE completed the Hazard Ranking System Package
March 14, 1986
The EPA proposed the Site for listing on the National Priorities List (NPL)
January 22, 1987
Administrative Order on Consent filed; remedial investigation/feasibility study (RI/FS)
initiated
February 18, 1988
The EPA started first removal action of equipment and stock within the plant
July 26, 1988
The EPA completed first removal action
September 19, 1988
The EPA started second removal action of part of plant and impacted soils
October 1988
The EPA completed second removal action
January 1989
The EPA finalized the Site on NPL
October 4, 1989
Potentially Responsible Party (PRP) completed RI/FS and the EPA signed Record of
Decision (ROD)
August 29, 1991
Unilateral Administrative Order signed
March 16, 1992
PRP started remedial design
March 30, 1992
PRP completed remedial design and PRP started Phase I of the remedial action
June 8, 1993
PRP completed Phase I remedial action
February 1995
PRP started Phase II remedial action
October 9, 1995
PRP completed Phase II remedial action
August 1996
PRP started Modifications to the Phase II remedial action
September 4, 1996
Preliminary Close-out Report (PCOR) completed
September 24, 1996
PRP started a karst hydrogeologic assessment
March 6, 1998
The EPA approved the karst hydrogeologic assessment
May 1, 1998
The EPA approved initiation of a dye tracer study
May 11, 1998
The EPA issued first FYR
July 1, 1998
PRP completed the dye tracer study
October 23, 1998
Consent Decree
September 4, 2001
The EPA issued the second FYR
July 1, 2003
The EPA issued the third FYR
June 27, 2008
The EPA issued an Addendum to the third FYR
June 24, 2009
PRP filed notice of land use restriction recorded in the Wayne County Register of Deeds
Office
August 17, 2011
The EPA issued the fourth FYR
July 2, 2013
City of Waynesboro enacted Ordinance Title 14 - Prohibition on Groundwater
Withdrawals in Certain Areas
May 27, 2014
The EPA issued the fifth FYR
September 18, 2018
PRP initiated a vapor intrusion study
November 2, 2022
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APPENDIX D - SITE BACKGROUND
P.R. Mallory & Co., Inc. purchased the 8.6-acre Site in 1968 (originally, a shoe factory occupied the Site
in the late 1940s). Commencing in 1969, the company, then known as Mallory Capacitor Company,
began to manufacture electrical capacitors until 1984. In early 1979, Dart Industries Inc. acquired
Mallory and sold the facility to Emhart Industries Inc. As part of the sales agreement with Emhart,
Mallory removed certain PCB wastes. In 1980, Mallory changed its name to Duracell International
Incorporated (Duracell). Litigation ensued, between Emhart and Duracell from 1985 to 1988 over PCB
liability. In 1988, Duracell's parent corporation formed a separate subsidiary, Battery Properties Inc.
(BPI), to assume ownership of the Site with all associated liability. The Site is currently occupied only
by the secured former warehouse that houses the groundwater extraction and containment system, and
various extraction and monitoring wells. It is grassed and well maintained.
The Site is located on Belew Circle in a residential/commercial/industrial/business area in the eastern
section of Waynesboro, Wayne County, Tennessee. The properties surrounding the Site are primarily
residential interspersed with some commercial establishments such as a dry-cleaning business and a
former woodcraft shop to the north of the Site. The land use surrounding the Site has not changed
appreciably since the 1991 ROD. The Green River forms the eastern boundary of the property.
From 1969 until 1978, the facility manufactured electrical capacitors impregnated with a dielectric fluid
containing PCBs; in 1978, Mallory replaced PCBs with dioctyl phthalate as a dielectric fluid. After
impregnation, a degreasing process using TCE removed dielectric fluid adhering to the outside of the
capacitors. During removal of the fluid-filled capacitors from the impregnation chambers, some
dielectric fluid typically dripped or spilled off the capacitors and from the chambers onto the floor.
Mallory collected the spilled dielectric fluid in troughs in the floor and transferred the fluid to an
underground holding tank, adjacent to the south wall of the plant, as waste fluid. The capacitor
manufacturing operations ceased on July 27, 1984.
The Site contaminants of concern include poly chlorinated biphenyls (PCBs) and chlorinated solvents
trichloroethylene (TCE), cis-l,2-dichloroethene (cis-DCE), trans-1,2-dichloroethene (trans-DCE) and
vinyl chloride (VC). Following a series of early removal actions through 1988, contaminated media still
remained, including soil in and around the Site's former manufacturing facility, and groundwater
beneath the former facility property and in the downgradient direction (northeast).
The geology of the Site consists of three stratigraphic units: alluvial deposits, residual soils, and
bedrock, with all three units varying in depth across the Site. The alluvial deposits consist of red to
brown silts and sands with some clay and gravel and range in depth from eight feet on the west side of
the Site to zero feet where they fan out at the edge of the Green River. The residual soils consist of
brown to tan mottled clay silts up to eight feet thick. The bedrock unit, Fort Payne Formation, consists
of three distinct subunits of fractured dolomitic limestone. The Fort Payne Formation provides numerous
domestic water supplies the Waynesboro area. (However, no potable water wells are located in the
downgradient vicinity of the Site.) General groundwater flow direction is northeasterly toward the Green
River; fractures and lenses control groundwater flow through preferential pathways.
Following removal actions in 1988 and 1989, all areas of the Site became freely accessible to the public
with the exception of the secured warehouse. The Site Inspection conducted on February 14, 2013,
reported finding golf balls in the open grassed area of the Site, indicating incidental use of the property
between the warehouse and the Green River. The Green River itself, although too shallow for
D-l
-------
recreational activities such as boating or swimming, reportedly supports occasional recreational fishing
by local residents. However, as presented in the 1991 Remedial Investigation/Feasibility Study (RI/FS)
and the June 2009 Addendum to Third Five Year Review, the aquatic habitat of the Green River
adjacent to the Site is not suitable to support recreational fish-taking.
The City of Waynesboro supplies municipal water to commercial and residential properties in the
immediate vicinity of the Site. Waynesboro obtains the water from surface water resources upstream of
the Site. Conestoga-Rovers & Associates completed an inventory of domestic water supplies within a
1-mile radius of the Site in 1987 as part of a hydrogeologic investigation. The inventory identified
54 private water sources that draw water from the Fort Payne Formation, consisting of 27 drilled wells,
19 dug wells and eight springs. One private well and two springs are located downgradient from the Site
(Well DW-18 and Springs S-2 and S-3). In the past, the well and springs reportedly were utilized for
drinking water sources. The two springs are located closest to the Site, and CRA sampled the springs in
1987. The analytical data showed no Site-related impacts at these two springs. In 2002, CRA conducted
a private water well survey resulting in the identification of three private wells located downgradient
from the Site (Wells 18108024, 18108023, and 18109037). The results of the survey show that Well
18108024 is abandoned, while wells DW-18, 18108023, and 18109037 and springs S-2 and S-3 are not
in use. In February 2009, CRA contacted the property owners of the identified downgradient wells and
springs to confirm that their uses had not changed since the 2002 water well search. Therefore, the
results of the previous water well searches are confirmed, and no potable water wells are identified
downgradient from the Site. In 2014, The City of Waynesboro enacted the Waynesboro Groundwater
Withdrawal Ordinance, which prohibits wells and groundwater use in the Site vicinity. Additionally, a
small spring is located on an adjacent property west of the Site, which discharges into Cold Water
Creek, and is not in use as a drinking water source. A 2006 sample from the spring indicated that Site
contaminants are not present.
There are no wetlands, endangered species, or critical habitats impacted by the Site. There are also no
historical landmarks or agricultural lands impacted by the Site.
BPI conducted a VI evaluation at the Site from 2004 to 2005 at the request of the EPA and results were
reported to the EPA in May 2005. Soil gas samples were collected on the facility property where the
maximum VOC concentrations occurred in shallow groundwater. In 2011, the EPA published an
updated toxicological assessment for TCE in the IRIS database. Additionally in 2015, the EPA finalized
the VI guidance. Considering the new VI guidances, the Fifth Five Year Review (2018) recommended
that BPI conduct another VI investigation under the 2015 EPA guidance methodology to supplement the
data from the 2005 VI investigation.
In 2022, the EPA approved the Work Plan for Updated VI Assessment and the Quality Assurance
Project Plan that considered both the 2015 VI guidance and the updated toxicological assessment of
TCE. Twelve soil gas boring locations were sampled in November based on shallow groundwater
concentrations and the calculated Vapor Intrusion Screening Levels (VISL). PCB was analyzed in four
borings and was not detected. Based on the results, additional soil gas samples were collected in
February and May 2023 and indoor air samples and crawl space air samples were collected in April and
May 2023 at the residential home located on the same property as soil gas boring location GP14-23.
The indoor air samples collected reported TCE concentrations up to 3.5 |ig/m3 which exceeds the TCE
residential action level for sensitive populations (2.1 |ig/m3 corresponds to a HQ=1 for pregnant woman
or a woman of child-bearing age). Temporary mitigation consisting of a motorized fan and opening all
D-2
-------
vents in the crawlspace was completed in July 2023. The VI assessment is currently ongoing with
additional samples being collected in June and August 2023; however, results were not available in time
to include in this document. Additionally, a plan for permanent mitigation was submitted to the EPA by
GHD in August 2023. The plan is under review by the EPA at the time of writing this document.
D-3
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APPENDIX E - DATA REVIEW TABLES AND FIGURES
Figure 1: Site Location Map
Source: Modified from EPA 2013
Disclaimer: This map and any boundary lines within the map are approximate and subject to change. The map is not a
survey. The map is for informational purposes only regarding the EPA's response actions at the Site.
E-l
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Figure 2: Site Layout
PROPERTY BOUNDARY
SHALLOW MONITORING WELL FOR HYDRAULIC
MONITORING
SHALLOW MONITORING WELL FOR HYDRAULIC
WELLFOR HYDRAULIC MONITORING AND
! OW68JD1
owe 9-011
DEEP MONITORING WELLFOR HYDRAULIC MONITOI
DEEP MONITORING WELLFOR HYDRAULIC
MONITORING AND AND GROUNDWATER SAMPLING
DEEPER MONITORING WELLFOR HYDRAULIC
MONITORING
DEEPER MONITORING WELLFOR HYDRAULIC
MONITORINGAND GROUNDWATER SAMPLING
EXTRACTION WELL
CLOSED/ABANDONED SOIL GAS PROBE
SOIL GAS PROBE
SURFACE WATER SAMPUNG LOCATION
[OW72-01I
gOW52-89|
1QW59-9C
OW71-01''
IOW6i^90l
»GP3-22_ ' -HG
"^«GP4-22®aC|: .
i
[QW37-89aggOW38-89
¦Slav...
'n7P|siWQW46-89]
OVV i 2-8*5 "
GSi,!j
[QW30-891
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SOW34-89
|CW6^0]
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)W40-89
iV39-09
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IOW21-86I
q OW48-90
0 CW55-90
0 CW70-01
4.CW66-95
gOW52-89
BOW36-89
aOW24-89
aOW62-90
HEW-a
A GP3-G4
~ GP6-22
0C-1
SITE PLAN AND MONITORING LOCATIONS
FVojed No 11220351
Date January 2023
FIGURE 1
Source: Annual Groundwater and Surface Water Sampling Results, March 2023. Disclaimer: This map and any boundary lines within the map are approximate and
subject to change. The map is not a survey. The map is for informational purposes only regarding the EPA's response actions at the Site.
E-2
-------
Figure 3:Shallow Bedrock Potentiometric Surface Map
Ma®
lQW65?92|
g).W6g95!
>70'2>461
MRGreeni Riveirtdown) ]
[QW5&90]
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. 702%3l
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ommsM
f ¦ggjsjl
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¦7.16 M
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|QW35fe9l
fc720T05M
@S£a&|?M
NM: Not Measured (location covered
with debris)
Legend
-700- GROUNDWATER elevation contour
DETERMINED USING LINEAR KRIGING (FT AMSL)
| MONITORING LOCATIONS
+ GREEN RIVER SURFACE WATER
703 81 ELEVATION (FT AMSL) (NOT INCLUDED
IN CONTOUR GENERATION)
© SHALLOW PIEZOMETER AND OBSERVED
700 55 GROUNDWATER ELEVATION (FT AMSL)
O SHALLOW MONITORING WELLAND OBSERVED
GROUNDWATER ELEVATION (FT AMSL)
H EXTRACTION WELLAND OBSERVED
GROUNDWATER ELEVATION (FT AMSL)
MALLORY CAPACrTOR CO. SITE
WAYNESBORO, TENNESSEE
SHALLOW BEDROCK GROUNDWATER
ELEVATION CONTOURS -
FEBRUARY 24,2023
Project No. 11220951
FIGURE 1
Source: GHD Quarterly Progress Report No. 97 (April 2023) Disclaimer: This map and any boundaiy lines within the map are approximate and subject to change. The
map is not a survey. The map is for informational purposes only regarding the EPA's response actions at the Site.
E-3
-------
Figure 4: Deep Bedrock Potentiometric Surface Map
fowegyil
^(698^1^
p)W57;9Q]
^703^571
LQW$|oJ
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OW26-89
¦698l27j|
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OW72-01 |
¦698?23M
vj» i-row52M
|BMpRSTRp£?fOW75^7A
703.65 . nmmm
%
|^OW56-90i
BK15.76M
J Legend
GROUNDWATER ELEVATION CONTOUR
DETERMINED USING LINEAR KRIGING (FT AMSL)
| MONITORING LOCATIONS
~ DEEP MONITORING WELL AND OBSERVED
703-81 GROUNDWATER ELEVATION (FT AMSL)
D EXTRACTION WELL AND OBSERVED
GROUNDWATER ELEVATION (FT AMSL)
(%p)
MALLORY CAPACITOR CO. SITE
WAYNESBORO, TENNESSEE
DEEP BEDROCK GROUNDWATER
ELEVATION CONTOURS ¦
FEBRUARY 24,2023
Project No. 11220951
Date. March 2023
FIGURE 2
Source: GHD Quarterly Progress Report No. 97 (April 2023)
Disclaimer: This map and any boundary lines within the map are approximate and subject to change. The map is not a survey. The map is for informational purposes only
regarding the EPA's response actions at the Site.
E-4
-------
Figure 5: Deeper Bedrock Potentiometric Surface Map
rQw6goi'
¦7.03^651
rQ.W60!90]
»7,03y4.Ql
4>
Hllo
DEEPER BEDROCK GROUNDWATER
ELEVATION CONTOURS -
FEBRUARY 24, 2023
ProjadNo 1I22M51
Date. March 2023
FIGURE 3
I Legend
-700- GROUNDWATER ELEVATION CONTOUR
DETERMINED USING LINEAR KRIGING (FT AMSL)
| MONITORING LOCATIONS
DEEPER MONITORING WELL AND OBSERVED
702 43 GROUNDWATER ELEVATION (FT AMSL)
|QW?6^7raM
^OW62-9Ql
mmsT
IO.W6&9Q1
Source: GHD Quarterly Progress Report No. 97 (April 2023)
Disclaimer: Tliis map and any boundary lines w ithin the map are approximate and subject to change. The map is not a survey. The map is for informational purposes only
regarding the EPA's response actions at the Site.
E-5
-------
Figure 6: Extent of PCBs and VOCs above MCLs, Shallow Bedrock - 2022
NIX0.52)
NDC1.CD
ND(1.C0
N 0(1.0)
ND(1.Q)
, OW48-90
ND(0.51)
ND(1.7)
, CW55-90
OW70-01
0VER8U RDEN/BEDROCK INTERFAC E MONITORING
WELLFOR HYDRAULIC MONITORING AND
IQW74-07
IOW65-92" QVvT^T
SHALLOW PIEZOMETER FOR HYDRAULIC MONITORING
EXTRACTION WELL
ND(14)
ND(1^
OW6492
10/18/20221
N D(0.50)
ND(1.0)
2-0 CE
ND(1£>)
ND(1D)
ND(10)
-1,2-DCE
rovwaoTl
IOW&4-92]
lOWS&gQl
1,2-DCE
M0
ND(20)
ND(20)
QW61-90
'
ND(0.48)
ND(1.0)
NCK1X))
N D(1.0)
NOTES
ND(25)/ND(25)
950 'S00 I
N D(25) / N D(25) I
1. FOR MONITOR IN G WELLS/PIEZOMETERS INSTALLED BYCRA. THE
LAST TWO DIGITS (85, 88. 89, 90.92. 95, 01, 07) DESIGNATE THE YE/
OF INSTALLATION (1985, 1988.1989, 1993. 1992. 1995.2001.2007).
2. ALL UN ITS ARE MICROGRAMS PER LITER (ms/I).
3. MCLs: COMPOUND MCI (io
-------
Figure 7: Extent of PCBs and VOCs above MCLs, Deep Bedrock - 2022
LEGEND
PROPERTY BOUNDARY
DEEP MONITORING WELLFOR HYDRAULIC MONITOf
DEEP MONITORING WELLFOR HWRAULIC
MONITORING AND AND GROUNDWATER SAMPLING
ND(0.60)
ND(1J3)
NDCtO)
ND(1.0)
OW52-89
OW36-89
EW-3
ND(0.48)
ND(1,0)
NDC1.0)
ND(1.0)
ND(1.0)
SCW68-01
OCTOBER 2022 ANNUAL GROUNDWATER
ND(0.60)
ND(1.0)
NDC2^>
ND(25)
ND(2S>
370
ND(25)
NDC25)
LAST TWO DIGITS
-------
Figure 8: Extent of PCBs and VOCs above MCLs, Deeper Bedrock - 2022
Source: GHD Quarterly Progress Report No. 97 (April 2023)
Disclaimer: This map and any boundary lines within the map are approximate and subject to change. The map is not a survey. The map is for informational purposes only
regarding the EPA's response actions at the Site.
E-8
-------
Table 7: PCB, TCE and cis-DCE Concentrations in Select Shallow Bedrock Monitoring Wells
DATE
PCB (jig/L)
TCE (jig/L)
cis-DCE (jig/L)
OW50-89
OW37-89
OW67-95
OW50-89
OW37-89
OW67-95
OW50-89
OW37-89
OW67-95
2018
1,900
1,200
26
27,000
13,000
1,800
13,000
23,000
190
2019
5,500
2,000
31
52,000
6,800
1,700
17,000
18,000
200
2020
2851
1651
30
33,000
440
1,100
20,000
8,100
200
2021
2,700
1,300
43
34,000
360
1,000
17,000
3,800
260
2022
180
490
24
29,000
1,800
870
17,000
16,000
380
Five-Year Averages13
1993-97
NA2
9,740
NA
NA
174,400
NA
NA
70,250
NA
1998-2002
NA
5,038,400
NA
NA
18,080
NA
NA
33,000
NA
2003-074'5
23,950
77,206
86
61,500
35,400
5,975
21,000
30,400
328
2008-12
3,380
1,348
45
72,800
58,000
2,260
23,400
22,400
219
2013-17
132,140
3,526
52
61,800
14,540
1,840
23,600
18,960
227
2018-22
2,113
1,031
28
35,000
4,480
1,294
16,800
13,780
246
Notes: All units micrograms per liter
1 = The half-value of the reporting limit is used for data evaluation of non-detects.
2 = Data Not Available
3 = Yearly averages were used when multiple results were reported in a year.
4= The first round of data available for OW67-95 is March 12, 2004.
5 = OW50-89 was only sampled in years 2003 and 2007.
E-9
-------
Figure 9: PCB Concentrations Shallow Bedrock
PCB Concentrations (jig/L)
Shallow Bedrock
10,000
1,000
100
10
2018
2019
2020
2021
2022
•OW50-89 OW37-89 OW67-95
E-10
-------
Figure 10: TCE Concentrations Shallow Bedrock
100,000
TCE Concentrations (|ig/L)
Shallow Bedrock
10,000
1,000
100
10
2018
2019 2020
—OW50-89 OW37-89
E-ll
2021 2022
OW67-95
-------
Figure 11: cis-DCE Concentrations Shallow Bedrock
100,000
cis-DCE Concentrations (|ig/L)
Shallow Bedrock
10,000
1,000
100
10
2018
2019 2020 2021
—OW50-89 OW37-89 OW67-95
2022
E-12
-------
Figure 12: Monitoring Well OW37-89 PCB, TCE and cis-DCE Concentrations
100
10
Monitoring Well OW37-89
PCB, TCE and cis-DCE (jig/L)
10,000,000
1,000,000
100,000
10,000
1,000
1993-1997 1998-2002 2003-20072 2008-2012 2013-2017 2018-2022
PCB (ng/L) TCE (ng/L) cis-DCE (ng/L)
E-13
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Table 8: PCB, TCE, and cis-DCE Concentrations in Select Deep Bedrock Monitoring Wells
DATE
PCB (jig/L)
TCE (jig/L)
cis-DCE (jig/L)
OW38-89
OW52-89
OW38-89
OW52-89
OW38-89
OW52-89
2018
420
20
1,100
1,700
6,800
980
2019
1,300
1,400
1,800
740
3,700
800
2020
70
160
1,300
1,600
1,600
810
2021
580
360
2,800
660
5,500
680
2022
100
22
5,700
730
20,000
370
Five-Year Averages13
1993-97
110,350
NA2
70,250
NA
10,150
NA
1998-2002
9,592,000
NA
222,000
NA
6,300
NA
2003-074
43,425
79
94,250
2,060
8,500
1,980
2008-12
36,020
48
47,280
2,170
8,800
1,562
2013-17
1,190
263
8,900
2,940
10,660
966
2018-22
494
392
2,540
1,086
7,520
728
Notes: All units micrograms per liter
1 -The half-value of the reporting limit is used for data evaluation of non-detects.
2-NA = Data Not Available
3-Yearly averages were used when multiple results were reported in a year.
4 ~ No data was reported in 2007 at monitoring well OW38-89
E-14
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Figure 13: PCB Concentrations Deep Bedrock
1600
PCB Concentrations (|ig/L)
Deep Bedrock
1400
1200
1000
800
600
400
200
2018
2019
2020
¦OW38-89 — OW52-89
2021
2022
E-15
-------
Figure 14: TCE Concentrations Deep Bedrock
TCE Concentrations (jig/L)
Deep Bedrock
6000
5000
4000
3000
2000
1000
2018
2019 2020 2021
OW38-89 OW52-89
2022
E-16
-------
Figure 15: cis-DCE Concentrations Deep Bedrock
25000
20000
15000
10000
5000
cis-DCE Concentrations(|ig/L)
Deep Bedrock
2018
2019
2020
•OW38-89 — OW52-89
2021
2022
E-17
-------
Figure 16: Monitoring Well OW38-89 PCB, TCE and cis-DCE Concentrations
Monitoring Well OW38-89
PCB, TCE and cis-DCE (jig/L)
10,000,000
1,000,000
100,000
10,000
1,000
100
1993-1997 1998-2002 2003-20072 2008-2012 2013-2017 2018-2022
PCB (ng/L) TCE (ng/L) — cis-DCE(ng/L)
E-18
-------
Table 9: PCB and TCE Concentrations in Select Deeper Bedrock Monitoring Wells
DATE
PCB (jig/L)
TCE (jig/L)
OW62-90
OW76-07
OW62-90
OW76-07
2018
2.9
49.0
170.0
201
2019
4.2
28.0
120.0
201
2020
5.2
43.0
110.0
12.51
2021
3.2
71.0
41.0
12.51
2022
2.41
31
14.51
7.51
Five-Year Averages1
1993-97
44
NA
3,383
NA
1998-2002
13
NA
619
NA
2003-072
4.5
40
58
25
2008-12
1.4
42
67
85
2013-17
2.8
38
49
ll1
2018-22
3.6
44
91
151
Notes: All units |ig/L
1 = The half-value of the reporting limit is used for data evaluation of non-detects.
2 = The first year of data for OW76-07 is 2007.
E-19
-------
Figure 17: PCB Concentrations Deeper Bedrock
80
PCB Concentrations (jig/L)
Deeper Bedrock
70
60
50
40
30
20
10
2018
2019
2020
•OW62-90 OW76-07
2021
2022
E-20
-------
Figure 18: TCE Concentrations Deeper Bedrock
180
160
140
120
100
80
60
40
20
0
2018
TCE Concentrations (jig/L)
Deeper Bedrock
2019
2020
•OW62-90
2021
2022
E-21
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Table 10: cis-DCE Concentrations in Select Deeper Bedrock Monitoring Wells
DATE
cis-DCE (jig/L)
OW62-90
OW76-07
OW60-90
2007
880
920
650
2008
1150
1100
670
2009
1000
650
620
2010
1200
550
650
2011
850
720
605
2012
770
570
700
2013
760
690
600
2014
740
420
545
2015
750
720
595
2016
680
550
500
2017
690
630
550
2018
680
640
600
2019
620
590
580
2020
650
610
590
2021
750
630
620
2022
610
320
520
E-22
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Figure 19: cis-DCE Concentrations Deeper Bedrock
cis-DCE Concentrations([ig/L)
Deeper Bedrock
2007-2022
1200
1000
800
600
400
200
2007 2009 2011 2013 2015
OW62-90 OW76-07
2017 2019
OW60-90
2021
E-23
-------
Table 11: Mass Removal Estimates Since the 2018 FYR
Extraction Well
Average
Pumping
Rate
(GPM)
Average
PCB Cone
(Hg/L)
Average
TCE Cone
(Hg/L)
Average
Cis-DCE
Cone
(Hg/L)
Estimated PCB
Mass Removed
(Lbs)
Estimated
TCE Mass
Removed
(Lbs)
Estimated cis-
DCE Mass
Removed (Lbs)
2018 (97.2% operational)
EW-1
0.18
27.5
1,025
2,267
0.02
0.8
1.7
EW-2
14.3
19.8
1,052
996
1.2
61.4
60.8
EW-3
6.1
818
832
1,408
21.4
21.2
36.7
EW-4
0.08
951
13,583
4,125
0.3
4.7
1.4
EW-5
7.3
1.15
29.9
31.0
0.03
0.9
1.0
2018 Estimatet
Total Mass
Removed
23.0
89.0
101.6
2019 (98.4
% operational)
EW-1
0.21
61.4
953
2,192
0.05
0.8
2.0
EW-2
13.6
29.3
1,042
977
1.7
59.9
57.4
EW-3
7.1
31,814
1,117
1,418
945.5
33.4
43.5
EW-4
0.07
2,432
14,727
4,075
0.5
4.3
1.2
EW-5
7.3
1.05
30.2
34.2
0.03
0.9
1.1
2019 Estimatet
Total Mass
Removed
947.8
99.3
105.2
2020 (96.4
% operational)
EW-1
0.2
16.0
858
2,108
0.01
0.7
1.8
EW-2
12.8
28.4
872
904
1.5
46.3
49.0
EW-3
6.3
17,387
1,044
1,742
408.9
27.3
46.4
EW-4
0.06
456
14,492
4,367
0.1
3.9
1.1
EW-5
6.8
2.15
28.4
29.3
0.06
0.8
0.8
2020 Estimatet
Total Mass
Removed
410.6
79.0
99.1
2021 (97.3% operational)
EW-1
0.19
20.6
1,023
1,499
0.02
0.8
1.2
EW-2
14.0
27.8
823
834
1.6
47.1
49.9
EW-3
5.0
43,523
933
1,883
891.3
18.5
40.2
EW-4
0.06
748
15,625
4,817
0.2
3.9
1.2
EW-5
6.0
2.8
32.2
27.8
0.06
0.8
0.7
2021 Estimatet
Total Mass
Removed
893.2
71.1
93.2
E-24
-------
Extraction Well
Average
Pumping
Rate
(GPM)
Average
PCB Cone
(Hg/L)
Average
TCE Cone
(Hg/L)
Average
Cis-DCE
Cone
(Hg/L)
Estimated PCB
Mass Removed
(Lbs)
Estimated
TCE Mass
Removed
(Lbs)
Estimated cis-
DCE Mass
Removed (Lbs)
2022 (97.4 % operational)
EW-1
0.15
10.8
488
1,663
0.007
0.3
1.1
EW-2
11.6
27.5
721
842
1.3
35.4
41.7
EW-3
5.5
163,476
349
1,138
4,134
8.0
26.8
EW-4
0.19
610
15,258
4,842
0.3
11.5
3.9
EW-5
6.7
1.8
10.7
19.9
0.05
0.3
0.6
2022 Estimatet
Total Mass
Removed
4,135.7
55.5
74.1
TOTAL ESTIMATED MASS REMOVED 2018 - 2022
6,410.3
393.9
473.2
Notes: |ig/L = micrograms per liter
gpm = gallons per minute
lbs = pounds
E-25
-------
Table 12: Mass Removal Summary (pounds)
Analyte/Period
1994-
1997
1998-
2002
2003-
2007
2008-
2012
2013-
2017
2018-
2022
Total
PCB
685
656
1,368
807
96
6,410
10,022
TCE
6,789
5,092
2,533
1,504
534
394
16,846
Figure 20: Annual Mass Removed
Annual Mass Removed (Pounds)
^'¦0>,OOOOOOOOOO^h^h^h^h^h^h^h^h^h^h
-------
Figure 21: Vapor Intrusion Assessment 2022-2023 - Soil Gas Boring Locations
PROPERTY BOUNDARY
SHALLOW MONITORING WELLFOR HYDRAULIC
; GW55-9G
OW70-01
IRDEN/BEDROCKINTERF AC E MONITORING
WELLFOR :
DEEP MONITORINO WELL FOR HYDRAULIC MONITORING
|OW36-BS
DEEPER MONITORINO WELLFOR HYDRAULIC
DEEPER MONITORING WELLFOR HYDRAULIC
MONITOR WO AND GROUNDWATER SAMPLING
EXTRACTION WELL
SURFACE WATER SAMPLING LOCATION
GP10-22'
igp.;-u4|
IOW29-39I
IOW48-S9I
IOW14-!
MALLORY CAPACITOR CO. SITE
WAYNESBORO, TENNESSEE
VAPOR INTRUSION REPORT
: tyidna<)MU£U
-
Ffojed No. 11220951
Date May 2023
FIGURE 1
A OW24-89
« CW62-90
Source: GHD DRAFT Phase I and Draft Phase II Vapor Intrusion Assessment (February 2023)
Disclaimer: This map and any boundary lines within the map are approximate and subject to change. The map is not a survey. The map is for informational purposes only
regarding the EPA's response actions at the Site.
E-27
-------
Table 13: TCE and cis-DCE soil gas concentrations (|ig/m3)
Boring Location
Sample
Date
TCE (jLig/m3)
cis-DCE
(JLig/m3)
GP1-22
11/8/2022
ND (1.1)
ND (0.79)
GP2-22
11/8/2022
ND (1.1)
ND (0.79)
GP3-22
11/8/2022
94,000
ND (120)
GP4-22
11/8/2022
9,200
1,500
GP5-22
11/8/2022
180
7.9
GP6-22
11/8/2022
15
ND (0.79)
GP7-22
11/8/2022
3.4
ND (0.79)
GP8-22
11/8/2022
1,100/1,100
2.6/2.6
2/5/2023
600
9.9
GP9-22
11/8/2022
2.1/2.0
ND (0.79)/ND (0.79)
GP10-22
11/8/2022
270,000
4,600
2/5/2023
220,000
3,300
GP11-22
11/8/2022
6.3
2.2
GP 12-22
11/8/2022
140
ND (0.79)
5/2/2023
47
ND (0.40)
GP13-23
2/5/2023
790
5.6
GP14-23
2/5/2023
32,000 /23,000
200/140
5/2/2023
62,000/16,000
67/65
GP15-23
2/5/2023
1,700
53
Note: two results indicate duplicate samples
E-28
-------
Table 14: TCE indoor air and crawl space air concentrations (jig/m3)
Sample Location
Sample
Date
TCE (jug/m3)
Indoor Air
4/5/2023
3.5/3.4
5/2/2023
3.0/3.1
Crawl Space (above
plastic sheeting)
5/2/2023
2.9
Crawl Space (below
plastic sheeting)
5/2/2023
300
Note: two results indicate duplicate samples
E-29
-------
APPENDIX F - COMPARISON OF TOXICITY FACTORS
This appendix provides additional detail to support the evaluation of Section V, Technical Assessment,
Question B: Are the exposure assumptions, toxicity data, cleanup levels and RAOs used at the time of
remedy selection still valid? Table F-l provides a comparison of toxicity factors. The toxicity factors for
vinyl chloride are included in Table F-l; although, the 1991 ROD does not consider vinyl chloride.
Table F-l: Comparison of Toxicity Factors
CONTAMINANTS
Carcinogenic toxicity changes
Non-carcinogenic toxicity changes
Oral Cancer Slope Factor
Oral Reference Dose (RfD)
1991 ROD
Oral Cancer
Slope Factor
( mg/kg-day)-l
2023
Oral Cancer
Slope Factor
(mg/kg-day)-l
Change in
Cancer Slope
Factor
1991 ROD
Oral RfD Value
(mg/kg-d)
2023
Oral RfD Value
(mg/kg-d)
Change in Oral RfD
PCB
0.077
0.07 - 2.01
Higher
NA
2.0E-5
NA
TCE
0.011
0.046
Higher
NA
5.0E-4
NA
cis-l,2-DCE
NA
NA
NA
0.02
0.002
Lower
trans-1,2-DCE
NA
NA
NA
0.02
0.02
Same
Vinyl chloride
NE
0.72
NA
NE
0.003
NA
Notes: NA = Not Applicable
NE = Contaminant Not Evaluated in 1991 ROD
1 = see IRIS database for when to use which value
Exposure assumptions, RAOs and ARARs used at the time of the remedy selection are still valid. In
2014, EPA updated default exposure factors, but the net effect on dose and risk is not significant. The
groundwater ARARs have not changed for any of the COCs since the 2008 FYR. Both TCE and vinyl
chloride are now assumed to have mutagenic mode of action; thus, adjustment factors are used for
childhood exposure. The remedies in place prevent unacceptable exposure to Site contaminants.
The Ambient Water Quality Criteria (AWQCs) for PCBs and TCE established as National Pollutant
Discharge Elimination System (NPDES) criteria for the groundwater treatment and subsequent
discharge to the Green River are more stringent with respect to the criteria based on human ingestion of
surface water and fish. The more stringent AWQC would not affect the remedy at the Site since human
exposure to fish impacted by the Site was not identified as a significant exposure pathway.
The 2009 Addendum to the 2008 FYR evaluated human health risks for the fish ingestion pathway from
the Green River. This evaluation indicated risk greater than 1E-04; however, the Addendum concluded
this exposure pathway was considered negligible. This conclusion was based on multiple lines of
evidence, including the following: (1) the results of surface water quality samples collected from three
locations adjacent to the Site which were all below detection limits for PCBs; (2) a supplemental field
survey of the Green River undertaken in February 2009 demonstrating that the Green River adjacent to
the Site and up to 600 feet downgradient of the Site cannot support a significant recreational fish
population; and (3) March 2009 statements by local personnel from the Tennessee Wildlife Resources
Agency (TWRA) that the presence of habitat for edible fish between the Site and the Lawrenceburg
Highway bridge is unlikely and that the nearest location for edible fish habitat is probably approximately
5,000 feet downstream from the Site.
F-l
-------
The EPA requested that BPI evaluate the Vl-exposure pathway because it was not included in the 1991
RI/FS. In response to the EPA's request, BPI summarized in the 2009 Addendum the VI risk assessment
that was prepared and approved in 2005.3
The 2005 VI risk evaluation calculated risks for TCE based on two sets of toxicity values: the
conservative draft provisional TCE toxicity values developed by the EPA's National Center for
Environmental Assessment (NCEA), as well as the TCE toxicity values developed by the EPA but
withdrawn from the EPA's Integrated Risk Information System (IRIS) in 1989. Although the more
current oral cancer slope factor (CSF) and inhalation unit risk factor (IUR) are more stringent than the
1989 withdrawn values, the 2005 risk assessment also calculated risks based on the NCEA CSF and IUR
values, which are significantly more stringent than the current values. The 2005 evaluation demonstrated
that using the NCEA toxicity values resulted in risks within the EPA's risk management range of 1E-06
to 1E-04. Since the more current carcinogenic toxicity values for TCE are less stringent than the NCEA
values, the estimated cancer risks would be even lower based on the analysis of data collected in 2004.
In its 2011 updated assessment of TCE, EPA (IRIS) published a recommended inhalation reference
concentration (RfC) for assessment of the noncarcinogenic endpoint that is more stringent than any
values used for TCE prior to 2011. Using this current IRIS toxicity values for TCE, and the EPA target
risk range for cancer, assessment of health risks from inhaled TCE is generally driven by the noncancer
endpoint.
EPA finalized guidance for the VI Assessment in 2015 and requested an updated VI assessment.
Considering the new VI guidances, the Fifth Five Year Review (2018) recommended that BPI conduct
another VI investigation under the 2015 EPA guidance methodology to supplement the data from the
2005 VI investigation. In 2022 EPA approved the Work Plan for Updated VI Assessment and the
Quality Assurance Project Plan that considered both the 2015 VI guidance and the updated toxicological
assessment of TCE. Twelve soil gas boring locations were sampled in November based on shallow
groundwater concentrations and the calculated Vapor Intrusion Screening Levels (VISL). PCB was
analyzed in four borings and was not detected; detection limits were deemed adequate relative to risk-
based levels. Based on the TCE results, additional soil gas samples were collected in February and May
2023. Indoor air samples and crawl space air samples were collected in April and May 2023 at the
residential home located on the same property as soil gas boring location GP14-23 (See Appendix E,
Figure E-9). Analysis of the indoor air sample reported TCE concentrations up to 3.5 |ig/m3 which
exceeds the TCE residential action level for sensitive populations (2.1 |ig/m3 corresponds to a HQ=1 for
pregnant woman or a woman of child-bearing age). Temporary mitigation consisting of a motorized fan
and opening all vents in the crawlspace was completed in July 2023. A work plan for permanent
mitigation is currently under review by EPA. The VI assessment is still ongoing.
3 Conestoga-Rovers & Associates. Final Vapor Intrusion Pathway Assessment, Mallory Capacitor Co. Site, Waynesboro,
Tennessee. February 2005.
F-2
-------
APPENDIX G - SITE INSPECTION CHECKLIST
FIVE-YEAR REVIEW SITE INSPECTION CHECKLIST
I. SITE INFORMATION
Site Name: MALLORY CAPACITOR COMPANY
Date of Inspection: NOVEMBER 16,2022
Location and Region: WAYNESBORO, WAYNE
COUNTY, TENNESSEE - EPA REGION 4
EPA ID: TND 075 453 688
Agency, Office or Company Leading the Five-Year
Review: EPA and TENNESSEE DEPARTMENT
OF ENVIRONMENT AND CONSERVATION,
Weather/lemperature: Sunny, light winds, 55"
DIVISION OF REMEDIATION
Remedy Includes
(Check all that apply)
2 Landfill cover/containment
2 Monitored natural attenuation
Access controls
H Ground water contaimnent
Institutional controls
"2 Vertical barrier walls
Ground water pump and treatment
2 Surface water collection and treatment
~ Other:
Attachments: E
3 Inspection team roster attached
1 1 Site map attached
II. INTERVIEWS (check all that apply)
1 O&M Site Manager WINSTON GUIDRY
PROJECT MANAGER
11/16/22
Name
Title
Date
Interviewed ^
at site ~ at office ~ by phone
Problems, suggestions ~ Report attached: No; reports are provided quarterly.
2. O&M Staff
(None)
Name
Title
Date
Interviewed ~ at site ~ at office ~ by phone :
Problems/suggestions ~ Report attached:
3. Local Regulatory Authorities and Response Agencies (i.e..
state and tribal offices, emergency
response office, police department, office of public health or enviromnental health, zoning office.
recorder of deeds, or other city and county offices). Fill in all that apply.
Asencv (None)
Contact
Name
Title
Date
Phone No.
Problems/suggestions ~ Report attached:
Agency
Contact
Name
Title
Date
Phone No.
Problems/suggestions I-! Report attached:
Agency
Contact
Name
Title
Date
Phone No.
G-l
-------
Problems/suggestions ~ Report attached:
Agency
Contact
Name
Title
Date
Phone No.
Problems/suggestions ~ Report attached:
Agency
Contact
Name
Title
Date
Phone No.
Problems/suggestions ~ Report attached:
4. Other Interviews (optional) Q Report attached:
(None)
III. ON-SITE DOCUMENTS AND RECORDS VERIFIED (check all that apply)
1. O&M Documents
1^1 O&M manual ^ Readily available £
^ Up to date
~ n/a
1^1 As-built drawings ^ Readily available ~ Up to date
~ n/a
1^1 Maintenance logs ^ Readily available
^ Up to date
~ n/a
Remarks
: The as-built drawings need to be ui)dated.
2. Site-Specific Health and Safety Plan
Readily available [
3 Up to date EH N/A
~ Contingency plan/emergency response plan ~ Readily available ~ Up to date ^ N/A
Remarks
3. O&M and OSHA Training Records
Readily available [
3 Up to date EH N/A
Remarks
4. Permits and Service Agreements
~ Air discharge permit
~ Readily available ~ Up to date IXI N/A
~ Effluent discharge
~ Readily available ~ Up to date [XI N/A
~ Waste disposal, POTW
~ Readily available ~ Up to date [XI N/A
Other permits:
~ Readily available ~ Up to date [XI N/A
Remarks
: Permits not reauired for onsite remediation.
5. Gas Generation Records
~ Readily available ~ Up to date N/A
Remarks
6. Settlement Monument Records
~ Readily available ~ Up to date ^ N/A
Remarks
7. Ground Water Monitoring Records
Readily available [
3 Up to date EH N/A
Remarks
Groundwater monitoring records are electronic; logbooks are kept at the GHD office in
G-2
-------
Franklin, Tennessee.
8. Leachate Extraction Records EH Readily available ~ Up to date N/A
Remarks:
9. Discharge Compliance Records
1)^1 Air Readily available ^ Up to date EH N/A
1)^1 Water (effluent) ^ Readily available ^ Up to date EH N/A
Remarks: Records are electronic; logbooks are kept at the GHD office in Franklin, Tennessee.
10.
Daily Access/Security Logs
^ Readily available Up to date EH N/A
Remarks:
IV. O&M COSTS
1.
O&M Organization
EH State in-house
EH Contractor for state
1X1 PRP in-house
1X1 Contractor for PRP
EH Federal facility in-house
EH Contractor for Federal facility
n
2. O&M Cost Records
153 Readily available Up to date
~ Funding mechanism/agreement in place ~ Unavailable
Original O&M cost estimate: $140.000 EH Breakdown attached
Total annual cost by year for review period if available
From:
January 2018
To:
December 2018
$379,000
EH Breakdown attached
Date
Date
Total cost
From:
January 2019
To:
December 2019
$410,000
EH Breakdown attached
Date
Date
Total cost
From:
January 2020
To:
December 2020
$421,000
EH Breakdown attached
Date
Date
Total cost
From:
January 2021
To:
December 2021
$355,000
EH Breakdown attached
Date
Date
Total cost
From:
January 2022
To:
December 2022
$457,000
EH Breakdown attached
Date
Date
Total cost
3. Unanticipated or Unusually High O&M Costs during Review Period
Describe costs and reasons: The resin filter media became spent and is no longer available. The
treatment system now uses an organoclav filter media, instead. Although not a planned cost. BPI
did not consider the modification cost to be excessive.
V. ACCESS AND INSTITUTIONAL CONTROLS |EI Applicable ~ N/A
A. Fencing
G-3
-------
1.
Fencing Damaged ~ Location shown on site map
~ Gates secured
M N/A
Remarks:
B.
Other Access Restrictions
1.
Signs and Other Security Measures ~ Location shown on site map ~ N/A
Remarks: The treatment building is kept locked.
C.
Institutional Controls (ICs)
1.
Implementation and Enforcement*
Site conditions imply ICs not properly implemented
~ Yes
|EI No ~ N/A
Site conditions imply ICs not being fully enforced
~ Yes
No ~ N/A
Type of monitoring (e.g., self-reporting, drive by): Drive-by
Frequency: 1/year
Responsible party/agency: TDEC-DoR
Contact John Hoffelt Project
11/16/22
615 687
Manager
7067
Name Title
Date
Phone no.
Reporting is up to date
IEI Yes
~ No ON/A
Reports are verified by the lead agency
IEI Yes
~ No ~ N/A
Specific requirements in deed or decision documents have been met 153 Yes
~ No ~ N/A
Violations have been reported
1 1 Yes
IEI No ~ N/A
Other problems or suggestions: ~ Report attached
2.
Adequacy ^ ICs are adequate ~ ICs are inadequate
~ n/a
Remarks:
D.
General
1.
Vandalism/Trespassing ~ Location shown on site map
No vandalism evident
Remarks:
2.
Land Use Changes On Site ~ N/A
Remarks: None
3.
Land Use Changes Off Site ~ N/A
Remarks: None
VI. GENERAL SITE CONDITIONS
A.
Roads ~ Applicable ^ N/A
G-4
-------
1.
Roads Damaged
Remarks:
~ Location shown on site map ~ Roads adequate ~ N/A
B.
Other Site Conditions
Remarks: No issues noted
VII. LANDFILL COVERS ~ Applicable
IK|n/a
A.
Landfill Surface
1.
Settlement (low spots)
Arial extent:
Remarks:
~ Location shown on site map
~ Settlement not evident
Depth:
2.
Cracks
Lengths:
Remarks:
I~1 Location shown on site map
Widths:
1 1 Cracking not evident
Depths:
3.
Erosion
Arial extent:
Remarks:
I~1 Location shown on site map
1 1 Erosion not evident
Depth:
4.
Holes
Arial extent:
Remarks:
~ Location shown on site map
~ Holes not evident
Depth:
5.
Vegetative Cover
I~1 No signs of stress
Remarks:
1 1 Grass Q Cover properly established
1 1 Trees/shrubs (indicate size and locations on a diagram)
6.
Alternative Cover (e g
Remarks:
, armored rock, concrete)
~ n/a
7.
Bulges
Arial extent:
Remarks:
~ Location shown on site map
~ Bulges not evident
Height:
8.
Wet Areas/Water Damage Q Wet areas/water damage not evident
I~1 Wet areas
1 1 Ponding
I~1 Seeps
1 1 Soft subgrade
Remarks:
1 1 Location shown on site map
1 1 Location shown on site map
1 1 Location shown on site map
1 1 Location shown on site map
Arial extent:
Arial extent:
Arial extent:
Arial extent:
9.
Slope Instability Q Slides
~ No evidence of slope instability
~ Location shown on site map
G-5
-------
Arial extent:
Remarks:
B.
Benches ~ Applicable ~ N/A
(Horizontally constructed mounds of earth placed across a steep landfill side slope to interrupt the slope in
order to slow down the velocity of surface runoff and intercept and convey the runoff to a lined channel.)
1.
Flows Bypass Bench ~ Location shown on site map
Remarks:
1 1 N/A or okay
2.
Bench Breached ~ Location shown on site map
Remarks:
1 1 N/A or okay
3.
Bench Overtopped ~ Location shown on site map
Remarks:
1 1 N/A or okay
C.
Letdown Channels ~ Applicable ~ N/A
(Channel lined with erosion control mats, riprap, grout bags or gabions that descend down the steep side
slope of the cover and will allow the runoff water collected by the benches to move off of the landfill
cover without creating erosion gullies.)
1.
Settlement (Low spots) ~ Location shown on site map
~ No evidence of settlement
Arial extent:
Depth:
Remarks:
2.
Material Degradation Q Location shown on site map
~ No evidence of degradation
Material type:
Arial extent:
Remarks:
3.
Erosion Q Location shown on site map
~ No evidence of erosion
Arial extent:
Depth:
Remarks:
4.
Undercutting Q Location shown on site map
~ No evidence of undercutting
Arial extent:
Depth:
Remarks:
5.
Obstructions Type:
Location shown on site map Arial extent:
Size:
Remarks:
~ No obstructions
6.
Excessive Vegetative Growth Type:
~ No evidence of excessive growth
~ Vegetation in channels does not obstruct flow
^ Location shown on site map Arial extent:
G-6
-------
Remarks:
D.
Cover Penetrations ~ Applicable ~ N/A
1.
Gas Vents ~ Active ~ Passive
1 1 Properly secured/locked ~ Functioning ~ Routinely sampled ~ Good condition
1 1 Evidence of leakage at penetration ~ Needs maintenance ~ N/A
Remarks:
2.
Gas Monitoring Probes
1 1 Properly secured/locked ~ Functioning ~ Routinely sampled
1 1 Evidence of leakage at penetration ~ Needs maintenance
Remarks:
1 1 Good condition
~ n/a
3.
Monitoring Wells (within surface area of landfill)
1 1 Properly secured/locked ~ Functioning ~ Routinely sampled
1 1 Evidence of leakage at penetration ~ Needs maintenance
Remarks:
1 1 Good condition
~ n/a
4.
Extraction Wells Leachate
1 1 Properly secured/locked ~ Functioning ~ Routinely sampled
1 1 Evidence of leakage at penetration ~ Needs maintenance
Remarks:
1 1 Good condition
~ n/a
5.
Settlement Monuments ~ Located ~ Routinely surveyed
Remarks:
~ n/a
E.
Gas Collection and Treatment ~ Applicable ~ N/A
1.
Gas Treatment Facilities
1 1 Flaring ~ Thennal destruction
1 1 Good condition ~ Needs maintenance
Remarks:
~ Collection for reuse
2.
Gas Collection Wells, Manifolds and Piping
1 1 Good condition ~ Needs maintenance
Remarks:
3.
Gas Monitoring Facilities (e.g., gas monitoring of adjacent homes or buildings)
1 1 Good condition Q Needs maintenance ~ N/A
Remarks:
F.
Cover Drainage Layer ~ Applicable ~ N/A
1.
Outlet Pipes Inspected ~ Functioning Q N/A
Remarks:
G-7
-------
2. Outlet Rock Inspected ~ Functioning
Remarks:
~ n/a
G. Detention/Sedimentation Ponds ~ Applicable
~ n/a
1. Siltation Area extent: Depth:
~ Siltation not evident
Remarks:
~ n/a
2. Erosion Area extent: Depth:
1 1 Erosion not evident
Remarks:
3. Outlet Works I~1 Functioning
Remarks:
~ n/a
4. Dam ~ Functioning
Remarks:
~ n/a
H. Retaining Walls ~ Applicable ~ N/A
1. Deformations ~ Location shown on site map ~ Deformation not evident
Horizontal displacement: Vertical displacement:
Rotational displacement:
Remarks:
2. Degradation ~ Location shown on site map
Remarks:
~ Degradation not evident
I. Perimeter Ditches/Off-Site Discharge ~ Applicable
~ n/a
1. Siltation ~ Location shown on site map
Area extent:
Remarks:
~ Siltation not evident
Depth:
2. Vegetative Growth ~ Location shown on site map
1 1 Vegetation does not impede flow
Area extent:
Remarks:
~ n/a
Type:
3. Erosion ~ Location shown on site map
Area extent:
~ Erosion not evident
Depth:
Remarks:
4. Discharge Structure ~ Functioning
Remarks:
~ n/a
G-8
-------
VIII. VERTICAL BARRIER WALLS ~ Applicable ^ N/A
1.
Settlement ~ Location shown on site map ~ Settlement not evident
Area extent: Depth:
Remarks:
2.
Performance Monitoring Type of monitoring:
1 1 Performance not monitored
Frequency: 1"! Evidence of breadline
Head differential:
Remarks:
IX.
GROUND WATER/SURFACE WATER REMEDIES ^Applicable ~ N/A
A.
Ground Water Extraction Wells, Pumps and Pipelines ^ Applicable ~ N/A
1.
Pumps, Wellhead Plumbing and Electrical
Good condition All required wells properly operating Q Needs maintenance Q N/A
Remarks:
2.
Extraction System Pipelines, Valves, Valve Boxes and Other Appurtenances
Good condition Q Needs maintenance
Remarks:
3.
Spare Parts and Equipment
1X1 Readily available Good condition Q Requires upgrade ~ Needs to be provided
Remarks:
B. Surface Water Collection Structures, Pumps and Pipelines ~ Applicable N/A
1.
Collection Structures, Pumps and Electrical
1 1 Good condition Q Needs maintenance
Remarks:
2.
Surface Water Collection System Pipelines, Valves, Valve Boxes and Other Appurtenances
1 1 Good condition Q Needs maintenance
Remarks:
3.
Spare Parts and Equipment
1 1 Readily available Q Good condition Q Requires upgrade Q Needs to be provided
Remarks:
C.
Treatment System ^ Applicable ~ N/A
1.
Treatment Train (check components that apply)
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1 1 Metals removal ~ Oil/water separation Q Bioremediation*
^ Air stripping ^ Carbon adsorbers Q In-situ chemical oxidation*
Kl Filters: Liauid resin filters changed to clav: liauid carbon filters remain.
1 1 Monitored natural attenuation*
3 Additive (e.g., chelation agent flocculent):
1 1 Others:
Good condition Q Needs maintenance
Sampling ports properly marked and functional
Sampling/maintenance log displayed and up to date
Equipment properly identified
153 Ouantitv of ground water treated annually: 13.5 M sals
3 Quantity of surface water treated annually:
Remarks:
2.
Electrical Enclosures and Panels (properly rated and functional)
1 1N/A Good condition Q Needs maintenance
Remarks:
3.
Tanks, Vaults, Storage Vessels
1 1 N/A Good condition ^ Proper secondary contaimnent Q Needs maintenance
Remarks:
4.
Discharge Structure and Appurtenances
1 1 N/A Good condition Q Needs maintenance
Remarks:
5.
Treatment Building(s)
1 1 N/A Good condition (esp. roof and doorways) Q Needs repair
Chemicals and equipment properly stored
Remarks:
6.
Monitoring Wells (pump and treatment remedy)
1X1 Properly secured/locked Functioning Routinely sampled Good condition
All required wells located Q Needs maintenance Q N/A
Remarks:
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D. Monitoring Data*
1.
Monitoring Data
Is routinely submitted on time ^ Is of acceptable quality
2.
Monitoring Data Suggests:
Ground water plume is effectively contained ^ Contaminant concentrations are declining
E.
Monitored Natural Attenuation*
1.
Monitoring Wells (natural attenuation remedy)
1 1 Properly secured/locked Q Functioning Q Routinely sampled Q Good condition
1 1 All required wells located ~ Needs maintenance ^ N/A
Remarks:
X. OTHER REMEDIES
If there are remedies applied at the site and not covered above, attach an inspection sheet describing the physical
nature and condition of any facility associated with the remedy. An example would be soil vapor extraction.
XL OVERALL OBSERVATIONS
A.
Implementation of the Remedy
Describe issues and observations relating to whether the remedy is effective and functioning as designed.
Begin with a brief statement of what the remedy is designed to accomplish (e.g., to contain contaminant
plume, minimize infiltration and gas emissions).
The remedv is designed to contain groundwater via hvdraulic Dummng and treatment of the
groundwater to remove PCBs and TCE; the treatment train includes treatment of air emissions
from the air strii)i)ers. The remedv is functioning as designed.
B.
Adequacy of O&M
Describe issues and observations related to the implementation and scope of O&M procedures. In
particular, discuss their relationship to the current and long-term protectiveness of the remedy.
The remedv and treatment svstem has been in nlacc for 30 vears and is fullv functional.
C.
Early Indicators of Potential Remedy Problems
Describe issues and observations such as unexpected changes in the cost or scope of O&M or a high
frequency of unscheduled repairs that suggest that the protectiveness of the remedy may be compromised
in the future.
The Dreliminarv filters now must be changed twice i)er month due to high turbiditv and organic
carbon in the extracted groundwater. These conditions mav be related to the increase of PCBs
recovered and treated.
D.
Opportunities for Optimization
Describe possible opportunities for optimization in monitoring tasks or the operation of the remedy.
The former resin filter media was 99.99% effective whereas the organoclav rei)lacement media is
95% effective: however, the down-treatment-stream liauid carbon filters are able to effectivelv
adsorb the difference.
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Site Inspection Participants:
Amanda Howell, EPA
Jim Ferreira, EPA
John Hoffelt, TDEC-DoR
Kevin Kyrias-Gann, BPI
Winston Guidry, GHD
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APPENDIX H - SITE INSPECTION PHOTOGRAPHS
Photo 1 Site: Mallory Capacitor Company (TND 075 453 688, TDOR 91-501)
Date: November 16, 2022 Time: lllOhrs. Personnel: Amanda Howell, Jim Ferreira (EPA); John
Hoffelt (TDEC-DoR); Kevin Kyrias-Gann (BPI); Winston Guidry (GHD) Direction: Southwest
Description: Former warehouse building now houses the groundwater treatment system; extraction well field in
the photo midground with residences in background. Note privacy fence screens carbon air filters.
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««|WKl55i8^JwisW:41
HsSsSPH
Photo 2 Site: Mallory Capacitor Company (TND 075 453 688, TDOR 91-501)
Date: November 16, 2022 Time: lllOhrs. Personnel: Amanda Howell, Jim Ferreira (EPA); John
Hoffelt (TDEC-DoR); Kevin Kyrias-Gann (BPI); Winston Guidry (GHD) Direction: West
Description: View across Cole Street and along Belew Circle Drive toward the Town Square. Hydraulic
monitoring wells OW11-85 and OW-12-85 in the foreground with the extraction well field and former building
pads in the mid-ground. Residences on right edge.
Photo 3 Site: Mallory Capacitor Company (TND 075 453 688, TDOR 91-501)
Date: November 16, 2022 Time: 1000 hrs. Personnel: Amanda Howell, Jim Ferreira (EPA); John
Hoffelt (TDEC-DoR); Kevin Kyrias-Gann (BPI); Winston Guidry (GHD) Direction: East
Description: Piping from the extraction wells enters the groundwater treatment building.
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Photo 4 Site: Mallory Capacitor Company (TND 075 453 688, TDOR 91-501)
Date: November 16, 2022 Time: 1000 hrs. Personnel: Amanda Howell, Jim Ferreira (EPA); John
Hoffelt (TDEC-DoR); Kevin Kyrias-Gann (BPI); Winston Guidry (GHD) Direction: North
Description: Control panel for the groundwater treatment system.
Photo 5 Site: Mallory Capacitor Company (TND 075 453 688, TDOR 91-501)
Date: November 16, 2022 Time: 1000 hrs. Personnel: Amanda Howell, Jim Ferreira (EPA); John
Hoffelt (TDEC-DoR); Kevin Kyrias-Gann (BPI); Winston Guidry (GHD) Direction: South
Description: Air strippers and other parts of the groundwater treatment system.
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Photo 6 Site: Mallory Capacitor Company (TND 075 453 688, TDOR 91-501)
Date: November 16, 2022 Time: 1015 hrs. Personnel: Amanda Howell, Jim Ferreira (EPA); John
Hoffelt (TDEC-DoR); Kevin Kyrias-Gann (BPI); Winston Guidry (GHD) Direction: South
Description: Carbon treatment vessels.
Photo 7 Site: Mallory Capacitor Company (TND 075 453 688, TDOR 91-501)
Date: November 16, 2022 Time: 1045 hrs. Personnel: Amanda Howell, Jim Ferreira (EPA); John
Hoffelt (TDEC-DoR); Kevin Kyrias-Gann (BPI); Winston Guidry (GHD) Direction: East
Description: Treatment waste storage area.
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Photo 8 Site: Mallory Capacitor Company (TND 075 453 688, TDOR 91-501)
Date: November 16, 2022 Time: llOOhrs. Personnel: Amanda Howell, Jim Ferreira (EPA); John
Hoffelt (TDEC-DoR); Kevin Kyrias-Gann (BPI); Winston Guiciry (GHD) Direction: East
Description: Effluent discharge pipe to the Green River showing bedrock and chert gravel in riverbed (with
leaves accumulation). W. Guidry points to the sediment sample collect location.
Photo 9 Site: Mallory Capacitor Company (TND 075 453 688, TDOR 91-501)
Date: November 16, 2022 Time: 1105 hrs. Personnel: Amanda Howell, Jim Ferreira (EPA); John
Hoffelt (TDEC-DoR); Kevin Kyrias-Gann (BPI); Winston Guidry (GHD) Direction: South
Description: Green River looking upstream of the effluent discharge pipe.
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Photo 10 Site: Mallory Capacitor Company (TND 075 453 688, TDOR 91-501)
Date: November 16, 2022 Time: 1105 hrs. Personnel: Amanda Howell, Jim Ferreira (EPA); John
Hoffelt (TDEC-DoR); Kevin Kyrias-Gann (BPI); Winston Guidry (GHD) Direction: Northeast
Description: Green River from effluent discharge pipe showing chert gravel bar.
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Photo 11 Site: Mallory Capacitor Company (TND 075 453 688, TDOR 91-501)
Date: November 16, 2022 Time: 1125hrs. Personnel: Amanda Howell, Jim Ferreira (EPA); John
Hoffelt (TDEC-DoR); Kevin Kyrias-Gann (BPI); Winston Guidry (GHD) Direction: South
Description: Hydraulic monitoring wells 39-89 and 40-89 and soil gas vapor monitoring point GP1-04.
H-7
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APPENDIX I - INSTITUTIONAL CONTROLS
TITLE 14
CHAPTER 4
TITLE 14. - PROHIBITION ON GROUNDWATER WITHDRAWALS IN CERTAIN
AREAS
Section 14-100. - Title.
This Ordinance will be known as the "Waynesboro Groundwater Withdrawal
Ordinance."
Section 14-101. - Purpose and intent.
(a)
The purpose of this Ordinance is to provide for and protect the health, safety, and
general welfare of the citizens of Waynesboro through the regulation of
groundwater withdrawals and groundwater use in certain areas of the City [(See
sub-section (d)]. This Ordinance identifies the areas where groundwater
withdrawal and use will be prohibited; prohibits the installation of any new
groundwater withdrawal wells and the use of groundwater in those areas; requires
the decommissioning of all existing groundwater withdrawal wells in those areas,
prohibits the cross-connection of certain groundwater withdrawal wells in those
areas; sets forth the methods and the timeframe within which the
decommissioning of existing groundwater water withdrawal wells must occur,
and establishes the legal authority to carry out all inspection, surveillance and
monitoring necessary to ensure compliance with this Ordinance.
(b)
This Ordinance is not intended to interfere with, abrogate, or annul any other
ordinance, rule or regulation, statute, or other provision of law. The requirements
of this Ordinance should be considered minimum requirements, and where any
provision of this Ordinance imposes restrictions different from those imposed by
any other ordinance, rule or regulation, or other provision of law, whichever
provisions arc more restrictive or impose higher protective standards for human
health or the environment shall be considered to take precedence.
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(C)
The City manager or designee shall administer, implement, and enforce the
provisions of this Ordinance.
(d) See Legal Description and Map as Exhibit A attached.
Section 14-102. - Definitions.
ITic following words, terms and phrases, when used in this division, shall have the
meaning ascribed to them under the Tennessee Safe Drinking Water Act, the Tennessee
Water Wells Act, and the Water Withdrawal Registration Act and as described in this
section, except where the context clearly indicates a different meaning:
City means Waynesboro, Wayne County, Tennessee.
Decommissioning means the conversion of a nonpublic water well to a monitoring
well or plugging and abandoning the well in accordance with Tennessee law.
Properly abandoned means plugged and abandoned in accordance with
Tennessee law.
Groundwater means "ground water" as defined by Tennessee law.
Identified area means the area identified in Exhibit A, and any additional area as
identified by future resolution of the City.
Nonpotahle water means groundwater that is unsuitable for direct human contact
but is appropriate for other uses such as irrigation, landscaping, laundering, heating and
cooling systems, fire control, street cleaning and controlling dust at construction sites.
Owner means the holder of the title in fee simple and every mortgagee of record
of real property in the identified area.
Person means any individual, partnership, copartnership, firm, company, limited
liability company, corporation, association, joint stock company, trust, estate, political
subdivision, or any other legal entity, or their legal representatives, agents or assigns.
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Potable water means groundwater that is suitable for direct human contact and
uses such as drinking, cooking, bathing, and some construction activities such as making
concrete.
Public officer means the building inspector or any other officer who is authorized
by the City to exercise the powers provided in this Ordinance, or any agent of such
officer.
Well means a "well" as defined by Tennessee law, and may include a dewatering
well, drilling or drilling operation, engineering borehole, individual water well, industrial
well, irrigation well, monitoring well, nonpublic water well, and other water well; but for
the purposes of this Ordinance alone, "well" shall not include any monitoring well,
geoprobe, or other similar device or measuring instrument necessary to be installed or
undertaken to comply with applicable local, state or federal environmental laws and
regulations.
Section 14-103. - Connection of real properties in identified area to public drinking
system.
All portions of real property located within the identified area shall be served by
and connected to the public water supply system.
Section 14-104. - Prohibitions on installation of new wells and use of groundwater for
potable and nonpotable water purposes in identified area.
No new wells shall be installed or constructed on any portion of real property in
the identified area. No groundwater beneath any portion of real property located within
the identified area may be used for potable water purposes or for nonpotable water
purposes, including but not limited to irrigation. This prohibition on use shall apply
regardless of the manner in which the groundwater is brought to surface for use,
including but not limited to natural artesian pressure in a well or in a spring or other
natural feature.
Section 14-105. - Prohibition on cross connection to publicly provided water supply.
No connection or cross connection shall be permitted between an existing,
abandoned or closed well located on any portion of real property in the identified area
and any public water supply system or piping for any potable water purposes. The
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construction, connection, use, maintenance, or continued existence of any illicit
connection to a well located on any portion of real property in the identified area shall be
prohibited. This prohibition expressly includes, without limitation, illicit connections
made in the past, regardless of whether the connection was permissible under law or
practices applicable or prevailing at the time of connection.
Section 14-106. - Permanent closure of existing wells located on any portion of real
property in identified area.
Within 60 calendar days after the effective date of this Ordinance, all wells
located on any portion of real property in the identified area, whether currently or
formerly used for potable or nonpotable purposes, shall be permanently decommissioned,
either by converting to a monitoring well or by being properly plugged and abandoned in
accordance with Tennessee law and all applicable guidance from the Tennessee Division
of Water or the Tennessee Geological Survey. The City will decommission all applicable
wells located on any portion of the identified area at the City's cost and expense, provided
the property owner requests such decommissioning writhin 30 days after the effective date
of this Ordinance. In the event any well on any portion of property located within the
identified area is required to be decommissioned under this Ordinance, the owner of such
property shall notify the county within 30 days of the permanent closure of such well,
certifying that the well has been decommissioned in accordance with this Ordinance.
Section 14-107, - Enforcement,
(a)
It shall be unlawful for any person to violate any provision, or to fail to comply
with any of the requirements, of this Ordinance. Any person who has violated or
continues to violate the provisions of this Ordinance may be subject to the
enforcement actions outlined in this Ordinance or may be restrained by injunction
or otherwise abated in a manner provided by law.
(b)
Whenever the City manager or designee finds that a person has violated a
provision or failed to meet a requirement of this Ordinance, the City manager
shall provide written notice of violation to the responsible person. The notice of
violation shall contain;
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(1)
The name and address of the resident or lessee at the property;
(2)
ITie street address or, if a street address is not available, a description of
the property, structure or land upon which the violation or failure to
comply is occurring;
(3)
A description of the violation;
(4)
A description of the measures necessary to bring the property into
compliance and a time schedule for the completion of such measures; and
(5)
A statement of the penalty or penalties, if any, that will or may be assessed
against the person to whom the notice of violation is directed.
Included in the notice of violation, whenever the City manager or designee finds
that a person has violated a provision or failed to meet a requirement of this
Ordinance, the City manager may issue an order to the responsible person to
undertake any or all of the following actions:
(1)
Decommission any and all temporary or permanent wells, including any
related piping or equipment;
(2)
Eliminate or disconnect any illicit groundwater connections, cross-
connections or other uses;
(3)
Cease and desist any uses of wells;
(4)
Abate or otherwise correct any hazards to public health and safety created
by the activity violating this Ordinance; and
(5)
Pay all expenses and a fine to cover administrative costs.
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Any person receiving a notice of violation from the City manager may appeal the
determination to the City Board of Commissioners. A written notice of appeal
must be received by the City Recorder -no later than ten days after the date of the
notice of violation, and the failure to file a written notice of appeal shall constitute
a waiver of all claims. A hearing on the appeal before the City Board of
Commissioners shall take place within 30 days from the date the Board of
Commissioners received the notice of appeal. The decision of the Board of
Commissioners shall be a final action and may be appealed in accordance with
Tennessee law.
If after 20 days the violation has not been corrected pursuant to the requirements
set forth in the notice of violation, or if no appeal has been filed in a timely and
appropriate manner, the City manager or designee shall have the authority to enter
upon the real property, and is authorized to take any and all measures necessary to
abate the violation, including but not limited to decommissioning the well. It shall
be unlawful for any person, owner, agent or person in possession of any premises
to refuse to allow the City or its designated contractor to enter upon the premises
for the purposes set forth above.
Any notice of violation or order issued by the City manager pursuant to this
Ordinance shall be served upon each person in possession of the real property or
to the record owner of the real property, in compliance with applicable law. Any
person who is affected by an order issued pursuant to this Ordinance may petition
the Circuit Court of Wayne County for an injunction restraining the City from
carrying out the provisions of the order; provided, however, that such person shall
present such petition to the court within 15 calendar days of the posting and
service of the order of the City. The court shall hear and determine the issues
raised and shall enter such final order or decree as law and justice may require;
provided, however, that it shall not be necessary to file bond in any amount before
obtaining a temporary injunction under this section.
In addition to the enforcement processes and penalties provided in this chapter,
any condition caused or permitted to exist in violation of any of the provisions of
this article is deemed a threat to public health, safety, and welfare, and is declared
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a nuisance, and may be summarily abated or restored at the violator's expense:
and a civil action to abate, enjoin, or otherwise compel the cessation of such
nuisance may be taken by the City or by any citizen permitted by law to file such
an action to abate a nuisance.
(g)
Any person that has purposefully violated or continues to violate this Ordinance
after receipt of a notice of violation shall be liable to prosecution to the fullest
extent of the law, and may be subject to a criminal penalty of $50.00 per violation
per day. Each day a violation continues, after notification thereof, shall be deemed
a separate offense under this Ordinance. The City shall be entitled to recover all
attorney's fees, court costs and other expenses associated with enforcement of this
Ordinance, including sampling and monitoring expenses, upon proof of the
violation.
(h)
The remedies listed in this Ordinance are not exclusive of any other remedies
available under any applicable federal, state or local law, and it is within the
discretion of the City manager or designee to seek cumulative remedies.
Section 14-14)8. - Costs incurred by City for violation shall be lien on property.
(a)
(b)
1-7
Within 30 days after abatement of a violation, the owner of the property will be
notified of the cost of abatement, including administrative costs. The notification
will include a description of the costs and expense incurred by City, its employees
or contractors. If the amount due is not paid within 30 days of receipt of the
notification, the charges shall become a special assessment against the property
and shall constitute a lien on the property for the amount of the assessment. Any
person violating any of the provisions of this Ordinance shall become liable to the
City by reason of such violation. Such lien shall attach to the real property upon
payment of all costs by the City and the filing of an itemized statement of costs
with the Register's Office of Wayne County, Tennessee, on a lien docket
maintained by the clerk for such purposes.
The City may enforce the collection of any amount due on such lien in the
following manner:
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(1)
The owner shall be allowed to satisfy the amount due on such a lien by
paying to the City within 30 calendar days after the perfection of the lien,
a sum of money equal to 25 percent of the total amount due and by paying
the remaining balance due on such lien, together with interest at the rate of
seven percent per year, in three equal annual payments, each of which
shall become due and payable on the anniversary date of the initial
payment made as prescribed in this subsection;
(2)
If the property upon which such lien is perfected be sold, transferred, or
conveyed by the owner or parties in interest at any time prior to the
termination of the three year period, then the entire balance due on such
lien shall be due and payable by the selling party to the City: and
(3)
Should the amount due on such lien, or any portion thereof, be unpaid
after the passage of the three-year period, or upon the occurrence of the
contingency provided for in subsection (2) of this section, the City may
enforce the collection of any amount due on such lien as provided by
Tennessee law. This procedure shall be subject to the right of redemption
by any persons having any right, title, or interest in or lien upon said
property.
Section 14-109. - Powers of public officers.
(a) The City manager shall have and exercise such powers as may be necessary and
convenient to carry out and effectuate the purpose and provisions of this Ordinance,
including but not limited to the following powers:
(1) to investigate real property located within the identified area
to determine compliance with this Ordinance;
(2) to enter upon real property for the purpose of making
examinations; provided, however, that such entries shall be made in such manner
as to cause the least possible inconvenience to the persons in possession;
(3) to appoint and fix the duties of such officers, agents,
contractors, and employees as the City manager deems
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necessary and convenient to carry out the purpose of this
Ordinance;
(4) and to delegate any of said functions and powers under the
Ordinance to such officers and agents as the City manager may designate.
Section 14-110. - Administrative appeal.
(a)
In addition to the rights of appeal above, any person aggrieved or significantly
affected by an action of the City manager pursuant to this Ordinance may present
a grievance to the Board of Commissioners for a hearing within 30 days of the
decision or order of the City manager. In such case, the Board of Commissioners
shall issue a written finding on the facts, evidence and arguments put forth at the
hearing,
(b)
Any person aggrieved or affected by the decision of the Board of Commissioners
shall have the right to appeal the decision of the Board of Commissioners to the
Circuit Court of Wayne County. Appeals to the Circuit Court shall be filed no
later than 30 days after the date of the decision of the Board of Commissioners,
and upon failure to file said appeal within 30 days, the decision of the Board of
Commissioners shall be final and not subject to appeal.
Section 14-111. - Miscellaneous.
(a)
If any subsection, sentence, clause, phrase or word of this Ordinance is for any
reason held to be invalid or unconstitutional by a court of competent jurisdiction,
such decision shall not affect the validity of the remaining portions of this
Ordinance.
(b)
Nothing in this Ordinance shall be construed to abrogate or impair the powers of
the courts or of any department of the city to enforce any provisions of its
ordinances or regulations, nor to prevent or punish violations thereof. The powers
conferred by this Ordinance shall be in addition to and supplemental to the
powers conferred by any other law or ordinance.
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(C)
In the computation of time for actions or events under this Ordinance, if a time
period ends on a Saturday, Sunday, or national holiday, the time period shall
extend to the next business day.
Section 14-112. - Effective date.
This Ordinance shall take effect on the 30th day following its adoption.
Section 14-113 et seq. - Reserved,
BE IT ORDAINED that this Ordinance shall be in full force and effect from and after its
passage, the public welfare and safety of the citizens of the City of Waynesboro requiring it.
Passed first reading , 2014
Passed second reading /jjAy ,^7 2014
Motion was made by HvuJ & ! ^ seconded by
{~ _, that the preceding Ordinance be adopted.
Those voting for the adoption thereof were CcrOfA- f-iC(AJe f / (nfYl/n. }
Those voting nay were:
AlodZ-
ATTKS^
TC '
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Google Earth Pro
feet
meters
1. Intersection Hwy 64 and Brewer Dr. at 35 degrees 19' 21.04" N, 87 degrees 45' 35.95" W
2. To the NW corner of parcel APN: 077C A01 000 000 and along the N boundary of of above parcel and
parcel APN: 077C A 01 001 000.
3. To intersection of extension of above northern parcel boundary with Waynesboro City Limits at 35 19'
19.77" N, 87 45' 23.54" W.
4. Follow City limit boundary South to intersection of Frank Boyd St extended to the SE corner of parcel
APN: 077G G 02400 000 at 35 18' 57.10" N, 87 45'27.85" W.
5. West along s parcel boundary and Frank Boyd St. to intersection of Frank Boyd St and South Main
Street at 35 18'58.56" N, 87 45' 45.94" W.
6. North along South Main and North Main to the intersection of North Main and Water St. at 35 19'
16.13" N, 87 45' 43.61" W.
7. Extend line Northeast to coordinate at Number 1 above at intersection of Hwy 64 and Brewer Dr.
4 Exhibit A - Map and Legal Description for Waynesboro Groundwater Withdrawal Ordinance
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NOTICE OF LAJND USE RESTRICTIONS
Notice is hereby given that pursuant to T.C.A. Section 68-212-225 of tbc- Hazardous
Waste Management Act of J 985, the Commissioner of the Tennessee Department of
Environment and Conservation ("TDEC") has determined that land use restrictions are an
appropriate remedial action at the beicw-describcd property. Pursuanf to 1,C,A. Section 68-212-
225(d), the register of deeds shall record this Notice and index it iti the grantor index. under the,
names of the owners of the land.
Witnesseth:
WHEREAS, Battery Properties, Inc. ("Grantor") is the owner of the real property
located oil Belew Drive, Waynesboro, Wayne County, Tesinessee. commonly and formerly
known as the Malloty Capacitor Company Superfund Site (hereinafter the "Propertywhich
was conveyed to Granlor by deed and recorded in the Register of Deeds' Office of Wayne
County (hereinafter "Register's Office"), at Boole 112, Page 162, as more particularly described
in Exhibit A, attached hereto and incorporated herein by reference;
WHEREAS, the Property is currently being remediated and monitored by Grantor under
the oversight of the United States Environmental Protection Agency ("EPA ), in cooperation
with TDEC, pursuant to the Comprehensive Environments! Response, Compensation, and
Liability Act, 42U.S.C. §§ 9601, et seg^ as amended ("CERCLA"). The remediation and
monitoring is being performed in & maimer consistent with the following: (a) the National
Contingency Plan, 40 C.F.R. Part 300, as amended ("NCF'j, to levels protective of human health
Mid the environment, as more particularly described in EPA's Record of Decision, issued in
September 1991 ("ROD"); and (b) die Unilateral Administrative Order for Remedial Design and
Remedial Action issued to Grantor by EPA on March 4,1992;
WHEREAS, the ROD requires (he implementation of institutional controls; and
WHEREAS, Grantor has agreed to impose as institutional controls certain land use
restrictions on the future use of the Property as set forth below.
NOW, THEREFORE, for and in consideration of the premises and other good and
valuable consideration, the receipt arid sufficiency of which is hereby acknowledged, Grantor
hetebv declares that all of the Property shall he held, sold, and conveyed subject to the following
land use restrictions, which shall run with the Property and shall be binding on all part.es having
any right., title, or interest in the Property or any part thereof, their hears, successors, and assigns.
I. Background of Contamination
1 The 8 5 acre Property is part of the Mallory Capacitor Company Superftind Site ("Site")
in Waynesboro, Wayne County/Tennessee, Electrical capacitors iwremaaufact^cm the
Property from 1969 to 1984, resulting in the release of polychlorsnated bjphenyls ( FUjs ) to
^ twiib Kogx-itor
Wayti* County TcMiftiiaiiQo
Raq ~: 51757 tBStrwoat #; S$l5i
HflO'd; 56.00 ttnoo*rfe
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Notsre of Land-Use Restrictions
Buttery Properties, inc. Property
ftelew Drive, waynesbwo, TN
soil at the Property and Use release of PCBs and volatile organic compounds f'VOCs"),
including trichloroeihene ("TCG") and 1,2-dichlt>roethene ("1, 2-DCE"), into (he groundwater.
2. Areas of the Property with soil PCB contamination abo ve 10 parts per m illion ("ppm")
were excavated down to. bedrock. Soils from the property determined to contain 10 ppm PCB or
less were used as fill dirt. Additional backfilling was completed with clean imported soils, EPA
and TDEChave determined that tlie remaining soil PCB levels are acceptable for industrial use.
X Currently, elevated levels of 1,2-DCE; TCE; and PCBs exist in the groundwater plume
under the Property, as depicted in Exhibit B, attached hereto and incorporated herein by
reference, As stated above, Grantor is monitoring and cleaning up this groundwater
contamination under EPA's oversight, in cooperation with TDEC, and irt accordance with the
ROD. The remedy includes hydraulic containment of contaminated groundwater and
contaminant mass removal utilizing groundwater extraction wells. Contaminated groundwater is
treated via air stripping, bag fittration and carbon adsorption. Treated groundwater is discharged
to the Green River east of the Property,
n. Land Use Restrictions
4. The Property shall not be used in any manner that would interfere with the performance
of the remedy called for in the ROD. Prohibited activities includes, but are not limited to, any
activity that would disturb wells or other equipment used to perform the remedy, or that would
limit access to wells and equipment.
5. The Property shall be used for industrial purposes only. In the event that any part;'
proposes a use of the Property for any non-industrial purpose, including but not limited to use as
a residence, domicile, daycare, school, church, elder care facility, playground, lecreatiopal
facility, or -form, then Grantor, its successors, and/or assigns shall givt prior written notice to
EPA, and must demonstrate to the satisfaction of TDEC that such proposed use will not pose an
unacceptable risk to public health, safety or the environment, and must obtain written approval
from TDEC before proceeding with the proposed use. For any approval granted by TDEC to be
effective, TDEC's approval shall be in writing, shall contain a reference- to this instrument, and
shall be filed hi (lie Register's' Office,
6. Except as provided in Paragraphs 6.a. and 6,h. below, before any land disturbing activity
occurs on the Property, Grantor, its successors, and/or assigns will provide no Jess than forty-five
(45) days written notice to TDEC and EPA of the location of the proposed disturbance. If
neither TDEC nor EPA provides written objection, within forty-five (45) days after its receipt of
notice, Grantor, its successors, and/or assigiis may proceed with the contemplated disturbance. If
TDEC or EPA. within forty-five (45) days after its receipt of notice responds in writing with
objections to or conditional approval of the proposed disturbance subject to terms or conditions,
2
1-14
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Notice of [.and Use Restrstikms
Battery Properties, inc. Property
Belew Drive, Waynesboro, TfJ
Grantor. its i.uccesscrs, and/or assigns stall proceed only in accordance with the terms or
f0^J[10n® specihod by TDEC or EPA. Lend disturbing activities include, but are net limited to,
building, filling, grading, excavating, mining, and boring. If TDEC ox EPA invests terras or
conditions as part of a conditional approval of a contemplated land disturbing activity, it may
additionally require in its conditional approval that Grantor, its successors, and/or assigns file
stJ tcrms or conditions in the Register's Office, together with a reference to this instrument.
a. Activities that arc related to further investigation or remediation of the Property
are exempt from the requirements of Paragraph <5. Such activities are required to be approved by
EPA m an appropriate work plan under the March 4, 1992. Unilateral Administrative Order and
must address risk to public health, safety, or the environment in an activity-specific Ifealth and
wfety Plan (' HASP"). Ail documents related to the investigation and remedial activities are
filed sn the Administrative Record and are not required to be filed with the Register's Office.
b, ff.it becomes necessary to perform any land disturbing activities as part of a
response to an emergency (e.g., repairing-atilily lines or responding to afire, flood oranv other
casualty), the requirements of Paragraph 6, except subparagraph c, shall be suspended, provided
that Grantor, its successors, and'or assigns:
i- Shall notify TDEC and EPA of such emergency as soon as possible, but no more than
twenty-four (24) hours after having learned of such emergency;
ii. Shall limit the actual land disturbance to the minimum reasonably necessary jo
adequately respond to the emergency;
Hi. Shall implement all measures necessary to limit unacceptable actual or potential risk to
public health, safety, public welfare or the environment; and
iv, Shall engage an environmental consultant to oversee the emergency excavation.
c. Notwithstanding any other provision of this document, all soil eiccavated at the
Property shall be managed, transported, and/or disposed in conoplisiKe with all applicable
federal, stale, and local laws, regulations, and ordinances including, without limitation, those
pertaining to environmental protection and occupational safety. In all instances of land
disturbance. Grantor, its successors, and/or assigns shall document the disturbance and whether
handling of excavated soils is in compliance with all such legal requiremente. Grantor, its heirs,
successors, and assigns shall make said documentation available to TDEC and EPA for
inspection and shall submit the documentation to TDEC and EPA upon request,
7, The installation of potable groundwater wells, and the access, extraction or use of
groundwater from the Site for any reason is prohibited, except for the installation of those wells
3
1-15
-------
Nfltks of Lar>d Use Hfistrictjons
Battery Properties, Inc. Property
BeJew Drive. Waynesfcero, TK
installed as a part of the ongoing remediation of the property arid the access, extract ion or use of
groundwater from those wells in the implementation of approved remedial activities. In the
event any party proposes installation of additional groundwater wells oc the access, extraction or
use of groundwater for any purpose other than the implementation of approved remedial
activities, Grantor, its successors, and/or assigns shall give prior written notice, to EPA, and must
demonstrate to the satisfaction of TDEC that such use of the groundwater will not pose, an
unacceptable risk to public health, safety or the environment and must obtain written approval
from TDEC before proceeding with the proposed use. For any approval granted by TDEC to be
effective, TDEC's approval shall be in writing, shall contain a reference to this instrument, and
shall be filed in the Register's Office.
8. Grantor, its successors, and/or assigns shall notify TDEC within no more than thirty (30)
days after any conveyance of any ownership interest or any conveyance of my leasehold interest
of all or sabstantiallyall of the property (excluding mortgages, liens, and other non-possessory
eDcumbranoes or conveyances), which notice shall include a copy of transfer documentation and
contact information for ail parties.
HI, Enforcement
9. This Notice of Land Use Restrictions may be enforced by any owner of the Property. The
Commissioner of TDEC, through issuance of an order or by means of a civil action, including
one to obtain an injunction against present or threatened violations of the restrictions, may also
enforce this Notice of Land Use Restrictions. This Notice of'Land Use Restrictions may also be
enforced by any unit of local government having jurisdiction over any part of the Property, by
means of a civil action without the unit of local government having first exhausted any available
administrative remedy.
10. The parties expressly recognize and agree that EPA is a third-party beneficiary of ibis
Notice of Land Use Restrictions and, as such, has the right of enforcement, through means that
include but are not limited to a civil action, including one to obtain att injunction against present
or threatened violations of the Notice of Land Use Restrictions. The parties expressly recognise
and agree that this Notice of Land Use Restrictions does not grant LP A or 1 DEC any interest in
the Property.
11. Any person who owns or leases the Property shall abide by this Notice or Land Use
Restrictions, Pursuant to T.C.A. Section 68-212*213, any person who fails, neglects or refuses to
comply with a land use restriction commits a Class B misdemeanor and, in addition, is subject to
a civil penalty of up to ten thousand dollars (1110,000) per day.
4
1-16
-------
Notice of land Use Restrictions
Battery Properties, Inc. Property
Belew Driw, Waynesboro, TN
rv. Notice
12. Grantor, its heirs, successors, and assigns shall include the following notice on all deeds,
mortgages (where modification to the mortgage form is allowed), piats, orany legal instruments
used lei convey any interest in the Property, The failure to comply with this paragraph doss not
impair the validity or enforceability of this Notice of T,and Use Restrictions.
NOTICii; This Property Subject to Notice of Land Use Restrictions aad any subsequent
Amendments Recorded at _ '
V. Compliance
13. Within 30 days following a written request by TDEC or EPA, Grantor, its successors,
and assigns shall submit a report to TDEC and EPA detailing the Property owner's compliance,
and any lack of compliance, with the terms of this Notice of land Uso F estri cti otss for the 12-
month period preceding the written request. The report shall include the items listed in Exhibit
C, attached hereto and incorporated herein by reference. The duty to provide such report shall
inure to the current owner of the Property at the time of the request; once title io all or a portion
of the Property has been conveyed by Grantor or any subsequent owner, such predecessor in title
shall no longer have any responsibility for submission of die report with respect to the portion of
the Property it previously owned. In addition, within thirty (30) days following any transfer of
ownership, the transferring parly shall submit to TDEC and EPA a report (in addition to the
notice of transfer pursuant to Paragraph 8) detailing that transferring party's compliance, and any
lack of compliance, with the terms of tills Notice of Land Use Restrictions for Hie ] 2-month
period preceding the dale of transfer.
VI. Term
14. This Notice of Land Use Restrictions shall run with and bind the Property unless and
until it is made less stringent or canceled as set forth under Section Y1I, "Amendment and
Termination".
VI3. Amendment or Termination
15. In accordance with T.C.A. Section 6S-212-225(e}, after public notice and an opportunity
for public input, this Notice of Land Uae Restrictions may be amended or terminated by the
Commissioner of TDEC if the risk has been eliminated or reduced such that less restrictive land
use controls ate protective of human health and the environment. Grantor, its heirs, successors
and assigns may request such amendment or termination by written request delivered to TDEC
and EPA. EPA shall have forty-five (45) days after receipt of such request within which to
comment to TDEC on such proposed amendment or termination. No amendment to or
5
1-17
-------
Notice of Land Usa Restriction;
Battery Properties, fnc. Property
BsHev.1 Drive, Waynesboro, TN
termination of this Notice of Land Use Restrictions shaii be tffective until such am end merit or
inatrnment terminating this Notice of Land Use Restrictions is recorded in the Register's Office.
VIII. No Property Interest Created in EPA or TDEC
16. This Notice of Land Use P^estriciitins does not in any way create any interest by EPA or
TDEC in the Property. Furthermore, the Act of approving this Notice of Land Use Restrictions
does not in any way create soy interest by EPA or TDEC in such Property.
IX. Severability
17, Invalidation of any of these covenants or restrictions by judgment or court order shall in
ug way affect any other provisions, which shall remain in fill! force and effect.
5
1-18
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Notice of Land Use Restrictions
Battery Properties, Inc. Property
Bciew Drive, Waynesboro, TN
IN WITNESS WHEREOF, the undersigned hss executed this Instrument tin this day
of I^W ,2011.
Grantor
Battery Properties, Inc.
By: H A NWJkj A
fts; K^ir .secretCv
Before irui, (he muior5)gt>cS Notaty Public in and for the State aforesaid, personally
aaoeaied and by his or her signature
executed the fofegcrfng fsstrament for the purpose therein contained.
WITNESS, fcis IHgdiy.{
csir
Notary Public L
Conrmi scionExpiration ^ If
2011.
OTT^tL,
OFBCWLSm
DQNNA L KOCH
H0TW5Y RJSIIC-STATE OF attfffltS
WCQMMtS&CW £)B>iRKtOMSffJ
IN WITNESS WHEREOF, TDEC has detenpmei that the land use restrictions herein, are m
appropriate remedial action at the Property, and hereby approves this instrument pnrstiaut to
Tern. Code Ana, Section 68-2U-225(a) on this /f day of , 2011.
Tennessee Department of Enviedomental and Conservation
By:
Commissioner
Before me the undesigned Notary Public in and for the Siate aforesaid, personally
appeared _ ^ture
executed the foregoing instrument for the purpose thsrti
mrtmss, this l^P"day of _~Qu,Lj , 2f fitf^^0%
Nctarv Public ^ !$\>\ rS|\ ^
?!
1-19
-------
Notice of Land Use Restrictions
ftattefy Properties, inc. Property
Relew Drive, Waynesboro, TK
Commission Expiration _
Tills Notice of Land Use Restrictions is hereby accepted by the Uitiitd States Environmental
Protection Agency as a third party beneficiary^ this 4/jj( day of /fts,4r/ c~t^ 20! 1,
U.S. Enviro&t&iSjtSl Protection Agency, Region 4
/* FhimLdij] R Hi]]
tr-vfi
Director
Superfund Division
B
1-20
-------
Wotlce of land use RestrittKins
flattery Properties, Inc. froperty
Dfilew Drive, VVavsWitcro, TN
Exhibit A
Deed and Parcel Mop
1-21
-------
m
ST. Of BOX
CtTV, jTATt
Zt3> CODE _
HAd £_
«»s3;-
^jXaJ' CtMr^As'
31? 33?-&/&9
-jfr CFTtMW^WATrt^COlNFV
-oragetoji hsw^r-anet and wr^tM-fr*
aj If.
ii-sstwnatwJHafii
¦..-SlRW^h^Dt fqagJCl
OJJ.7" [
ftggi bxuci
fcesftftr
PogftflA
1-22
-------
TO
BMrna-iseepgiES. xkc.
^DBitli IIMCHWU (1) *1 rOLUJW« =
Battery Properties;, ag,
Kraft Cboirt - Of
no-nw * anient
Slesiviow, il 3S
Font ~
iiwri
ir. 9. n.
wemsBO Br:
(M&GB95 a KEJfflSID
Attorneys at Law
First rattiest; center, 12th Floor
Rsshvllle, W 37258-0109
KlNb TAX BDLLIt -ifr,
Nstt otrvsr
I
tf^itr4auitl
rcwrt
tFOR ftEORTWG Wl\
H.^AP-CBi. huSSS?
STATE OP j'ftrr.Mgfta
COtWTT OF Davidson J
IBs KmiM. conkbsw.tkw oft vat®. wantm-
EVER IS CBRWS8. POa TfSSTMM«K IS
«i.QTO.oo ^— Wrt32-2~*
snjuscFrato am sworV -to nfflwi m, this ths
2&l..rB*Y or m . iJ1^— -V
(' HCUtj
MY CDifMISftQU -
(AFW* S£-Uv
speciMi HRjmaim desd
POS aME> i[f cossjBEROTloif of the aiujii of One Thousand Dollars
($1 j OOll 00) r oaeh in hand paid by tie hereinafter ns^ed Grantee, the
receipt of which is hereby acknowledged, nqBaCEM IBTERHKTIOSil,, XBC.,
a Delavara corporation, hereinafter called the GHAUTOft, has bargained
and sold, and by. these presents does transfer and convey unto BATTBSUf
J'SOPEHffiBs, inc., a Delawax® corporation, hereinafter called the
GEAHTEE, its successors end assigns, a certain tract or parcel of land
located in Wayne county, ECata of Tennessee, descrlikad as follows,
bo-witj
BSGIKHIEG on an iron pin in the South margin of Sslew
circle, thu, same being this ftortiioaet comer of th© lot, of'
fJarold Cole as recorded in Deed 3ooJc Ho. 47, page 565,
Bolster's Office for Wayao County, Xeanessee; thence with
the South margin of Sales Circle, South 36' 21' 00" East
passing eat railroed splice at 654,3 feet, passing set
railroad spike at the intersection on the South margin of
Balew street and the wast margin of osle Straet at, 670,0
feet, paasiwpr 1/2 inch iron ptpa sat as witness corner at
939,40 feet, In all 95$. Q feet to a point in Grettn Sliver j
thence 3outh 13' 34' 03" West 460,6B feet with the meanders
to a point in said river; thenoe Worth S6° 33' 00" Wast
passing iron pin witness corner at 10,88 feet, l/'i trash iron
pipe1 on Waet margin o£ Col® Street on North margin of. Kariva
Street at 200,0 feet, in all 649,(1 feet to an iron pin in
the North margin of Hariva Street, the sanis being the South-
east corner of Lot Mo, 37 in the Frank Boyd a
-------
Jl.
ctJBUce witsi Snath 16* $!' *8.* West 211,1 fwt tp
¦wi iros p&ft iP, ttui OSTOeS nf cJi& Icna^ thz hacta btirjq tt.u
nec^HWKt www or H, e , nail ay is xuardod in ohe(5 #«>k
TSg. J5, pafs H?, Rftgist??:'# offiw tat sfajao chanty*
tfirn«rtdrjr>, fcho Uaitbaiat eiwtws 1>L ttli lj&t 9mVi4 lavrios
as recorded in Stead 3^1*1 n&„ It, pa^e fsi, ?iK|icta;'r Ofificft
foi H»yi» Csanti', ffcnawwjRr eni hHi* Ssuthssat ccfifce sff
C* s. Bel^w lats fch&isc with tiis fifsittia, Seefch Q* S3* 27*
Saab i$S,St f«0t. rtifi SJ« being tiso East tic.-lhidsft' V& lS)t*
tfa. 4i 7j flCMl aj Sa tliii at bftgltrcitigF t*arttafnin¥ CW>.
fnelufcd iritkin Eka active dTjtoripiJsii 1e an aanefcPi #9*
fcri Ira. to citfr City of
«i¥T.CBbOCi5 «d UftJBfl ClMrity bf»iTA Cei=fi"af.f
"Tc-ftJlfcrroijO, nrti thfl -Cit^f Ot tteyraabBW* bp A^oi doiartJ
tejyfiif 13, Itil, ifl. is 9W4 ȣS frit to Utt Ssntl: rtttESiii 0* &#!&* Clitilfl; StltUsC*
ti* 7C.4 £«mt ws » rail£oed «p&K» in tl» Sewsh
pi lwl#y CHiclni t)i(iiW!Ht mm 1«4>ris, fry 5f3 W Dbet!! BiwS to. 3S, 13((
lUftfiistffr'p Ofiiw fM tfayno OandtVj WW!j*#<=ui cans ti€nce
3&uth >6* 2*1 East »N.« foot t« tlw d>nt»r uruflft Kll'tn
fcnanca- itateh St. 4 Cdaij tJiOftW HOBlH Et* J4' tost IfftiSiS^ *
flu J?' 3T" Iu« ifl.Di £«St fRWO ttuS »5TfVn«t
4& «wi4 CrSf WHf# i*Mt Bt. iGS.U £*»&, i* *11 JtSft.i
tact to thfr P»»t aa.*eri» ftsMrl ptrwt; tlmtuso fliiiiai SJ.O
tact fc? tli» 4aM-W pargiB t>C JelMf «t tAa HfertJ»»WMf
©reww #i tlia Jlarsifi CelC lot.** CflGQidwl Bissk ifo.
41, tutor, Si5, JtMietWD rcjMctt fee tfityn? "Smwity, • ttfcmatiiwtaj
ihesiw Setstli &6* i*1 to* -in t f«rt tc th? &t
bHlaiMi bbIhA Jfcrwfi now liiinfil M KHJlPrf ClTCk »nrl la «-foi
•an TraCurde^ ill P-as&fe Ii>. S2j 3SSP fl^iBfc^TLl
£n( tJayr.w dCiftlty, Ti^eairo, in Scrdet Mo- 1
ft]rHO' *p£tfc®T kiwi'ti flS Str»-ot ta?, ? flfl necstrisd in
BaDd We, lfi. fas® »(. RSfliawx'® 0Pft2E. f*Jr Vayiio
CSiyiaMf, tflwufsseftx sni li«u^ Wa- is> ^3*" 145 * ,
TSegiiJrtBr1-H OfliCT for W4/ns iieuiniSr ¦JaniBflau^ t i» ¦«»
lrstorflhccd tf.fl iflli-'Jia •
BFINE 31,0 f^ot Ju vlSlH worth end JSwtH Wi£ SatKKliSJ
iff 3C Eait i« SollftWSl
flSGCTKCTB Da «3 ie«i pis J»i tilt *SWtb bbE^IJV 9t. Jpel^ll
Jta.lU pin bsift? Ww 3g«IJM«
-------
1Q HAVE ABC TO HOIB the said real property -togeth&r with all
appurteaaiice£"-0nd hereditament's thereunto helongirvj or In any wise
appertaining to f!RHNSK2r its suoijesBars and assigns, forever.
Graxtok, with regard to setters arising subsequent to GSAHTOR' S
acqaisition of audi property, does covenant with flEftjstBS that GEM'TOR
is lawfully s®i«*d and possessed of said land in Pee simple, Kau a
good tight to oonvey it, ana the Kama la tnesicupbetfed escept for those
^attars set forth isi Exhibit A attaches hereto and incorporated hereir,
by reference, GP&Ksoii fioos farther sovensnt and S>iad itself, its
representatives, sccoesaors and assigns, to warrant specially and
forevsr dofand the title to said land to G HASTES, its successors and
assigns, against the lawful claims of til persons claiming fay, through
and under GRAHTOR, but Wt farther or otherwise, G»MTQR specifically
doaa not asake any ^aizi-anties whafcaoaver with regard to matters arising
prior to GKjurrQK'S acquisition of the property ofnvayed herein.
Wherever used, the singular number shall include Use plural, the
plural the singular, anS the use of any gender nhall be applicable to
all genders,
IN witness MHSEEO? f the BntiersigMd has execute this Special
Warranty Dead on behalf of GRAKTOa on this the ^3ni day of June
me, .
SOSACBbL lETERtfATIGKM., ISC.
Title ¥iea President
1-25
-------
- 156
SM&TS or Illinois t
oouotv r^r~:j
Personally Appeal before »e, tba undersign, a Notary Public
within and for the Stat® and Oounty aforesaid, Th^st* i..
——¦——— » with whora I am personally acwr,
U; frwuiltifoi Ufiia Scti, 17, J HO . J
»y'Coawissioa Expires; 'Sfuf /90
fT
i
i
I jpagoQE
1-26
-------
—vSxmairjt
Famitfced jfacmnbiancss
but not y«adar»^«ySt" 'f°r "" n"d ^«q"8nt yaare, a lien,
TnT,nf.!L.E>S6:'B9'1! y°. C^ty of pfaynesboro and Wayne County,
Coynty, -rennlwaa? *" B' ' Pa3S 37 4' B**i*tar,e Offie® Soe Wayne
^ Ir'if i j
Bnotr l'-> "'¦«*)¦¦¦ egsws- ease merit contained in Dead recorded in
wfi 5 3' *m 9F
1-27
-------
-------
Notice of Lard Lisa Restrictions
Esttary propCftias, Inc. Property
Baiew Ork'Cj Wayncsboft), TM
Exhibit B
Area of Potential Environmental Concern
1-29
-------
U>
O
=i3 CSJLVSftr
• ^ umnYPcuf
#"* tAM3 POST
Ow WATER VBtVE
¦fr** RH£ MfBRAKI
AREA Of PtWCMmi,
r-W.RDW^TAL easfcew*
V
C=I
1. TCP oa PAP HIC CO*TOLUtS AAJJ R CTm>
AT OWE POCT ^FEfWAt6.
an ?MGN^VA£»l OCT OJKMj?
Page 1GA
ExMbttB
AREA OF POTENTIAL ENVIRONMENTAL CQMCERN
MAL.IQRY CAPACITOR SITE
W&yneshoro, Tennessee
-------
notice of Land Use Restrictions
Rstfery Properties, inc. Property
E-etew Drive, Waynesboro, TN
Exhibit €
LAND USE RESTRICTIONS REPORTING: REQUIREMENTS
Upon written requests Grantor und its heirs, successors, soccessors-in-title, and assigns shall
submit a report to TTDEC and EPA detailing the Property owner's compliance and/or non-
compliance, with the terms of the Notice oFLand Use Restrictions far the 12 month period
preceding receipt of the request. In addition, this report shall be submitted to TDEC and EPA
within thirty (30) days following any transfer of ownership by the transferring party, The report
shali include, at a minimum, the following:
» site name and location;
• site contact;
» repeating period;
• photographs, if any; and
» details of the Property owner's compliance and/or noa-compiiance, with the following:
* vise of the Property in any manner that would interfere with the
performance of 11k remedy, as described in the Notice of Land Use
Restrictions;
* use of the Property for any non-industrial purpose, as described in the
Nodes of Land Use Restrictions;
* any land disturbing activity on line Property, as described in the Notice of
Land Use Restri ctions; and
o use of groundwater under the property, as described in the Notice of Land
Use Restrictions.
The report shall he submitted to the following:
Field Office Manager
Division of Remediation
Tennessee Department of Environment and
Conservation
711R. S. GassBoulevard
Nashville, Tennessee 37216
Director
Superfund Division
US. Environmental Protection Agency,
Region 4
Sam Nunn Atlanta Federal Center
61 Forsyth Street, S\V
Atlanta, Georgia 30303
ll
1-31
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APPENDIX J - PRESS NOTICE
U.S. ENVIRONMENTAL PROTECTION AGENCY
NEWS RELEASE
EPA.GOV/NEWSROOM
EPA to Review Cleanups at 45 Southeast Superfund Sites
Contact Information: reaion4press@epa.gov. 404-562-8400
ATLANTA (Oct. 19, 2022) - Today, the U.S. Environmental Protection Agency (EPA) announced that
comprehensive reviews will be conducted of completed cleanup work at 45 National Priority List (NPL)
Superfund sites in the Southeast.
The sites, located in Alabama, Florida, Georgia, Kentucky, Mississippi, North Carolina, South Carolina,
and Tennessee, will undergo a legally required Five-Year Review to ensure that previous remediation
efforts at the sites continue to protect public health and the environment.
"The Southeast Region will benefit tremendously from the full restoration of Superfund sites, which can
become valuable parts of the community landscape," said EPA Region 4 Administrator Daniel
Biackmon. "The Five-Year Review evaluations ensure that remedies put in place to protect public health
remain effective overtime."
The Superfund Sites where EPA will conduct Five-Year Reviews in 2022 are listed below. The web links
provide detailed information on site status as well as past assessment and cleanup activity. Once the
Five-Year Review is complete, its findings will be posted in a final report at
https://www.epa.gov/superfund/search-superfund-five-vear-reviews.
Alabama
Alabama Army Ammunition Plant https://www.epa.gov/superfund/alabama-armv-ammunition-plant
Alabama Plating Company, Inc. https://www.epa.gov/superfund/alabama-plat.ing-co
Mowbray Engineering Co. https://www.epa.gov/superfund/mowbrav-enqineering
US NASA Marshall Space Flight Center
US Army/NASA Redstone Arsenal https://www.epa.gov/superfund/redstone-aresenal
Florida
ALARIC Area GW Plume https://www.epa.gov/superfund/alaric-area-groundwater-plume
Beulah Landfill https://www.epa.gov/superfund/beulah-landfill
Chevron Chemical Co. (Qrtho Division) https://www.epa.gov/superfund/chevron-chemical-companv
Florida Petroleum Reprocessors https://www.epa.gov/superfund/florida-petroleum-reprocessors
Miami Drum Services https://www.epa.gov/superfund/miami-drum-services
Pensacola Naval Air Station https://www.epa.gov/superfund/naval-air-station-pensacola
Raleigh Street Dump https://www.epa.gov/superfund/raleiqh-street-dump
Taylor Road Landfill https://www.epa.gov/superfund/tavlor-road-landfill
Tower Chemical Co. https://www.epa.gov/superfund/tower-chemical-companv
Georgia
Alternate Energy Resources Inc. https://www.epa.gov/superfund/alternate-energy-resources
Peach Orchard & Nutrition Co. Rd PCE Groundwater Plume Site https://www.epa.gov/superfund/peach-
orchard-road-pce-plume
Powersville Site https://www.epa.gov/superfund/powersville-site
T.H. Agriculture & Nutrition Co (Albany Plant) https://www.epa.gov/superfund/t-h-agriculture
Kentucky
A.L. Taylor (Valley of the Drums) https://www.epa.gov/superfund/al-tavlor-vallev-of-drums
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Brantley Landfill https://www.epa.qov/superfund/brantlev-landfill
Distler Brickyard https://www.epa.gov/superfund/distler-brickvard
Distler Farm https://www.epa.gov/superfun https://www.epa.gov/superfund/lee-lane-landfilld/distler-farm
Lee's Lane Landfill https://www.epa.gov/superfund/lee-lane-landfill
National Electric Coil Co./Cooper Industries https://www.epa.gov/superfund/national-electric-coil-cooper-
industries
Tri City Disposal Co. https://www.epa.gov/superfund/tri-citv-disposal
North Carolina
ABC One Hour Cleaners https://www.epa.gov/superfund/abc-one-hour-cleaners
Aberdeen Pesticide Dumps https://www.epa.gov/superfund/aberdeen-contaminated-groundwater
Benfield Industries, Inc. https://www.epa.gov/superfund/benfield-industries
Cherry Point Marine Corps Air Station https://www.epa.gov/superfund/cherrv-point-marine-corps
CTS of Ashville, Inc. https://www.epa.gov/superfund/cts-millsgap
GEIGY Chemical Corp (Aberdeen Plant) https://www.epa.gov/superfund/ciba-geigy-corporation
Gurley Pesticide Burial https://www.epa.gov/superfund/gurlev-pesticide-burial
North Carolina State University (Lot 86, Farm Unit #1) https://www.epa.gov/superfund/north-carolina-
state-university
Sigmon's Septic Tank Service https://www.epa.gov/superfund/sigmon-septic-tank
South Carolina
Admiral Home Appliances https://www.epa.gov/superfund/admiral-home-appliances
Beaunit Corp (Circular Knit & Dyeing Plant) https://www.epa.gov/superfund/beaunit
Carolawn Inc. https://www.epa.gov/superfund/carolawn
Elmore Waste Disposal https://www.epa.gov/superfund/elmore-waste-disposal
International Minerals and Chemicals (IMC) https://www.epa.gov/superfund/imc
Kalama Specialty Chemicals https://www.epa.gov/superfund/kalama-specialtv-chemicals
Koppers Company, Inc. (Charleston Plant) https://www.epa.gov/superfund/koppers-charleston-plant
Savannah River Site (USDOE) https://www.epa.gov/superfund/savannah-river-site
SCRDI Bluff Road https://www.epa.gov/superfund/scrdi-bluff-road
Tennessee
Mallory Capacitor Co. https://www.epa.gov/superfund/mallorv-capacitor
Memphis Defense Depot (DLA) https://www.epa.gov/superfund/memphis-defense-depot
Background
Throughout the process of designing and constructing a cleanup at a hazardous waste site, EPA's
primary goal is to make sure the remedy will be protective of public health and the environment. At many
sites, where the remedy has been constructed, EPA continues to ensure it remains protective by requiring
reviews of cleanups every five years. It is important for EPA to regularly check on these sites to ensure
the remedy is working properly. These reviews identify issues (if any) that may affect the protectiveness
of the completed remedy and, if necessary, recommend action(s) necessary to address them.
There are many phases of the Superfund cleanup process including considering future use and
redevelopment at sites and conducting post cleanup monitoring of sites. EPA must ensure the remedy is
protective of public health and the environment and any redevelopment will uphold the protectiveness of
the remedy into the future.
The Superfund program, a federal program established by Congress in 1980, investigates and cleans up
the most complex, uncontrolled or abandoned hazardous waste sites in the country and endeavors to
facilitate activities to return them to productive use. In total, there are more than 280 Superfund sites
across the Southeast.
More information:
EPA's Superfund program: https://www.epa.gov/superfund
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EPA.GOV
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APPENDIX K - INTERVIEW FORMS
Mallory Capacitor Company Superfund Five-Year Review Interview Form
Site
Site Name; Ma lion C apacitor C ompanv EPA ED No.: TND0"f45j&SS
Interviewer Name: Zariah Lewis Affiliation: EPA
Subject Name; Amanda Howell Affiliation: EPA
Subject Contact Information: HowelLAmaada a epa.gov
Time: 7:30 prn n.it>: ^140023
Interview Location: NA
Interview Formal (circle one): In Person Phone Mail Other: Email
Interview Category:
1. Are you aware of the former environmental issues at the Site and the cleanup activities that have taken place
to date7 yes
2. What is your overall impression of the project, including cleanup maintenance and reuse activities (as
appropriate)7 The site has been conducting groundwater cleanup for approximately 30 years Maintenance
of the site and monitoring wells appear to be in good condition and under control of BP!
3 What have been the effects of this Site on the surrounding community if any7 Groundw ater is contaminated
and recent sampling his indicated that vapor intrusion it a potential risk in toe immediate surrounding area
4. Have there been any problems with unusual or unexpected activities at the Site, such as emergency
response, vandalism or trespassing? A temporary mitigation system has been installed at a residential
property adjacent to the Site property 1 don't have any knowledge of vandalism or trespassing at the Site
5 Has EPA kept involved parties and surrounding neighbors informed of activities at the Site7How can EPA
best provide site-related information m the future7 Yes. with the site repository at the local library and letters
mailed to residence and property owner regarding the recently vapor intrusion assessment.
6 Are you aware of the city's drinking water well restrictions near the Site? yes
7. Do you have any comments, suggestions or recommendations regarding any aspects of die project7
Additional data is still needed to complete the vapor intrusion assessment
8 How would you like to receive information about this site mailing hst phone calls, postcards, emails or
face-to-face7 NA
9. Are you aware of any local activist or local group addressing the site in any way7 no
10. If ever needed, where do you think would be a good place to hold a public meeting7 local high school gym
II Do you have any final questions for us? no
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Mallory Capacitor Company Superfund Five-Year Review Interview Form
Site
Site Name: Mallorv C apachor Company
Interviewer Name: Zariah Lewis
Subject Name: Amanda Howell
EPA ID No.: TND07?4>36SS
Affiliation: EPA
Affiliation: EPA
Subject Contact Information: HowelLAmanda a epa.gov
Time: 7:30 pm
Interview Location: N'A
Date: 81-V2023
Interview Format (circle one): In Person Phone Mail Other: Email
Interview Category:
1 Are you aware of the former environmental issues at the Site and the cleanup activities that have taken place
2 What is your overall impression of the project, including cleanup, maintenance, and reuse activities (as
appropriate)'' The site lias bees conducting groundwater cleanup for approximately 30 years Maintenance
of the site and monitoring wells appear to be tn good condition and under control of BPl
3. What have been the effects of this Site on the surrounding community, if am-1 Groundwater is contaminated
and recent sampling has indicated that v^ior intrusion is a potential nsk in me immediate sun winding area
4. Have there been any problems with unusual or unexpected activities at the Site, such as emergency
response, vandalism or trespassing? A temporary mitigation system has been installed at a residential
property adjacent to the Site property I don't have any knowledge of vandalism or trespassing at the Site
5 Has EPA kept involved parties and surrounding neighbors informed of activities at the Site''How can EPA
best provide site-related information m the future? Yes. with the site repository at the local library and letters
mailed to residence and property owner regarding the recently vapor intrusion assessment.
6. Are you aware of the city's drinking water well restrictions near the Site? yes
7 Do you have any comments, suggestions or recommendations regarding any aspects of die project1
Additional data is still needed to complete die vapor intrusion assessment
8. How would you like to receive information about this site mailing list phone calls, postcards, emails or
face-to-face"* NA
9. Are you aware of any local activist or local group addressing the site m any way? no
10 If ever needed where do you think would be a good place to hold a public meeting? local high school gym
11. Do you have any final questions for us? no
to date? yes
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Mallory Capacitor Company Superfund
Site
Fil e-Year Review Interview Form
Site Name: Mallory C apacitor Company
Interviewer Name: Zariali Lewis
Subject Name: John Hosnapffelt
E PA ID No.: TND07S4S3688
Affiliation: EPA
Affiliation: TDEC-DoR Project
Manager
Subject Contact Information: john.hoffelt@lrs.gov
Time:
Interview Location:
Date: August 15, 2023
Interview Format (circle one): In Person Phone
Mail Other:
Interview Category:
1. Are you aware of the former environmental issues at Che Site and the cleanup activities that
have taken place to date? Yes.
2. What is your overall impression of the project: including cleanup, maintenance, and reuse
activities (as appropriate)? The original remedial action removed accessible contamination,
but significant contamination remains in the aquifer and is subject to migration in both the
liquid and vapor phases.
3. What have been the effects of this Site on the surrounding community, if any?
Recent sampling for the vapor intrusion pathway shows concern for indoor 3)reathing air
in the surrounding residential neighborhood.
4. Have there been any problems with unusual or unexpected activities at the Site, such as
emergency response, vandalism or trespassing? No.
5. Has EPA kept involved parties and surrounding neighbors informed of activities at the Site? Yes.
How can EPA best provide site-related information in the future?
At this time, direct contact with the surrounding neighbors works well. If community participation
broadens, EPA may consider a public meeting or information forum.
5. Are you aware of the cits'"s drinking water well restriction; near the Site? Yes.
6. Do you have any comments, suggestions or recommendations regarding any aspects of the
project? Continue to control migration of contaminants in groundwater; control and mitigate
contaminant migration and exposures through the vapor intrusion pathway.
7. How would you like to receive information about this site: mailing hst. phone calls,
postcards, emails or face-to-face? Phone and email.
8. Are you aware of any local activist or local group addressing the site m any way? No.
9. If ever needed, where do you think w ould be a good place to hold a public meeting?
That may be coordinated with The City of Waynesboro; TDEC-DoR is available to assist.
10. Do you have any final questions for us? No.
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Mallory Capacitor Company Supeifund
Site
Five-Year Review Interview Form
Site Name: MaDoiv Capacitor Company EPA ID No.: TND075453688
Interviewer Name: Zatiah Lewis .\ffiliation: EPA
Subject Name: Winston L. Guidry .Affiliation: ghd
209 Gothic Ct_, Ste. 109, Franklin, TN, 37067
Subject Contact Informs rion: {615) 721 -0682; Winston.Guidry@GHD.com
Time: Date: August 17.2023
Interview Location:
Interview Format (circle one): In Person Phone
Mail
Interview Category: O&M Contractor
I.
Aie you aware of the former environmental issues at the Site and the cleanup activities that
have taken place to date?
Yes. GHD (formerly known as L-CRA:T) has been involved with the iovestigaticHi and
cleanup activities at die Sire since the 1980s ana I have been involved since -00
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